GDPR·Article Article 97·low·Component: Chapter XI: Final Provisions

What this control requires

This control mandates that the Commission submit a report every four years, starting from 25 May 2020, on the evaluation and review of GDPR. The report will focus on the application of specific chapters related to data transfers and cooperation, and may lead to proposals for amendments based on technological developments and feedback from relevant bodies. This control addresses Final Provisions.
— GDPR, Article Article 97

In plain English

This control mandates that the Commission submit a report every four years, starting from 25 May 2020, on the evaluation and review of GDPR. In practice, this means you can prove you data transfers-level controls on a defined cadence.

Why it matters

GDPR administrative fines reach the greater of €20 million or 4% of global annual turnover. The European Data Protection Board (EDPB) coordinates supervisory-authority enforcement across the EU/EEA, and DPAs publish enforcement decisions citing specific Articles.

What an auditor looks for

A DPA or privacy auditor expects: a Records of Processing Activities (RoPA) entry, a documented lawful basis, evidence the Article's data-subject right is operationalised end-to-end, a named DPO contact (where required), and Article 30 records that match what the front-end actually does.

Within Chapter XI: Final Provisions, the assessor will trace your implementation back to the catalogue reference (Article Article 97) and look for objective evidence on the latest two assessment cycles.

How to implement

Secure Development

Pipeline. Require code review, SAST (Semgrep / Snyk Code), SCA (Dependabot / Renovate), secret-scanning and IaC scanning in the merge pipeline.

Branch protection. Protected branches enforce reviews, signed commits and passing CI before merge; document the protection rules as the control evidence.

Code Review Testing

Pipeline. Require at least one human reviewer plus passing CI (lint, type, unit, security scan) before merge — protected branches enforce this.

Operational checklist

  • Data. Document the trigger, the owner and the cadence.
  • Cooperation. Document the trigger, the owner and the cadence.
  • Security. Document the trigger, the owner and the cadence.
  • Transfers. Document the trigger, the owner and the cadence.
  • Reports. Document the trigger, the owner and the cadence.
  • Scope: transfers, reports, commission.

Evidence to collect

  • Code Repo Scan. Source-control evidence — branch protection, required reviewers, CI status, SCA / SAST reports.

Source control pipelines (GitHub, GitLab) enforce SDLC guardrails. Focus: Commission reports.

Common pitfalls

  • CI security checks set to warn-only; the merge button is faster than the security feedback.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

Related controls in GDPR

References

Topics: application securitysecure developmentcode review testingdevsecops