What evidence do auditors commonly ask for on IPY-04 Data Portability Contractual Obligations?

Standard customer agreement or data processing terms with the exit and data return clause; Offboarding procedure with retention period and deletion steps; Deletion certificates or records for a sample of terminated customers; Register of non-standard contracts that vary the exit terms.

What is the most common gap auditors find on IPY-04?

Retention period after termination not stated

CSA CCM v4.1 · IPY - Interoperability & Portability

`IPY-04` Data Portability Contractual Obligations

Customer agreements must state what access service customers keep to their data when the contract ends, covering the data format, how long the data is kept, which data is retained and offered back, and the deletion policy.

Source: CSA CCM v4.1, IPY-04. 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

Deletion certificates or records for a sample of terminated customers · Vendor register / contract repository

governing documentDocuments that govern the control

Standard customer agreement or data processing terms with the exit and data return clause · Vendor register / contract repository
Offboarding procedure with retention period and deletion steps · HR system / LMS
Register of non-standard contracts that vary the exit terms · 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

Retention period after termination not stated
Deletion policy not aligned with the actual retention in backups
Data offered back only in a proprietary format

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

IPY-03 Secure Interoperability and Portability Management · LOG-01 Logging and Monitoring Policy and Procedures