IPY-04 Data Portability Contractual Obligations
Write into customer agreements what access to data the customer keeps when the contract ends, covering data format, retention period, scope of data retained and the deletion policy.
4
artefacts
0
held by a system
0
at each review
hard
to go live
Vendor register / contract 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
none for this control
governing documentDocuments that govern the control
- Agreement clauses covering all four required elements · Vendor register / contract repository
- Evidence the operational process can deliver what the clause promises · Document repository
- Records of data returned or deleted at recent contract terminations · Vendor register / contract repository
- The data format actually offered and its usability · 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
- Clause promises a format the platform cannot actually produce
- Retention period stated in the contract and not enforced in the platform
- Deletion policy referenced but not written down anywhere
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 sheetIPY-03 Secure Interoperability and Portability Management · IVS-01 Infrastructure and Virtualization Security Policy and Procedures