DSP-10 Sensitive Data Transfer
Protect personal and sensitive data whenever it is transferred, and confine the processing to purposes the relevant laws and regulations permit.
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
- Records of transfers including cross-border ones · Document repository
- Evaluation evidence that the measures work as intended · Document repository
governing documentDocuments that govern the control
- Technical protections applied to transfers, such as encryption in transit and endpoint authentication · Policy repository / GRC workspace
- The legal basis and permitted scope for each category of transfer · 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
- Transfer protections applied to external transfers while internal ones are unprotected
- Cross-border transfer legal basis not recorded
- Scope permitted by law not translated into any technical restriction
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-09 Data Protection Impact Assessment · DSP-11 Personal Data Access, Reversal, Rectification and Deletion