Art.12 Transparent information, communication and modalities for rights
Provide the Article 13 and 14 information and every Article 15 to 22 and 34 communication in a concise, transparent, intelligible and easily accessible form, in clear and plain language, with particular care where the in
5
artefacts
0
held by a system
1
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
- Readability evidence for the privacy information, such as a plain language review or a reading age assessment · Data governance / DLP tooling
governing documentDocuments that govern the control
- The request register showing receipt date, response date, and any extension with its notification and stated reasons · Policy repository / GRC workspace
- The identity verification standard applied, with the reasoning that it is proportionate rather than routine · Policy repository / GRC workspace
- Every refusal or fee decision with the manifestly unfounded or excessive justification recorded against it · Document repository
- Refusal responses showing both the supervisory authority complaint route and the judicial remedy were given · 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
- The one month clock started when the request reached the privacy team rather than when it reached the organisation
- Extensions taken without notifying the data subject inside the first month, which is the condition attached to the extension
- Identity verification demanded as standard from every requester, adding friction Article 12(6) does not permit
- Refusals issued without the complaint and judicial remedy information, which is a breach separate from the refusal itself
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 sheetArt.11 Processing which does not require identification · Art.13 Information to be provided where personal data are collected