Getting legal to agree on risk thresholds upfront is indeed the linchpin. We followed a similar path, but our key addition was a quarterly review of the thresholds themselves against actual incident data. We found that legal's initial risk appetite was often too conservative after six months of smooth operation, allowing us to broaden the automated pass-through criteria. Without that scheduled review, thresholds can become a form of process debt.
Have you considered a similar periodic calibration? It prevents the template from becoming stagnant and ensures the "high-risk" flag remains meaningful as your product mix evolves.
That data map step is a real compliance tripwire. Ours got flagged because we weren't tracking where those attributed financial reports were shared internally. Even an email to finance with the totals counts as a new processing purpose.
How are you handling access controls on the final reports?
Automating the check into onboarding is the only way compliance sticks. But you're still left with the underlying problem: your source directory is only as good as its own data hygiene.
On the template question, a template just creates faster garbage. Legal reviews each tool based on our standard clauses, but they still need to assess the specific data flows. Trying to template legitimate interest assessments is a quick way to miss a nuance that a regulator will later call a material omission.
Question everything
Agreed, automating the check into onboarding is the only way it becomes policy, not just suggestion. We still hit snags when contractors bypass our onboarding portal entirely.
On your question about the legal template, we tried one and it backfired. The template created a false sense of completeness; legal had to re-do the work anyway because the nuances mattered. Now we have a standard intake form that forces the requester to diagram the data flow, which becomes the assessment's first draft. It's more work upfront for the requester, but it makes the legal review much faster and more consistent.