What evidence do auditors commonly ask for on IDM-07 Access to cloud customer data?

Notification template showing the cause, time, duration, type and scope fields; Log of provider staff reads and writes on customer content matched to notifications issued; Elapsed-time evidence between the access event and the customer being informed; Contractual record of customers who expressly waived this information duty.

What is the most common gap auditors find on IDM-07?

Engineer access during incident handling is treated as operational and never reported

BSI C5 (121-criteria catalogue) · C5: Identity and Access Management

`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 agreed period.

Source: BSI C5 (121-criteria catalogue), IDM-07. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open BSI C5 (121-criteria catalogue) in the compliance library.

The edition of the catalogue is not stamped here; check the edition your attestation is issued against.

artefacts

held by a system

at each review

easy

to go live

SIEM / log platform

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

Log of provider staff reads and writes on customer content matched to notifications issued · SIEM / log platform
Elapsed-time evidence between the access event and the customer being informed · Document repository

periodic reviewEvidence produced at each review

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

Automate the pull from your SIEM / log platform. Retention and alert rules exported from the SIEM; review evidence is the closed-alert record with reviewer and time.

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 sheet

IDM-06 Privileged access rights · IDM-08 Confidentiality of authentication information