Building a Personal Data Protection Policy and Governance Framework

Identify Risks – Standardize Systems – Ensure Legal Compliance

CDLAF supports businesses in building a comprehensive personal data protection policy and governance framework that complies with Vietnam’s Decree 13/2023/NĐ-CP and the draft Personal Data Protection Law, while aligning with international standards such as GDPR (EU), ISO/IEC 27701, and the NIST Privacy Framework.

This is a foundational solution for enterprises to meet personal data compliance requirements and avoid legal penalties, especially important for:

Foreign Direct Investment (FDI) enterprises operating in Vietnam.
Multinational corporations processing large volumes of personal data.
Businesses preparing for audits, IPOs, fundraising, or global partnerships.

Our service helps your organization:

Establish a full internal legal framework, including legal framework – procedures – roles – forms for personal data protection.
Standardize processes for collecting, storing, using, sharing, and deleting personal data in accordance with legal and operational standards.
Ensure the business is prepared to cooperate with competent authorities during inspections, internal compliance audits, or audits by partners and M&A activities.
Integrate data protection into enterprise governance, risk control, and ESG initiatives.

Scope of Service:

Draft or update Personal Data Protection Policies, ncluding: scope of application, principles, purposes, retention rules, internal responsibilities, and data subject rights.
Define and assign governance roles and responsibilities, including appointing a Data Protection Officer (DPO) or designated focal point.
Develop or refine Standard Operating Procedures (SOPs) for data lifecycle activities.
Set up processes to handle data subject requests (access, correction, deletion, consent withdrawal, etc.)
Define retention periods and data handling rules by data type and usage purpose
Draft a Personal Data Breach Response Procedure, covering detection, management, reporting, and post-incident review for improvement.
Provide guidance on policy publication, internal communication, and employee compliance acknowledgment.

How we do it

Process	Detailed description
Step 1: Draft or update Personal Data Protection Policy	We begin by reviewing your current documentation (if any) and evaluating compliance with Decree 13/2023/NĐ-CP and international standards. Based on this, we draft or revise your policy to include: Scope of application (organization-wide, data types, data subjects) Principles of personal data processing. Mechanisms for collection, use, sharing, storage, and deletion of data. Protection of data subject rights (access, withdrawal, complaints) Departmental responsibilities and accountability. Internal oversight,violation handling procedures…. The policy is prepared in Vietnamese, with an optional bilingual version (Vietnamese-English), professionally formatted and suitable for submission to authorities or foreign partners.
Step 2: Assign Governance Roles and Responsibilities	Clear assignment of roles and responsibilities will help ensure that data control and processing activities follow the correct procedures, preventing omissions or data loss. We will: Support the appointment of a Data Protection Officer (DPO) or establish a suitable dual-role structure Develop a responsibility matrix (RACI) across departments :approval, execution, oversight, audit) Define key roles across departments such as legal,- HR – IT, – operations-customer service – marketing. Provide job descriptions for roles involving personal data.
Step 3: Develop Standard Operating Procedures (SOPs)	In addition to policies, businesses need concrete operational procedures integrated into their daily activities. We build SOPs that align with each stage of the data lifecycle: SOPs for data collection (via forms, websites, apps, contracts, surveys) SOPs for data storage on internal systems or third-party platforms. SOPs for access control and usage (roles, permissions, access logs) SOPs for internal and third-party data sharing (with conditions and control mechanisms) SOPs for deletion or anonymization after data retention periods expire. Each SOP is accompanied by process diagrams, real-life scenarios, role assignments, and relevant templates.
Step 4: Set Up Data Subject Request Handling Procedures	Organizations must be able to respond to individual requests (customers, staff, users) in line with the law. We develop a five-step process: Receive request (access, modification, deletion, consent withdrawal) Verify identity and request validity. Assign internal handler and approve response. Respond within legally required timeframe. Store documentation and conduct periodic audits. We also provide template forms (request forms, response samples, processing logs) and guidance on identifying invalid or fraudulent requests.
Step 5: Develop Data Retention and Disposal Policy	Businesses need to control the retention period and storage methods, avoiding the retention of unnecessary data which can lead to legal risks. We will: Classify data by type, purpose, sensitivity, and legal context Create a data retention reference matrix Develop rules for permanent deletion, removal from backups, or anonymization Provide best practices for storing sensitive data on cloud, on-premise systems, or physical media with access controls For companies using multiple systems (CRM, HRM, ERP, etc.), we assist in integrating policies into real-world operations.
Step 6: Establish Personal Data Breach Response Procedures	When a breach occurs, timely and transparent response is critical. We create: Security Incident Response Flowchart: from Detection → Classification → Emergency Handling → Recovery → Post-Incident Review. Reporting templates for submission to the Ministry of Public Security (per Decree 13/2023) Notification templates for affected data subjects. Guidelines for forming an Incident Response Team (IRT) with defined roles and response timelines. Instructions on recordkeeping and updating SOPs after incidents.
Step 7: Issue Policy and Conduct Internal Communication	Policies are only effective when properly communicated and implemented. Therefore, CDLAF will: Draft a decision to issue a policy, to be signed by the CEO. Draft email content to disseminate the policy to all personnel.. Guidelines for internal training sessions or e-learning content. Provide commitment to compliance forms for personnel and the storage process.. (Optional) internal awareness checks (quizzes, spot audits) after implementation.

Why choose us?

Experienced Legal Professionals

We are a team of trained lawyers and legal consultants with extensive experience in implementing personal data compliance under Decree 13, GDPR, APPI, and CCPA. Our portfolio includes FDI, tech startups, banks, and financial institutions.

In-Depth Analysis and Practical Solutions

We go beyond problem identification. We offer solutions that are aligned with your budget, size, and operational model—ensuring both feasibility and efficiency.

Confidential and Long-Term Support

We strictly protect client information and continue to provide support for policy refinement, staff training, contract reviews, and internal audits.

Tailored to Your Industry

We do not use generic templates. Your policy is built based on your organization’s structure, industry, and technology landscape.

High-Quality Deliverables

Documents are logically structured, professionally formatted, and available in bilingual versions (upon request), ready for submission to banks, investors, partners, or authorities.

Ongoing Support Beyond Documentation

We support implementation, training, operational integration, and post-launch follow-up.

30-Point Personal Data Compliance Self-Assessment Checklist

Receive a specialized document package containing 30 key criteria, enabling your organization to quickly self-assess its compliance status under Decree No. 13/2023/NĐ-CP — entirely free of charge.

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