Privacy Code Scanning · Acompli add-on

Privacy code scanning software that finds the personal data in your code

Surface personal-data handling, processor SDKs, transfer indicators and AI components from live repositories — then turn approved findings into RoPA, DPIA and AI-governance evidence your reviewers have already signed off.

A privacy scanner, not a vulnerability scanner — Code Scan does not replace SAST, malware scanning or SBOM tooling.

00Connect01Scope02Discover03Review04Record05Mitigate
On this page
01

The Code Scan workflow

From repository evidence to governed action

Each stage adds review context. By the time a finding is approved, it carries source evidence, decision history and the governance route it supports.

01Connect
02Scope
03Discover
04Review
05Record
06Mitigate

Connect & scope

Start from nominated repositories and a defined governance purpose before findings are produced.

  • Repository, branch and access scope
  • Privacy, transfer, vendor or AI-review lens
  • Zero-copy evidence workflow

Discover evidence

Surface privacy-relevant implementation signals across source, dependencies, schemas and configuration.

  • Personal-data handling patterns
  • Processor SDKs and API endpoints
  • Transfer, retention and AI-component signals

Review with context

Keep the decision with named reviewers and preserve the reasoning behind accepted findings.

  • File, line, branch and commit provenance
  • Confirm, reject, annotate or refine
  • Privacy and engineering review trail

Feed governance

Turn approved technical evidence into connected records instead of another isolated scan report.

  • RoPA, DPIA and data map updates
  • AI Act and vendor follow-up
  • Change history for later scans
02
What Code Scan finds

PII detection in source code and privacy evidence

Acompli Code Scan can help identify privacy-relevant signals in source repositories, including personal-data handling patterns, data categories, processor SDKs, transfer indicators, retention or deletion logic signals, AI components and evidence that can support RoPA and DPIA records. Findings are reviewed before they become compliance evidence.

StartConnect

Connect technical evidence without breaking governance boundaries

Code Scan is built to inspect repository content in a controlled and reviewable way. The objective is to establish technical context, understand what the system is doing, and bring that evidence into the compliance workflow without turning the exercise into an unmanaged copy of the engineering estate.

The first step is to connect real technical evidence to the governance process, so review starts from what the codebase is doing in practice rather than from narrative descriptions alone. In Acompli, a connected repository becomes governed evidence inside the same platform that holds the RoPA and DPIA records it will later support.

Repository context

Files, structure, dependencies, and implementation signals are used to establish technical context.

Implementation signals

The codebase is examined as it exists in practice, helping reviewers assess actual implementation.

Connected workflow

Technical context sits alongside the wider governance workflow rather than being separated from privacy review.

01Scope

Define the right governance scope before findings are produced

A useful scan starts with scope. Code Scan can be framed around the governance question that matters: visibility over personal-data processing, vendor and transfer signals, AI-related components, or a combination of these.

Each scan is driven by governance purpose, not technical curiosity. A review point before execution keeps the work aligned to the business question and filters out noise before findings are produced. Acompli records the chosen scope against the scan, so a later reviewer can see which governance question each set of findings was produced to answer.

Scope
Privacy reviewFocus on personal-data handling, processors, transfers, and wider privacy relevance.
AI-governance reviewFocus on AI-related components, model integrations, and follow-up that may be needed.
Pre-execution reviewAlign the scan to the repository context and compliance objective before results are produced.
02Discover

Discover personal-data handling, vendors, transfer signals, and AI components from the codebase itself

Code Scan works as privacy code scanning rather than a basic keyword scan. It analyses source code together with surrounding technical signals such as dependencies, schemas, configuration, and implementation patterns.

Reviewers see compliance-relevant evidence across the technical estate in a form that is useful for DPO, legal, security, and engineering teams. Acompli Code Scan carries the file, line, branch and commit with each signal, so review starts from inspectable evidence rather than an assertion.

Code Scan - Evidence signals
Personal-data handling signals across code and schema layersPrivacy
Third-party tools and SDK usage that may indicate processor relationshipsVendor
Transfer-relevant implementation signals that may need follow-upTransfer
AI-related components and model integrations for governance reviewAI
Cross-surface context from dependencies, config, and implementation patternsContext
Multi-surface ->Discover compliance-relevant evidence across the technical estate, not just isolated text matches.
03Review

Review findings with provenance that privacy and engineering teams can inspect

Findings arrive with provenance, not as unsupported alerts. Reviewers can understand what was found, where it was found, and why it matters.

Evidence becomes useful when people can inspect it, challenge it, and approve it with confidence. Human reviewers can confirm, reject, annotate, and refine findings before anything is treated as an official output. In Acompli, each of those decisions is recorded against the finding, so the approval trail stays inspectable alongside the evidence itself.

Inspectable provenance

Findings are reviewed against the underlying repository evidence and surrounding technical context.

Human decisions

Privacy, legal, security, and engineering reviewers hold the decision on every finding.

Shared review workflow

Acompli's review layer supports collaboration between privacy, legal, security, and engineering stakeholders.

Principle ->Discover from code, decide with people, and preserve the reasoning behind every approval.
04Record

Turn approved technical evidence into durable governance records

The real value emerges when approved findings are no longer trapped in a scan report. Once reviewed, technical evidence can support the organisation's wider operating record across assessments, risk, records, data mapping, and related documentation. With Acompli, an approved finding feeds those connected records directly, keeping the link back to the reviewed code intact.

A strong compliance workflow does not end with findings. It creates an accountable record that different audiences can use without losing the link back to reviewed technical evidence.

Data Mapping

Support connected records

Approved findings can support documentation of systems, suppliers, processing context, and broader data-mapping work.

Risk & review

Curate evidence for different reviewers

Technical evidence can be shaped into outputs suitable for operational teams, privacy reviewers, and governance stakeholders.

Leadership

Preserve a durable record

The point is not only to generate a report, but to preserve reviewed evidence in a usable governance record.

Connected platform

Feed the wider operating model

Approved work products feed connected compliance records rather than sitting in isolation from the rest of the platform.

05Mitigate

Use approved findings to route downstream privacy and AI-governance mitigation

Code Scan turns reviewed evidence into the next stage of governance work: update the record, launch the assessment, ask engineering for context, or assign follow-up where a mitigation is needed.

The objective is not merely to detect issues. It is to turn technical evidence into governed action, while later scans can revisit changes in the codebase and preserve earlier review history. Acompli preserves that review history across scans, so a repeat scan shows what changed and what was already decided.

Mitigate
DPIA
AI Review
Records
History
Outcome ->Reviewed evidence can support follow-up action now and remain useful as the codebase changes over time.

How Code Scan works, in six steps

  1. ConnectRepository content is inspected in a controlled, reviewable way within governance boundaries.
  2. ScopeThe scan is framed around the governance question that matters before findings are produced.
  3. DiscoverPersonal-data handling, vendors, transfer signals and AI components are found in the code itself.
  4. ReviewFindings arrive with provenance that privacy and engineering reviewers can inspect.
  5. RecordApproved findings become durable governance records, not a throwaway scan report.
  6. MitigateReviewed evidence routes the next step of privacy and AI-governance work.
06

Scanner comparison

How is privacy code scanning different from a vulnerability scanner or SBOM tool?

Privacy code scanning answers a different question from application security tooling. A SAST tool, malware scanner, vulnerability scanner or SBOM generator looks for security defects and component inventories. Acompli Code Scan looks for privacy and AI-governance evidence — what personal data the code handles, which processors it calls, where data crosses borders, and which AI components are in use — and routes those findings into RoPA, DPIA and EU AI Act work. Keep your security tooling; Code Scan complements it rather than replacing it.

Security scanners (SAST / SBOM / vulnerability)Acompli privacy code scanning
Looks for security defects, vulnerabilities, malware or a component inventory.Looks for personal-data handling, processor SDKs, transfer indicators and AI components.
Outputs security alerts, vulnerability reports or an SBOM.Outputs reviewable findings carrying the file, line, branch and commit where each was found.
Acted on by security and engineering teams to fix code.Acted on by privacy, legal, security and engineering reviewers who confirm, reject or annotate each finding.
Evidence for application-security posture.Evidence for a GDPR Article 30 RoPA, an Article 35 DPIA, data mapping and EU AI Act review.
Can patch code or open pull requests.Never patches code or opens pull requests — it surfaces signals for a human to decide on.
Flags a finding for the security backlog.Surfaces a signal; a named reviewer makes the determination, and the EU AI Act Annex III risk tier stays a human decision.
03

Finding anatomy

Every finding needs provenance and a decision trail

This shows what makes Code Scan defensible: the finding carries file, line, branch, commit, detected signal, risk hint and the reviewer decision before it routes into records.

Code Scan findingFinding record
  • File & lineservices/export.py · L214
  • Branch · commitmain · a41f2c9
  • Detected signalProcessor SDK write
  • Data signalEmail + IP address
  • Risk hintPossible third-country transfer

A reviewer confirms or dismisses each finding — named and dated

Routes to

  • RoPA
  • DPIA
  • Transfer review
  • Vendor oversight
  • AI Act review
04

Finding routing

A technical finding only counts after review and routing

This makes clear Code Scan is not a vulnerability scanner: confirmed findings are mapped to RoPA, DPIA, transfer review, vendor oversight, AI Act review or risk actions.

Confirmed findingReviewed by a person — not raw scanner output
  • RoPAProcessing activity updated
  • DPIANew risk enters the assessment
  • Transfer reviewThird-country signal starts a TIA
  • Vendor oversightUndeclared processor SDK surfaced
  • AI Act reviewModel integration enters triage
  • Risk actionsTreatment task assigned and tracked
05

Privacy code scanning answer

What is privacy code scanning software?

Privacy code scanning software examines an organisation's source code, dependencies, schemas and configuration for the personal-data handling, third-party SDKs and processors, transfer destinations and AI components that compliance records depend on. Acompli Code Scan turns what the software actually does into reviewable evidence for a GDPR Article 30 RoPA, an Article 35 DPIA, data mapping and EU AI Act follow-up.

It is privacy and AI-governance evidence, not application security: Code Scan does not replace SAST, SBOM or vulnerability tooling, and it is a paid add-on to any Acompli platform plan. The scan surfaces candidate findings with file-and-line provenance; a named reviewer confirms, edits or rejects each one before it becomes an official record.

Key takeaways

  • Privacy code scanning is not a vulnerability scanner — it looks for personal-data, processor, transfer and AI-governance evidence, not security defects, and complements rather than replaces SAST/SBOM tooling.
  • Evidence for Article 30, Article 35 and Annex III work — approved findings can support a GDPR Article 30 RoPA, an Article 35 DPIA, data mapping and EU AI Act review for teams accountable to the DPC (Ireland) and ICO (UK).
  • AI surfaces; a human approves — findings arrive with provenance and a reviewer confirms, edits or rejects each before it counts as a record. Code Scan does not decide whether a system is high-risk.
  • A paid add-on, licensed separately from the five-module platform — request pricing based on repository scope, review workflow and security requirements.

What to look for in privacy code scanning software

  • Privacy-relevant findings, not security defects — it should surface personal-data handling, processor SDKs, transfer indicators and AI components, and complement (not replace) your SAST, SBOM and vulnerability tooling.
  • Finding-level provenance — each finding should carry the file, line, branch and commit where it was found, so a reviewer can verify it before it becomes an Article 30 RoPA or Article 35 DPIA record.
  • A human-review step before evidence counts — a named reviewer should confirm, edit or reject every finding; the tool surfaces signals and never makes the legal determination or the EU AI Act risk-tier classification itself.
  • Mapping to the obligation each finding triggers — special-category data to an Article 9 / Article 35 DPIA, a transfer indicator to Chapter V and SCCs, a processor SDK to the Article 30 RoPA. Getting the core processing principles or international transfers wrong carries exposure of up to €20 million or 4% of global annual turnover under GDPR Article 83(5).
  • Findings that flow into connected records — approved evidence should feed DPIA software, privacy risk software and vendor risk management software work rather than sitting in a one-off scan report.
07

Which scanner

Which type of code scanner do you need?

“Code scanning” spans very different tools. The privacy question — what personal data and AI the code handles — is a different job from the security question, and the right tool depends on which you are answering.

Type of toolBest forWhat it findsWatch-out
Security scanner (SAST / SCA)Engineering and AppSec teams finding vulnerabilitiesSecurity defects, CVEs, exposed secretsNot built for privacy — it does not map findings to personal-data categories or to Article 30 / Article 35 obligations
Open-source PII scannerDevelopers spot-checking a repo for personal dataPII patterns in source filesA point script, not a workflow — no human review, provenance or governance record behind each finding
Dedicated privacy code scannerPrivacy teams wanting code-level data discoveryPersonal-data handling, processor SDKs, transfer indicators, AI componentsOften produces a standalone scan report, separate from where the RoPA and DPIA actually live
Privacy-platform-integrated scanner (where Acompli sits)Privacy and engineering teams who need findings to become reviewed RoPA, DPIA and AI-governance evidenceThe same privacy and AI signals, each with file, line, branch and commit provenanceA paid add-on to the Acompli platform — a privacy scanner, not a standalone security tool
08

Primary sources

Where code-level evidence fits in GDPR and EU AI Act records

Code Scan provides the human-reviewed technical evidence behind the records regulators inspect: the Article 30 register, the Article 35 DPIA, and EU AI Act documentation for in-scope systems. The high-risk Annex III determination is a human decision made on the EU AI Act page, not in the scanner.

Last reviewed: 11 June 2026.

Connected Acompli pages

EU AI Actowns the Annex III classification; Assessmentsshows how approved findings feed an Article 35 DPIA and Article 30 RoPA; Data Mapping renders the systems and flows the scan surfaces.

Evidence controls

Findings should carry the source location, commit context and reviewer decision before they become governance evidence.

Governance outputs

Approved findings can support RoPA fields, DPIA descriptions, transfer review, processor evidence and AI-system follow-up.

09

At a glance

What privacy code scanning software does, in four lines

Privacy evidence, not application security

Privacy code scanning is about personal-data handling and data-flow evidence, not generic application security.

Personal data discovered from source code

Code-level findings can support RoPA records, DPIAs, transfer reviews, vendor evidence and AI system discovery.

Human-reviewed compliance records

Acompli surfaces privacy signals for human review before they become compliance records.

Engineering evidence for privacy teams

Engineering evidence helps privacy teams avoid relying only on interviews and spreadsheets.

RoPA requirements guide for Ireland and the UK · EU AI Act requirements for Ireland and the UK · EU AI Act governance.

Recent technical-governance updates

AI Act and technical-governance signals worth reviewing

Code Scan is scoped for teams who need technical evidence to line up with privacy and AI governance as the regulatory picture changes.

Code Scan FAQ

Frequently Asked Questions

Privacy code scanning software analyses source code for privacy-relevant signals: personal-data handling, data flows, processor SDKs, transfer indicators and AI components. Acompli Code Scan reads nominated repositories through zero-copy GitHub access and looks across source, dependencies, schemas and configuration together - every finding carries the file, line, branch and commit where it was found, so a reviewer can verify it before it becomes evidence.

More Code Scan lifecycle questions

From live codebase to reviewable governance evidence

Approved findings leave the scan as connected governance evidence, not a one-off report. Code Scan is a paid add-on that extends any Acompli platform plan.

Code Scan is a paid add-on to any Acompli platform deployment; pricing is based on repository scope, review workflow and security requirements. See Acompli pricing.