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01 Implementation control catalogue

Thirty-two controls. Every label earns its place.

Search by a system problem, filter by operating area, then open a control to see the implementation pattern, evidence, owners, test and official-source trail.

32 controls shown

Reviewed as an editorial record · 2026-08-30 · not counsel reviewed

MAP-01

Inventory · Implementation evidence

Collection-point inventory

Know what personal data enters the organisation, why it is used and which system owner is accountable.
Source-mapped2027-05-13
Provision status—not a control certificationMapped provision notified · scheduled 2027-05-13

Mapped provision: Act s. 4. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

List forms, interfaces, imports and human collection paths.

Evidence artefacts
  • Owned register
  • Field-to-system trace
  • Dated review record
Likely owner roles
  • Product
  • Operations
  • Privacy/Legal
Practical test

Run one synthetic case end to end; save the dated result, owner and unresolved exceptions.

PURPOSE-01

Inventory · Implementation evidence

Purpose register

Know what personal data enters the organisation, why it is used and which system owner is accountable.
Source-mapped2027-05-13
Provision status—not a control certificationMapped provision notified · scheduled 2027-05-13

Mapped provision: Act s. 4. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

Record each business purpose beside the data category.

Evidence artefacts
  • Owned register
  • Field-to-system trace
  • Dated review record
Likely owner roles
  • Product
  • Operations
  • Privacy/Legal
Practical test

Run one synthetic case end to end; save the dated result, owner and unresolved exceptions.

RIGHTS-03

Rights · Implementation evidence

Correction workflow

Turn a Data Principal request into an owned, searchable and reviewable operating workflow.
Source-mapped2027-05-13
Provision status—not a control certificationMapped provision notified · scheduled 2027-05-13

Mapped provision: Act s. 12. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

Exercise a correction through the systems of record.

Evidence artefacts
  • Request register
  • System search record
  • Decision and response evidence
Likely owner roles
  • Operations
  • Support
  • Privacy/Legal
Practical test

Run one synthetic case end to end; save the dated result, owner and unresolved exceptions.

RIGHTS-04

Rights · Implementation evidence

Erasure workflow

Turn a Data Principal request into an owned, searchable and reviewable operating workflow.
Source-mapped2027-05-13
Provision status—not a control certificationMapped provision notified · scheduled 2027-05-13

Mapped provision: Act s. 12. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

Trace deletion through active and downstream systems.

Evidence artefacts
  • Request register
  • System search record
  • Decision and response evidence
Likely owner roles
  • Operations
  • Support
  • Privacy/Legal
Practical test

Run one synthetic case end to end; save the dated result, owner and unresolved exceptions.

PROC-01

Processors · Implementation evidence

Processor register

Connect external services, contracts, access paths, sub-processing and exit responsibilities.
Source-mapped2027-05-13
Provision status—not a control certificationMapped provision notified · scheduled 2027-05-13

Mapped provision: Act s. 8. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

List processors, data flows, access and review dates.

Evidence artefacts
  • Service register
  • Contract reference
  • Access and exit review
Likely owner roles
  • Procurement
  • System owner
  • Privacy/Legal
Practical test

Run one synthetic case end to end; save the dated result, owner and unresolved exceptions.

TRANSFER-01

Transfers · Implementation evidence

Location and remote-access map

Make storage and remote-access locations visible before assessing any applicable restriction.
Source-mapped2027-05-13
Provision status—not a control certificationMapped provision notified · scheduled 2027-05-13

Mapped provision: Act s. 16. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

Record hosting, backups, support access and sub-processors. Do not assume blanket localisation, unrestricted transfer or an approved-country list; recheck government restrictions and stricter Indian laws.

Evidence artefacts
  • Location and remote-access map
  • Contract review
  • Restriction watch
Likely owner roles
  • Procurement
  • IT
  • Privacy/Legal
Practical test

Sample two services and compare the recorded locations and access paths with current contracts and official vendor records.

SDF-01

SDF readiness · Conditional indicator

Significant Data Fiduciary notification watch

Prepare conditionally without implying that the organisation has been designated as a Significant Data Fiduciary.
Source-mapped2027-05-13
Provision status—not a control certificationMapped provision notified · scheduled 2027-05-13

Mapped provision: Act s. 10. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

The Central Government—not an internal score—may notify an organisation or class as an SDF. Keep a Gazette-watch owner and a factual impact note without claiming designation.

Evidence artefacts
  • Gazette watch record
  • Conditional mobilisation plan
  • Leadership decision
Likely owner roles
  • Leadership
  • Privacy/Legal
  • Security
Practical test

Confirm the owner can show the latest source-set check and the escalation route if a relevant Gazette notification appears.

CONTACT-01

Rights · Implementation evidence

Public processing contact

Turn a Data Principal request into an owned, searchable and reviewable operating workflow.
Source-mapped2027-05-13
Provision status—not a control certificationMapped provision notified · scheduled 2027-05-13

Mapped provision: Act s. 10. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

Maintain the business contact able to answer processing questions under Act section 8(9) and Rule 9. Keep this distinct from the DPO requirement that applies conditionally to a notified SDF.

Evidence artefacts
  • Request register
  • System search record
  • Decision and response evidence
Likely owner roles
  • Operations
  • Support
  • Privacy/Legal
Practical test

Send a synthetic question through the published route and confirm it reaches an accountable role.

SDF-02

SDF readiness · Conditional indicator

Conditional SDF accountability pack

Prepare conditionally without implying that the organisation has been designated as a Significant Data Fiduciary.
Source-mapped2027-05-13
Provision status—not a control certificationMapped provision notified · scheduled 2027-05-13

Mapped provision: Act s. 10. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

If the organisation or its class is later notified as an SDF, section 10 and Rule 13 duties become relevant. An internal DPIA is readiness practice, not proof of SDF status or a current statutory duty.

Evidence artefacts
  • Gazette watch record
  • Conditional mobilisation plan
  • Leadership decision
Likely owner roles
  • Leadership
  • Privacy/Legal
  • Security
Practical test

Tabletop a hypothetical designation and identify owners for the DPO, independent audit, DPIA and periodic-audit work.

EVID-01

Evidence · Implementation evidence

Evidence index

Make an implementation claim retrievable without needlessly centralising sensitive records.
EditorialNo legal date
Provision status—not a control certificationEditorial implementation indicator · no commencement date

Mapped provision: Preview editorial method. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

Link each claim to an owner, record and review date.

Evidence artefacts
  • Evidence index entry
  • Version record
  • Retrieval test
Likely owner roles
  • Programme owner
  • Control owners
Practical test

Run one synthetic case end to end; save the dated result, owner and unresolved exceptions.

Official-source trail

Editorial method only. No legal requirement is asserted for this control.

Reviewed 2026-08-20 · not counsel reviewed

EVID-02

Evidence · Implementation evidence

Change log

Make an implementation claim retrievable without needlessly centralising sensitive records.
EditorialNo legal date
Provision status—not a control certificationEditorial implementation indicator · no commencement date

Mapped provision: Preview editorial method. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

Version notices, workflows and legal-status assessments.

Evidence artefacts
  • Evidence index entry
  • Version record
  • Retrieval test
Likely owner roles
  • Programme owner
  • Control owners
Practical test

Run one synthetic case end to end; save the dated result, owner and unresolved exceptions.

Official-source trail

Editorial method only. No legal requirement is asserted for this control.

Reviewed 2026-08-20 · not counsel reviewed

BREACH-02

Breach · Implementation evidence

Breach communication pack

Prepare the people, facts and distinct communication steps needed after awareness of a breach.
Source-mapped2027-05-13
Provision status—not a control certificationMapped provision notified · scheduled 2027-05-13

Mapped provision: Rules r. 7. This control is not a prescribed form and does not create a legal conclusion.

Implementation pattern

Maintain separate, fact-led checklists for affected Data Principals, the Board’s initial description and the Board’s later detailed information. Do not turn a template into a legal conclusion.

Evidence artefacts
  • Incident timeline
  • Communication decision
  • Tabletop result
Likely owner roles
  • Incident lead
  • Security
  • Privacy/Legal
Practical test

Use one tabletop scenario to draft all three outputs and verify their different content and timing owners.

02 Use the catalogue honestly

Start with a failed retrieval, not a perfect score.

The quickest useful test is simple: choose one claimed control, retrieve its current evidence, name its owner and run the stated procedure.