Risk Management · Article 5(2) accountability

Privacy risk management software for evidence-linked risk records

Extract candidate risks from approved assessment evidence, route them through review, assign owners and treatment plans, and report on current exposure without re-keying findings into a separate register. Acompli's Risk module keeps each register entry traced to the assessment evidence that produced it.

01Readiness02Extraction03Consistency04Treatment05Governance06Dashboards
On this page
01
Risk ownership and mitigation tasks

From assessment to action — with nothing lost in between

Acompli builds your risk register directly from approved assessments — extraction, consistency checks, treatment plans, and dashboards in one governed workflow.

  1. 01Readiness
  2. 02Extraction
  3. 03Consistency
  4. 04Treatment
  5. 05Governance
  6. 06Dashboards
01Readiness

A readiness check before anything runs

Before any extraction begins, Acompli's readiness assessment validates whether the assessment covers the questions needed for meaningful risk identification, where quality signals are strong, and which areas are likely to produce low-confidence results.

The DPO knows whether the data is ready before any AI analysis runs — not after a set of unreliable results has already been generated.

Coverage validation

Does the assessment cover the questions needed for meaningful risk identification?

Quality prediction

Where are signals strong? Where are inputs missing or likely to produce low-confidence results?

Proceed or improve

Clear recommendation on whether to proceed with extraction or improve the assessment first.

02Extraction

Risks extracted from the whole assessment

Acompli analyses the complete set of responses holistically — identifying cross-question patterns, contextual risks, and control gaps that isolated analysis would miss. Each extracted entry includes structured fields, confidence scoring, and a check that ties every claim back to the source text.

The DPO reviews each proposed entry, accepting, adjusting, or rejecting individual fields before anything is published. The register reflects human decisions, supported by machine-generated analysis.

Risk Extraction — Employee Monitoring DPIA
Excessive data collectionCritical
Inadequate legal basisHigh
Retention period overreachHigh
Cross-border transfer exposureMedium
Consent withdrawal mechanismLow
Processor contractual gapsMedium
Inherent risk levels
CriticalHighMediumLow
03Consistency

Consistency analysis catches what humans miss

Acompli's consistency analysis runs across the full set of extracted risks, identifying duplicates, severity mismatches, and control contradictions.

An overall quality score aggregates all checks into a single readiness indicator, with a clear recommendation on whether the set is ready for DPO review. Probing questions resolve ambiguity while context is still accessible.

Duplicate detection

Same risk captured from different questions — similarity scores and suggestions to merge or cross-reference.

Severity inconsistencies

Similar risks rated differently without documented rationale. Control effectiveness vs risk gap contradictions.

Probing questions

Targeted clarifying questions for ambiguous responses — tracked through pending, answered, dismissed, or resolved.

Quality →Overall quality score with clear recommendation on review readiness
04Treatment

Treatment plans that track to completion

Every risk in Acompli's register supports a structured treatment plan with a defined strategy, named owners, costed actions, and ROI tracking.

Each treatment plan is a managed programme of work, accountable to named individuals, with measurable outcomes. Budget allocated and budget spent are tracked against the plan.

Mitigate

Implement controls to reduce likelihood or impact to an acceptable level.

Avoid

Redesign the processing activity to eliminate the risk entirely.

Transfer

Address risk contractually — through processor agreements or insurance.

Accept

Document a reasoned decision to tolerate risk within defined thresholds.

Tracked →Named owners, due dates, cost estimates, progress tracking, and ROI measurement
05Governance

Designed for review, control, and traceability

Risks are proposed by AI, but the register is owned by humans. Every stage of the process is controlled, auditable, and reversible. Nothing enters the register until a human approves it. In Acompli, extracted risks arrive as drafts; the reviewer's accept, adjust or reject decision is what publishes them.

Enterprise organisations operating across multiple legal entities get entity-level segregation with consolidated group-level reporting. Entity-scoped users see only the risks relevant to their entity.

Draft-first workflow

Extracted risks are presented as drafts for the reviewer to accept, adjust, or reject.

Evidence-linked entries

Every risk traces to its source assessment question, response, and approval.

Complete audit history

Every decision, edit, approval, and status change permanently recorded.

Checked against the source

Every AI claim verified against actual assessment text. Nothing asserted without source evidence.

06Dashboards

Dashboards that reflect the current truth

Risk heatmaps, trend analysis, severity distribution by category, treatment progress, residual exposure — all derived from live data, not a quarterly export. When the status changes in Acompli, the dashboard changes.

Filter by business unit, legal entity, risk category, or processing activity, then export to your board packs, audit committees, and downstream GRC platforms.

Risk heatmap

4×4 likelihood-by-impact matrix with drill-down to individual risks per cell.

Status distribution

Open, In Treatment, Mitigated, Accepted, and Closed — at a glance.

Monthly trends

Time-series view of how the register is evolving over time.

Ageing buckets

Risks grouped by age to highlight entries going stale.

Owner breakdown

Risk distribution by assigned owner, prioritising critical and high severity.

GRC export & API

PDF for board packs, Excel for audit, and API with custom field mapping.

How risk management works, in six steps

  1. ReadinessA readiness check confirms the assessment covers what meaningful risk work needs.
  2. ExtractionRisks are extracted from the whole assessment, including cross-question patterns.
  3. ConsistencyConsistency analysis catches duplicates, severity mismatches and control gaps.
  4. TreatmentEach risk carries a structured treatment plan with owners, costed actions and tracking.
  5. GovernanceAI proposes risks, but the register stays owned and approved by humans.
  6. DashboardsHeatmaps, trends and residual exposure are derived from the live register.
02

The outcome

Evidence-linked risk management that drives action

Six connected stages, one governed register. From assessment evidence to action, every risk has a source, owner, treatment path and audit history. Acompli stores that chain on the risk record itself, so reporting never depends on reconstructing it.

Evidence-linked

Every risk is grounded in approved assessments.

Actionable

Treatment plans with owners, dates and ROI.

Governed

Draft-first, reviewed, approved and audit-ready.

Always current

Live dashboards reflect the latest reality.

03

Built for GDPR accountability

Meet Article 5(2) accountability and Article 35 DPIA follow-up obligations

Acompli links risk records to assessments, RoPA, suppliers and approvals so privacy teams can evidence how risks were identified, evaluated, treated and reviewed.

01

Article 5(2)

Demonstrate how risks are identified, assessed and managed.

02

Article 35

Follow up on DPIA results with action and evidence of implementation.

03

DPO oversight

Full audit trail for regulators and internal review.

04

Inspector-ready

Clear evidence of risk management over time.

04

Article 5(2) & Article 35 answer

Is maintaining a data protection risk register a legal requirement in Ireland and the UK?

There is no standalone statutory duty to keep a ‘risk register’ in either jurisdiction, but both regulators expect data protection risks to be documented and acted on. Under GDPR Article 5(2) accountability — enforced by the Data Protection Commission (DPC) in Ireland and, under the UK GDPR, by the ICO — you must be able to demonstrate how risks are identified, rated and treated, and Article 35 requires the risks a DPIA surfaces to be followed up. A risk register is the practical evidence of that.

Acompli builds the register from approved assessments so each entry traces to its source question, response and approval — the kind of demonstrable record the DPC and ICO look for. The AI drafts and scores each entry; nothing is published until the DPO signs off.

Key takeaways

  • Evidence shows why a risk exists, what mitigation was chosen, who approved it and when it was reviewed.
  • Risks should connect to RoPA through the relevant processing activity, data category, system, vendor, transfer or assessment.
  • Risk ownership matters because mitigation needs named owners, review dates and task status.
  • AI may draft and score, but a human reviews and approves the final risk record.
  • No standalone ‘risk register’ law, but it is expected evidence. GDPR Article 5(2) accountability (DPC in Ireland) and the UK GDPR (ICO) require you to show how risks are identified, rated and treated; Article 35 requires DPIA risks to be followed up.
  • The DPC and ICO expect a current, demonstrable risk record — not a stale spreadsheet — in an audit, inquiry or post-breach investigation.
  • When comparing risk-register tools, score on evidence links back to the source DPIA, separate inherent vs residual scoring, and a tracked treatment plan with named owners — the full five-point checklist is in the questions below.
  • For Schrems II transfers, the register should record the destination, the Article 46 mechanism, whether a Transfer Impact Assessment is approved, the supplementary measures and the residual risk.
05

Primary sources

An evidence-linked register the DPC and ICO can inspect

The accountability principle in GDPR Article 5(2) and the DPIA follow-up duty in Article 35 are why a documented, traceable risk record matters in an Irish or UK regulatory review. Acompli builds that record from approved assessments, with every AI-drafted entry grounded against the source text and signed off by the DPO.

Last reviewed: June 11, 2026. For the legal-requirement and when-mandatory detail on the assessments that feed the register, see the DPIA guide and Assessments; for international transfers, see the Transfer Impact Assessment guide.

Recent privacy risk updates

Risk signals privacy teams need to keep on the register

Recent enforcement, breach and transfer developments often become risk-register work: update the evidence, confirm owners, review treatment and track residual exposure.

Risk FAQ

Risk management questions answered

How Acompli builds and maintains a GDPR risk register grounded in evidence.

Privacy risk management software turns assessment findings, incidents and control gaps into governed risk records. In Acompli, each risk links back to the source DPIA or assessment evidence, carries inherent and residual scoring, has named owners and treatment tasks, and remains draft until a human reviewer approves it.

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See risk management in action

Risk management is built into the platform — connected to your DPIAs, RoPA, and data map in one workflow.