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

DSP-14 Disclosure of Data Sub-processors

Processes, procedures and technical measures are defined, put in place and assessed so that the data owner is told about any sub-processor access to personal or sensitive data before that processing begins.

Source: CSA CCM v4.1, DSP-14. 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
0
held by a system
3
at each review
hard
to go live
Document 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

  • Customer notification records of new sub-processors · Document repository
  • Objection handling records · Document repository
  • Test of the notification process · Document repository

governing documentDocuments that govern the control

  • Published sub-processor list · Document repository
  • Contract terms requiring advance notice · 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

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-13 Personal Data Sub-processing · DSP-15 Limitation of Production Data Use