If your HubSpot data only exists inside the portal, you have access but limited control. A clear data inventory and ownership register gives you a single source of truth for what you hold, who is responsible, how long you keep it, and how you prove custody and recovery. This guide shows you how to build a practical register that Compliance, Legal, Security and Operations can all use, and how to make it verifiable with acceptance criteria, auditable logs and measurable KPIs.
A register turns “we think we know” into “we can prove it”. It aligns SaaS shared responsibility with your obligations under GDPR and your contracts, and it underpins restore readiness. When something breaks, you need more than sign‑in rights; you need custody, portability and control. A well‑run register ties together scope, ownership, retention, backup, restore drills and evidence so you can satisfy auditors and recover quickly. For context on access versus ownership, see Access rights versus data ownership in HubSpot (/learning-centre/hubspot-access-vs-data-ownership) and HubSpot exports versus secure backups (/learning-centre/hubspot-exports-vs-secure-backups).
- SaaS (Software as a Service). The provider runs the platform; you control your data and configuration.
- GDPR and your DPA. GDPR drives portability, retention and erasure; your Data Processing Agreement sets controller/processor duties.
- RBAC (role‑based access control). Who can back up, restore and approve changes.
- RPO and RTO. How much data you can lose between copies (RPO) and how quickly you must recover (RTO).
- RoPA (Records of Processing Activities). GDPR Article 30 register of what you process, why and how it is protected.
- API. Scripted read/write access to objects and configuration.
- WORM, KMS and HSM. Immutability (write once, read many) and encryption key management methods.
The outcome is a single register that lists HubSpot data, assets, configuration and flows; names accountable owners and approvers; states retention rules, legal holds and residency; and shows how backup and restore work and where the evidence lives. The structure should reflect people, scope and evidence: owners and approvers per entry; complete coverage across objects, engagements, files, CMS and configuration; and links to policy, logs and drill reports that prove control.
Start by defining the purpose: support recovery, compliance, audit and change approval. Confirm scope across production portals and sandboxes, and include all HubSpot objects, custom objects and engagements; files and CMS assets; and configuration such as properties, pipelines, workflows, lists and permissions. Appoint roles with deputies:
- Data Owner per domain: accountable for retention, access and quality.
- Data Steward per domain: responsible for day‑to‑day coordination and documentation.
- Backup and Restore Owner: responsible for backup scope and recovery drills.
- Validator: independent reviewer for restore checks.
- Approver: authority for high‑risk actions and final sign‑off.
Create an itemised list with short descriptions and dependencies:
- Core objects: Contacts, Companies, Deals, Tickets, Custom Objects.
- Engagements: notes, tasks, meetings, calls, emails, marketing email events.
- Files and attachments: stored files and links to records.
- CMS assets: pages, themes, modules, blogs and media.
- Configuration: properties and field mappings; pipelines and stages; workflows and enrolment triggers; lists and segments; permissions and teams; subscription types and lawful basis settings.
Document where data enters, how it changes and where it goes. Capture entry points (forms, imports, sales activity, service interactions and external sources), integrations (systems, objects touched, flow direction and the system of record per field), keys and identifiers (HubSpot IDs and external IDs used for matching), and destinations (warehouses, reporting tools and exports with purpose and cadence). This lineage lets you prove system‑of‑record decisions and helps design restore tests that reflect reality.
For each data class and configuration area, record the Data Owner, Steward, Backup and Restore Owner and Approver, with contact details and deputies. Make ownership visible in the register and keep it fresh; stale ownership is a common source of delay at the point you most need speed. If you use human‑in‑the‑loop checkpoints for restores or sensitive changes, define the approval pattern clearly (/learning-centre/human-in-the-loop-checkpoints).
Write rules that Legal and Compliance can sign off. Set retention periods by data class for production and backups, with references to legal or contractual bases. Record the erasure log location and the process to re‑delete erased items after a restore. Define how to place, monitor and release a legal hold, who can authorise it, and how you evidence it. Link to the RoPA entry for each processing activity that uses HubSpot.
Prove that backups cover what matters and that you can restore. Record that backups capture data, assets and settings with relationships preserved; include exclusions and why they exist. State capture schedule and cadence and how you monitor success. List storage regions to meet residency policy (for example United Kingdom or European Union). Describe security controls: encryption in transit and at rest, whether you use a KMS or HSM, access restrictions and audit logging. Finally, document where WORM immutability is applied, which data classes are covered and for how long. If you need a robust tool, see backHUB (/solutions/backhub-hubspot-backup). If you centralise logs and evidence on records where teams work, see the strutoIX role in outcomes (/kb/strutoix-role-in-outcomes).
Show that only the right people can act. Define your RBAC model across requester, executor, validator and approver roles for backup and restore. Require dual control for production restores and sensitive configuration changes. Use time‑bound elevation for drills and incidents, then revoke. Review access quarterly against HR and ticket logs; record findings and corrective actions.
Agree targets for the HubSpot environment with business owners. Run a quarterly restore in a sandbox or constrained scope, rotating scenarios such as bulk update reversal, configuration rollback and a portability exercise. Validate record counts and key fields, association integrity, configuration parity, automation behaviour, reporting results and export completeness. Keep logs with timestamps and user IDs, approvals, before and after screenshots or diffs, reconciliation notes and a pass/fail summary. For practical drill design and instrumentation, see agentic orchestration (/learning-centre/verify-agent-assisted-steps-safely), acceptance criteria (/learning-centre/outcome-acceptance-criteria-testable) and our metrics guide (/learning-centre/metrics-that-prove-value-beyond-vanity).
Track a small set of indicators and review them with leadership:
- Register coverage: the percentage of identified data/config classes with complete entries.
- Ownership freshness: the percentage of entries with owner/steward updated in the last 90 days.
- Drill pass rate and average RTO: percentage of drills meeting acceptance criteria and time to recovery versus target.
- RPO adherence: percentage of runs within target.
- Evidence completeness: percentage of entries with full evidence packs (RoPA, DPA, drill report, chain‑of‑custody log).
- Access hygiene: number of open exceptions from RBAC access reviews.
- Erasure follow‑through: percentage of re‑deletions completed after a restore within policy.
- Residency compliance: percentage of entries with region evidence aligned to policy.
Set up a single repository with controlled access. Each row represents a data class or configuration area. Capture: name; description and purpose; system of record and related systems; objects in scope; keys and identifiers; Data Owner, Steward, Backup and Restore Owner and Approver; retention (production and backups) with legal basis; legal hold process link; backup scope and frequency; tool used; storage locations and regions; security controls (encryption, KMS/HSM); immutability policy (WORM); residency regions; RBAC roles required for changes or restores; last drill date, scenario and result; links to evidence (RoPA entry, DPA reference, diagrams, chain‑of‑custody log).
- Contacts: personal data for marketing, sales and service. System of record is HubSpot for engagement and consent. Owner is Head of RevOps; Steward is CRM Manager; Backup and Restore Owner is Platform Lead; Approver is Data Protection Officer for holds and Legal for retention. Keys are contact ID and email. Retention is five years post last meaningful activity in production and twelve months in backups, subject to policy. Backups run nightly and include settings. Residency is EU; encryption at rest uses customer‑managed keys; WORM applies to retention classes that require it. Last drill date, scenario and result are linked to the evidence pack.
- Properties & pipelines: configuration for CRM process and reporting. Owner is Sales Operations Lead; Steward is Sales Systems Analyst; Backup and Restore Owner is Platform Lead; Approver is Head of Sales. Retain configuration history for one year. Backups run nightly. The last drill shows configuration rollback within target RTO; evidence is linked.
Update the register whenever you add objects, fields, integrations or storage locations. Review the full register quarterly with Data Owners, the Backup and Restore Owner and Compliance. Record changes and keep a version history. Include the register and the latest drill pack in your board or audit review. When you run change freezes or pause/rollback procedures, document them and link them in the register (/kb/pause-rollback-outcomes). If you’re piloting your first drill, use our pilot guidance (/kb/pilot-for-outcomes).
Common issues include ignoring configuration (records restore but pipelines, properties and workflows do not), missing relationships (flat exports without association keys), no evidence trail (actions without approvals and timestamps), unclear ownership (decisions stall), and residency mismatch (backups in the wrong region). Avoid them by cataloguing configuration, capturing association keys, enforcing tamper‑evident logs, naming roles and deputies, and aligning storage locations to policy.
It is a single register of data, assets and configuration that names owners, sets retention and residency, and links evidence for backup, restore and audits.
Coverage exceeds 95% of identified classes; owners are named; retention and legal holds are documented; backup scope and storage are recorded; and the last restore drill passed with evidence linked.
Quarterly is typical. Each drill should meet RTO, validate associations and configuration, and produce an audit pack with immutable logs and approvals.
No. It complements them. Link your RoPA entries and DPA references from each register entry to align privacy, contract and recovery evidence.