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FFL / QAQatar feasibility deskFeasibility worksheet

Data review / engineering

Make the data flow visible before it becomes code

The technical review documents what personal or sensitive data enters the system, why it is needed, where it moves, who can see it, how long it remains, and which client or specialist decisions are still open.

Prepare the project brief
Authority starting point
Qatar NCSA and current law
Engineering posture
Minimize and separate
Legal conclusion
Client / qualified adviser
01

Inventory purpose before fields

Begin with the user task and business purpose, then justify each field. Names, contact details, identifiers, location, health, financial, employment, biometric, and children’s data create different risk. The interface should not collect information merely because a generic form template includes it.

  • Purpose and audience
  • Field-level necessity
  • Required versus optional data
  • Deletion and correction paths
02

Map every processor and transfer

Hosting, analytics, email, support, identity, payments, AI services, backups, and monitoring may each receive data. The architecture records the party, data categories, region, configuration, access model, retention, contract owner, and fallback. A vendor’s marketing page is not proof that a transfer or use is lawful.

  • Processor and subprocessor inventory
  • Storage and access regions
  • Secrets and privileged access
  • Export, backup, and recovery paths
03

Turn decisions into verifiable controls

Engineering can implement access limits, encryption in transit, consent or notice mechanisms, audit trails, retention jobs, incident contacts, and request workflows after the responsible owner approves the requirements. Validation proves the mechanism works; it does not certify the organization’s legal position.

  • Least-privilege roles
  • Testable retention behavior
  • Documented incident escalation
  • Evidence for qualified review
next decision

Sketch the data flow before choosing vendors

List the users, fields, systems, countries, vendors, access roles, retention needs, and the person who can approve each decision.

Prepare the project brief