EvidenceSheet
CIS Controls v8.1 · CIS Control 3: Data Protection

3.8 Document Data Flows

Document how data moves, including flows to and from service providers, basing the documentation on the data management process. Review it yearly or after significant change. Implementation Groups: IG2 and IG3 (not in the IG1 baseline; applies from IG2 upward). Asset type: Data. Security function: Identify.

Source: CIS Controls v8.1, 3.8. 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.

Scope: Implementation Groups: IG2, IG3. Security function: Identify; asset type: Data.

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.

3
artefacts
0
held by a system
1
at each review
hard
to go live
Vendor register / contract repository
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

none for this control

periodic reviewEvidence produced at each review

  • Annual review sign-off · Document repository

governing documentDocuments that govern the control

  • Data flow diagrams for sensitive data including third-party transfers · Vendor register / contract repository
  • Flow register listing source, destination, transfer method and owner · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

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.

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3.7 Establish and Maintain a Data Classification Scheme · 3.9 Encrypt Data on Removable Media