What evidence do auditors commonly ask for on DSP-13 Personal Data Sub-processing?

Data processing agreements with sub-processors; Sub-processor register; Due diligence and audit records for sub-processors; Contract clauses on sanctions and reporting; Sample of transfers checked against agreements.

What is the most common gap auditors find on DSP-13?

Sub-processors engaged without a processing agreement

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

`DSP-13` Personal Data Sub-processing

Processes, procedures and technical measures are defined, put in place and assessed for passing personal data to, and having it processed by, sub-processors in the service supply chain, in line with applicable law.

Source: CSA CCM v4.1, DSP-13. 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

Vendor register / contract repository

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

Due diligence and audit records for sub-processors · Vendor register / contract repository
Sample of transfers checked against agreements · Vendor register / contract repository

governing documentDocuments that govern the control

Data processing agreements with sub-processors · Vendor register / contract repository
Sub-processor register · Policy repository / GRC workspace
Contract clauses on sanctions and reporting · Vendor register / contract repository

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

Sub-processors engaged without a processing agreement
Register not maintained
No ongoing monitoring after onboarding

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-12 Limitation of Purpose in Personal Data Processing · DSP-14 Disclosure of Data Sub-processors