IDM-07 Access to cloud customer data
Notify the affected cloud customer of every provider access to their unencrypted data, stating cause, time, duration, type and scope in enough detail for the customer to assess risk, within 72 hours or the contractually
4
artefacts
1
held by a system
2
at each review
moderate
to go live
SIEM / log platform
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Log of provider staff reads and writes on customer content matched to notifications issued · SIEM / log platform
periodic reviewEvidence produced at each review
- Elapsed-time evidence between the access event and the customer being informed · Document repository
- Contractual record of customers who expressly waived this information duty · Document repository
governing documentDocuments that govern the control
- Notification template showing the cause, time, duration, type and scope fields · Policy repository / GRC workspace
First move
Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.
Common gaps auditors find
- Engineer access during incident handling is treated as operational and never reported
- Message confirms that access occurred but omits scope, leaving the customer unable to assess risk
- Exemption claimed on the basis of encryption when encryption had been disabled for that session
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetIDM-06 Privileged access rights · IDM-08 Confidentiality of authentication information