Context

A multinational Financial Services platform processes “Personally Identifiable Information” (PII) and “Sensitive Personal Data” across multiple jurisdictions (EU/GDPR, California/CCPA). The system must ensure data remains protected even in the event of partial system compromise or administrative errors.

Trigger

Personal data is ingested, stored, accessed for processing, or requested for deletion by a data subject.

Acceptance Criteria

• Encryption at Rest & Transit: 100% of PII fields (defined in the Data Dictionary) are encrypted at rest using AES-256-GCM with per-customer keys (Envelope Encryption). 100% of data in transit uses TLS 1.3 with Perfect Forward Secrecy.
• Anonymization for Non-Production: 100% of data exported to staging or analytics environments is automatically anonymized via k-anonymity (k≥5) or differential privacy, ensuring no individual can be re-identified with >0.01% probability.
• Data Subject Rights (SRR): The system provides an automated “Self-Service Privacy Portal” where users can trigger a “Right to be Forgotten.” 100% of the user’s PII is purged from all active databases and search indexes within 24 hours, and from all immutable backups within 30 days.
• Access Accountability: Every access to sensitive data fields (e.g., Social Security Numbers, Health Records) is logged with a tamper-proof audit trail (HMAC-chained). Audit logs must be searchable and reportable within 60 seconds for any 24-hour window.
• Breach Notification Latency: In the event of unauthorized data access detection, the system automatically generates a “Data Impact Report” identifying 100% of affected records and their jurisdictions within 4 hours of incident confirmation.
• Data Retention Enforcement: 100% of records exceeding the legal retention period (e.g., 7 years for financial records) are automatically flagged and securely overwritten (not just logically deleted) within 7 days of expiry.