Start with stable identification fields: record ID and version, entity, controller and operator roles, product or process, purpose, people and data, source provision, owner, reviewer, decision date, and evidence location. Add the event-specific fields only after the applicable rule is known.
Distinguish a fact from a conclusion and a planned action from completed evidence. For example, a security-policy link does not prove that access was revoked, and an unsigned contract draft does not prove that an international-transfer mechanism is in force.
A rights template should not assign the 15-day Article 19 period to every Article 18 right. It should distinguish immediate simplified confirmation or access, a complete confirmation or access statement within 15 days, and other rights whose timing depends on the applicable ANPD or sector rule and the facts.