74 lines
4.2 KiB
Markdown
74 lines
4.2 KiB
Markdown
# APPI Data Processing and Cross-Border Assessment
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## Status and use
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This is a customer-specific assessment template for CASAN deployments in Japan.
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It records facts needed for an APPI review; it does **not** claim that CASAN or
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a customer deployment is APPI-compliant. The customer’s privacy/legal owner
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must approve the completed version before production processing begins.
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## Processing inventory
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| Data category | Typical source | CASAN purpose | Storage / recipient | Default retention | Deployment decision required |
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|---|---|---|---|---|---|
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| Source code and diffs | Git repository, AI coding tool | policy/test/security evaluation; Evidence Pack | customer workspace and Evidence Pack store | customer policy | whether any code may leave customer network |
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| Prompts and chat content | Control Panel / AI tool | governed response, routing, audit | customer runtime; selected model provider only when configured | customer policy | provider, country/region, model and allowed fields |
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| Secrets / credentials | source, logs, environment | detection/blocking only | should be masked; must not be placed in Evidence Pack | not retained intentionally | scanner/exception procedure |
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| Developer identifiers | IdP claims, audit record | RBAC, accountability, approval trace | customer identity/audit store | customer policy | legitimate purpose, access roles |
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| Telemetry and costs | model/provider and runner | FinOps, reliability, anomaly detection | customer telemetry store / selected provider | customer policy | provider API and export destination |
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| Evidence Pack metadata | CASAN gates and manifests | auditability and proof | customer Evidence Pack storage; optional Gitea artifact | customer policy | retention, immutable-storage setting, artifact access |
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## Required deployment register
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For every customer project, complete the following fields and attach it to the
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PoC or production change record.
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| Field | Value / approval |
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|---|---|
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| Customer data controller / privacy contact | |
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| CASAN operator and support contact | |
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| Processing purpose and affected projects | |
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| Personal information expected in source, prompts or logs | |
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| Model providers, model IDs, processing country/region | |
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| Subprocessors and service locations | |
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| Cross-border transfer assessment / required information | |
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| Retention, deletion and export schedule | |
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| Evidence Pack, backup and artifact storage location | |
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| Incident notification contacts and target timing | |
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| Approved masking / secret-scanning policy | |
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| Approval date, reviewer and next review date | |
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## CASAN control mapping
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- H4 / data-exfil guard scans prompts and artifacts before release. A BLOCK is
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evidence of detection, not evidence that no sensitive data was ever sent.
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- H5 audit records accountable actions and policy changes.
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- H6 records execution/cost telemetry. It must be included in the retention
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decision because it can identify a user, project, provider or run.
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- Evidence Pack stores summaries and hashes; it still needs a retention,
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access-control, backup and deletion decision.
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- Cloud-model use is opt-in at deployment time. The customer must document what
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fields are transmitted and select an allowed provider/region.
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## Data-subject and operational procedures
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The operator must implement customer-approved procedures for access requests,
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correction/deletion/export where applicable, retention expiry, secret leak
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investigation, incident triage and vendor/subprocessor changes. A Gitea Actions
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artifact is not an immutable long-term retention system by itself.
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## Evidence required before a production claim
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1. Completed register for each tenant/project and model route.
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2. Network/data-flow diagram tested against the deployed configuration.
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3. Provider and subprocessor review, including cross-border transfer facts.
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4. Retention/deletion test for logs, Evidence Packs, backups and CI artifacts.
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5. Incident-response tabletop or drill with named contacts.
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6. Review by the customer’s Japanese privacy/legal owner.
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## Reference
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Use the authoritative Japanese APPI text and Personal Information Protection
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Commission guidance for the final legal assessment. English translations and
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this template are working aids only; they are not the controlling legal text.
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