Michael K. Onyekwere, CIPP/E
AI governance for the agent era. Data Protection Officer, common law qualified lawyer, founder of Janus Compliance, and author of the AI Agent Incident Register — legal analysis of how AI agents fail and who is liable when they do.
What I do
I run an independent AI governance practice under the Janus Compliance name, focused on the questions agentic AI is forcing onto compliance and legal teams: who is accountable when an autonomous agent acts, and what governance holds. The work is split into two visible surfaces. The first is Janus DPO-as-a-Service, a fractional Data Protection Officer engagement for businesses procuring and deploying AI tooling without a full-time DPO on the headcount. The second is CompanyScope, the publishing arm: the AI Agent Incident Register (AI agent failures analysed legally), vendor compliance profiles, topic guides, and side-by-side comparisons, all CIPP/E-reviewed and dated.
The published work is the same compliance work clients pay for, written down so a prospective client can see how the practice thinks before deciding to engage. Each profile, hub, and comparison stays current on a quarterly refresh cadence.
Credentials
- CIPP/E — Certified Information Privacy Professional / Europe (IAPP)
- Common law qualified lawyer, practising as a Data Protection Officer
Experience
Ten years in compliance across financial services and corporate services:
- Royal Bank of Scotland — financial services compliance
- Fidelity Investments — asset management compliance
- UnitedHealth Group — healthcare compliance
- TMF Group — corporate services compliance and data protection
What I write about
- AI agent incidents and liability — who answers when an autonomous agent causes harm (the AI Agent Incident Register)
- Agentic AI governance — accountability, human oversight, and the EU AI Act / NIST AI RMF controls that map to it
- GDPR and UK Data Protection Act 2018 in AI deployments
- EU AI Act — provider and deployer-side obligations
- Data Processing Addenda for AI vendors — what clauses actually decide the risk
- Cross-border data transfers under SCCs and the UK Addendum
- HIPAA and the BAA gate for US healthcare AI deployments
- Nigerian NDPA / NDPC compliance for fintech and diaspora-founded businesses
- The practical tradeoffs of choosing between OpenAI, Anthropic, Microsoft 365 Copilot, Google Gemini, Perplexity, ElevenLabs, and their enterprise alternatives
Browse the full output: everything published on CompanyScope.
How profiles are made
- Start from public documentation: DPA, subprocessor list, trust center, privacy policy, security pages.
- Cross-check against vendor blog posts and public regulatory filings.
- Apply the standard schema (data processed, DPA, subprocessors, training position, transfers, security docs, AI Act role, DPIA prompts, red flags).
- Flag every gap, contradiction, or recently-changed default explicitly.
- Date the review. Refresh on a quarterly cadence or when the vendor announces a material change.
What CompanyScope is not
- It is not legal advice. Use it as research input, not as a sign-off.
- It is not a vendor-paid directory. Vendors do not pay to be profiled, and a positive profile is not for sale.
- It is not a snapshot guarantee. Vendor terms change. Last-reviewed dates show how fresh the research is.
- It is not a marketing channel for the vendor. The profile reflects what the research finds, including what it does not find.
Get in touch
For ongoing AI compliance support or a CIPP/E-reviewed Vendor Risk Note on a specific decision, work with Janus Compliance directly.
- Janus DPO-as-a-Service — fractional Data Protection Officer engagements from £500/month
- Janus Compliance contact form
- Or use the CTA at the bottom of any vendor profile, topic guide, or comparison