← NDPA 2023 · Governance
s.44 — Registration as a data controller or processor of major importance
Requirement
A data controller or processor of major importance shall register with the Commission within six months of the Act's commencement or of becoming one, and notify the Commission of significant changes (s.44). Under the GAID 2025 these organisations are designated ultra-high, extra-high or ordinary-high level; ordinary-high level registrations are renewed annually. This duty has no direct GDPR equivalent and is frequently missed by organisations that have simply reused their GDPR programme.
What the engine looks for
Every group below must be satisfied — by an affirmative statement, not a plan, a hedge or a denial — for the control to count as covered. A term ending in … matches any word it begins. Supporting terms do not change the verdict — they raise confidence and distinguish a policy that names a mechanism from one that gestures at a category.
Finding any of these outranks coverage — a policy that admits the gap is worse than silence.
Equivalent controls elsewhere
Matched on shared topics. Satisfying this control usually moves these too.
| Framework | Control | Title | Shared topics |
|---|---|---|---|
| GDPR | Art.5(2) | Accountability | policy-governance records |
| ISO 27001 | A.5.31 | Legal, statutory, regulatory and contractual requirements | policy-governance records |
| GDPR | Art.24 | Responsibility of the controller | policy-governance |
| GDPR | Art.30 | Records of processing activities | records |
| GDPR | Art.31 | Cooperation with the supervisory authority | policy-governance |
| CCPA/CPRA | Regs 7101 | Records of consumer requests kept for 24 months | records |
| SOC 2 | CC1.1 | Commitment to integrity and ethical values | policy-governance |
| SOC 2 | CC1.2 | Board independence and oversight | policy-governance |