Art.19 Notification obligation regarding rectification, erasure or restriction
Communicate every rectification, erasure or restriction of processing carried out under Articles 16, 17(1) and 18 to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves
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
- Notification records tied to individual rectification, erasure and restriction actions, with dates and recipients · Data governance / DLP tooling
- The impossible or disproportionate effort assessment for any recipient not notified · Data governance / DLP tooling
governing documentDocuments that govern the control
- A recipient register per dataset, current enough to answer who must be told when a record changes · Policy repository / GRC workspace
- The response given to a data subject who asked which recipients were informed · 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
- No recipient register exists, so the obligation cannot be performed and is silently skipped
- Notification treated as covered by the processor contract rather than as an act the controller must carry out and evidence
- Recipients told about erasures but not about rectifications or restrictions, which the Article treats identically
- A data subject's request to know the recipients answered with categories when the specific recipients are known
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.18 Right to restriction of processing · Art.20 Right to data portability