The following eight findings were classified as Phase 1 priorities: High-priority Non-Compliant controls requiring remediation within 0–30 days. These represent active compliance violations or governance gaps with direct regulatory exposure.

Phase 1 — Most Critical Findings (0–30 Days)

ID Finding Owner Why It Cannot Wait
GA-001 Information Security Policy CISO No documented management commitment to information security. ISMS certification cannot proceed without it.
GA-002 Roles and Responsibilities CISO No defined ownership for information security roles. Without assigned accountability, every other control is unenforceable.
GA-004 Incident Response Plan CISO No structured process for detecting, containing, or recovering from a security incident. The 72-hour GDPR notification window cannot be met without this.
GA-007 Access Control Policy CISO No documented rules governing who can access what systems and under what conditions. All access management controls are unverifiable without a policy baseline.
GA-028 Lawful Basis for Processing Compliance Officer Personal data of 100,000 users is being processed across 10 data types with no documented Article 6 legal basis. Active GDPR violation.
GA-029 Privacy Notice Compliance Officer Users receive no information about how their data is processed. Direct violation of GDPR Articles 13 and 14.
GA-034 Breach Notification Procedure Compliance Officer No 72-hour escalation chain, no supervisory authority notification template, no breach register. GDPR Article 33 compliance is not achievable without this.
GA-035 Data Protection Impact Assessment Compliance Officer Three processing activities — KYC biometric verification, behavioural profiling, and large-scale financial processing — meet the DPIA threshold under Article 35 and have not been assessed.