# How we handle GDPR data-subject requests on a deadline

The GDPR-DSAR agent we run on Kortix — it verifies each incoming access or deletion request, locates the subject's data across our product database, compiles the report inside the SLA, and flags it for legal to review before anything goes out.

Canonical page: https://kortix.com/use-cases/gdpr-dsar

A GDPR data subject access request starts a clock. From the day we can verify who's
asking, we have one calendar month to tell them what we hold on them, or to delete
it — and that data is never in one place. It's spread across a users table, an
orders table, a support history, an events table, a dozen joins a person has to
know to write by hand. Miss the deadline or miss a table, and the exposure is the
regulator's, not just the requester's.

We run a GDPR-DSAR agent on Kortix that reads each request out of our legal inbox,
verifies it, locates the subject across the product database, and compiles the
access-or-deletion report as a Google Doc — every day, well inside the SLA. It
never deletes anything and never replies to the requester. It compiles and flags;
legal decides and sends.

- **Team:** Kortix
- **Runs on:** Daily cron
- **Connected systems:** Gmail · Postgres · Google Docs
- **Mode:** Compile + flag only · legal signs off before anything ships

## The problem

A DSAR arrives as an email, but the data it's asking about lives in a relational
schema built for the product, not for privacy law. "Everything you have on me"
means rows in the users table, orders, invoices, support tickets, login history,
marketing consent, and whatever else joins off a customer ID — tables that were
never designed to be read together, by someone who has one month to do it and get
it right every time.

The common approaches don't hold up under repetition. A shared spreadsheet of
"where subject data lives" goes stale the moment the schema changes. Assigning it
to whoever's free that week means the verification step — confirming the requester
actually is the subject, not someone phishing for their data — gets rushed or
skipped. And a script that queries and deletes in the same run has no way to stop
and ask a lawyer first.

## What we built

On Kortix, a daily cron triggers an agent. It spawns a fresh session that checks
our legal inbox in Gmail for new DSAR emails, verifies each requester against the
identity details we already hold, then queries Postgres read-only across every
table keyed to that subject — account, orders, support history, consent records —
and compiles the findings into a Google Doc formatted as an access report (or a
deletion inventory, if that's what was asked for). The doc, and a recommended
action, get flagged to legal for review. The agent never runs a delete and never
emails the subject back.

## How it works

### Run on a daily cron

A **cron trigger** fires the agent once a day. Each firing spawns a fresh
**session** in its own sandbox, so every DSAR is worked from a clean read of the
inbox and the database — nothing from a prior day's run carries over, and a stale
verification never gets reused.

### Verify before locating anything

Verification lives as a **skill** that travels with the agent: what counts as
proof the requester is the subject (matching the request email against the account
on file, or the identity details supplied), what to do when verification fails or
is ambiguous, and what the SLA clock actually is under GDPR — one month from a
verified request, extendable once for complex cases. Nothing is located until a
request passes this check.

### Connect the systems it needs

Through scoped **connectors**, brokered server-side so no raw token reaches the
model, the agent:

- **Reads the DSAR out of Gmail** — the inbound request and any identity details
attached, and labels the thread once it's been actioned.
- **Queries Postgres read-only** — every table keyed to the subject: account,
orders, invoices, support tickets, consent and login history — to build a
complete picture of what we hold.
- **Writes the report to Google Docs** — a structured access report or deletion
inventory, one doc per request, ready for a lawyer to read start to finish.

### Set the guardrails

The agent's only writes are the Google Doc it compiles and the label on the Gmail
thread. Postgres access is read-only — there is no delete path the agent can reach,
even for a request that explicitly asks for erasure. It never emails the requester.
Credentials are encrypted in the Secrets Manager and injected at runtime, scoped to the agents you grant them to.

### Flag it for legal review

With the report compiled, the agent posts it to the legal team's review channel
with a recommended action — fulfill the access request, or proceed with deletion —
and the SLA deadline it's working against. Legal reviews the report, decides, and
is the one who replies to the subject or authorizes any deletion. The agent's job
ends at the flag.

> **The pattern**
> A daily **cron** spawns a fresh session that verifies the request, reads Gmail for
> the ask, queries Postgres read-only to locate the subject's data everywhere it
> lives, and compiles a Google Doc report. The agent compiles and flags; legal
> decides, deletes, and replies.

## Guardrails

A DSAR touches the most sensitive data we hold, so the agent's access is scoped and
its authority stops well short of the parts that matter:

- **Isolation.** Every run happens in its own isolated sandbox. The session is granted access only to Gmail, Postgres, and Google Docs, and only the compiled report and the
  legal-channel flag are written back out.
- **Read-only on the data itself.** Postgres access is read-only. The agent can
  locate a subject's data across every table; it cannot delete a row, update a
  record, or run anything but a `SELECT`.
- **Never replies to the subject.** The agent's only outbound message is the flag
  to legal. It does not draft or send anything to the person who filed the
  request — that response is legal's to write and send.
- **Deletion always waits for approval.** Even when a request explicitly asks for
  erasure, the agent only recommends it in the flagged report. No deletion happens
  until a lawyer approves it and someone else executes it.
- **Everything is code.** The verification rules, the table map, and the agent's
  per-system permissions are files in the repo, versioned and changed through a
  reviewed **change request** rather than a dashboard setting.

## The outcome

- **Every day:** DSAR inbox checked and any new request worked the same day
- **0 deletions:** Every erasure held for a lawyer to approve and execute
- **1 flag:** One compiled report and recommendation per request, in legal's queue

A request that used to mean someone manually joining tables under deadline pressure
now arrives in legal's queue as a compiled report, well inside the SLA, with the
data located and the action recommended. The agent verifies and compiles; the
people decide, delete, and reply.
