P09 / Privacy / Independent work sample
Processor governance.
Processor relationships require contract and subprocessor oversight.
The decision
behind the work.
Model controller, processor, subprocessor, processing, transfer, obligation, evidence, and change events as a reviewable relationship graph.
Methodology and scope are defined in the project manifest. Listed capabilities describe the module design; source files show the implemented subset.
Assessment approach
- Role and processing graph
- DPA clause evidence map
- Subprocessor authorization workflow
- Transfer-mechanism record
- Change notice timer
- Flow-down gap detection
Evidence
to request.
Start with source records, owner confirmation, scope and observation dates. A completed template alone does not establish operating effectiveness.
Defined output contract
- processor-obligation-graph.json
- dpa-gap-review.json
- subprocessor-change-queue.json
- transfer-register.json
The manifest defines these expected artifacts; confirm their existence and completion in source before relying on an output.
Read the full manifest ↗Review & decision boundaries
- Contract interpretation remains legal review
- Do not expose confidential agreements publicly
- Record evidence and reviewer rationale for every conclusion
Remediation sequence
Record each finding with its evidence reference, risk rationale, accountable owner, target date and closure test. Escalate missing evidence rather than treating it as a pass.
Present management with the supported conclusion, remaining uncertainty and a specific decision request.