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

DSP-08 Data Privacy by Design and Default

Systems, products and business practices are developed on the principle of privacy by design and recognised practice, and system privacy settings are set by default in line with all applicable law.

Source: CSA CCM v4.1, DSP-08. 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.

5
artefacts
2
held by a system
1
at each review
moderate
to go live
Cloud console / configuration management
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 baseline showing privacy-protective defaults · Cloud console / configuration management
  • Mapping of default settings to legal requirements · Data governance / DLP tooling

periodic reviewEvidence produced at each review

  • Privacy review records for new features · Data governance / DLP tooling

governing documentDocuments that govern the control

  • Privacy by design procedure in the development lifecycle · Policy repository / GRC workspace
  • Sub-processor privacy obligations · Policy repository / GRC workspace

First move

Start with the 2 of 5 artefacts that already live in a system (Cloud console / configuration management); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

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.

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DSP-07 Data Protection by Design and Default · DSP-09 Data Protection Impact Assessment