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The compliance calendar
These are the dates that decide whether a privacy program is real. The 72-hour clock is the one most organizations get wrong — it starts from knowledge or reasonable belief, not from confirmation.
Notify the NPC and affected data subjects of a notifiable breach
The clock starts from knowledge or reasonable belief — not from confirmation. An organization that spends four days establishing the facts before notifying has already missed the deadline.
NPC Circular 16-03
Submit the full breach report through the DBNMS portal
Measured from discovery.
NPC Circular 16-03
File the Annual Security Incident Report
Covers the preceding calendar year. Due every year, incident or not.
NPC Circular 16-03
Register a new personal data processing system
From the date processing commences. Registration is entirely online.
NPC Circular 2022-04
Register the DPO designation
From the effectivity of the designation.
NPC Circular 2022-04
Notify the NPC of a minor change
Changes to registered details that do not alter the scope of processing.
NPC Circular 2022-04
Notify the NPC of a major change
Changes that alter the nature, scope or purpose of processing.
NPC Circular 2022-04
Cure deficiencies flagged at registration review
Miss it and the application lapses; you start again.
NPC Circular 2022-04
Renew the Certificate of Registration
The certificate is valid for one year.
NPC Circular 2022-04
DPO report to management or the board
Roadmap review and spot checks on controls. Not a statutory deadline, but it is the evidence that the program is actually running.
Good practice
Update the registers
Records of processing, vendor register, data subject request log, incident log, and intake for any new system.
Good practice
Refresher training, tabletop exercise and notice review
A breach plan that has never been exercised is not a tested plan, and the audit will say so.
Good practice
Internal privacy audit, PIA refresh and Manual review
The evidence base for the following year’s program.
Good practice
This calendar is what a retainer actually takes off your desk
Nexthread Solutions is an information technology solutions provider for both hardware and software needs. Current as of July 27, 2026. Reviewed quarterly, and on each new NPC issuance.