5.14 Information transfer
Requires transfer rules, procedures or agreements to be in place for every type of transfer facility, covering transfers within the organisation and between the organisation and outside parties.
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
- Technical evidence of protection in transit, such as enforced transport encryption, secure file transfer configuration and managed file transfer logs · SIEM / log platform
periodic reviewEvidence produced at each review
- Records of transfers of classified information, showing authorisation and receipt · Document repository
governing documentDocuments that govern the control
- Transfer rules covering each transfer type in use, being electronic, physical and verbal · Policy repository / GRC workspace
- Transfer agreements with external parties, setting out protection, liability and traceability requirements · Vendor register / contract repository
- Procedures for physical transfer, including courier selection, packaging and receipt confirmation · 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
- Rules cover email while file sharing services, application programming interfaces and system to system feeds are undocumented
- Agreements in place with major partners only, with ad hoc transfers to smaller parties uncovered
- Encryption in transit assumed from the platform and never verified in configuration
- Verbal transfer, including discussion of confidential matters in public or on calls, not addressed at all
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