Compliance for a bulk analysis workflow depends on what data is processed, why it is used, where it is handled, and which organizations receive it. A feed or lookup platform does not remove those responsibilities. Document the processing path before production use and involve the people responsible for privacy, security, procurement, and legal review.

1. Define purpose and ownership

Write down the defensive purpose for each data source and who owns the resulting records. Specify which use cases are in scope—such as alert triage, incident response, or retrospective analysis—and prevent unrelated reuse without review.

2. Inventory data and recipients

Identify indicator values, associated event fields, user or device identifiers, provider responses, logs, and exported reports. Map where each item is collected, normalized, transmitted, stored, and deleted. Record external providers and internal systems that can access it.

3. Review external sharing

Before sending indicators outside the organization, check provider terms, permitted purposes, retention and deletion options, onward sharing, and any applicable contractual or regional requirements. Minimize submissions and avoid sending user or case context unless necessary and approved.

4. Set access, retention, and deletion controls

• Grant access according to role and operational need.
• Set retention periods for raw telemetry, lookup results, and audit records separately.
• Document how corrections, deletion requests, and legal holds are handled.
• Protect exports and logs that may contain identifiers or confidential indicators.

Retention and deletion rules should follow the organization's approved requirements and incident procedures. Do not assume that longer retention is always necessary or that a hash, IP address, or pseudonymous ID is automatically outside privacy scope.

5. Preserve accountability

Keep an audit trail of provider access, lookup time, data source, user or service identity, and administrative changes. Make sure the record distinguishes a provider assessment from an analyst's conclusion. Limit the audit data itself to what is needed and apply appropriate access and retention controls.

6. Reassess when the workflow changes

Revisit the review when a new provider is added, collected fields change, data crosses a new boundary, the purpose expands, or the retention model changes. Test deletion and access procedures rather than relying only on written policies.

Privacy and legal requirements differ by jurisdiction, data type, and organization. Use this checklist to identify questions for qualified internal reviewers; it is not a determination that a particular workflow complies with any law.