What evidence do auditors commonly ask for on DSP-03 Data Inventory?

Data inventory or record of processing listing sensitive, regulated and personal data sets; Data discovery tool output used to populate the inventory; Sample of inventory entries verified against systems; Review records for the annual and change-driven updates; Owner assignment per inventory entry.

What is the most common gap auditors find on DSP-03?

Regulated data such as payment or health data missing

CSA CCM v4.1 · DSP - Data Security and Privacy Lifecycle Management

`DSP-03` Data Inventory

A data inventory is created and kept current, covering at minimum all sensitive, regulated and personal data. It is revisited every year, and sooner after a significant change.

Source: CSA CCM v4.1, DSP-03. 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 CSA CCM v4.1 in the compliance library.

Version 4.1 adds 11 controls (among them API security, log sanitisation and a service bill of materials) and renumbers several domains. CSA accepts v4.0.x during its transition; if your STAR assessment is still on v4.0.1, check the numbering against it.

artefacts

held by a system

at each review

hard

to go live

Data governance / DLP 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

Data discovery tool output used to populate the inventory · Data governance / DLP tooling

periodic reviewEvidence produced at each review

Data inventory or record of processing listing sensitive, regulated and personal data sets · Data governance / DLP tooling
Sample of inventory entries verified against systems · Data governance / DLP tooling
Review records for the annual and change-driven updates · Data governance / DLP tooling

governing documentDocuments that govern the control

Owner assignment per inventory entry · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Data governance / DLP tooling on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

Regulated data such as payment or health data missing
Inventory compiled once for a privacy project and never refreshed
Shadow data stores in cloud services not discovered

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

DSP-02 Secure Disposal · DSP-04 Data Classification