What evidence do auditors commonly ask for on DSP-11 Personal Data Access, Reversal, Rectification and Deletion?

Data subject request procedure and intake channel; Request log with response times against legal deadlines; Sample of completed requests with identity verification; Technical capability to locate and delete personal data across systems; Roles and responsibilities.

What is the most common gap auditors find on DSP-11?

Deletion not propagated to backups or sub-processors

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

`DSP-11` Personal Data Access, Reversal, Rectification and Deletion

Processes, procedures and technical measures are defined and put in place so that data subjects can ask to see, change or delete their personal data, as applicable law requires.

Source: CSA CCM v4.1, DSP-11. 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

Request log with response times against legal deadlines · SIEM / log platform

periodic reviewEvidence produced at each review

Sample of completed requests with identity verification · Data governance / DLP tooling

governing documentDocuments that govern the control

Data subject request procedure and intake channel · Policy repository / GRC workspace
Technical capability to locate and delete personal data across systems · Policy repository / GRC workspace
Roles and responsibilities · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your SIEM / log platform 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

Deletion not propagated to backups or sub-processors
Deadlines missed without tracking
No identity verification before release

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-10 Sensitive Data Transfer · DSP-12 Limitation of Purpose in Personal Data Processing