3.2 Establish and Maintain a Data Inventory
Build and keep a data inventory driven by the data management process, covering sensitive data as a minimum. Review it at least yearly, starting with the sensitive data. Implementation Groups: IG1, IG2 and IG3 (part of the IG1 essential cyber hygiene baseline, so every enterprise applies it). Asset type: Data. Security function: Identify.
Source: CIS Controls v8.1, 3.2. 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 CIS Controls v8.1 in the compliance library.
Each safeguard shows its Implementation Groups. IG1 is the essential baseline for every enterprise, IG2 adds to it, IG3 is all 153. Version 8.1 adds the Govern security function and asks for more processes to be documented; numbering is unchanged from v8.
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
none for this control
periodic reviewEvidence produced at each review
- Annual review record prioritising sensitive data · Document repository
governing documentDocuments that govern the control
- Data inventory listing sensitive data sets, location, owner and classification · Policy repository / GRC workspace
- Link between inventory fields and the data management process · Policy repository / GRC workspace
First move
Common gaps auditors find
- Inventory covers structured databases only, missing file shares and SaaS
- Owners not assigned
- Review overdue by more than a year
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 sheet3.1 Establish and Maintain a Data Management Process · 3.3 Configure Data Access Control Lists