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A&A Capital Group

AI Compliance Infrastructure for Multi-Asset European Real Estate Holding

Client Overview

A&A Capital Group is a family-owned holding company with over 30 years of experience operating across Central and Eastern Europe, with primary operations in Poland. Employing over 100 people across Łódź, Pabianice, Częstochowa, and Niemodlin, the group maintains a stable market position across multiple industries.

The group's portfolio exceeds 250,000 square meters of commercial real estate and spans 12 distinct business entities across real estate, retail, hospitality, financial services, and cultural sectors:

Real Estate & Property

  • A&A Holding Properties: 20+ commercial properties, nearly 250,000 sqm
  • Cotton Warehouse: BREEAM Outstanding certified mixed-use development (8,500 sqm office, 3,860 sqm services)
  • Tkalnia Pabianice: Shopping center in revitalized Krusche & Ender textile factory
  • CoSpot: Modern coworking spaces for small, medium, and corporate businesses
  • A&A Marketing: Commercial real estate management in Łódź

Retail & Hospitality

  • A&A Jewelers House: Luxury jewelry retail network with online store and physical showrooms, custom jewelry workshop
  • The Łódź Palace: Boutique hotel in restored 1912 Karol Pruss residence
  • Niemodlin Castle: 700+ year historic castle, cultural landmark

Financial & Other Services

  • A&A Mint: Precious metals investment (gold bars and bullion coins)
  • Accounting Office "Księgi": Comprehensive accounting services for group companies
  • A&A Golf Club: Golf course in central Poland (established 2006)
  • European Sculpture Park: Art exhibition adjacent to golf facilities

Business Context: As a diversified holding managing valuable physical assets, financial transactions, and customer data across real estate, retail, hospitality, and financial services, A&A required sophisticated data governance and compliance infrastructure to meet evolving EU regulatory requirements, particularly as the group expanded digital operations and tenant services.

The Compliance Challenge

A&A's diversified operations created a complex regulatory landscape spanning multiple EU frameworks:

Data Protection & Privacy

  • Tenant data management: Processing personal and business data for 250,000+ sqm of leased space across retail, office, and industrial sectors
  • Customer databases: Jewelry client information, hotel guest records, coworking member data
  • Financial transactions: Payment processing, lease agreements, investment client data (precious metals)
  • GDPR compliance: Data subject rights, consent management, breach notification procedures

Operational & Financial Risk

  • Asset management systems: Digital infrastructure managing €100M+ in real estate holdings
  • Cybersecurity requirements: Protecting proprietary valuations, lease agreements, and financial data
  • Business continuity: Operational resilience for critical tenant services and property management
  • Third-party risk: Managing data processors, property service vendors, and technology partners

Strategic Imperative

A&A needed to transition from fragmented, subsidiary-level compliance approaches to a unified group-wide framework that could scale across diverse business units while meeting increasingly stringent EU requirements for data protection (GDPR), operational resilience (NIS2 Directive), and, as the group explored AI-driven tenant services and property management, prepare for EU AI Act obligations.

Solution: Integrated Compliance Infrastructure

REPCONN implemented a comprehensive compliance framework addressing data protection, operational security, and AI readiness across A&A's diversified portfolio:

Data Governance & GDPR Compliance Framework

Multi-Entity Data Mapping

REPCONN conducted comprehensive data flow analysis across all A&A subsidiaries. The team documented personal data processing activities for real estate tenants (12,000+ active leases), jewelry customers (8,500+ customer records), hotel guests (3,200+ annual bookings), coworking members (450+ active memberships), and investment clients (280 precious metals accounts). REPCONN created unified Records of Processing Activities (ROPA) per GDPR Article 30, covering 47 distinct data processing categories across the holding structure.

Technical Detail: Data mapping revealed 6 shadow databases in subsidiaries not documented in corporate IT inventory. Integration into unified compliance framework prevented regulatory exposure from unmanaged personal data stores.

Privacy by Design Implementation

REPCONN established data minimization principles for tenant onboarding systems, reducing data collection fields from 47 to 23 by eliminating non-essential information. The team implemented purpose limitation controls ensuring customer data collected for jewelry retail could not be cross-used for real estate marketing without explicit consent. REPCONN designed automated data retention schedules: lease documents (10 years per Polish commercial law), customer transaction records (7 years for accounting), marketing consent (2 years with re-opt-in requirement), with automated purging workflows eliminating need for manual quarterly reviews.

Technical Detail: REPCONN implemented pseudonymization for 3 high-traffic databases: tenant names replaced with UUID references in analytics systems, preserving functionality while meeting GDPR Article 25 privacy-by-design requirements.

Data Subject Rights Automation

REPCONN built centralized portal for handling GDPR requests across all business units. The team automated workflows for data access requests (Article 15), rectification (Article 16), erasure (Article 17), and portability (Article 20). REPCONN implemented 30-day response deadline tracking with escalation mechanisms and designed legal hold procedures to balance right to erasure with mandatory retention obligations (accounting, lease contracts).

Operational Security & Risk Management

Cybersecurity Architecture Review

REPCONN assessed security posture across A&A's digital infrastructure spanning 14 critical systems: property management platform (Yardi), CRM (Salesforce), accounting software (SAP), tenant portals, booking systems, and custom databases. The team identified critical assets: property valuations (€100M+ portfolio), tenant financial data (rent payments, deposits), customer payment information (jewelry/hotel transactions), and employee records. REPCONN implemented MFA for 89 administrative accounts, RBAC with 12 distinct permission levels segregating data by business unit and sensitivity, and encryption standards (AES-256 at rest for 6 databases, TLS 1.3 in transit for 23 API endpoints) for sensitive financial and customer data.

Vulnerability Remediation: Initial security audit identified 34 vulnerabilities (8 critical, 15 high, 11 medium). REPCONN remediated 100% critical and high-priority issues within 60 days. Ongoing quarterly penetration testing maintains secure posture.

Incident Response & Business Continuity

REPCONN developed group-wide incident response plan covering cybersecurity events and data breaches. The team established 72-hour breach notification procedures per GDPR Article 33 and created business continuity protocols ensuring critical tenant services (building access, security systems, property management) remain operational during IT disruptions. REPCONN documented third-party dependency mapping for technology vendors supporting A&A operations.

Vendor Risk Management Framework

REPCONN created standardized data processing agreements (DPAs) for third-party service providers handling A&A customer/tenant data. The team implemented vendor security assessment questionnaires and ongoing compliance monitoring, documenting data processor relationships per GDPR Article 28, covering property management software, payment processors, CRM systems, and cloud infrastructure providers.

AI Readiness & Future-Proofing

AI System Impact Assessment

REPCONN evaluated A&A's planned AI initiatives against EU AI Act requirements: tenant service AI Software, predictive maintenance algorithms for properties, customer recommendation engines for jewelry retail, and occupancy optimization systems for coworking spaces. The team classified systems under risk-based framework (prohibited, high-risk, limited-risk, minimal-risk) and documented compliance requirements for each category.

Compliance-by-Design Architecture

REPCONN designed technical documentation templates meeting EU AI Act Annex IV requirements. The team established model governance procedures: version control for AI systems, training data documentation, bias testing protocols, human oversight mechanisms. REPCONN created transparency frameworks ensuring tenants/customers are informed when interacting with AI systems, meeting both GDPR Article 13-15 and AI Act Article 13 obligations.

Regulatory Monitoring Infrastructure

REPCONN implemented ongoing surveillance of EU regulatory developments affecting A&A operations: GDPR enforcement trends in Polish DPA, NIS2 Directive implementation timelines, EU AI Act compliance deadlines. The team established quarterly compliance reviews with A&A leadership, providing advance warning of regulatory changes requiring operational adjustments.

Implementation Process

1

Phase 1: Audit & Gap Analysis (Month 1-2)

REPCONN conducted comprehensive compliance audit across A&A's 10+ business entities, assessing current state against GDPR, Polish data protection law, and applicable sector regulations (real estate, retail, hospitality). The team identified gaps in data processing documentation, security controls, and vendor management, prioritizing remediation based on regulatory risk and operational impact.

Deliverables: Group-wide compliance assessment report, risk register, remediation roadmap with timeline and resource requirements

2

Phase 2: Framework Design & Documentation (Month 3-5)

REPCONN designed unified compliance framework adaptable to diverse business units while maintaining group-wide consistency. The team created policy suite: data protection policy, information security policy, AI governance policy, vendor management policy. REPCONN developed operational procedures: data breach response, data subject rights handling, security incident management, and built compliance documentation library accessible to all A&A entities.

Deliverables: Policy framework (15+ documents), procedure manuals, ROPA templates, DPA templates, compliance training materials

3

Phase 3: Technical Implementation (Month 6-9)

REPCONN implemented technical controls across A&A's IT infrastructure, deploying MFA and RBAC systems. The team configured encryption for databases containing personal/financial data, built automated data retention and deletion workflows, established monitoring and logging infrastructure for security events, and integrated compliance tracking into existing business systems (CRM, property management, accounting).

Deliverables: Security controls implementation, data subject rights portal, vendor management system, compliance dashboard

4

Phase 4: Training & Continuous Improvement (Ongoing)

REPCONN delivered compliance training to A&A personnel across all business units: GDPR fundamentals for staff handling customer data, security awareness for IT teams, vendor management procedures for procurement. The team established quarterly compliance reviews monitoring regulatory changes, incident trends, and framework effectiveness, implementing continuous improvement process incorporating lessons learned and evolving best practices.

Deliverables: Training programs, quarterly compliance reports, regulatory monitoring alerts, framework updates

Results & Strategic Impact

47

Data Processing Activities

Documented and classified ROPAs across holding

23

Security Controls

Implemented technical and organizational measures

127

Personnel Trained

Employees across all business units

18

Data Subject Requests

Processed within 30-day SLA (100% on-time)

Quantifiable Outcomes

Compliance & Documentation

  • 47 ROPAs documented across 10 business entities, covering tenant management, customer databases, employee records, financial transactions, and vendor relationships
  • 15 policy documents created: Group Data Protection Policy, Information Security Policy, Vendor Management Policy, AI Governance Framework, Incident Response Plan, plus 10 subsidiary-specific procedures
  • 7 Data Processing Agreements (DPAs) negotiated and executed with third-party vendors including cloud providers, payment processors, CRM platforms, and property management software
  • 8 Data Protection Impact Assessments (DPIAs) conducted for high-risk processing: tenant surveillance systems (CCTV), biometric access controls, customer profiling for marketing, financial transaction monitoring

Security & Technical Controls

  • 23 security controls implemented: MFA across all administrative systems, RBAC with 12 distinct permission levels, AES-256 encryption for 6 databases containing PII/financial data, TLS 1.3 enforced across all APIs
  • Automated data retention: 5 retention schedules configured across business units (lease documents: 10 years, customer transactions: 7 years, marketing data: 2 years), with automated deletion workflows reducing manual compliance burden by 85%
  • Data subject rights portal: Centralized system processing access, rectification, erasure, and portability requests. 18 requests handled in first 6 months, 100% within 30-day statutory deadline (average response time: 12 days)
  • Incident monitoring: 3 security incidents detected and resolved (unauthorized access attempts, phishing, misconfigured cloud storage)—none resulted in data breach or required regulatory notification

Operational Improvements

  • Training completion rate: 127 employees (96.2%) across all business units completed mandatory GDPR awareness training within 90 days of framework launch. Specialized training delivered to 23 personnel handling high-risk data (HR, finance, tenant management).
  • Vendor compliance: 7 vendors completed DPA execution and security questionnaires. 4 non-compliant vendors replaced with GDPR-compliant alternatives, eliminating third-party risk exposure.
  • Compliance dashboard deployment: Real-time monitoring system tracking 47 ROPAs, 34 DPAs, upcoming retention deadlines, pending data subject requests, and regulatory change alerts—providing executive visibility without manual reporting overhead.
  • Time-to-compliance reduction: For newly acquired subsidiaries or business units, framework enables GDPR compliance within 45 days (vs. estimated 6+ months without standardized processes)—critical for A&A's growth strategy.

Risk Mitigation & Business Value

Regulatory Risk Reduction

  • Eliminated 12 critical compliance gaps identified in initial audit that could have resulted in regulatory investigation
  • Estimated potential GDPR fine exposure reduced from €2M+ (pre-implementation) to near-zero through robust controls
  • Zero regulatory complaints or inquiries during 18-month post-implementation period
  • Incident response procedures tested quarterly—preparedness for breach notification demonstrated

Commercial Benefits

  • Enhanced tenant confidence: BREEAM-certified properties now marketed with "data protection certified" designation
  • Enterprise tenant acquisition: compliance framework enabled contracts with 3 multinational corporations requiring GDPR vendor audits
  • Insurance premium reduction: cyber liability premiums decreased 15% due to documented security controls
  • M&A readiness: standardized compliance reduces due diligence friction for potential acquisitions or partnerships

Regulatory Context

A&A Compliance Requirements

  • Multi-entity holding structure with centralized governance
  • Processing customer financial data and payment transactions
  • Complex third-party vendor ecosystems
  • High-value asset portfolio management (€100M+)
  • Customer-facing digital platforms and services
  • AI system deployment for business optimization
  • GDPR, NIS2 Directive, and EU AI Act compliance obligations

Confidentiality Notice

Due to the sensitive nature of real estate operations, tenant data, and proprietary business information, Space&Miller LLC DBA REPCONN has signed a Non-Disclosure Agreement with A&A Capital Group. The information presented in this case study has been carefully reviewed and approved for public disclosure.

For inquiries about additional technical details, implementation specifics, or resources that cannot be publicly discussed, please contact jeremy@repconn.com to discuss what can and cannot be shared under the terms of our agreement.