The challenge
Global businesses juggle conflicting laws and local practices. Policies must be universal; execution must be local. The trick is to avoid duplicative work while proving compliance anywhere you operate.
Build a single playbook, execute locally
- Core control set: Define organization-wide controls (access, retention, incident response, vendor onboarding).
- Local overlays: For each country/state, maintain a short addendum: stricter retention, unique notices, localization.
- Gold sources: One policy wiki; one control library; one case/task system to track exceptions.
Exception management
- Document the “why”: Legal citation, business need, time-boxed duration.
- Compensating controls: Extra approvals, segregation, monitoring.
- Review cadence: Quarterly check to retire or renew exceptions.
Data moves and sanctions
- Data mapping: Systems, data types, jurisdictions, processors.
- Transfer mechanisms: SCCs/agreements tracked with renewal dates.
- Screening & holds: Sanctions checks on counterparties; automated holds on hits.
Assurance and evidence
- Test once, reuse many: Central testing for shared controls; local teams attach context proof.
- Evidence catalog: What to collect, where it lives, retention period, owner.
- Regulator-ready packets: Pre-built exports (policy, control, test, exceptions, incidents).
30 / 60 / 90-day plan
- Day 0–30: Stand up the core control set; publish the wiki; pick a single case/task system.
- Day 31–60: Create top-5 local overlays; map data flows; list transfer mechanisms.
- Day 61–90: Implement exception workflow; pilot regulator-ready packets in two regions.
Metrics
- % of controls tested centrally vs. locally.
- Exception volume and average time open.
- % of cross-border transfers with current mechanisms attached.
Pitfalls
- Policy forks: Competing versions of “truth.”
- Endless localization: Country binders nobody reads.
- Evidence chaos: Files spread across drives with no retention plan.
Outcome
One playbook, many local implementations—clear ownership, faster audits, fewer surprises.