SERVICE PROVIDER OVERVIEW

• SIRI Law LLP is a multidisciplinary law firm providing legal, regulatory, and operational excellence advisory services across data privacy, cybersecurity, technology risk, and digital governance. The firm works with domestic and multinational enterprises to design, implement, and operationalize privacy and cybersecurity frameworks that are legally defensible, regulator-ready, and aligned with business objectives.
• The firm’s approach integrates legal interpretation, governance design, operational implementation, and behavioral risk management. Rather than treating data protection and cybersecurity as compliance checklists, SIRI Law LLP positions them as enterprise risk domains requiring continuous oversight, accountability, and integration into decision-making.
• This case study demonstrates SIRI Law LLP’s ability to deliver end-to-end data privacy and cybersecurity advisory for complex organizations operating across jurisdictions, technologies, and regulatory regimes.

CLIENT BACKGROUND

• The client was a multinational enterprise with operations across multiple jurisdictions, including Asia, Europe, and North America. The organization operated digital platforms, technology-enabled services, and customer-facing systems that processed significant volumes of personal data, financial data, and confidential business information.
• The client’s business model relied heavily on cloud infrastructure, third-party technology providers, data analytics, and cross-border data flows. The organization collected and processed personal data relating to customers, employees, contractors, vendors, and business partners. This included sensitive data categories in certain jurisdictions.
• Over time, the organization’s digital footprint expanded rapidly due to organic growth, acquisitions, new product launches, and changes in working models, including remote and hybrid work. While technology capabilities scaled quickly, governance, legal oversight, and operational controls struggled to keep pace.
• Senior leadership became increasingly concerned about regulatory exposure, cyber incidents, contractual liability, and reputational risk arising from data misuse or security failures. Regulators, customers, and business partners were demanding greater transparency, accountability, and assurance regarding data protection practices.
• SIRI Law LLP was engaged as strategic legal advisor to assess, redesign, and operationalize the client’s data privacy and cybersecurity posture across the enterprise.

ENGAGEMENT OBJECTIVES

• The engagement was structured around several interrelated objectives.
• The first objective was to obtain a clear, evidence-based understanding of how personal and sensitive data flowed through the organization, and where legal, regulatory, and contractual risk crystallized.
• The second objective was to assess whether existing privacy and cybersecurity policies, controls, and governance structures were effective in practice rather than merely documented.
• The third objective was to design a coherent, defensible privacy and cybersecurity governance framework aligned with applicable laws, regulatory expectations, and the organization’s risk appetite.
• The fourth objective was to strengthen cyber incident readiness and legal response capability, ensuring that the organization could respond to breaches or cyber events in a timely, coordinated, and legally defensible manner.
• The fifth objective was to embed privacy and cybersecurity considerations into business operations, product design, contracting, procurement, and strategic decision-making.
• The engagement was deliberately positioned as a transformation program rather than a one-time compliance exercise.

REGULATORY AND BUSINESS CONTEXT

• The regulatory environment in which the client operated was complex and evolving. Data protection laws imposed obligations relating to lawful processing, transparency, purpose limitation, data minimization, security safeguards, accountability, and breach notification. Sector-specific cybersecurity requirements imposed additional obligations around risk management, incident reporting, and resilience.
• Regulatory enforcement trends showed increasing penalties for data breaches, inadequate safeguards, delayed notifications, and failure to demonstrate accountability. Regulators were no longer satisfied with policy documents alone and expected evidence of operational effectiveness.
• At the same time, the business operated in competitive markets that demanded speed, innovation, and data-driven insights. Product teams sought to leverage analytics, personalization, and automation. Commercial teams relied on data sharing with partners and vendors. Technology teams adopted new tools and platforms to enable scalability.
• Legal advice therefore needed to strike a careful balance between regulatory compliance and commercial feasibility. Overly restrictive controls risked stifling innovation, while inadequate controls exposed the organization to enforcement and reputational damage.
• SIRI Law LLP approached the engagement with the understanding that privacy and cybersecurity frameworks must be practical, scalable, and integrated into how the business actually operates.

PHASE ONE: ENTERPRISE PRIVACY AND CYBER RISK ASSESSMENT

• The first phase focused on establishing a factual baseline of the client’s privacy and cybersecurity posture.
• SIRI Law LLP conducted a comprehensive assessment covering the full data lifecycle. This included identifying what data was collected, from whom, for what purposes, where it was stored, how it was processed, with whom it was shared, how long it was retained, and how it was ultimately deleted or archived.
• The assessment covered customer data, employee data, contractor data, vendor data, and internal business information. It also examined data flows across systems, business units, and jurisdictions.
• In parallel, SIRI Law LLP reviewed governance structures, roles and responsibilities, reporting lines, and decision-making authority relating to privacy and cybersecurity. This included assessing whether accountability was clearly defined or fragmented across functions.
• The firm reviewed policies, procedures, standards, and guidelines, evaluating whether they reflected actual operational practices or aspirational statements. Technical safeguards, access controls, and security measures were reviewed from a legal and governance perspective, in coordination with technology and security teams.
• Incident management processes were assessed, including detection, escalation, investigation, remediation, and notification practices. Third-party risk management processes were also examined.
• The assessment identified several recurring issues. Ownership of privacy and cybersecurity risk was fragmented across legal, IT, security, and business teams. Data inventories were incomplete or outdated. High-risk processing activities were not consistently documented or reviewed. Incident response plans existed but had not been tested under realistic conditions.
• This phase established a clear and evidence-based understanding of the organization’s risk profile.

PHASE TWO: PRIVACY GOVERNANCE AND ACCOUNTABILITY FRAMEWORK

• Based on the assessment findings, SIRI Law LLP designed a privacy and cybersecurity governance framework grounded in accountability principles.
• The framework clarified ownership and responsibility at multiple levels. Strategic oversight responsibilities were assigned to senior leadership, while operational accountability was defined for legal, security, technology, and business functions. Escalation pathways and decision-making authority were clearly documented.
• SIRI Law LLP supported the client in defining and formalizing privacy and cybersecurity leadership roles. Reporting lines were aligned to ensure independence, authority, and access to decision-makers.
• Policies were rationalized and rewritten to align with actual operational practices. Privacy notices, internal policies, employee guidance, and contractual commitments were reviewed to ensure consistency and legal defensibility.
• Importantly, governance was operationalized through committees, reporting mechanisms, and review cycles. Privacy and cybersecurity risks were incorporated into enterprise risk management processes rather than addressed in isolation.

PHASE THREE: DATA PROTECTION BY DESIGN AND BUSINESS INTEGRATION

• A critical focus of the engagement was embedding privacy and cybersecurity into business processes.
• SIRI Law LLP advised on integrating privacy impact assessments into product development, procurement, and vendor onboarding workflows. Business teams were trained to identify high-risk processing activities and escalate them early for legal and risk review.
• The firm worked closely with product, marketing, and analytics teams to align data use cases with lawful processing grounds, transparency obligations, and data minimization principles. Where business objectives conflicted with legal constraints, SIRI Law LLP facilitated structured decision-making and risk acceptance at appropriate levels.
• Privacy and cybersecurity considerations were incorporated into internal approval processes, ensuring that legal and regulatory risk was evaluated alongside financial, operational, and reputational risk.
• This integration reduced the need for retroactive compliance fixes and improved trust between legal and business teams.

PHASE FOUR: CYBERSECURITY LEGAL READINESS AND INCIDENT RESPONSE

• Cyber incident readiness was identified as a priority area.
• SIRI Law LLP reviewed and refined incident response plans from a legal and regulatory perspective. This included clarifying notification thresholds, timelines, and responsibilities. The firm ensured alignment between technical incident handling and legal decision-making.
• Roles for legal, IT, security, communications, and senior management were clearly defined. External engagement strategies with regulators, customers, partners, and law enforcement were documented.
• SIRI Law LLP facilitated tabletop exercises simulating realistic breach scenarios. These exercises tested coordination, escalation, and decision-making under pressure. Gaps were identified in communication, documentation, and response timing.
• Following the exercises, incident response plans were updated, and targeted improvements were implemented. The organization gained confidence in its ability to respond to incidents in a controlled, coordinated, and defensible manner.

PHASE FIVE: THIRD-PARTY AND SUPPLY CHAIN RISK MANAGEMENT

• Third-party risk was a significant exposure area given the client’s reliance on vendors, cloud providers, and partners.
• SIRI Law LLP conducted a detailed review of vendor contracts, data processing agreements, and outsourcing arrangements. The review identified inconsistent data protection obligations, weak security commitments, limited audit rights, and inadequate breach notification provisions.
• The firm redesigned contractual frameworks to introduce tiered data protection and cybersecurity obligations based on risk. Standard clauses were developed covering security safeguards, audit rights, sub-processing, breach notification, and liability.
• Vendor onboarding and review processes were updated to include legal and cybersecurity risk assessments. Ongoing monitoring mechanisms were introduced for high-risk vendors.

PHASE SIX: CROSS-BORDER DATA TRANSFERS AND GLOBAL OPERATIONS

• The client’s multinational operations involved frequent cross-border data transfers.
• SIRI Law LLP advised on lawful transfer mechanisms and supported the client in documenting transfer risk assessments and mitigation measures. Internal policies and operational practices were aligned with contractual safeguards.
• This work reduced regulatory uncertainty and enabled continued global operations without unnecessary disruption.

PHASE SEVEN: TRAINING, AWARENESS, AND ORGANIZATIONAL CULTURE

• Recognizing that human behavior plays a critical role in privacy and cybersecurity, SIRI Law LLP supported targeted training and awareness initiatives.
• Training programs were tailored by role and function. Senior leadership received briefings on accountability and personal exposure. Business teams were trained on practical decision-making scenarios. Technical teams were aligned on legal expectations.
• This helped shift privacy and cybersecurity from abstract compliance topics to shared organizational responsibilities.

OUTCOMES AND VALUE DELIVERED

• The engagement delivered significant value.
• The client achieved a coherent, defensible privacy and cybersecurity governance framework aligned with regulatory expectations and business realities. Data processing practices became more transparent, controlled, and auditable.
• Incident readiness improved materially, reducing legal and reputational exposure. Third-party risk was reduced through stronger contractual and operational controls.
• Most importantly, privacy and cybersecurity became embedded into business decision-making rather than treated as reactive compliance obligations.

MATURITY PROGRESSION AND STRATEGIC IMPACT

• Using a structured maturity model, the organization progressed from a fragmented and reactive posture to a defined, measured, and governed approach.
• Leadership gained visibility into digital risk and confidence in regulatory defensibility. Privacy and cybersecurity became strategic enablers of trust, supporting long-term growth and digital transformation.

EXECUTIVE REFLECTION

• This engagement demonstrated that data privacy and cybersecurity are enterprise governance challenges requiring legal, operational, and cultural alignment. By applying rigorous yet practical legal advisory, the organization materially reduced risk while enabling innovation.

CONCLUSION

• This case study reflects SIRI Law LLP’s capability to deliver comprehensive data privacy and cybersecurity legal advisory for complex, multinational enterprises. The firm’s approach emphasizes accountability, operational integration, and sustainable resilience.