EVIDENCE ARTEFACTS
- Versioned decision record
- Named ownership and approval
- Implementation or test evidence
DISC-05v1.0
CONTROL RECORD · REVIEWED 2026-08-30
Processor discovery
Make processor discovery an inspectable system decision with a named owner, defined trigger and retrievable evidence.
Engineering control
Catalogue status
not legal status
RECORD ANATOMY
What this control needs to be reviewable.
- Objective
- Make processor discovery an inspectable system decision with a named owner, defined trigger and retrievable evidence.
- Rationale
- Make systems, data categories, purposes, owners and processors visible before deciding what should change.
- Owner model
- Processing inventory owner · System owner · Independent reviewer
- Review frequency
- Quarterly and on material system or purpose change
- Architecture layer
- Discovery and ownership
- Version
- 1.0 · 2026-08-30
IMPLEMENTATION SEQUENCE
Move from scope to retrievable evidence.
- 01
Scope the decision: define the decision, owner, trigger, evidence and review path before implementation.
- 02
Record the approved design and its source-status verification boundary.
- 03
Connect implementation events to evidence that a reviewer can retrieve without broad production access.
CONTROL TEST
- Select a recent, in-scope sample for processor discovery and record why it was chosen.
- Trace the sample from its trigger and owner through the implemented system to the retained evidence.
- Record exceptions, confidence and remediation without converting an unknown into a pass.
ANTI-PATTERNS
Completion labels can hide an evidence gap.
- Treating “processor discovery” as a policy sentence without an operating owner
- Marking the control complete from self-attestation alone
- Hiding missing, stale or inaccessible evidence behind a pass label
ARCHITECTURE → EVIDENCE DECISION JOURNEY
Follow the dependency, then inspect the proof.
Each connection uses existing catalogue records. Source IDs remain verification pointers—not provision mappings.
Add to a review route- Control pathwayDISC-05: Processor discovery
- 01 · PrerequisiteCollection-surface review
Review DISC-04 before testing this dependent record.
Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 - 02 · Implementation patternProcessor and sub-processor register
Link approved providers to instructions, data flows, locations, assurance and exit work.
Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023, dpdp-rules-2025, act-commencement-2025 - 03 · Validation / testSelect a recent, in-scope sample for processor discovery and record why it was chosen.
Trace the sample from its trigger and owner through the implemented system to the retained evidence. Record exceptions, confidence and remediation without converting an unknown into a pass.
Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 - 04 · Evidence artefactVersioned decision record
Named ownership and approval · Implementation or test evidence
Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 - 05 · Failure modeTreating “processor discovery” as a policy sentence without an operating owner
Marking the control complete from self-attestation alone · Hiding missing, stale or inaccessible evidence behind a pass label
Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 - 06 · Research noteFrom obligation to evidence: the DPDP implementation stack
Implementation teams benefit from separating legal interpretation from the engineering artefacts used to execute and test a decision. Radar context: Software and data-flow inventories is Adopt.
Editorial analysis · reviewed 2026-08-30 · sources act-commencement-2025, pib-status-2026 - 07 · Specialist propertyImplementation pathways
Explore implementation planning when the inventory is ready to drive work. This route remains optional if the destination is unavailable.
Contextual external property · no affiliation or availability implied
- 01 · PrerequisiteCollection-surface review
Open semantic relationship table (1pathway)
| Record | Phase | Relationship | Status / boundary | Source pointers |
|---|---|---|---|---|
| DISC-05: Processor discovery | 01 · Prerequisite | Collection-surface review Review DISC-04 before testing this dependent record. | Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 | dpdp-act-2023 |
| DISC-05: Processor discovery | 02 · Implementation pattern | Processor and sub-processor register Link approved providers to instructions, data flows, locations, assurance and exit work. | Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023, dpdp-rules-2025, act-commencement-2025 | dpdp-act-2023 · dpdp-rules-2025 · act-commencement-2025 |
| DISC-05: Processor discovery | 03 · Validation / test | Select a recent, in-scope sample for processor discovery and record why it was chosen. Trace the sample from its trigger and owner through the implemented system to the retained evidence. Record exceptions, confidence and remediation without converting an unknown into a pass. | Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 | dpdp-act-2023 |
| DISC-05: Processor discovery | 04 · Evidence artefact | Versioned decision record Named ownership and approval · Implementation or test evidence | Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 | dpdp-act-2023 |
| DISC-05: Processor discovery | 05 · Failure mode | Treating “processor discovery” as a policy sentence without an operating owner Marking the control complete from self-attestation alone · Hiding missing, stale or inaccessible evidence behind a pass label | Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 | dpdp-act-2023 |
| DISC-05: Processor discovery | 06 · Research note | From obligation to evidence: the DPDP implementation stack Implementation teams benefit from separating legal interpretation from the engineering artefacts used to execute and test a decision. Radar context: Software and data-flow inventories is Adopt. | Editorial analysis · reviewed 2026-08-30 · sources act-commencement-2025, pib-status-2026 | act-commencement-2025 · pib-status-2026 |
| DISC-05: Processor discovery | 07 · Specialist property | Implementation pathways Explore implementation planning when the inventory is ready to drive work. This route remains optional if the destination is unavailable. | Contextual external property · no affiliation or availability implied | None · contextual external route |
VERIFY BEFORE MAPPING
GENERIC VERIFICATION POINTER · NOT A PROVISION MAPPING
dpdp-act-2023
Provision-specific applicability must be verified against the primary-text ledger.
Boundary: Operational control pattern; not a standalone legal conclusion.
Open the source ledgerCONNECTED SYSTEM PATTERN
Processor and sub-processor register
Link approved providers to instructions, data flows, locations, assurance and exit work.
LOCAL WORKSPACE NOTE
Give this work a next owner.
Nothing is sent anywhere. Avoid names, personal data or confidential incident details.
CHANGE LOG
Version 1.3 — Architecture-to-evidence journey and non-personal review-route relationship added; verification-pointer boundary retained.
Version 1.2 — Official-source status rechecked; command-centre indexing and the non-mapping boundary retained.
Version 1.1 — Engineering fields, source verification pointers and acceptance evidence reviewed.
Version 1.0 — Stable catalogue ID, objective, evidence model, test sequence and verification boundary established.