DSP-19 Data Location
Record the physical locations where data is held, processed and backed up, and be able to produce that record.
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
- The data location record covering processing, storage and backup sites · Backup / DR tooling
- Evidence it is available to customers or regulators who may ask · Document repository
governing documentDocuments that govern the control
- The method that keeps it current as infrastructure changes · Policy repository / GRC workspace
- Coverage of sub-processor locations · 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
- Locations recorded for primary storage with backup and replica locations omitted
- Record based on contracted regions rather than actual deployment
- Sub-processor locations unknown
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-18 Disclosure Notification · GRC-01 Governance Program Policy and Procedures