8.11 Data masking
Requires data masking to be used in accordance with the topic specific policy on access control, other related topic specific policies and business requirements, taking applicable legislation into account. Supporting mat
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
- Technical evidence of the masking applied, including the technique and evidence it resists re-identification · Data governance / DLP tooling
- Records of exceptions where real data is used outside production, with approval and compensating controls · Data governance / DLP tooling
- Evidence of testing that masked data sets contain no residual identifiable values · Data governance / DLP tooling
governing documentDocuments that govern the control
- The rules on masking, pseudonymisation and anonymisation, tied to the access control policy and to applicable legislation · Policy repository / GRC workspace
- Identification of the environments and use cases where masking applies, such as development, testing, training, analytics and support · HR system / LMS
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
- Production data copied to non production with masking applied to obvious fields only, leaving free text and attachments identifiable
- Masking that is reversible or consistent enough to permit re-identification by combination
- Exception process absent, so teams take production copies informally and nobody knows
- Masking implemented once and never re-verified after new fields were added to the schema
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