DMARC Aggregate Reports: GDPR/CCPA Compliance Checklist

DMARC aggregate (RUA) reports help teams see who is sending on their behalf, whether SPF and DKIM align, and where spoofing attempts originate. The same XML feed can also include data points—source IPs, sending domains, and counts—that intersect with privacy obligations. This article gives US teams a practical path to keep the security value of RUA while aligning with privacy rules, contracts, and audits.

What DMARC aggregate reports contain—and why that matters

A typical RUA file is a compressed XML with records that summarize authentication outcomes by source. You will see your domain, the reporter, a time range, the source IP, the aligned or failed identifiers, and a count for each row. There is no message content, but several fields can still fall under privacy rules when linked to a person or a household. The principles in GDPR Article 5—data minimization, purpose limitation, and storage limitation—map cleanly to how you collect and retain RUA. In California, the broad definition in California Civil Code § 1798.140 often treats IP addresses and persistent identifiers as “personal information,” depending on context.

Are RUA fields “personal data” or “personal information”?

Context drives the answer. A source IP used only to evaluate a sending platform may not identify a person. An IP that can be connected to a user or a small household might. The safest approach is to apply consistent rules: collect the minimum necessary for enforcement, retain it for a documented period, and mask or drop fields when you share outside the core team. This approach preserves the security signal without creating a larger privacy footprint than you need.

A practical intake-to-disposal workflow

Start by defining where RUA lands and who can see it. A dedicated mailbox routes files to a parser that normalizes XML into a table. Access is limited to the small group that owns email authentication. Storage is segmented so production data is not mixed with analytics sandboxes. Retention is short and written down, usually 90 to 180 days, which is enough to baseline senders, tune SPF and DKIM, and prove DMARC enforcement trends. This same flow should power dashboards that leadership uses to track policy coverage and spoofing declines without exposing raw XML broadly.

Collection and parsing with minimization in mind

Ingest only the fields you need for enforcement and reporting. If you are not using autonomous system numbers, user agents, or derived hostnames, do not enrich the dataset with them. Avoid copying the raw XML into tickets or chat threads. When a support case requires a sample, attach only the lines that explain the issue. Internal references like DMARC aggregate report and the broader DMARC report overview can help stakeholders understand what the data contains so they do not ask for more than is necessary.

Retention, access, and audit that hold up to questions

Document the retention window and implement deletion jobs that actually run. A 90-day default is a good starting point for many US teams; extend to 180 days if you need multi-quarter trend lines. Access should be role-based and logged. Keep a simple audit trail that notes who viewed or exported which date ranges. When auditors ask for evidence, the log and the deletion job history show that the policy is real, not aspirational. For privacy teams, the alignment with GDPR Article 5 is clear: you store less and you store it for less time.

Masking before sharing outside the core team

Many teams share RUA excerpts with vendors, MSPs, auditors, or cross-functional leaders. Before any distribution, mask or remove fields that are not required for the purpose. If you export to a BI tool or a shared folder, use a workflow that can remove personal data from reports so IPs, hostnames, or other identifiers are not exposed more widely than needed. This is especially useful for decks or monthly summaries that circulate to non-technical audiences.

Case study: a US retailer rolling RUA into quarterly reporting

A national retailer ingested daily RUA into a secure bucket, parsed only the fields needed for enforcement, and retained the data for 120 days. The deliverability team kept raw access to five users. Leadership saw a dashboard that showed total pass rates, top authentic sources by volume, and a count of blocked spoofing attempts. When the security vendor requested samples, the team exported just the relevant rows with masked IPs. The process cut ad-hoc sharing, reduced privacy review time, and improved DMARC enforcement decisions because everyone looked at the same curated view.

Case study: an MSP packaging client reports without PII

An MSP supporting mid-market clients wanted to include DMARC trends in monthly service reports. The RUA pipeline was multi-tenant, but the summary output was client-specific. The MSP masked source IPs, grouped by sending platform, and reported on alignment rates and failure declines. A small team retained raw data for 90 days and stored summaries for a year. The approach satisfied client privacy teams and produced a consistent, low-risk story about progress. For background on what “good” looks like at the policy level, linking to DMARC compliance helps non-technical stakeholders read the charts in context.

Vendor and processor governance that fits on one page

List every system that touches RUA—from the mailbox to the parser to any dashboards. For each vendor, note where data is stored, default retention, and the role they play (processor or service provider). Keep security summaries and DPAs on file. If a webhook or export sends rows to another system, make sure it is necessary and that it receives masked data, not full XML. Small reviews like this prevent accidental sprawl and make privacy reviews faster.

Handling access requests without leaking third-party data

Design a method to respond to data access or deletion requests without exposing other parties. The query should identify rows that relate to the requester and produce a summary where possible. In California, the definitions and rights in California Civil Code § 1798.140 guide scoping; in the EU context, the purpose, minimization, and storage rules in GDPR Article 5 support narrow responses that still meet obligations.

Bringing it all together for security and deliverability

Write a one-page standard that names the mailbox, the parser, the storage location, the access roles, the retention window, the masking rules, and the steps for sharing. Train the core team once and review the log quarterly. Link the checklist from your internal wiki pages on RUA handling, and keep the summary near your incident and vendor procedures so people can find it. If leadership wants a single reference for non-engineers, point them to the DMARC aggregate report explainer and the enforcement overview so everyone uses the same language.

Conclusion: keep DMARC aggregate reports useful and compliant

You can keep DMARC aggregate reports effective for security while staying within privacy bounds by collecting only what you need, retaining it for a short period, limiting access, and masking identifiers before you share outside the core team. Grounding the workflow in GDPR Article 5 and the definitions in California Civil Code § 1798.140 gives you a defensible position for audits while you continue raising alignment rates and blocking spoofing across your domains.