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This page is part of the ForgeSDLC knowledge base — an AI-assisted, human-directed methodology for taking product work from concept to production. For the core operating model and vocabulary, see Forge SDLC overview and What is ForgeSDLC?.

Compliance body of knowledge

This document maps the core concerns of Compliance for digital products — regulatory and legal obligations spanning privacy, accessibility, sector-specific data, AI governance, minors’ protection, certification, and third-party assurance — to the blueprint ecosystem.

How compliance relates to PDLC and SDLC: Compliance is front-loaded in product strategy (especially P3) and continuous through delivery (A–F) and operations. See COMP-SDLC-PDLC-BRIDGE.md for the full mapping.

Framework guides: The frameworks/ index lists framework-specific deep dives as they are added to this package.

Relationship to Security: ../security/README.md addresses threat-driven protection. This package addresses obligation-driven conformance — laws, standards, and contractual regimes — including many requirements that are not strictly “security” (e.g., subject access workflows, accessibility conformance, AI transparency).


1. Compliance principles

Principle Description
Compliance by design Obligations are scoped before commitment, embedded in architecture and UX, and verified continuously — not retrofitted after launch.
Proportionality Controls, documentation, and process depth match actual risk, data sensitivity, and regulatory exposure; avoid uniform “maximum” process for all features.
Accountability Clear ownership for registers (ROPA), DPIAs, policies, vendor decisions, and evidence; decisions are traceable (who approved what, when).
Transparency Users, regulators, and auditors receive accurate notices and artifacts (privacy policies, accessibility statements, model cards where required) aligned with real processing.
Continuous compliance Regulations, case law, and product behavior change — controls and evidence are refreshed on a cadence, not only at annual audit.
Risk-based approach Prioritize effort using combined legal, operational, and technical risk; document residual risk and acceptance where full mitigation is infeasible.

2. Compliance lifecycle

Stage Activities Typical outputs
1. Identify applicable regulations Map jurisdictions, user segments, data categories, industry (health, finance, gov), AI use, minors; review contracts and certification commitments Applicability matrix, legal intake, regulatory change watchlist
2. Map to technical & organizational controls Translate articles/sections into control objectives; assign to systems, teams, vendors Control library, data flow + legal basis mapping, architecture constraints
3. Implement controls Engineering, data, product, and ops changes; training; vendor alignment Config standards, feature flags, access models, retention jobs, consent flows
4. Collect evidence Logs, screenshots, test reports, policies, tickets, approvals, configuration exports Evidence repository, sampling methodology, control owners
5. Audit / certify Internal audit, external QSA/ISO stage audits, SOC 2 fieldwork, regulatory inspection readiness Audit reports, certification, corrective action plans
6. Maintain / update Impact analysis for roadmap changes, breach drills, control regression testing, subprocessors updates Change log, updated DPIAs/ROPA, refreshed VPAT/ACR

3. Data protection (GDPR / CCPA / LGPD — core concepts)

Cross-jurisdictional summary — always confirm with counsel for your facts.

Topic Core ideas Engineering / product implications
Lawful basis GDPR: necessity (contract, legal obligation, vital interests, public task, legitimate interests), or consent where required; CCPA/CPRA: “sale/share” and opt-out frameworks differ from GDPR Document basis per processing purpose; avoid “consent” as blanket when another basis applies; tie collection UI to stated purposes
Consent management architecture Valid consent: informed, specific, granular where needed, withdrawable; CPRA: notice at collection, opt-out links, sensitive data limits Consent records with versioned policies; APIs for preference centers; propagation to downstream tools; proof of timing and scope
Data subject rights Access, rectification, erasure, restriction, objection, portability (where applicable); timelines vary by law Identity verification; export pipelines; deletion across stores, caches, backups, logs (with legal retention carve-outs); ticketing and SLAs
Data minimization Collect only what is necessary for specified purposes Feature design reviews; schema discipline; analytics sampling; pseudonymization where appropriate
Purpose limitation No incompatible secondary use without new basis/notice Segregate datasets; constrain ML training reuse; vendor contract purpose clauses
DPIAs / PIAs Systematic assessment of high-risk processing (GDPR DPIA triggers; analogous PIAs elsewhere) Cross-functional template; residual risk sign-off; consultation with DPA where required
Cross-border transfers GDPR: adequacy, SCCs (with TIA), BCRs, derogations; other regions increasingly restrict export Data residency options; encryption and access models in TIA; subprocessors in approved regions
Breach notification GDPR: 72h to supervisory authority in many cases; CPRA timelines for consumers; sector laws may differ Playbooks; logging and detection; legal escalation; customer comms templates
DPO Mandatory in some GDPR contexts; advisory and monitoring role DPO access to processing records; independence; reporting line documented

4. Accessibility

Topic Detail
WCAG 2.2 principles (POUR) Perceivable — alternatives for non-text content, adaptable layout, distinguishable foreground/background. Operable — keyboard accessible, enough time, seizure-safe, navigable. Understandable — readable, predictable, input assistance. Robust — valid markup, compatible with assistive technologies.
Conformance levels A (minimum), AA (common legal reference), AAA (stringent; not always required as a whole). Claim conformance only for defined scopes (pages, flows, products).
Legal frameworks (examples) US ADA Title III (digital accessibility caselaw varies by circuit); Section 508 for US federal; EAA (EU) and EN 301 549 (harmonized standard referencing WCAG); national transpositions and procurement rules.
Audit methodology Combine automated scans (fast, incomplete) with manual expert review (keyboard, screen readers, forms, errors) and user testing with people with disabilities where feasible.
VPAT / ACR Voluntary Product Accessibility Template documents how product meets criteria; Accessibility Conformance Report is the completed VPAT — used in procurement and enterprise sales.

5. Healthcare data (HIPAA — US)

Topic Detail
PHI Protected Health Information — identifiers + health information held by covered entities/BAs; 18 identifiers listed in HIPAA Privacy Rule guidance.
Safeguards Administrative — policies, workforce training, risk analysis, BA agreements. Physical — facility controls, workstation security. Technical — access control, audit controls, integrity, transmission security.
BAAs Business Associate Agreements required before BAs create, receive, maintain, or transmit PHI on behalf of a covered entity.
Minimum necessary Use/disclose the minimum PHI necessary for the intended purpose (with exceptions).
Breach Notification Rule Notify affected individuals, HHS, and sometimes media based on breach threshold and risk assessment.
HITECH Strengthened enforcement, breach rules, and BA liability — interact with HIPAA Security and Privacy Rules.

6. Financial data

PCI-DSS (payment card industry)

Topic Detail
Scope All system components in or connected to the CDE (cardholder data environment). Reduce scope via segmentation, outsourcing, tokenization.
SAQ types SAQ A, A-EP, B, C, C-VT, D, etc. — depend on how cards are handled (redirect, iframe, POS, e-commerce hosting).
12 requirements (overview) Firewall configs; defaults; stored cardholder data protection; encryption in transit; malware protection; secure development; need-to-know access; unique IDs; physical access; logging and monitoring; security testing; ISMS/policy program.
Tokenization Replace PAN with tokens where possible; tokens out of scope only when properly implemented per PCI guidance.
ASV scans Approved Scanning Vendor quarterly external vulnerability scans for applicable deployments.
QSA audits Qualified Security Assessor for RoC (Report on Compliance) at higher validation levels.

SOX (IT general controls — product/engineering angle)

Topic Detail
ITGC Controls over access, change management, operations, and program development affecting financial reporting systems.
Audit trails Tamper-evident logs for financial data changes; retention and review.
Segregation of duties No single person can authorize, record, and reconcile without independent check — reflected in roles and workflows.

7. AI and algorithmic compliance

Topic Detail
EU AI Act — risk classification Unacceptable (e.g., certain social scoring/manipulation — prohibited); High-risk (Annex III domains such as employment, education, essential services, law enforcement support, etc., subject to conditions); Limited risk (transparency obligations); Minimal risk — light touch. GP AI models (general-purpose) have additional obligations for providers.
Transparency Inform users when interacting with AI; mark synthetic content where required; instructions for downstream deployers.
Human oversight Design so natural persons can understand, monitor, and intervene for high-risk systems.
Conformity assessment Internal or notified-body routes depending on classification; technical documentation, quality management, logging.
NIST AI RMF Govern, Map, Measure, Manage — voluntary risk management lifecycle for trustworthy AI; aligns with organizational governance.
NYC Local Law 144 (example) AEDT — automated employment decision tools: bias audit and notice requirements — representative of jurisdiction-specific algorithmic hiring rules.

8. Children and minors

Topic Detail
COPPA (US) Verifiable parental consent before collecting personal information from children under 13; limits on conditioning participation on excessive data collection; parental rights to review/delete.
GDPR Article 8 Conditions for child’s consent in relation to information society services; member states set age (13–16). Parental authorization where required.
UK Age Appropriate Design Code 15 standards — best interests of child, DPIA, age assurance, transparency, detrimental use, policies and community, default settings, data minimization, sharing, geolocation, parental controls, profiling, nudge techniques, connected toys, online tools — applied to services likely accessed by children.

9. Industry certification

ISO 27001

Topic Detail
ISMS Information Security Management System — risk assessment, Statement of Applicability, continuous improvement.
Annex A Control themes (organizational, people, physical, technological) — mapped to implemented controls.
Certification Stage 1/2 audits by accredited CB; surveillance audits; three-year recertification cycle.

SOC 2 (AICPA)

Topic Detail
Trust Service Criteria Security (required); plus Availability, Confidentiality, Processing Integrity, Privacy as applicable to the report.
Type I vs Type II Type I — design suitability at a point in time; Type II — design and operating effectiveness over a period (e.g. 6–12 months).
Readiness Gap assessment; control mapping; evidence collection; policy suite; vendor register; incident history.

10. Compliance-as-code

Practice Description
Policy-as-code Encode rules in Open Policy Agent (Rego), HashiCorp Sentinel, or cloud-native policy engines — evaluate plans (Terraform), K8s admissions, API payloads.
CI/CD gates Block deploy on missing encryption flags, public buckets, non-compliant regions, or failed accessibility checks in pipelines.
Evidence automation Export configs, ticket closures, scan results, access reviews into an evidence store on schedule; reduce manual screenshot hunting.
Continuous compliance monitoring CSPM/CWPP, drift detection, periodic access recertification, log retention verification.

11. Vendor and third-party compliance

Topic Practice
DPAs Data Processing Agreements under GDPR — subject matter, duration, nature/purpose, sub-processors, transfers, assistance with rights, deletion/return, audit rights.
BAAs HIPAA Business Associate Agreements before PHI exposure.
Subprocessor management Inventory, change notification, assessment, flow-down obligations.
Supply chain SBOM and security expectations may overlap; compliance adds data and jurisdiction clauses, DPIA support, and certification evidence.
Due diligence checklist Certifications, penetration test summaries, subprocessors, breach history, access model, residency, AI use, insurance, SLA for breach assistance.

12. Competencies

Competency Description
Regulatory scoping Identifying which laws and standards apply to a product, feature, or market entry.
Control design Translating legal articles into implementable technical and organizational measures.
Privacy engineering Minimization, retention, rights fulfillment, consent systems, and PETs in software architecture.
Accessibility engineering WCAG interpretation, component libraries, manual testing, VPAT authoring support.
Audit readiness Evidence design, sampling, control narratives, auditor interaction without fire drills.
Vendor risk Contract negotiation support, subprocessor reviews, transfer mechanisms.
AI governance Risk classification, documentation, human oversight UX, monitoring for drift and misuse.
Incident & breach response Legal timelines, forensics coordination, comms, regulatory filings.
Policy literacy Reading primary law and regulator guidance; distinguishing binding vs. draft texts.

13. External references

Topic URL Why it is linked
GDPR (EUR-Lex) https://eur-lex.europa.eu/eli/reg/2016/679/oj Primary EU GDPR text
EDPB guidelines https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en GDPR interpretation (EU-wide)
IAPP https://iapp.org/ Privacy profession — CIPP/CIPM/CIPT and resources
WCAG 2.2 https://www.w3.org/TR/WCAG22/ W3C accessibility standard
WAI https://www.w3.org/WAI/ Education, techniques, WAI-ARIA
HIPAA (HHS) https://www.hhs.gov/hipaa/index.html US healthcare privacy and security rules
PCI-DSS https://www.pcisecuritystandards.org/ Payment card standard and SAQ guidance
EU AI Act (EUR-Lex) https://eur-lex.europa.eu/ Primary EU AI regulation
NIST AI RMF https://www.nist.gov/itl/ai-risk-management-framework AI risk management lifecycle
ISO/IEC 27001 https://www.iso.org/standard/27001 ISMS certification standard
SOC 2 / AICPA TSC https://www.aicpa.org/soc4so Trust Services Criteria overview
COPPA (FTC) https://www.ftc.gov/business-guidance/resources/childrens-online-privacy-protection-rule-coppa US children’s privacy rule
EN 301 549 https://www.etsi.org/ EU accessibility standard for ICT procurement

Keep project-specific compliance documentation in docs/security/compliance/, DPIAs in docs/security/, and compliance decisions in docs/adr/, not in this file.