I have concluded that since it does not say so, Art 28 does not 'require' an unlimited right of audit. However any limitation must not put controller in breach of its own obligations, in particular principle 6. As certification is only an element it would not remove the need for an audit but may help determine what is reasonable.
In my example I am happy the proposed limitation is not reasonable. Only allowing an audit after there is evidence of non-compliance is the antithesis of due diligence.
In my case it would also be contrary to the recommended terms for government procurement in Action Note PPN 02/18 - which have a very simple "The Processor shall allow for audits of its Data Processing activity by the Controller or the Controller’s designated auditor" - i.e. no formal limitation but subject to any general rule of reasonableness in contractual relationships or specific rules in the main contract
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