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Portfolio sample · Arcline is fictional
Arcline · Data Governance Framework

The company's data practices were built for a smaller operation.

A data governance framework that classifies company data by risk and defines how the organization responds when something goes wrong. Why Arcline needs it now, and what changes when it's in place.

Prepared for senior leadershipQ2 2025
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01 — The Landscape

What worked five years ago doesn't hold at this scale.

When Arcline was smaller, data handling ran on team norms and good judgment. People knew what was sensitive because they knew the work. That was adequate when thirty people shared a Slack channel and the data footprint fit in one platform.

The company now operates across multiple business units, holds data subject to regulatory frameworks in several jurisdictions, and onboards people who have no institutional memory of which systems contain customer financials. The informal system scaled past the point where it functions as a system.

02 — The Exposure

Some of this data already carries obligations. Arcline has no reliable way to know which.

Customer records, financial credentials, and government-issued identifiers sit in production systems today. Some of that data triggers mandatory breach notification within 72 hours if exposed. The people handling it may not know what protections apply. The people accountable for it may not know they're accountable.

Meanwhile, sales and partnerships represent data handling practices to clients and prospects. Those representations rest on assumptions about what engineering does. No documented policy backs them up. That gap is a liability with or without a breach.

72h
Regulatory notification window for the most sensitive data
4h
Internal reporting deadline under the proposed framework
0
Defined processes currently in place for either
03 — The Framework

Four tiers. Defined protocols. Named owners at every level.

The framework classifies all company data by the severity of what happens if it's exposed. Each tier carries its own controls and response timelines, with accountability assigned at every level.

Tier 1 — Restricted

Legal consequences on exposure

Health records, financial credentials, government IDs. Breach triggers mandatory regulatory notification within 72 hours.

Tier 2 — Confidential

Business harm, no regulatory mandate

Unreleased financials, vendor pricing, pre-board audit results. Serious damage to the company but no external reporting obligation.

Tier 3 — Internal

Standard protections

Departmental planning docs and internal communications. Standard access controls, baseline encryption.

Tier 4 — Public

Cleared for distribution

Press releases, published financials. Already through the approval process.

One deliberate design choice: the people who make governance decisions and the people who implement them are separated. This prevents the failure mode where the person closest to the data makes access decisions based on convenience.

04 — Ownership

Every data domain has three roles. None of them overlap.

Clear accountability at every level means incidents move through a defined chain instead of stalling while people figure out who's responsible.

Domain Owner

VP-level

Sets policy. Accountable for classification decisions and regulatory compliance within their domain.

Data Steward

Day-to-day governance

First point of contact for data questions. Maintains access lists and runs quarterly reviews. Coordinates with legal as needed.

Custodians

Technical implementation

Implements controls and manages encryption. Handles access provisioning based on steward and owner directives.

When an incident happens, the chain activates in sequence. The discovering party reports. The steward triages. The owner decides. Nobody guesses who does what, and the response runs on structure rather than whoever happens to be in the room.

05 — The Return

The framework operationalizes commitments Arcline is already making.

It creates three things the company currently lacks.

Incident readiness

The playbook exists before the incident does

A breach today forces the company to build the response while the clock runs. The framework maps every step in advance.

Training foundation

Professional development becomes possible

A defined system lets the company build training so every team knows their responsibilities. Right now, there's no process to train people on.

Client confidence

Sales speaks to documented practices

Client-facing teams gain the ability to describe data governance specifics because a documented framework backs up the conversation.

06

Build the infrastructure once. Maintain it. Stop improvising.

Regulatory changes, client inquiries, incidents: the company handles all of them with a system that already exists instead of assembling one under pressure.