What evidence do auditors commonly ask for on DSP-16 Data Retention and Deletion?

Retention schedule with periods by data type and legal basis; Automated deletion job configurations and logs; Archive procedures; Sample checks of data deleted on schedule; Legal hold procedure.

What is the most common gap auditors find on DSP-16?

Data kept indefinitely by default

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

`DSP-16` Data Retention and Deletion

Keeping, archiving and deleting data is handled according to business needs and applicable legal and regulatory obligations.

Source: CSA CCM v4.1, DSP-16. 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

Automated deletion job configurations and logs · SIEM / log platform

periodic reviewEvidence produced at each review

Sample checks of data deleted on schedule · Data governance / DLP tooling

governing documentDocuments that govern the control

Retention schedule with periods by data type and legal basis · Policy repository / GRC workspace
Archive procedures · Policy repository / GRC workspace
Legal hold procedure · 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

Data kept indefinitely by default
Backups ignore retention periods
Retention schedule not linked to systems

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-15 Limitation of Production Data Use · DSP-17 Sensitive Data Protection