Vailor: the sovereign AI-native GRC alternative to OneTrust

They describe different objects: the record covers processing activities, their purposes, recipients and retention periods, while the security inventory covers the assets that run them, applications, servers, hosting arrangements and data flows. They still describe one reality, and keeping them unconnected means writing up the same application twice until the two versions drift. Vailor does not hold the record of processing, but a project's pre-assessment flags GDPR obligations from the start: the DPO is involved before the risk analysis begins, and both pieces of work start from the same project description.

Article 30 of the GDPR places the obligation on the controller; the processor keeps a record of its own, covering the categories of processing it carries out on behalf of its clients. The text puts it on neither the DPO nor the CISO. Under Article 39 the data protection officer informs, advises and monitors compliance with the regulation; in practice they often maintain the record, but accountability stays with the organisation. The CISO owns the security measures it refers to. In Vailor, custom roles and fine-grained rights keep each person's contribution separate, and the audit log shows who changed what and when.

The two exercises look at different risks. A data protection impact assessment under Article 35 weighs the risk to the rights and freedoms of the individuals concerned; an EBIOS RM analysis weighs the risk to the organisation and its missions. Their inputs overlap heavily: the same processing activities, the same supporting assets, the same threat scenarios and often the same controls. Running them without coordination ends in two contradictory risk ratings on one subject. In Vailor, the pre-assessment flags from the start that a project falls under the GDPR: the DPIA, run with your DPO, and the cyber risk analysis then start from the same documents instead of contradicting each other.

Three duties trigger at once. Notification to the supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach, unless it is unlikely to result in a risk to the rights and freedoms of individuals (Article 33). Communication to the individuals concerned where that risk is high (Article 34). And internal documentation of every breach, notified or not, covering the facts, the effects and the action taken. The hard part is linking a technical incident to the processing activities and people actually affected. It goes faster when projects, their assets and their risk analyses are already documented, which is what Vailor organises on the security side.

Start from an export of your current record, in whatever format it comes. The headings Article 30 asks for do not change from one support to another (purposes, categories of individuals and data, recipients, transfers and retention periods, among others), so mapping the columns is mechanical work. What needs care is everything living outside the table: impact assessments already carried out, decisions and the reasons behind them, processor contracts. The migration loads the record first, then reattaches those items to the right processing activities. Plan for one review cycle run in parallel before retiring the old support. Vailor does not replace that record: it flags, from the pre-assessment, the projects that touch personal data.

Two tools stay workable, particularly when the DPO and the CISO do not report to the same director. The cost shows up at the seams: the same processor assessed twice, the same control written twice, the same incident logged twice, and on audit day nobody knows which version stands. What matters is that both sides talk at the right moment. Vailor focuses on security: it flags GDPR obligations in a project's pre-assessment and leaves the record of processing to your DPO's tool. The judgement calls stay with your teams.