DSP-14 Disclosure of Data Sub-processors
Tell the data owner which sub-processors will access their personal or sensitive data before that processing starts.
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
- Notification records sent to data owners · Document repository
- Evidence of notification when a sub-processor changed · Document repository
governing documentDocuments that govern the control
- The notification procedure and its timing relative to processing · Policy repository / GRC workspace
- The detail disclosed, such as sub-processor identity, location and 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
- Notification given after processing has already begun
- Sub-processor list published on a web page with no active notification
- Changes to the sub-processor set not notified
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-13 Personal Data Sub-processing · DSP-15 Limitation of Production Data Use