Organizational model

Roles, governance cadences, processes and lean controls in a software house delivering highly regulated SaaS. Complementary to the code of ethics. It does not replace bylaws, corporate compliance models (e.g. Italian Legislative Decree 231) or legal opinions: run it in parallel with your real structure and advisors.

NexStudio operates from Bangkok. Numbers in parentheses below are indicative (early stage): formalize appointments and delegations and update them as the team grows.

Document on roles, governance cadences and lean controls for the Company, with LexAura (Legal Tech) and MediAura (Health Tech) as product lines. It does not replace Legislative Decree 231 models, bylaws or legal opinions: align it with the legal entity, board and advisors.

Index

  1. Roles and scope
  2. Essential governance
  3. Key responsibilities (summary)
  4. RACI for critical processes
  5. Fast decision flows
  6. Mandatory minimum controls (lean)
  7. Essential KPIs
  8. Minimum documentation to maintain
  9. First operating plan (30 days)
  10. Recommended outsourcing
  11. Practical notes and recommendations

1. Roles and scope

A concise list of functions and expected commitment. To align the product domain (Legal Tech, Health Tech) with roles and advisors, also refer to the code of ethics and, for data processing, to the privacy policy and DPA.

  • Founder / CEO (1): strategy, policy approval, board and investor relations, overall accountability toward law and contracts.
  • CTO / Head of Product (1): architecture, roadmap, product quality gates, end-to-end technical responsibility.
  • Lead Engineer (1–2): development, code review, CI/CD, code quality within the team.
  • DevOps / Platform (1, or outsourcing): deploy, KMS, backup and disaster recovery, production environment governance.
  • Security & Privacy Lead (1, hybrid or contractor): operational security, vulnerabilities, alignment with DPO and sensitive releases.
  • DPO / Privacy responsible (fractional or outsourcing): DPIA, data subject rights, notice consistency and records of processing.
  • Legal & compliance (fractional or external): contracts, NDAs, sector regulations relevant to Legal Tech and Health Tech.
  • Product / domain advisor (part-time or consultant): validation of features impacting medical or legal decisions, usage warnings.
  • Customer success / support (1): onboarding, requests, escalation to engineering and governance.
  • Operations / HR (1, part-time): staff onboarding, training, internal reporting and whistleblowing channels.
  • Finance (1, part-time or outsourcing): accounting, collections, vendor policies.

2. Essential governance

  • Weekly tactical: Founder, CTO, Security/privacy, customer success. — priorities, open incidents, critical releases.
  • Product sync (biweekly): CTO, lead engineer, domain advisor. — backlog, release, product compliance checkpoint (per line where needed).
  • Compliance check (monthly): CEO, legal, DPO, security. — DPIA, high-risk vendors, incident and remediation summary.
  • Quarterly review: board or founders. — strategy, budget, risks and capacity.

3. Key responsibilities (summary)

  • Code of ethics and policies: owned by legal & compliance; approved by CEO.
  • Operational security and incident response: owned by security lead; technical execution by CTO.
  • Privacy, sensitive processing, DPIA: owned by DPO; legal support.
  • Production releases: accountable CTO; responsible lead engineer; consulted security, DPO, domain advisor.
  • Vendors and sub-processors: owned by operations and legal; due diligence by security and DPO.
  • Data subject requests (DSR): owned by DPO; customer success operations where applicable.
  • Reports and whistleblowing: owned by operations/HR; investigative support by legal.

4. Condensed RACI for critical processes

Legend: R = Responsible, A = Accountable, C = Consulted, I = Informed.

Production release

Role R A C I
Lead engineer
CTO
Security lead, DPO, product advisor
CEO, customer success

Incident response (data breach or P0 incident)

Role R A C I
Security lead
CEO
DPO, legal, CTO
Affected customers, board (if high impact)

Vendor onboarding (sub-processor)

Role R A C I
Operations
Legal
Security lead, DPO
CTO, finance

DPIA (by perimeter: LexAura, MediAura, platform)

The RACI matrix does not replace the legal criterion (who is controller, who is processor) defined in contracts and in §5.1 of the code of ethics . Here: who coordinates the internal impact assessment exercise.

Role R A C I
DPO
Legal
Product advisor, CTO, security lead
CEO

5. Fast decision flows

  • Ordinary technical decision: lead engineer → CTO (ticket with a note if it affects privacy/security or contractual risks).
  • Release with privacy or security impact: go-ahead from security lead and DPO, target 48 business hours unless a reasoned written waiver.
  • P0 incident (e.g. probable or confirmed data breach): security notifies CEO, DPO and legal within 4h; board if impact on customers, regulators or sensitive data classes is high.

6. Mandatory minimum controls (lean)

  • IAM with MFA for production and secrets access.
  • CI/CD with SAST and dependency scanning in the pipeline.
  • SBOM for every release.
  • TLS in transit; encryption at rest for sensitive data.
  • Daily backups; quarterly DR test with documented restore.
  • Logging and alerting on anomalies (SIEM or managed service).
  • Pre-release security/privacy checklist with approval trail.

7. Essential KPIs

  • Security: critical patches within SLA; MTTD and MTTR on incidents.
  • Privacy: DSR response time; open vs completed DPIAs by perimeter (Legal, Health, platform).
  • Product: deploy lead time; test coverage on critical modules (per product line).
  • Operations: uptime vs SLA; support response time; reports closed in the period.

8. Minimum documentation to maintain

  • Code of ethics, adhesions in the register.
  • Privacy notice, DPA, terms of use.
  • DPIA for critical processing (reference by perimeter, as in the code of ethics).
  • Trust/security brief for customers and audits (1–2 pages).
  • Incident response playbook (executable version).
  • SBOM and register of vendors and sub-processors.
  • Pre-release checklist and approval log.

9. First operating plan (30 days)

  1. Days 0–3: written appointments for security, DPO and fractional legal, with delegations.
  2. Days 4–10: pre-release checklist in the pipeline; MFA and IAM policy at the minimum above.
  3. Days 11–17: start or update a DPIA on the most critical processing (e.g. MediAura or LexAura perimeter); due diligence on high-risk vendors.
  4. Days 18–24: basic trust center: links to code of ethics, DPO/security channels, privacy/DPA materials if available.
  5. Days 25–30: incident drill; rollback and backup test; initial mandatory security/privacy training.

10. Recommended outsourcing (to stay lean)

  • Security ops / SOC: logging, alerting, periodic penetration tests.
  • DPO and legal: advisors with PDPA, GDPR and the medico-legal context of the markets you serve.
  • DevOps / platform: managed cloud services (KMS, managed databases) to reduce internal toil.

11. Practical notes and recommendations

  • Separation of duties: whoever approves production is not the only one granting admin access.
  • Automate repetitive controls (SAST, SBOM, dependency scans).
  • Document risk acceptance and decisions in ticketing for audit and post-mortems.
  • For LexAura and MediAura: external validation on high-risk domain features.
  • Quarterly review of the model; update the entries in this document and written delegations.