Some of the GDPR lives in code: where personal data flows, how it is scoped and how it is protected.
The GDPR blueprint gives code evidence for Articles 5, 25 and 32 on every pull request, with supporting evidence for erasure and breach notification. Lawful basis, records of processing and data subject rights stay with your privacy programme.
Toevan gives evidence for controls; it never certifies them or claims a framework is covered. Whether the evidence is sufficient is your auditor’s judgement.
Live3
Code evidence today, sealed on every pull request. Always partial: the control also asks for things outside code. Code evidence today: rules in the GDPR blueprint check part of this on every pull request.
Art.5Principles relating to processing of personal data
Core Principles
Art.25Data protection by design and by default
Design Requirements
Art.32Security of processing
Security
Supporting2
Toevan records related evidence, today or in v1.4.0, but the duty is organisational, so it never counts as covered.
Art.17Right to erasure (‘right to be forgotten’)
Data Subject Rights
Supporting evidence today: a rule records evidence related to this duty. The duty itself is an operational process.
Art.33Notification of a personal data breach to the supervisory authority
Incident Response
Supporting evidence today: a rule records evidence related to this duty. The duty itself is regulatory procedure.
Your organisation35
Policy, people, physical security, contracts, regulatory procedure, operations or external audit. Your organisation evidences these.
Show all 35 controls
Core Principles
Art.6Lawfulness of processingorganisational policyArt.7Conditions for consentorganisational policyArt.8Conditions applicable to child's consent in relation to information society servicesorganisational policyArt.9Processing of special categories of personal dataorganisational policyArt.10Processing of personal data relating to criminal convictions and offencesorganisational policyArt.11Processing which does not require identificationorganisational policy
Data Subject Rights
Art.12Transparent information, communication and modalities for the exercise of the rights of the data subjectan operational processArt.13Information to be provided where personal data are collected from the data subjectan operational processArt.14Information to be provided where personal data have not been obtained from the data subjectan operational processArt.15Right of access by the data subjectan operational processArt.16Right to rectificationan operational processArt.18Right to restriction of processingan operational processArt.19Notification obligation regarding rectification or erasure of personal data or restriction of processingan operational processArt.20Right to data portabilityan operational processArt.21Right to objectan operational processArt.22Automated individual decision-making, including profilingan operational process
Controller and Processor
Art.24Responsibility of the controllerorganisational policyArt.26Joint controllersorganisational policyArt.27Representatives of controllers or processors not established in the Unionorganisational policyArt.28Processorcontracts and vendorsArt.29Processing under the authority of the controller or processororganisational policyArt.30Records of processing activitiesorganisational policyArt.31Cooperation with the supervisory authorityorganisational policyArt.34Communication of a personal data breach to the data subjectregulatory procedureArt.36Prior consultationorganisational policyArt.37Designation of the data protection officerorganisational policyArt.38Position of the data protection officerorganisational policyArt.39Tasks of the data protection officerorganisational policy
Risk Assessment
Art.35Data protection impact assessmentorganisational policy
International Transfers
Art.44General principle for transfersregulatory procedureArt.45Transfers on the basis of an adequacy decisionregulatory procedureArt.46Transfers subject to appropriate safeguardsregulatory procedureArt.47Binding corporate rulesregulatory procedureArt.48Transfers or disclosures not authorised by Union lawregulatory procedureArt.49Derogations for specific situationsregulatory procedure
Using it in an audit
Read the code evidence for the period
Each pull request carries sealed code results against the blueprint’s rules, pinned to the commit and the rule-set version in force.
Test a sample
For each sampled record, check its results, then verify its signature and its place in the chain offline.
toevan audit verify --path evidence-clone --pub-key toevan.pub
How each fact was obtained
Every fact in a record and a report carries one of six labels, so your auditor knows how far to rely on it.
- Recomputed
- Toevan computed it from the code or git history itself.
- Re-perform it from the same inputs and get the same result.
- Reported + sealed
- GitHub reported it; Toevan captured it at the event and signed it.
- Rely on it as far as you rely on GitHub. Any later change is detectable.
- Declared + sealed
- The organisation declared it, such as a change to what is checked; Toevan signed the declaration and its history.
- See who declared what, when, and every later change.
- Toevan record, not sealed
- Held in Toevan’s database but not sealed in the ledger, such as a waiver today. Nothing protects it by a signature.
- Treat it as Toevan’s statement, and ask the organisation for the approval behind it.
- Consumed
- Taken from another system’s signed record, such as build provenance, and linked by commit or digest. Planned.
- Check the original record independently.
- Not captured
- No reliable source was available. Toevan does not infer it.
- Obtain it from the organisation by other means.
See it in a report
The sample change evidence report shows the evidence as your auditor receives it, with every fact labelled.
Open the sample reportTest the mapping on a real audit.
Bring one repository and an upcoming audit. We’ll set up the blueprint and walk your auditor through verification.