CerulithCompliance A Year in the Chair · 6 modules
UK GDPR & DPA 2018 · DUAA 2025 · PECR

A Year in the Chair

Twelve months as a DPO. Six decisions that determine whether you are an exhibit or an example.

You are Dr Aisha Khan, Data Protection Officer at Cerulith Health Ltd. Across six interlocking modules — a Subject Access Request, a 72-hour breach, a DPIA on Art 9 health data + automated decision-making, a Schrems II vendor migration, a PECR-edge re-engagement campaign, and an ICO investigation — you make the decisions that decide what Helena Brandt finds in her binder when she arrives at Bishopsgate on 19 January 2027.

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1M1
The Request
Sam Chen files an Article 15 SAR. Eighteen thousand data points across three years across three processors. Rachel wants to refuse it. The clock starts at receipt.
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2M2
72 Hours
Friday 16:10. Imran walks in with a ransom note. 428,302 records, 39,241 health-data subjects. Three decisions before Monday's deadline. The Art 33 clock does not stop for weekends.
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3M3
The Register
Six weeks to launch. Pulse Clinic AI: triage on Art 9 health data, automated decision-making, no human in the loop. ROPA, DPIA, Art 36 — what gets logged, what gets shipped.
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4M4
The Transfer
Quarter-end vendor switch to a US analytics processor. DPF on the cover sheet, Palisade Compute on page 14. Three transfer-basis decisions. Schrems II is alive in your inbox.
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5M5
The Consent Trap
Wednesday 16:42. James Okafor's Slack DM lands. Operation Pulse Back — 310k re-engagement, a redesigned cookie banner, a Voxly data-append. Recital 47 vs PECR Reg 22. The two-layer test.
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6M6
The Room
Monday 19 January 2027, 09:42. Helena Brandt arrives at Bishopsgate with the binder. Three decisions across the morning. Everything from M1–M5 is in the binder. You defend it.
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