DSP-12 Limitation of Purpose in Personal Data Processing
Confine personal data processing to the purposes declared to the data subject and permitted by applicable law, and be able to demonstrate that limit.
4
artefacts
0
held by a system
2
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
- Evaluation evidence such as a review of actual processing against declared purpose · Document repository
- Records of new purposes and how consent or legal basis was re-established · Data governance / DLP tooling
governing documentDocuments that govern the control
- The declared purposes per processing activity and the notice given to data subjects · Policy repository / GRC workspace
- Controls that prevent processing outside the declared purpose · Document repository
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 collected for one purpose reused for analytics without re-establishing a basis
- Declared purposes written so broadly they permit anything
- No review comparing actual processing to declared purpose
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-11 Personal Data Access, Reversal, Rectification and Deletion · DSP-13 Personal Data Sub-processing