What evidence do auditors commonly ask for on PSS-12 Locations of Data Processing and Storage?

Contract or ordering options listing the selectable processing and storage regions; Architecture documentation showing regional placement is technically enforced; Configuration evidence that backup copies remain within the chosen region; Record confirming a tenant's actual data placement matches its selection.

What is the most common gap auditors find on PSS-12?

Primary storage pinned regionally while backups or replicas leave the region

BSI C5 (121-criteria catalogue) · C5: Product Safety and Security

`PSS-12` Locations of Data Processing and Storage

Let the cloud customer choose, from the options available under its contract, the location or country in which its data is processed, stored and backed up, and ensure the cloud architecture itself enforces that choice.

Source: BSI C5 (121-criteria catalogue), PSS-12. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open BSI C5 (121-criteria catalogue) in the compliance library.

The edition of the catalogue is not stamped here; check the edition your attestation is issued against.

artefacts

held by a system

at each review

moderate

to go live

Backup / DR tooling

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

Configuration evidence that backup copies remain within the chosen region · Backup / DR tooling

periodic reviewEvidence produced at each review

Record confirming a tenant's actual data placement matches its selection · Document repository

governing documentDocuments that govern the control

Contract or ordering options listing the selectable processing and storage regions · Vendor register / contract repository
Architecture documentation showing regional placement is technically enforced · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Backup / DR tooling); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Primary storage pinned regionally while backups or replicas leave the region
Placement honoured by process alone with nothing preventing a cross region deployment
Support tooling and telemetry data processed outside the selected location
Customers given a choice with no means of verifying where data actually resides

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

PSS-11 Images for Virtual Machines and Containers · SIM-01 Policy for security incident management