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Units and files

A repository is a set of units (the images of snow.yml, or the entries of .model-wtf.yml), each with its own compliance/ folder next to the code, plus the shared root compliance/ for what belongs to the product as a whole.

  • compliance/app.yaml — name, description, controller (party id, the client), optional processor (party id, the agency), large_scale (Art. 35(3)(b); absent means no: a DPIA is then only required for special-category data; !todo asks the question once) and owners (dpo/ciso GitHub teams for CODEOWNERS).
  • compliance/parties/<id>.yaml — name, country (ISO alpha-2), address, email; optional phone, website, hosts (API hostnames the code calls when they differ from the website, e.g. api.hubapi.com: a call to one is a transfer to this party), registration, dpa (where the processing agreement lives), safeguard/dpf_certified, dpo and representative contact blocks. A party is role-less: controller, processor or recipient is decided per processing activity. A party nothing refers to (no transfer, no role, no recipients) is a Todo.

Unit discovery

Units are read from snow.yml at the repo root: every images[] entry that carries a compliance: block is a unit. discover names the discovery backend for that codebase (django, sveltekit, none); the compliance folder is compliance/ next to the image's Dockerfile unless dir (relative to the build context) says otherwise. An image without compliance produces a warning (an error under --strict).

images:
    - id: api
      context: api                 # Dockerfile at api/Dockerfile
      compliance:
          discover: django         # -> api/compliance
    - id: front
      context: .
      dockerfile: front/Dockerfile
      compliance:
          discover: sveltekit      # -> front/compliance
    - id: docs
      context: .
      compliance:
          discover: none
          dir: docs/compliance     # -> docs/compliance

Repos not deployed through Snow can use .model-wtf.yml instead (units: [{id, context, dockerfile, compliance}]). When both files exist snow.yml wins.

The repo-root compliance/ folder is always loaded as the shared scope (controller, actors, assumptions, recipients).