DSP-05 Data Flow Documentation
Document where data is processed, stored and transmitted, and refresh that mapping on a set schedule, yearly at the outside, and whenever something changes.
4
artefacts
0
held by a system
2
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
- Review records against the defined interval · Data governance / DLP tooling
- Evidence of update after a system or supplier change · Vendor register / contract repository
governing documentDocuments that govern the control
- Current data flow documentation showing processing, storage and transmission points · Policy repository / GRC workspace
- Coverage across the systems handling sensitive and personal data · 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
- Data flow diagrams drawn for an audit and not maintained afterwards
- Third party and sub-processor flows omitted
- No change trigger, so the map silently diverges from the architecture
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 sheetDSP-04 Data Classification · DSP-06 Data Ownership and Stewardship