CHECKPOINT 01Inventory and purpose
For each field, record who provides it, the service purpose, whether it is necessary, where it is stored, who can see it, and when it leaves active systems and backups.
- Reduce unnecessary identity collection
- Separate operational data from analytics
- Document exports and deletion
CHECKPOINT 02Notice, access, and vendors
Map the approved notice/permission path, user questions or rights requests, staff roles, service providers, cross-border movement, logging, and incident contacts.
- AI use needs a specific approved boundary
- Vendor contracts and locations are dependencies
- Access follows least privilege
CHECKPOINT 03Approval gate
The client and adviser determine Law 787 and sector obligations. Engineering implements the approved workflow, tests it, and records evidence without claiming certification.
- No blanket compliance statement
- Recheck sources before release
- Assign a human response owner