Map what the Egyptian service actually does
List each information type, purpose, collection point, recipient and storage location. Include remote support and backups. A short policy copied from another market may miss the entity responsible for the Egyptian customer and the real use of their data. Work through a sample customer record from sign-up to deletion. Note who collects it, the system holding it, access roles, downstream transfers and retention trigger. Mark exports, copies and logs separately so the map reflects where the data can still be found.
Inspect vendors and permissions
Compare customer notice, contracts and live access controls. Which processor can view, copy or move records? If marketing, analytics or model training is proposed, document it separately from providing the core service. Restrict unnecessary access and keep evidence of any changes. List each vendor’s function, location, onward suppliers and access method. Reconcile the written agreement with actual permissions and administrator accounts. Test whether a withdrawn marketing preference stops downstream use, and whether the notice accurately describes the analytics tools in use.
Rehearse a problem before one occurs
Run an incident drill and a request to access or correct a record. Identify who preserves logs, contacts vendors, assesses scope and replies. Current Egyptian legal duties and timing need to be checked for the actual facts, not inferred from a general article. The internal plan should leave an audit trail of decisions. Run a tabletop using a leaked export: contain access, preserve timestamps, identify affected records, obtain supplier facts, and record the legal assessment and communication decision. For an access request, make sure the response can be assembled without exposing another person’s data.
Set a contract exit path
Plan usable export, retention decisions, deletion and proof from suppliers. When the platform adds a feature or changes hosting, update the data map, contracts and public text together. The goal is a notice that continues to describe real operations, not one that was accurate only at launch. Include backups and subcontractors in the exit checklist. Specify who returns data in a usable format, what must be retained, what can be deleted, when deletion can be evidenced, and whether old access credentials are revoked.
Privacy review file
- Data-flow map by purpose, system, access role and destination.
- Vendor inventory with contracts, access and onward supplier details.
- Incident and individual-request drills with dated decision logs.
- Retention, export, deletion and credential-revocation plan.
See our data protection and privacy practice and technology practice for related questions.