Art.31 Cooperation with the supervisory authority
The controller and the processor and, where applicable, their representatives must cooperate, on request, with the supervisory authority in the performance of its tasks. In practice that means responding to the authority
5
artefacts
1
held by a system
2
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- The log of authority contacts, complaints and requests, with the response given and its date against any deadline set · SIEM / log platform
periodic reviewEvidence produced at each review
- Evidence that requested information was assembled from source records rather than asserted, including the underlying records provided · Document repository
- Where a deadline was missed or an extension sought, the record of the request and the authority's response · Document repository
governing documentDocuments that govern the control
- A named owner and a documented route for handling correspondence from a supervisory authority, covering local languages and absence cover · Document repository
- Contractual and operational arrangements binding processors and representatives to cooperate through the controller · Document repository
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
- Authority correspondence arriving at a general or legal mailbox and sitting unactioned past the deadline, which is an infringement separate from the matter under inquiry
- Responses drafted to minimise disclosure, which converts a procedural request into a finding of non-cooperation and aggravates the eventual penalty
- No owner for the relationship, so each request is handled from scratch and successive responses take inconsistent positions
- Records of processing and impact assessments not held in a state where they can be produced on request, so cooperation fails on evidence rather than on intent
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.30 Records of processing activities · Art.32 Security of processing