PDPL map / gate 03
A data-transfer decision begins with the actual data flow
- Maintaining source
- SDAIA
- Technical default
- Minimize and restrict
- Decision authority
- Client / qualified reviewer
Map purpose, people, and fields
Record each user task, field and event, purpose, required or optional status, sensitivity, source, role, authoritative record, downstream copy, and deletion path. Special attention may be required for identifiers, finance, health, employment, location, biometrics, children, or other sensitive categories.
- Purpose before collection
- Sensitive-category review
- Role and access map
- Correction and deletion routes
Map processors and international access
Hosting, support, analytics, identity, payment, e-invoicing, email, AI, backups, exports, and developers may create processing or access. Record entity, account owner, countries, data, purpose, safeguards or approved requirements, retention, incident contact, contract owner, and fallback.
- Processor and subprocessor register
- Storage versus remote access
- Privilege and secret controls
- Transfer decision evidence
Map proof and response
Test approved notice and preference mechanisms, roles, logs, retention, requests, export, deletion, backup, restore, and incident escalation. Keep evidence scoped to the actual route and environment. A passing mechanism does not certify the organization's compliance or guarantee regulator acceptance.
- Fictional test data
- Request workflow
- Incident and breach decision roster
- Known limitations and review date
Draw the actual data and access map
List fields, purposes, systems, vendors, countries, access roles, retention, sensitive categories, incidents, and the qualified owner of each open decision.
Prepare the project brief