Trace real data copies and controls; do not infer compliance from a policy document.
Workflow
- Define scope and authority. Identify data subjects, systems, environments, policy sources, contractual requirements, owners, and review boundary. Mark legal conclusions as out of scope unless supplied by qualified authority.
- Inventory data elements. Classify direct identifiers, quasi-identifiers, credentials, financial or health data, content, telemetry, model inputs and outputs, and derived attributes. Record purpose and collection source.
- Trace every copy. Follow writes and replication into databases, blobs, caches, queues, logs, traces, analytics, warehouses, search indexes, feature stores, exports, backups, local files, and third parties.
- Map retention rules. For each copy, identify owner, purpose, legal or business basis supplied, creation time, retention clock, deletion trigger, hold or exception, and maximum duration. Flag indefinite or undocumented storage.
- Inspect enforcement. Locate TTLs, partitions, lifecycle policies, deletion jobs, anonymization, key destruction, vendor APIs, and access controls. Verify whether controls apply to historical records and failure retries.
- Test subject workflows. Trace access, correction, export, and deletion identifiers across aliases, tenant moves, merged accounts, and derived data. Check authorization, auditability, partial failure, retry, and completion evidence.
- Handle backups honestly. Document backup retention, restore implications, deletion propagation after restore, and access restrictions. Do not claim immediate erasure when recovery copies persist under a defined lifecycle.
- Verify with samples and metrics. Use safe synthetic or authorized records to test expiry and deletion. Require counts of eligible, processed, failed, overdue, and restored records without exposing sensitive values.
[!WARNING] Do not copy real sensitive values into the audit report. Reference systems, fields, record identifiers approved for audit, and aggregate evidence.
Output
Provide a data inventory and lineage matrix, policy-to-control mapping, retention and deletion gaps, backup and vendor caveats, workflow test evidence, prioritized remediation, owners, and unresolved questions requiring privacy or legal judgment.