Findings with evidence and the law
Each finding shows where it came from: the page, document or code line, the date it was collected, and the article it rests on.
Agents that work alongside you, not instead of you.
Dembri Privacy Records reads your website, code and documents. Two agents propose findings with the evidence and the law. Your DPO reviews them. You decide.
An assessment tool. It does not act as your Data Protection Officer.
Provide your website, upload your documents and, if you choose, authorise read access to your code.
acme-example.aeprivacy-policy.pdf, 4 DPAsgithub.com/acme-example/appDraft ready for your DPO to review.
Narrated with an AI voice. Captions available.
A new tool in your product is often a new vendor. Privacy Records checks each vendor three ways at each scan: is it in your code, is its DPA on file, and does your privacy policy name it.
Before
Tools in your product
| Vendor | In code | DPA on file | In policy |
|---|---|---|---|
| Supabase | yes | yes | yes |
| Stripe | yes | yes | yes |
| Resend | yes | yes | yes |
| Anthropic | yes | yes | yes |
These vendors appear in your code, your uploaded DPAs and your policy pages.
After you add a voice assistant
Tools in your product
| Vendor | In code | DPA on file | In policy |
|---|---|---|---|
| Supabase | yes | yes | yes |
| Stripe | yes | yes | yes |
| Resend | yes | yes | yes |
| Anthropic | yes | yes | yes |
| ElevenLabs | yes | no | no |
ElevenLabs is in your code, but no DPA is on file and your privacy policy does not name it. ElevenLabs publishes its DPA as part of its terms: save a copy, record the date you accepted it, and name it in your policy.
Each finding shows where it came from: the page, document or code line, the date it was collected, and the article it rests on.
Each vendor in your code checked against the DPAs you hold and the vendors your privacy policy names.
One card per AI system with the DIFC Regulation 10 conditions: a gap only when a finding shows one, otherwise for your DPO to confirm.
Your processing activities, their recipients and AI systems on one map. Select an activity to see its purpose, lawful basis and findings.
Each finding becomes a task with an owner and a due date. Overdue work comes first.
One page for leadership: what needs a decision, what is overdue, and what waits for your DPO to verify.
Draft answers for your DIFC data protection notification, with each transfer checked against the list of adequate jurisdictions.
A named reviewer accepts, rejects or edits each finding and records the residual risk decision. Nothing is final until they approve.
The library currently contains 67 vendors: AI, cloud, payments, analytics, communication, CRM, identity and productivity tools, including UAE payment providers.
A draft finding before review.
Evidence, redacted excerpt
/signup: "Upload your trade licence and we set up your account." No mention of automated processing. Contact: [email redacted]
Source: website, page /signup
Citation
DIFC Regulation 10.2.2(a)
Clear notice when a System first processes personal data without human direction.
Proposed fix
Add a short notice on the upload step that names the AI system and what it reads.
A scripted replay on the fictional company. It stops where people take over.
The log records who acted and when.
One finding, three roles
Reads, screens and proposes. It makes no legal decision.
Reviews each finding and each fix, and advises in writing.
Fix gaps, prove fixes and sign the controller's decisions.
| Activity | Purpose | Basis | Source |
|---|---|---|---|
| declared | |||
| declared | |||
| inferred | |||
| declared |
| System | Use | Human review |
|---|---|---|
Drafts assemble from the scan. A person approves them.
Findings link to stored evidence and legal text.
A draft in the DIFC worksheet structure until approved.
From declared facts and evidence, with a source per row.
Regulation 10 register, or an inventory under other laws.
Screening, your DPO's advice and your signed decision.
What changed, the test and the result, for your DPO.
Decisions include a name, time and version.
Optional. It shows what changed.
The law that applies depends on where you are licensed.
Data Protection Law No. 5 of 2020 and the Regulations, including Regulation 10 on AI systems.
Data Protection Regulations 2021.
Federal Decree Law No. 45 of 2021, for most other UAE companies.
A citation shows where a finding comes from. It is not a statement that you comply.
In 2025 the DIFC Commissioner of Data Protection listed 273 administrative fine decision notices for basic contraventions, such as non-renewal of notification.
Since 15 July 2025, people can bring claims in the DIFC Courts for breaches of the Data Protection Law.
In 2024 an ADGM start up with a DPO and an ISO 27001 framework received a USD 20,000 penalty. One access request was not answered within the legal deadline. It had no procedure for such requests.
These are public records and a law change. They do not predict the outcome for your company.
Connectors only read. Repositories are read at a fixed commit.
Personal data detected in excerpts is redacted before storage.
Data is stored on our server at Hetzner Online GmbH, Falkenstein, Germany.
The AI providers listed on the privacy page process redacted excerpts.
Read only MCP access for Claude, Cursor and other tools.
Tokens expire and you can revoke them.
claude mcp add --transport http dembri-privacy-records https://privacy.dembri.com/mcp --header "Authorization: Bearer dpr_pat_YOUR_TOKEN"Which findings still wait for our DPO?list_findings (status: open), read only3 findings proposed, not reviewed.
Start with a free scan. Further work is quoted separately.
Access is by invitation. Request a scan and we reply by email.
No. It is an assessment tool. Your DPO is a named data protection professional who reviews the findings; where the law requires a DPO, you still appoint one.
Yes, read only, through the MCP server, with a token you create and can revoke.