CCR §7060 Consumer Identity Verification
Businesses must establish, document, and comply with reasonable methods to verify the consumer is the person about whom the PI was collected. Verification must avoid collecting more PI than necessary, match data to exist
4
artefacts
0
held by a system
0
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Documented verification standards (2-3 data points for less sensitive, 3+ plus signed declaration for sensitive) · Policy repository / GRC workspace
- Verification failure handling · Document repository
- Data minimisation in verification · Document repository
- Audit of verification outcomes · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- Verification too lax (single data point)
- Verification too restrictive (creating account required)
- No documented standard
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 sheetCCR §7050 Service Provider and Contractor Obligations · CCR §7100-7102 Recordkeeping Requirements