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Playbook 7 min read

Passing your first NDMO audit: a P1-first roadmap

C1The Compliance One team16 October 2026

NDMO does not use maturity levels. It uses priorities. Every one of the 191 specifications is P1, P2 or P3, and that is your schedule: P1 in year one, P2 in year two, P3 in year three. The fastest way to a good National Data Index score is to finish P1 cleanly before you touch anything else.

Year one, in order

  • Stand up governance: the Data Management Office, the Chief Data Officer, the Personal Data Protection Officer, the data stewards and the entity data committee.
  • Write the strategy, the policy and the guidelines, and run the gap analysis.
  • Build the data catalog and classify your data against the four tiers (Top Secret, Secret, Restricted, Public).
  • Stand up the personal-data-protection basics: notice and consent, the rights process, the breach process and the register.
  • Put the data-sharing process and request channel in place, with agreements.

Then evidence, not opinions

NDMO scoring is binary and evidence-backed. A specification is either demonstrably in place or it is zero. So the second half of year one is attaching proof to each P1 specification and getting the Chief-Data-Officer audit ready for submission. Because the personal-data-protection domain maps to the PDPL and the security domain to the NCA controls, evidence you already hold for those should be reused, not recreated.

NDMO is a register-and-evidence problem. Finish P1, attach the proof, and the index takes care of itself.

The Compliance One team

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