Art.7 Conditions for consent
Where processing rests on consent, be able to demonstrate that the data subject consented. Where the consent request forms part of a wider written declaration, present it in a manner clearly distinguishable from the othe
5
artefacts
0
held by a system
3
at each review
hard
to go live
Data governance / DLP tooling
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
- Consent records capturing who consented, when, to what wording, and through what mechanism · Data governance / DLP tooling
- The consent wording and interface as presented, versioned, so an old record can be tied to what was actually shown · Data governance / DLP tooling
- The withdrawal mechanism, with evidence it works and takes no more steps than giving consent did · Data governance / DLP tooling
governing documentDocuments that govern the control
- Evidence that consent requests bundled inside terms or a wider declaration are visually and textually separated · Policy repository / GRC workspace
- Per service, the analysis of which processing is genuinely necessary for the contract and which rests on consent · Vendor register / contract 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
- Consent logged as a boolean with no record of the wording shown, so the organisation cannot demonstrate what was agreed to
- Withdrawal routed through a support ticket or a postal address while giving consent was a single click
- Service access blocked on consent to analytics or marketing the service does not need
- Pre-ticked boxes, silence, or continued use of a site treated as consent
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.6 Lawfulness of processing · Art.8 Conditions applicable to child's consent