DLP Implementation Checklist

Implementation Overview

This comprehensive checklist covers all essential tasks for implementing a PDPA-compliant DLP solution in your organization. Follow these phases sequentially to ensure successful deployment.

0%

Complete

0 of 0 tasks

5

Implementation Phases

6-12

Months Timeline

80+

Tasks & Items

100%

PDPA Aligned

Free

Open Source

1

Phase 1: Planning & Assessment

Timeline: Months 0-2

Stakeholder Engagement

Secure executive sponsorship

Obtain C-level support and budget approval for DLP initiative

Form steering committee

Include IT, Legal, HR, Compliance, and Business representatives

Appoint Data Protection Officer (DPO)

As required under PDPA Section 11 for organizations processing personal data

Identify department champions

Select representatives from each department to drive DLP adoption

Current State Assessment

Document existing data protection measures

Inventory current security controls, policies, and technologies

Conduct PDPA gap analysis

Compare current practices against PDPA requirements (Sections 6-20)

Map data flows

Identify how personal and sensitive data moves through your organization

Assess risk exposure

Evaluate potential data breach scenarios and impact

Project Planning

Define project scope and objectives

Clarify what data, systems, and users will be covered

Create implementation timeline

Develop detailed project schedule with milestones

Allocate budget and resources

Secure funding for tools, training, and personnel

Establish success metrics

Define KPIs to measure DLP effectiveness

Phase 1 Deliverable

Project charter, gap analysis report, and implementation roadmap approved by steering committee

2

Phase 2: Discovery & Classification

Timeline: Months 2-4

Data Discovery & Classification

Deploy data discovery tools

Scan file shares, databases, cloud storage, and endpoints

Identify Sri Lankan personal data types

NIC numbers, passport numbers, bank account numbers, mobile numbers

Create data classification scheme

Public, Internal, Confidential, Restricted levels

Build comprehensive data inventory

Document location, volume, and ownership of sensitive data

Identify high-risk data stores

Prioritize systems with large volumes of personal data

Create data classification labels

Develop visual and metadata labels for documents and emails

Technology Assessment

Evaluate DLP solution options

Research and compare commercial and open-source DLP tools

Assess infrastructure requirements

Determine server, storage, and network requirements for DLP deployment

Plan integration with existing systems

SIEM, email gateway, cloud services, endpoint management

Procure and deploy DLP platform

Select vendor, complete procurement, and install DLP infrastructure

Phase 2 Deliverable

Complete data inventory, classification scheme, and deployed DLP infrastructure

3

Phase 3: Policy & Controls

Timeline: Months 4-6

Policy Development

Develop data handling policies

Define acceptable use, transfer, and storage policies aligned with PDPA

Create DLP policy framework

Define rules for each classification level and data type

Establish incident response procedures

Document process for handling DLP alerts and data breaches

Define exception and override processes

Create workflow for legitimate business exceptions to DLP rules

Get policy approval from stakeholders

Review and obtain sign-off from Legal, Compliance, and Executive teams

Detection Rules Configuration

Configure content inspection rules

Set up pattern matching for NIC, passport, credit cards, etc.

Set up contextual scanning

Configure rules based on sender, recipient, subject, file type

Configure classification-based rules

Apply policies based on data classification labels

Test detection accuracy

Validate rules against sample data sets to reduce false positives

User Training & Awareness

Develop training materials

Create presentations, videos, and quick reference guides

Train Data Champions

Provide in-depth training to department representatives

Create awareness campaign

Launch internal communications about data protection and DLP

Phase 3 Deliverable

Approved policies, configured detection rules, and trained Data Champions

4

Phase 4: Pilot & Rollout

Timeline: Months 6-9

Pilot Deployment

Select pilot group

Choose representative departments or teams for initial rollout

Deploy in monitor-only mode

Start with logging and alerting without blocking to gather baseline data

Conduct pilot user training

Train pilot group on data handling policies and DLP system

Monitor pilot performance

Track alerts, false positives, and user feedback for 2-4 weeks

Tuning & Optimization

Analyze false positives

Review and adjust rules causing excessive false alerts

Refine detection patterns

Improve accuracy of content matching rules based on pilot results

Address user feedback

Resolve usability issues and clarify policy ambiguities

Optimize performance

Fine-tune system resources and scanning schedules

Organization-Wide Rollout

Conduct organization-wide training

Roll out training to all employees handling personal data

Deploy to all departments

Gradually expand DLP coverage to entire organization

Establish support channels

Set up helpdesk and escalation procedures for DLP issues

Enable enforcement mode

Transition from monitor-only to active blocking after stabilization

Phase 4 Deliverable

Fully deployed DLP solution with trained users across the organization

5

Phase 5: Continuous Monitoring

Timeline: Ongoing (Months 9+)

Continuous Monitoring

Review DLP alerts daily

Investigate and respond to policy violations promptly

Generate monthly reports

Track incidents, trends, and compliance metrics

Tune detection rules continuously

Reduce false positives and improve accuracy based on operational data

Monitor system performance

Track system health, resource utilization, and scanning coverage

Compliance Management

Conduct quarterly PDPA audits

Verify compliance with data protection requirements

Maintain data processing records

As required by PDPA Section 12

Update data inventory annually

Reflect changes in systems and data flows

Prepare for regulatory inspections

Maintain documentation ready for PDPA Authority review

Incident Response

Investigate data breach incidents

Follow documented incident response procedures

Notify PDPA Authority within 72 hours

If breach affects personal data (PDPA Section 21)

Inform affected individuals

Communicate breach details and remediation steps as required

Conduct post-incident review

Analyze root causes and implement corrective actions

Continuous Improvement

Review and update policies annually

Adapt to changing business needs and regulatory requirements

Conduct annual user training refreshers

Keep staff updated on data protection best practices

Assess new data sources

Extend DLP coverage to new systems and applications

Stay informed on PDPA updates

Monitor regulatory changes and update program accordingly

Phase 5 Deliverable

Mature DLP program with continuous monitoring, compliance reporting, and ongoing improvement