What evidence do auditors commonly ask for on Art.24 Responsibility of the controller?

The data protection policy set, each with an approval authority, an effective date and a review cycle; The risk assessment that drove the choice of measures, referencing nature, scope, context, purposes and risk to individuals; Review records showing the measures were reassessed and updated after material changes to the processing; The assignment of data protection responsibilities across the organisation, and evidence the assignees act on them; Assurance output such as internal audit, control testing or DPO reporting that demonstrates rather than asserts compliance.

What is the most common gap auditors find on Art.24?

A policy suite adopted once and never reviewed, so it describes processing the organisation no longer carries out

GDPR · Chapter IV - Controller and Processor

`Art.24` Responsibility of the controller

Implement appropriate technical and organisational measures to ensure, and to be able to demonstrate, that processing is performed in accordance with the Regulation, taking into account the nature, scope, context and purposes of processing and the risks of varying likelihood and severity for the rights and freedoms of natural persons. Review and update those measures where necessary. Where proportionate in relation to the processing activities, the measures must include implementing appropriate data protection policies. Adherence to an approved code of conduct or an approved certification mechanism may be used as one element by which to demonstrate compliance, not as a substitute for it.

Source: GDPR, Art.24. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open GDPR in the compliance library.

Many articles apply only where their condition is met (a data protection officer under Article 37, an impact assessment under Article 35, a representative under Article 27); the condition is in each statement.

artefacts

held by a system

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. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

The risk assessment that drove the choice of measures, referencing nature, scope, context, purposes and risk to individuals · Policy repository / GRC workspace
Review records showing the measures were reassessed and updated after material changes to the processing · Document repository

governing documentDocuments that govern the control

The data protection policy set, each with an approval authority, an effective date and a review cycle · Policy repository / GRC workspace
The assignment of data protection responsibilities across the organisation, and evidence the assignees act on them · Policy repository / GRC workspace
Assurance output such as internal audit, control testing or DPO reporting that demonstrates rather than asserts compliance · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

A policy suite adopted once and never reviewed, so it describes processing the organisation no longer carries out
Measures selected from a generic checklist with no link to the risk this organisation's own processing presents
Accountability documentation that records what should happen with no evidence that it does
Certification or code adherence presented as the whole of compliance rather than as one element of it

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 sheet

Art.22 Automated individual decision-making, including profiling · Art.25 Data protection by design and by default