GRC-04 Policy Exception Process
Handle any deviation from an established policy through an approved exception process defined by the governance programme.
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
- Exception records with justification, compensating control, approver and expiry · Document repository
- Evidence expired exceptions are closed or renewed deliberately · Document repository
governing documentDocuments that govern the control
- The documented policy exception process · Policy repository / GRC workspace
- A register of open exceptions · 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
- Exceptions granted with no expiry, becoming permanent by default
- Compensating controls not stated, so the residual risk is unmanaged
- Deviations occurring with no exception raised at all
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 sheetGRC-03 Organizational Policy Reviews · GRC-05 Information Security Program