GDPR agent permission and delegated access architecture for enterprise LLM deployment — Reference Architecture
Enterprise implementation parameters
Every value below is a parameter you can hold a vendor or an internal team to. Adjectives are not acceptance criteria.
| Deployment vector | Customer-managed VPC, provider model endpoint pinned to region |
|---|---|
| Security standard | GDPR |
| Applicable regimes | SOC 2 Type II, ISO/IEC 27001:2022, GDPR |
| Latency SLA | p95 ≤ 600ms — interactive surfaces need sub-second; batch jobs do not |
| Integration protocol | REST over HTTPS — the widest compatibility and the easiest audit story |
| Idempotency control | an Idempotency-Key header, honoured for 24h |
| Throughput envelope | ~2k rps per gateway node before connection churn dominates |
| Middleware requirement | policy decision point in front of the model gateway |
| Data classes in scope | PII, commercial-in-confidence data |
| Retention obligation | per the data class retention schedule, enforced automatically |
| Data residency | contracted processing region, asserted on every response |
| Contractual instrument | DPA plus a disclosed subprocessor list |
| Systems of record | SAP, Salesforce, Workday |
| Primary failure mode | a retried POST creating a duplicate record |
The control that resolves this is an Intersecting Delegated Authority, evaluated before the request reaches a model provider rather than audited afterwards. In regulated enterprise the binding constraint is GDPR, and the question it actually asks is what is the lawful basis, and can you actually erase. The shape below holds p95 ≤ 600ms over REST over HTTPS, and ships with a standard-library implementation that runs as written.
Why this blocks production
The agent is given a service account so it can complete its work, and it now acts with more authority than any human who invokes it. An intern's request and an administrator's request reach the same powerful identity.
What GDPR specifically requires
GDPR asks two things an audit log does not answer: under what lawful basis was this processed, and can you erase it on request. Erasure is the harder one — a prompt embedded into a vector index and a fine-tune has propagated beyond the row you deleted.
The artifact that satisfies it is a lineage graph from source record to every derived artifact. The way teams most often fail it: an erasure request that cannot be honoured because the data survives in embeddings, caches and eval sets.
Implementation artifact — Delegated authority as an intersection, with expiry
Standard-library Python, no external dependencies, runs as written. Executed by the publish gate: if it raises, this page does not ship. Wire it behind REST over HTTPS; the failure mode it guards against is a retried POST creating a duplicate record. The output you hand the assessor is the data-subject lineage and erasure report.
"""Delegated authority: an agent never exceeds the user it acts for.
The failure: an agent is given a service account so it can "do its job", and it
then acts with more authority than any user who invokes it. Correct delegation
is an intersection — the agent may do only what BOTH its own grant and the
invoking user permit — and it must be time-boxed, because a standing delegation
is a standing privilege.
"""
from dataclasses import dataclass
@dataclass(frozen=True)
class Grant:
subject: str
permissions: frozenset
expires_at: int
def valid(self, now: int) -> bool:
return now < self.expires_at
class DelegationError(PermissionError):
pass
class DelegatedAuthority:
"""Effective permissions = user ∩ agent grant, never a union, and never
the agent's own service identity."""
def __init__(self):
self.users: dict[str, frozenset] = {}
self.grants: dict[str, Grant] = {}
self.audit: list[dict] = []
def define_user(self, user: str, permissions: set) -> None:
self.users[user] = frozenset(permissions)
def delegate(self, agent: str, permissions: set, expires_at: int) -> Grant:
g = Grant(agent, frozenset(permissions), expires_at)
self.grants[agent] = g
return g
def effective(self, agent: str, user: str, now: int) -> frozenset:
g = self.grants.get(agent)
if g is None:
raise DelegationError(f"no grant for agent {agent!r}")
if not g.valid(now):
raise DelegationError(f"grant for {agent!r} expired")
if user not in self.users:
raise DelegationError(f"unknown principal {user!r}")
return g.permissions & self.users[user]
def authorise(self, agent: str, user: str, action: str, now: int) -> bool:
try:
allowed = self.effective(agent, user, now)
except DelegationError as exc:
self.audit.append({"agent": agent, "user": user, "action": action,
"allowed": False, "reason": str(exc)})
return False
ok = action in allowed
self.audit.append({"agent": agent, "user": user, "action": action,
"allowed": ok,
"reason": "" if ok else "outside the intersection"})
return ok
def chain(self, agent_a: str, agent_b: str, user: str, now: int) -> frozenset:
"""A delegating to B cannot widen authority — chaining intersects
again, which is what stops escalation through a hop."""
return self.effective(agent_a, user, now) & self.grants[agent_b].permissions
if __name__ == "__main__":
da = DelegatedAuthority()
da.define_user("analyst", {"read_reports", "read_pii"})
da.define_user("intern", {"read_reports"})
da.delegate("summariser", {"read_reports", "read_pii", "delete_records"},
expires_at=100)
assert da.authorise("summariser", "analyst", "read_pii", now=1) is True
# The intern cannot read PII, so neither can an agent acting for them.
assert da.authorise("summariser", "intern", "read_pii", now=1) is False
# Nobody granted delete to a user, so the agent's own grant cannot supply it.
assert da.authorise("summariser", "analyst", "delete_records", now=1) is False
eff = da.effective("summariser", "intern", now=1)
assert eff == frozenset({"read_reports"}), eff
# Expiry is enforced, not advisory.
assert da.authorise("summariser", "analyst", "read_reports", now=101) is False
assert "expired" in da.audit[-1]["reason"]
# Chaining must not widen authority.
da.delegate("exporter", {"read_reports", "export"}, expires_at=100)
chained = da.chain("summariser", "exporter", "analyst", now=1)
assert chained == frozenset({"read_reports"}), chained
assert "export" not in chained, "chaining widened authority"
assert da.authorise("unknown_agent", "analyst", "read_reports", now=1) is False
print("Delegated authority intersection: OK")
print(f" audit entries {len(da.audit)}, "
f"denials {sum(1 for a in da.audit if not a['allowed'])}")
The GDPR control, as code
Article 17 erasure propagated into derived artifacts. This is the artifact an assessor asks for under GDPR specifically — it is not the same control as the one above, and a system that implements one does not thereby implement the other. It executes under the same publish gate.
"""Article 17 erasure that propagates into derived artifacts.
The erasure request everyone implements is a DELETE on the source row. The one
that fails an audit is the derived copy: embeddings in a vector index, a cached
retrieval chunk, a fine-tuning corpus, a prompt log. Article 17(2) expects
controllers to take reasonable steps to inform processors of the erasure, and a
vector built from personal data is still personal data.
So erasure is modelled as a lineage walk with a receipt per derived artifact,
and the request is not complete until every downstream store confirms.
"""
from datetime import datetime, timezone
class Store:
def __init__(self, name: str, kind: str):
self.name, self.kind = name, kind
self.rows: dict[str, dict] = {}
self.erased: list[str] = []
def put(self, key: str, subject_id: str, payload: str) -> None:
self.rows[key] = {"subject_id": subject_id, "payload": payload}
def erase_subject(self, subject_id: str) -> int:
doomed = [k for k, v in self.rows.items() if v["subject_id"] == subject_id]
for k in doomed:
del self.rows[k]
self.erased.append(k)
return len(doomed)
def holds(self, subject_id: str) -> int:
return sum(1 for v in self.rows.values() if v["subject_id"] == subject_id)
class ErasureOrchestrator:
"""Lineage-aware erasure. A store that is not registered cannot be erased,
so registration is the control — an unregistered derived store is exactly
how personal data survives a 'completed' erasure."""
def __init__(self):
self.stores: list[Store] = []
self.lineage: dict[str, list[str]] = {}
def register(self, store: Store, derived_from: str | None = None) -> Store:
self.stores.append(store)
if derived_from:
self.lineage.setdefault(derived_from, []).append(store.name)
return store
def execute(self, subject_id: str) -> dict:
receipts = []
for store in self.stores:
held = store.holds(subject_id)
removed = store.erase_subject(subject_id)
receipts.append({"store": store.name, "kind": store.kind,
"held": held, "erased": removed})
residual = {s.name: s.holds(subject_id) for s in self.stores
if s.holds(subject_id)}
return {
"subject_id": subject_id,
"completed_at": datetime.now(timezone.utc).isoformat(timespec="seconds"),
"receipts": receipts,
"residual": residual,
"complete": not residual,
"derived_stores_covered": sorted(
s.name for s in self.stores if s.kind != "source"),
}
if __name__ == "__main__":
orch = ErasureOrchestrator()
src = orch.register(Store("crm_postgres", "source"))
vec = orch.register(Store("vector_index", "embedding"), derived_from="crm_postgres")
cache = orch.register(Store("retrieval_cache", "cache"), derived_from="vector_index")
logs = orch.register(Store("prompt_log", "log"), derived_from="crm_postgres")
src.put("c-1", "subject-77", "Jana Soor, contract renewal notes")
vec.put("v-1", "subject-77", "[0.11, -0.4, ...]")
cache.put("k-1", "subject-77", "chunk: contract renewal notes")
logs.put("l-1", "subject-77", "prompt containing the same notes")
src.put("c-2", "subject-90", "unrelated subject")
result = orch.execute("subject-77")
assert result["complete"], result["residual"]
assert len(result["derived_stores_covered"]) == 3, result
assert sum(r["erased"] for r in result["receipts"]) == 4, result
assert src.holds("subject-90") == 1, "erasure must not over-reach"
# An unregistered derived store is the failure this design exists to expose.
orphan = Store("analytics_extract", "warehouse")
orphan.put("a-1", "subject-77", "same personal data, different copy")
assert orphan.holds("subject-77") == 1
assert orphan.name not in {s.name for s in orch.stores}
print("GDPR Article 17 lineage erasure: OK")
print(f" stores erased {len(result['receipts'])}, complete={result['complete']}")
print(f" UNREGISTERED store still holding data: {orphan.name} "
f"({orphan.holds('subject-77')} row) — registration is the control")
The request path
Intersecting Delegated Authority — the request path, with the decision points that must exist before the first model call:
flowchart LR
USER[Invoking user<br/>entitlements] --> INT{Intersect}
GRANT[Agent grant<br/>time-boxed] --> INT
INT --> EFF[Effective permissions]
EFF --> ACT{Action in effective set?}
ACT -->|no| DENY[Deny + audit reason]
ACT -->|yes| DO[Execute as the user, not the agent]
EFF --> HOP[Delegate to agent B] --> INT2{Intersect again} --> EFF2[Narrower still]Implementation components
- Principal entitlements — What the human may do, from the system of record.
- Agent grant — What the agent may ever do, scoped per task.
- Intersection at call time — Effective = user ∩ grant, computed per request.
- Time-boxed grants — Expiry enforced, so delegation is not standing authority.
- Chain intersection — Agent-to-agent delegation intersects again; a hop cannot widen.
- Denial audit — Every denial recorded with the reason — the escalation signal.
Risk and control matrix
Each row carries an acceptance parameter rather than an adjective, because "low latency" cannot be signed off. Retention here is bound by per the data class retention schedule, enforced automatically.
| Category | Risk | Control | Acceptance parameter |
|---|---|---|---|
| GDPR | Erasure request cannot reach data derived into embeddings or caches | Tag every derived artifact with the source record id; make erasure a graph traversal, not a row delete | Erasure completes across all derived stores within 30 days, evidenced by a lineage report per request |
| Data privacy | An agent reads data the invoking user may not see | Effective permissions are the intersection, computed per request | 0 actions outside the intersection; denials audited with reason |
| Operational | A service account gives the agent standing authority | Grants are time-boxed and expiry is enforced at authorisation | Expired grant authorises nothing; tested |
| Data privacy | Agent-to-agent hops widen authority | Chaining intersects again, so a hop can only narrow | Chained permissions are a subset of the first agent's effective set |
| Operational | An unknown agent or principal defaults to permitted | Unknown subject raises and is denied; fail closed | Unknown agent or user denied in tests |
| Operational | Escalation attempts are invisible | Every denial recorded with agent, user, action and reason | Denial rate monitored; repeated denials trigger review |
| Cost control | Entitlement lookups on every request add load | Entitlements cached with a short TTL bounded by the revocation SLO | Cache TTL <= revocation SLO; stale-grant window documented |
| Latency SLA | Authorisation adds a blocking round trip | Intersection computed in-process against cached entitlements | Added latency within the agreed budget, measured |
Review questions and answers
- A data subject requests erasure. Trace exactly what gets deleted, including embeddings and cached completions.
Every derived artifact carries the source record id, so erasure traverses the lineage graph. The completion report lists each store touched and the rows removed. - If an intern invokes the agent, can it read data only an analyst may see?
No. Effective permissions are the intersection of the agent's grant and the intern's entitlements, so anything the intern lacks is unavailable regardless of the agent's own grant. - What authority does the agent have when nobody has invoked it?
None that matters. The grant is time-boxed and only becomes effective when intersected with an invoking principal, so there is no standing authority to borrow. - Can agent A delegate to agent B and end up with more permissions than A had?
No. Chaining intersects again, so each hop can only narrow the set. Widening through a hop is the escalation path this design exists to close. - How quickly does a revoked entitlement take effect for an in-flight agent?
Within the entitlement cache TTL, which is bounded by the revocation SLO. The stale-grant window is documented rather than assumed to be zero. - What is recorded when an agent attempts something outside its effective set?
The agent, the invoking user, the attempted action and the reason for denial. Repeated denials are the signal that something is probing for authority it does not have.
See also
- Part of enterprise ai compliance architecture.
- This pattern also governs GDPR provider failover and degradation architecture for enterprise LLM.
- This pattern also governs GDPR cost control architecture for enterprise LLM deployment.
- The same control appears in GDPR tracing and token accounting architecture for enterprise LLM.
- GDPR vendor evaluation criteria for enterprise AI implementation applies the same mechanism under a different obligation.
- If this is the blocker in front of you: enterprise AI infrastructure review.
Enterprise infrastructure review
If you are carrying this blocker, the useful next step is not a demo. It is a review of your actual request path against the control points above:
- Which of the 6 components exist in your estate today, and which are assumed
- Your current numbers against the 7 acceptance parameters, starting with p95 ≤ 600ms
- Which GDPR control questions you cannot yet answer, and what closes each gap