> ## Documentation Index
> Fetch the complete documentation index at: https://docs.regentra.io/llms.txt
> Use this file to discover all available pages before exploring further.

# Data Subject Rights Requests

> Track and respond to access, deletion, correction, and portability requests using Regentra's canonical DSR procedure template and the HIPAA Privacy Rule controls dashboard.

When an individual exercises a right under HIPAA (access, amendment,
accounting), GDPR (access, erasure, portability, restriction), or a
state law like CCPA/CPRA (know, delete, correct, opt out), you have a
legally binding window to respond. Regentra supports this work
through three concrete capabilities:

1. **A canonical DSR procedure template** that operationalizes the
   regulatory process — adopt it, adapt the deadlines and routing to
   your org, and use it as the runbook your team follows for every
   request.
2. **The Privacy Rule controls dashboard** at
   **Compliance → Privacy**, which surfaces every HIPAA Privacy Rule
   control (§164.520, §164.524, §164.526, §164.528) with response-
   deadline reminders and status tracking.
3. **Policy-template annexes** that document the rights your org is
   bound to — the *Individual and Data Subject Rights Policy*, the
   *Patient Rights Annex*, and the *Notice of Privacy Practices Annex*.

There is **no dedicated "DSR inbox" feature inside Regentra today** —
intake itself still happens through whatever channel you publish
(email, web form, patient portal). What Regentra gives you is the
authoritative procedure, the control framework, and the audit-grade
evidence to defend your response on a regulator inquiry.

## The DSR procedure template

The **Data Subject Rights Request Procedure** is one of the 64
canonical templates in Regentra's policy library. It is framework-
neutral — the regulatory citations live on the version metadata, not
in the body — and covers:

* Intake channels and minimum information you must collect
* Identity verification, including elevated verification for
  authorized agents under CCPA
* Classification against applicable regimes (HIPAA, GDPR, CCPA, state
  laws) and the deadlines for each
* Data retrieval routing to system owners / data stewards
* Carve-outs and denials with regulatory citations
* Response delivery and recordkeeping

<Steps>
  <Step title="Adopt the procedure template">
    Go to **Compliance → Policies → Canonical Library** and search for
    *Data Subject Rights Request Procedure*. Click **Adopt** to
    materialize a copy in your org. Open it in the editor.
  </Step>

  <Step title="Customize routing for your org">
    Drop in your intake addresses (privacy mailbox, patient portal
    URL, CCPA toll-free), your Privacy Officer / DPO contact, and the
    internal owners for each downstream data steward role.
  </Step>

  <Step title="Route for review and approval">
    Click **Send for Review**. Your Privacy Officer is the typical
    reviewer; Compliance Admin can also approve. Once published,
    the procedure becomes the binding internal runbook.
  </Step>

  <Step title="Distribute and acknowledge">
    Wrap the procedure into a [policy campaign](/compliance/acknowledgment-campaigns)
    targeting your Privacy Officer, intake team, and data stewards.
    Their signed acknowledgments become the evidence that the
    procedure is operative.
  </Step>
</Steps>

## The Privacy Rule controls dashboard

For HIPAA-covered customers, **Compliance → Privacy** consolidates
every Privacy Rule control with its statutory citation and current
implementation status. Today the dashboard surfaces four patient-
rights controls explicitly:

| §ref     | Right                       | Statutory deadline              |
| -------- | --------------------------- | ------------------------------- |
| §164.524 | Right of Access             | 30 days (60 with one extension) |
| §164.526 | Right to Amend PHI          | 60 days (90 with one extension) |
| §164.528 | Accounting of Disclosures   | 60 days                         |
| §164.520 | Notice of Privacy Practices | At first service                |

Each row links into the underlying internal control on the
[Controls](/compliance/controls) page. Click through to attach
evidence, link the procedure, assign an owner, and update status as
implementation progresses.

## Tracking individual requests

Today Regentra does not provide a dedicated per-request DSR record
type. Operators use one of the following patterns:

* **A PSA ticket** with a `DSR` tag, the requester's contact details,
  and the regulatory regime in the subject. SLA timers and assignment
  workflows on the ticket give you deadline pressure without a
  bespoke schema.
* **A row in your DSR procedure's worksheet appendix** — the procedure
  template includes an example log table you can copy into a
  spreadsheet or table for low-volume orgs.
* **Compliance issues** for any request that surfaces an underlying
  gap (e.g., "we couldn't retrieve all data because system X has no
  search-by-subject capability") so the structural fix is tracked
  separately from the individual response.

A first-class DSR record type is on the roadmap. Until it ships,
the procedure + PSA-ticket combination is the audit-defensible path.

## Deadlines by regime

The procedure template ships with the standard deadlines pre-filled:

| Regime                                                                  | Right                                                | Deadline                                    |
| ----------------------------------------------------------------------- | ---------------------------------------------------- | ------------------------------------------- |
| HIPAA                                                                   | Access (§164.524)                                    | 30 days; 60 with one extension              |
| HIPAA                                                                   | Amendment (§164.526)                                 | 60 days; 90 with one extension              |
| HIPAA                                                                   | Accounting (§164.528)                                | 60 days                                     |
| GDPR                                                                    | Access, erasure, portability, restriction, objection | 30 days; up to 90 if complex                |
| CCPA / CPRA                                                             | Know, delete, correct                                | 45 days; 90 with one extension              |
| State laws (CT, VA, CO, UT, TX, OR, DE, IA, IN, TN, NH, NJ, MN, MT, RI) | Varies                                               | Generally 45 days with one 45-day extension |

If a deadline will be missed, the procedure documents the extension-
notice requirement (form and timing differs per regime) and the
records you must keep to defend the extension.

## Related templates

* **Individual and Data Subject Rights Policy** — the policy-level
  document that names the rights your org honors and the rule it
  applies (HIPAA, GDPR, state). Adopt this *before* the procedure.
* **Patient Rights Annex** (HIPAA-specific) — the patient-facing
  rights catalog you incorporate into your Notice of Privacy
  Practices.
* **Notice of Privacy Practices Annex** — the patient-facing notice
  document itself.
* **Privacy Program Policy** — the umbrella policy that names your
  Privacy Officer and scopes the program.

## Frequently asked questions

<AccordionGroup>
  <Accordion title="Is there a Regentra inbox that auto-collects DSRs?">
    Not today. Intake stays on your own channels (email, web form,
    portal). The roadmap item is a first-class DSR record type; until
    it ships, use a PSA ticket with a `DSR` tag for tracking.
  </Accordion>

  <Accordion title="How do I evidence to an auditor that we responded on time?">
    Combine three artifacts: (1) the published DSR procedure with its
    acknowledgment campaign, (2) the response letter you sent to the
    requester, and (3) the PSA-ticket timeline showing the receipt,
    verification, retrieval, and dispatch timestamps. Attach all three
    to the relevant [audit request](/compliance/audit-requests).
  </Accordion>

  <Accordion title="Can I deny a request?">
    Yes, on regulatory grounds — the procedure template enumerates
    them (HIPAA: legal proceedings, third-party PHI carve-outs; GDPR:
    rights of others, disproportionate effort; CCPA: cannot verify
    identity). Document the denial reason and provide appeal
    instructions where required.
  </Accordion>

  <Accordion title="What if a processor holds some of the data?">
    Your Data Processing Agreement template requires processors to
    respond to controller-forwarded DSRs within a defined SLA. The
    procedure includes a vendor-forward step and tracks the processor
    response separately from the in-house retrieval.
  </Accordion>
</AccordionGroup>
