DSP-06 Data Ownership and Stewardship
Record who owns and who stewards each set of personal and sensitive data, and review those assignments at least annually.
4
artefacts
0
held by a system
3
at each review
hard
to go live
Document repository
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
- Annual review record of the assignments · Document repository
- Evidence owners exercise their duty, such as approving access · Document repository
- Handover records when an owner changes · Document repository
governing documentDocuments that govern the control
- The ownership and stewardship register naming individuals or roles · 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
- Ownership assigned to a department rather than an accountable person
- Owners who have left still recorded
- Owners unaware they hold the role
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-05 Data Flow Documentation · DSP-07 Data Protection by Design and Default