What evidence do auditors commonly ask for on DSP-05 Data Flow Documentation?

Data flow diagrams showing systems, locations and transfers; Review records at the defined interval; Change records that triggered data flow updates; Accuracy checks of diagrams against system configurations; Owner for each data flow document.

What is the most common gap auditors find on DSP-05?

Diagrams cover only the core platform, not integrations

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

`DSP-05` Data Flow Documentation

Documentation of data flows shows which data is processed, stored or transmitted and where. It is reviewed at set intervals, at least yearly, and when significant changes occur.

Source: CSA CCM v4.1, DSP-05. 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

Change records that triggered data flow updates · Data governance / DLP tooling

periodic reviewEvidence produced at each review

Review records at the defined interval · Data governance / DLP tooling
Accuracy checks of diagrams against system configurations · Data governance / DLP tooling

governing documentDocuments that govern the control

Data flow diagrams showing systems, locations and transfers · Policy repository / GRC workspace
Owner for each data flow document · 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

Diagrams cover only the core platform, not integrations
Cross-border flows not shown
Diagrams outdated after architecture changes

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-04 Data Classification · DSP-06 Data Ownership and Stewardship