Art.15 Right of access by the data subject
On request, confirm whether personal data concerning the data subject is being processed and, where it is, provide access to that data together with the purposes, the categories of personal data, the recipients or catego
5
artefacts
1
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
- The redaction position and the applied redaction log where third party data was withheld, with a reason recorded per redaction · SIEM / log platform
periodic reviewEvidence produced at each review
- Timeliness records for the last twelve months of requests measured against the one month limit · Data governance / DLP tooling
governing documentDocuments that govern the control
- The search methodology showing every system, archive and unstructured store searched, and how completeness was assured · Policy repository / GRC workspace
- A worked response covering all the supplementary information items, not only the copy of the data · Policy repository / GRC workspace
- The source information provided where the data was not collected from the data subject · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your SIEM / log platform on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Structured database records returned while email, chat, ticketing and free text notes naming the person are never searched
- The copy of the data provided with none of the supplementary information the Article requires alongside it
- Blanket redaction of anything mentioning another person, rather than a balance carried out item by item
- A fee charged for the first copy, or the request refused for effort where it is not manifestly unfounded or excessive
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.14 Information where personal data have not been obtained from the data subject · Art.16 Right to rectification