What evidence do auditors commonly ask for on DSP-19 Data Location?

Data location register by region and site; Cloud region configuration evidence; Backup location records; Customer-facing data residency statements; Controls preventing data storage outside approved regions.

What is the most common gap auditors find on DSP-19?

Backups replicated to unlisted regions

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

`DSP-19` Data Location

Processes, procedures and technical measures are defined and put in place to state and record the physical places where data sits, including where it is processed and where it is backed up.

Source: CSA CCM v4.1, DSP-19. 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

moderate

to go live

Cloud console / configuration management

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

Cloud region configuration evidence · Cloud console / configuration management
Backup location records · Backup / DR tooling

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Data location register by region and site · Policy repository / GRC workspace
Customer-facing data residency statements · Document repository
Controls preventing data storage outside approved regions · Document repository

First move

Start with the 2 of 5 artefacts that already live in a system (Cloud console / configuration management); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Backups replicated to unlisted regions
Support access from other countries not considered
Register not kept current

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-18 Disclosure Notification · GRC-01 Governance Program Policy and Procedures