What evidence do auditors commonly ask for on DSP-10 Sensitive Data Transfer?

Data transfer procedure including lawful transfer mechanisms (for example standard contractual clauses); Encryption in transit configuration; Transfer register with legal basis; Sample of transfers checked against policy; Transfer impact assessments.

What is the most common gap auditors find on DSP-10?

Cross-border transfers without a legal mechanism

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

`DSP-10` Sensitive Data Transfer

Processes, procedures and technical measures are defined, put in place and assessed so that whenever personal or sensitive data moves it is shielded from unauthorised access and processed only within the limits the relevant laws permit.

Source: CSA CCM v4.1, DSP-10. 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

Policy repository / GRC workspace

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

none for this control

periodic reviewEvidence produced at each review

Sample of transfers checked against policy · Policy repository / GRC workspace
Transfer impact assessments · Document repository

governing documentDocuments that govern the control

Data transfer procedure including lawful transfer mechanisms (for example standard contractual clauses) · Policy repository / GRC workspace
Encryption in transit configuration · Policy repository / GRC workspace
Transfer register with legal basis · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Cross-border transfers without a legal mechanism
File transfers by unencrypted email
Transfer register incomplete

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-09 Data Protection Impact Assessment · DSP-11 Personal Data Access, Reversal, Rectification and Deletion