IT Audit Report — Spreewald Logistik GmbH
Oct 23, 2026 · Prepared by Kosmo Team
Sample report: Spreewald Logistik GmbH is a fictional company; all data is invented.
Company profile
Regional freight forwarder in Berlin-Brandenburg: 34 employees, €4.2M turnover, B2B only. IT is handled part-time by the office manager plus a freelancer on call.
| Scoping question | Answer | Effect |
|---|---|---|
| S1 Employees | 20–49 | Data Protection Officer required |
| S2 Turnover | €2–10M | E-invoicing: must send e-invoices from 2027 |
| S3 Sector | Transport | NIS2 sector, but below size threshold |
| S4 Customers | B2B | Accessibility act (BFSG) not triggered |
| S5 Online presence | Website, no shop | Impressum, cookie consent |
| S6 Sensitive data | Employee data (driver licences, health certificates) | Extra protection, impact assessment check |
| S7 AI use | Staff use ChatGPT ad-hoc | AI literacy duty (AI Act Art. 4) |
| S8 AI for evaluating people | No | No high-risk duties |
| S9 Online card payments | No | — |
| S10 Supplies critical infrastructure | Yes (food retail chains) | NIS2 supply-chain questions shown |
Each row is one of the 10 scoping questions you answered. The Effect column shows which legal duty or check that answer triggers, so you can see why a law appears later in the report.
Audit scope & method
Findings combine your answers with our own checks, so every red flag is verified.
| Step | What we did | Time |
|---|---|---|
| Intake form | 52 questions, answered by owner and office manager | ~45 min (you) |
| Kickoff interview | Walked through processes, tools and pain points | 90 min |
| Remote checks | MFA settings, backup restore test, cookie scan, email security (SPF/DKIM/DMARC), user account list | 4 h |
| Analysis & report | Scoring, legal mapping, savings estimate, review by 2 team members | 6 h |
| Results call | Walkthrough and Q&A | 60 min |
The steps we took to reach the findings. Time shows how much of your team's time each step needed; the rest was our own work.
Laws that apply to you
Six laws apply to you, based on your scoping answers.
| Law | Why it applies |
|---|---|
| DSGVO / BDSG | You process customer and employee data; 20+ staff handle it |
| EU AI Act Art. 4 | Your staff use AI tools at work |
| GoBD | Digital bookkeeping and record retention |
| E-invoicing (Wachstumschancengesetz) | B2B invoices; sending becomes mandatory for you in 2027 |
| DDG / TDDDG | Your website needs an Impressum and valid cookie consent |
| NIS2 (indirect) | Not directly in scope, but retail customers will demand security proof by contract |
Only the laws that apply to your company are listed. Why it applies links each law to a fact from your scoping answers.
Standards we check against
Best-practice findings cite a recognised standard, so every recommendation has a reference.
| Standard | What it covers | Why it matters for you |
|---|---|---|
| DIN SPEC 27076 (CyberRisikoCheck) | IT security baseline for companies under 50 staff, backed by the BSI | Our main security benchmark for your size |
| BSI IT-Grundschutz | German reference catalogue of security modules | Detailed guidance per topic (backups, accounts, email) |
| CIS Controls v8 (IG1) | Practical baseline for small IT setups | Clear, prioritised technical steps |
| ISO/IEC 27001 | International information security management standard | Often requested by larger customers and NIS2 supply chains |
| VdS 10000 | Information security for SMBs | Often referenced by cyber insurers |
Standards are not legally required, but they are the benchmarks we use for best-practice findings. Why it matters explains which one is most relevant at your size and for your customers.
Overall score: 41 / 100 (Red)
Basic tools work, but legal gaps and missing backups put daily operations at risk.
| Area | Score | Status | Biggest gap |
|---|---|---|---|
| Data protection (GDPR) | 25 | Red | No DPO, no record of processing |
| Security | 30 | Red | No MFA, backups never tested |
| AI use | 35 | Red | No AI policy or training |
| Processes & automation | 45 | Yellow | Orders typed into 3 systems |
| CRM & customer data | 50 | Yellow | Contacts in Excel and Outlook |
| Bookkeeping & invoicing | 55 | Yellow | No e-invoicing yet |
| Website | 70 | Green | Cookie banner not compliant |
Each area is scored 0–100. Red (under 40) needs action now, Yellow (40–69) within 90 days, Green (70+) is in good shape. Biggest gap is the main reason for the score.
Findings: legal obligations
Five must-fix gaps. Each can lead to fines or lost contracts.
| Gap | Source | Why it matters | Evidence |
|---|---|---|---|
| No Data Protection Officer | BDSG §38 | Required at 20+ staff handling personal data; fines possible | Interview; no DPO named in privacy policy |
| No record of processing activities | DSGVO Art. 30 | Authorities can request it at any time | Requested, none exists |
| Data processing agreements missing for 4 tools | DSGVO Art. 28 | Every provider handling your data needs one | Contract review: dispatch tool, Dropbox, TeamViewer, newsletter tool |
| No AI training or usage rules | AI Act Art. 4 | Staff paste customer data into ChatGPT without rules | 6 of 9 office staff use it (interview) |
| Cookie banner pre-ticks tracking | TDDDG §25 | Consent must be active; common target of warning letters | Cookie scan: 3 trackers load before consent |
These gaps break a legal duty. Source is the exact law, Evidence shows how we verified it, so each point can be checked by your lawyer or DPO.
Findings: best practice
Not required by law, but each gap costs time or raises risk.
| Gap | Why it matters | Evidence | Reference |
|---|---|---|---|
| No MFA on email and cloud | Blocks most account takeovers; setup takes one day | Admin console: 0 of 34 accounts with MFA | DIN SPEC 27076; CIS 6 |
| Backups never tested | Untested backups often fail when you need them | Restore test failed: last usable backup 5 weeks old | DIN SPEC 27076; BSI CON.3; CIS 11 |
| Shared logins for the dispatch tool | You can't see who changed what; ex-staff keep access | 1 login shared by 7 people | BSI ORP.4; CIS 5 |
| No offboarding checklist | Former staff keep access | 2 former drivers' accounts still active | BSI ORP.2; CIS 5 |
| Email domain not protected | Others can send email in your name (phishing) | DMARC record missing | BSI APP.5.3; CIS 9 |
| No training on tools; old workarounds persist | New tools only pay off when people actually use them | No onboarding for M365 or dispatch tool; Excel lists still used (interview) | ISO/IEC 27001 A.6.3 |
| Orders entered in 3 systems by hand | ~18 hours/week of copy-paste across the office team | Interview + process walkthrough | Efficiency (no standard) |
| Customer contacts in Excel and Outlook | Follow-ups get lost; no shared view of customers | 3 separate contact lists found | Efficiency (no standard) |
| Same customer questions by phone daily | ~6 hours/week answering "where is my delivery?" | Phone log sample, 1 week | Efficiency (no standard) |
These gaps are not illegal, but they cost time or raise risk. Reference is the standard behind each recommendation.
Tool inventory & savings
You pay €1,200/month for 8 paid tools; cutting overlaps saves about €2,900/year, almost three times the audit fee.
| Tool | Use | Cost/month | Finding |
|---|---|---|---|
| Dispatch software | Orders, routes | €450 | Keep; connect via API |
| Microsoft 365 Business Basic | Email, OneDrive, Teams | €190 | Keep; turn on MFA |
| Dropbox Business | File sharing | €180 | Overlaps OneDrive → cancel |
| Telematics | Truck tracking | €220 | Keep; feed into chatbot |
| TeamViewer | Remote support | €60 | Used twice in 6 months → cancel |
| lexoffice | Bookkeeping | €40 | Keep; supports e-invoicing |
| Newsletter tool | Customer mailings | €35 | Keep; add data processing agreement |
| Website hosting | Website | €25 | Keep |
| Excel | Contacts, order lists | in M365 | Replace with CRM |
All paid tools found in the audit with their monthly cost. Finding says whether to keep, connect or cancel each tool; the cancellations make up the €2.9k yearly saving.
Top 3 risks
Together these three put an estimated €80k+ per year at stake.
- Ransomware or account takeover: no MFA plus untested backups. A 3-day outage costs about €50k in lost turnover (€16.8k per working day).
- Manual order entry: 18 hours/week × 46 weeks × €35/hour = €29k per year, plus typing errors in delivery addresses.
- Losing retail contracts: your food retail customers fall under NIS2 and will ask for security proof. Without it you risk failing their supplier checks.
Fine risk from the GDPR gaps comes on top and depends on the authority.
Roadmap: 30, 60 and 90 days
The first 30 days need no outside help; days 31–90 close the remaining gaps.
Days 1–30 · you, no outside help
| Action | Owner | Effort (person-hours) |
|---|---|---|
| Turn on MFA for all accounts | Office manager | 6 h |
| Disable former staff accounts; start offboarding checklist | Office manager | 2 h |
| Fix backup and run a monthly restore test | Freelancer | 6 h |
| Fix cookie banner; add DMARC record | Freelancer | 3 h |
| Interim rule: no customer data in ChatGPT | Owner | 0.5 h |
| Cancel Dropbox and TeamViewer | Office manager | 1 h |
Days 31–60 · with Kosmo Team
| Action | Owner | Effort (person-hours) |
|---|---|---|
| Kickoff workshop: goals, roles, AI literacy for all office staff | Kosmo Team | 8 h |
| Appoint DPO; build record of processing; sign missing agreements | Owner + Kosmo Team | 16 h |
| AI usage policy | Kosmo Team | 6 h |
| Individual logins for dispatch tool | Freelancer | 4 h |
Days 61–90 · with Kosmo Team
| Action | Owner | Effort (person-hours) |
|---|---|---|
| Order automation across 3 systems | Kosmo Team | 80 h |
| CRM setup and contact migration, with team training | Kosmo Team | 40 h |
| Adoption check-ins: are people using the new tools? | Kosmo Team | 2 h |
| E-Rechnung ready: sending and receiving set up before 1.1.2027 | Kosmo Team + office manager | 16 h |
Actions in three phases, in the order they should happen. Owner says who does the work (your team or Kosmo Team), Effort is the estimated working time in person-hours. Days 1–30 need no outside help.
Team readiness: why training matters
New tools only pay off when people use them. Without training, staff go back to Excel and phone calls, and the savings in this report stay on paper.
- Legal: Art. 4 EU AI Act (since 2.2.2025) requires AI literacy for staff who use AI tools at work.
- Security: most attacks start with phishing; MFA helps only if staff recognise fake login pages.
- Today: no training on security, the dispatch tool or AI so far; knowledge sits with the office manager and one freelancer.
Plan time for training in every rollout step, and check after 30 days whether the new tools are used.
Recommended packages
Seven packages close every gap; the first three are urgent, and E-Rechnung has a hard deadline. Prices are placeholders for testing.
| Priority | Package | Fixes | Price (placeholder) | Yearly effect |
|---|---|---|---|---|
| 1 | GDPR & AI Act starter | DPO setup, records, agreements, AI policy | €3,500 | Removes fine and contract risk |
| 2 | Security baseline | MFA, tested backups, offboarding, individual logins | €2,500 | Cuts outage risk (~€50k exposure) |
| 3 | Change management & rollout | Kickoff workshop, tool training, 2 adoption check-ins | €1,500 | Makes savings real: people use the new tools |
| 4 | Order automation | One entry, synced to 3 systems | €8,000 | Saves ~€29k |
| 5 | CRM setup | Shared customer view, follow-up tracking | €4,000 | Fewer lost leads |
| 6 | Delivery-status chatbot | Answers "where is my delivery?" | €3,000 | Saves ~€9.7k |
| 7 | E-Rechnung ready | XRechnung/ZUGFeRD sending and receiving, GoBD archive, training | €1,500 | Legal from 1.1.2027; faster invoicing |
Packages that close the gaps above, sorted by urgency (Priority 1 = start first). Yearly effect is the expected saving or avoided cost per year. Prices are placeholders.
ROI: €24,000 one-off for all seven packages against ~€38.7k in measurable yearly savings. Payback in about 7.5 months, before counting risk reduction.
A re-audit in 6 months will show the before/after scores and actual savings.
Next step
Book a 60-minute review call with Kosmo Team to agree on a plan. If you book any package within 60 days, the full €1,000 audit fee is credited.
Included with this audit:
- Annex 1 — AI usage policy
- Annex 2 — Offboarding checklist
- Annex 3 — Record of processing activities starter (pre-filled with your tools)
- Annex 4 — Backup restore test guide
This is a compliance and IT check, not legal advice. It is aligned with, not certified against, the standards listed. Legal points should be confirmed with a lawyer.
Annex 1 — AI usage policy
Applies to all Spreewald Logistik staff and freelancers who use AI tools for work. Owner: managing director. Review: every 12 months.
1. Allowed tools
| Tool | Allowed for | Account |
|---|---|---|
| ChatGPT (business plan) | Drafting emails, summaries, translations | Company account only |
| Microsoft 365 Copilot (if licensed) | Work with internal M365 documents | Company account |
| Any other AI tool | Only after written OK from the managing director | — |
2. Never enter into AI tools
- Personal data of drivers, staff or customers (names, addresses, licences, health certificates)
- Customer contracts, prices, delivery addresses
- Passwords, access codes, bank details
3. Rules for use
- Check every AI output before you use it; you stay responsible for the result.
- Do not use AI to evaluate or select people (applicants, drivers).
- Mark texts as AI-assisted when they go to customers without changes.
- Report mistakes or data leaks to the office manager on the same day.
4. Training (AI Act Art. 4)
Everyone using AI tools completes a short AI literacy training before first use and once a year. The office manager keeps the attendance list.
| Name | Role | Training date | Signature |
|---|---|---|---|
Fill in one row per person after the training. Keep this list for 3 years as proof of AI literacy (AI Act Art. 4).
Annex 2 — Offboarding checklist
Use for every employee, driver or freelancer who leaves. Owner: office manager. Complete on the last working day.
| # | Step | System | Done | Date |
|---|---|---|---|---|
| 1 | Block Microsoft 365 account; forward mailbox to manager for 30 days | Microsoft 365 | ☐ | |
| 2 | Remove from Teams and shared OneDrive folders | Microsoft 365 | ☐ | |
| 3 | Disable dispatch software login | Dispatch software | ☐ | |
| 4 | Remove telematics app access and driver card link | Telematics | ☐ | |
| 5 | Remove bookkeeping access | lexoffice | ☐ | |
| 6 | Remove from newsletter tool and website admin | Newsletter, hosting | ☐ | |
| 7 | Change shared passwords the person knew (Wi-Fi, office alarm, shared accounts) | Various | ☐ | |
| 8 | Collect laptop, phone, keys, fuel and access cards | Hardware | ☐ | |
| 9 | Remove company data from private devices | BYOD | ☐ | |
| 10 | Delete or archive personal data per retention rules | HR files | ☐ | |
| 11 | Record completion in the offboarding log | — | ☐ |
Go through all steps on the person's last working day. Tick Done and add the date, so you can prove access was removed.
Checked by (name, date): ______________________
Annex 3 — Record of processing activities (starter)
Required by Art. 30 GDPR. Pre-filled with the tools found in this audit; complete the open fields with your Data Protection Officer.
| Processing activity | Purpose | Data subjects | Data categories | Tool / processor | Data processing agreement | Storage location | Deletion period |
|---|---|---|---|---|---|---|---|
| Order handling and routing | Execute freight orders | Customer contacts, drivers | Name, phone, delivery address | Dispatch software | ☐ to check | ☐ to check | 10 years (commercial law) |
| Fleet tracking | Route planning, delivery status | Drivers | GPS position, times | Telematics provider | ☐ to check | ☐ to check | ☐ define |
| Email and documents | Internal and customer communication | Staff, customers | Contact data, correspondence | Microsoft 365 | ☐ to check | EU (check tenant) | ☐ define |
| Bookkeeping and invoicing | Accounting, tax | Customers, suppliers | Billing data, bank details | lexoffice | ☐ to check | Germany | 8–10 years (tax law) |
| Customer mailings | Marketing to business customers | Customer contacts | Name, email, opt-in | Newsletter tool | ☐ missing — sign | ☐ to check | Until opt-out |
| Website | Company information, contact | Visitors | IP address, cookies | Hosting provider | ☐ to check | ☐ to check | ☐ define |
| Personnel files | Employment, licence checks | Staff, drivers | Contract, driver licence, health certificate (special category) | OneDrive / paper | — | ☐ to check | Per HR retention rules |
| AI-assisted drafting | Texts, translations | — (no personal data allowed) | — | ChatGPT | ☐ to check | USA (check transfer basis) | — |
One row per processing activity. Pre-filled cells come from the audit; fields marked ☐ still need to be checked or filled in with your DPO.
Responsible: Spreewald Logistik GmbH, managing director. DPO: ☐ to appoint.
Annex 4 — Backup restore test guide
Run once a month. Owner: freelancer IT support; office manager signs off. Time needed: about 1 hour.
Before the test
- Check that last night's backup finished without errors.
- Pick one test item: rotate between a single file, a full OneDrive folder and one dispatch software export.
Test steps
- Restore the item to a separate test folder — never over the original.
- Open the restored file and compare it with the original (date, size, content).
- Note how long the restore took.
- Delete the test copy.
Every 6 months: full test
Restore a complete system copy (e.g. dispatch data export) and check that the office could work from it within one working day.
Log
| Date | What was restored | Source backup | Result (OK / failed) | Restore time | Checked by |
|---|---|---|---|---|---|
Log every restore test. A failed result must be fixed and the test repeated; this log is your proof that backups work.
If a test fails: inform the managing director the same day and repeat after the fix.