EVIDENCE ARTEFACTS
- Test scope and sample
- Timestamped result with evidence references
- Finding and remediation record
PROC-03v1.0
CONTROL RECORD · REVIEWED 2026-08-30
Sub-processor review and approval
Make sub-processor review and approval 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 sub-processor review and approval an inspectable system decision with a named owner, defined trigger and retrievable evidence.
- Rationale
- Keep processor instructions, sub-processors, locations, transfer conditions and exit evidence connected.
- Owner model
- Vendor owner · Procurement or legal reviewer · Security and exit owner
- Review frequency
- Before onboarding, on material change and at least annually
- Architecture layer
- Processor and transfer governance
- 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 sub-processor review and approval 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 “sub-processor review and approval” 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 pathwayPROC-03: Sub-processor review and approval
- 01 · PrerequisiteProcessor instruction and contract map
Review PROC-02 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 sub-processor review and approval 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 artefactTest scope and sample
Timestamped result with evidence references · Finding and remediation record
Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 - 05 · Failure modeTreating “sub-processor review and approval” 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
Move from the register into a reviewed implementation plan. This route remains optional if the destination is unavailable.
Contextual external property · no affiliation or availability implied
- 01 · PrerequisiteProcessor instruction and contract map
Open semantic relationship table (1pathway)
| Record | Phase | Relationship | Status / boundary | Source pointers |
|---|---|---|---|---|
| PROC-03: Sub-processor review and approval | 01 · Prerequisite | Processor instruction and contract map Review PROC-02 before testing this dependent record. | Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 | dpdp-act-2023 |
| PROC-03: Sub-processor review and approval | 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 |
| PROC-03: Sub-processor review and approval | 03 · Validation / test | Select a recent, in-scope sample for sub-processor review and approval 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 |
| PROC-03: Sub-processor review and approval | 04 · Evidence artefact | Test scope and sample Timestamped result with evidence references · Finding and remediation record | Engineering indicator · not a legal requirement · Verification pointers: dpdp-act-2023 | dpdp-act-2023 |
| PROC-03: Sub-processor review and approval | 05 · Failure mode | Treating “sub-processor review and approval” 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 |
| PROC-03: Sub-processor review and approval | 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 |
| PROC-03: Sub-processor review and approval | 07 · Specialist property | Implementation pathways Move from the register into a reviewed implementation plan. 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.