DPCH09 — Compliant by Design
“Policy-as-Code and Entitlement Controls Enforced”
What DPCH09 is really asserting
DPCH09 is not asserting that:
“The product is compliant” or “someone reviewed it.”
It is asserting that:
Compliance, access, and regulatory constraints are encoded as federated, executable policies (policy-as-code) that are visible during design, bound to the data product at publish-time, and enforced automatically at runtime.
Compliance is compiled into the product, not bolted on after the fact.
The Essence (Data Mesh + HDIP Interpretation)
A Data Product satisfies DPCH09 if and only if:
- Governance is federated across layers: Global → Divisional → Domain → Product
- Applicable policies are discoverable and visible to the DPRO at design time
- Policies are bound to the product through its lifecycle (test, deploy, publish)
- Policies are enforced computationally at runtime (not manual controls)
This is the Data Mesh “computational governance” pillar in action.
Federated Policy Layers (What must exist)
DPCH09 assumes a layered model:
- Global policies (enterprise-wide): e.g., data classification rules, baseline retention, audit requirements
- Divisional policies (CB/IB/PB): e.g., local regulatory rules, divisional risk controls
- Domain policies (Payments, Risk): e.g., business-specific constraints, sharing rules
- Product policies (optional): e.g., a product-specific usage restriction or additional control introduced by the DPRO
Critically: the DPRO can introduce product-specific policies, but only within permitted bounds (i.e., cannot override higher-level constraints).
Positive Criteria — When DPCH09 is met
DPCH09 is met when all of the following are true:
1. Policies are visible during design (self-service governance)
In the product management self-service portal, the DPRO can see:
- which global/divisional/domain policies apply
- why they apply (e.g., classification, jurisdiction, consumer type)
- what choices are available (e.g., access posture options)
Visibility prevents “surprise compliance” later.
2. Policies are bound to the product during lifecycle
During test/deploy/publish:
-
policies are linked to the data product descriptor/bundle
-
the product carries explicit references to:
- applicable policy sets
- entitlements model
- classification/residency/retention attributes
This ensures compliance is not “out-of-band”.
3. Policies are executed at runtime (computational enforcement)
Enforcement happens automatically through platform capabilities such as:
- authorization checks (RBAC/ABAC/ReBAC/PBAC as applicable)
- row/column filtering
- purpose-based access gating
- residency routing
- audit logging and control execution
No reliance on “people remembering”.
4. Product-specific policies can be declared safely
The DPRO may add product-specific policies like:
- “only allowed for risk-approved consumers”
- “mask these attributes for external sharing”
- “retain only 90 days for this product”
These are added declaratively and enforced by the same policy engine.
Negative Criteria — When DPCH09 is not met
DPCH09 is not met if any of the following are true:
❌ Policies exist but are not visible to the DPRO
Examples:
- governance rules live in documents
- policies are applied later by governance teams
- DPRO discovers constraints only after build
This is governance as surprise, not design.
❌ Policies are manual or procedural
Examples:
- ticket-based approvals for each access request
- manual reviews substituting for policy enforcement
- email-based sign-offs
Manual compliance does not scale and violates computational governance.
❌ Enforcement is optional or inconsistent
Examples:
- some ports enforce policies, others bypass them
- policies exist but are not automatically executed
- enforcement depends on engineers implementing it per pipeline
Compliance must be systemic, not bespoke.
Edge Cases (Important Guidance for Agents)
Case 1: “Access control exists, but only RBAC at app level”
⚠️ Partial
Rationale:
- some enforcement exists
- but not product-level, federated, or policy-as-code
- missing residency/retention/purpose controls
Case 2: “Policies applied after deployment by central governance”
❌ Not met
Rationale:
- violates compliant-by-design
- creates bottlenecks and delays
- breaks self-service principle
Case 3: “Federated policies + design-time visibility + runtime enforcement”
✅ Met
Rationale:
- this is exactly the Data Mesh governance pillar realized
Evidence Signals an Agent Should Look For
Authoritative evidence:
- Policy registry bindings for the product (global/divisional/domain/product)
- Entitlement model declaration linked to product
- Runtime enforcement evidence (audit logs, access decisions)
Supporting evidence:
- Portal screens showing applicable policies at design time
- Policy conformance reports (pass/fail + reasons)
- DPP trust section referencing compliance posture (optional linkage with DPCH06)
Red flags:
- policies in PDFs
- compliance “checklists” without enforcement
- access granted via manual groups/tickets only
How an AI Agent Should Decide
Decision rule (simplified):
If applicable policies are not visible at design time and not enforced computationally at runtime through federated policy-as-code, DPCH09 is not met.
Canonical Statement
DPCH09 is satisfied only when federated computational governance (global → divisional → domain → product) is visible to the DPRO during design, bound to the product through deployment and publishing, and executed automatically at runtime via policy-as-code and entitlement enforcement.