5.3.2 Policy
The policy requirements of ISO/IEC 27001 apply to the PIMS, meaning the policy set must commit the organization on privacy as well as on information security under the extended interpretation.
3
artefacts
0
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
none for this control
periodic reviewEvidence produced at each review
- Communication and availability records · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Policy set, whether a single extended policy or a separate privacy policy, approved and current · Policy repository / GRC workspace
- Traceability from policy commitments to privacy objectives · Policy repository / GRC workspace
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
- Security policy left untouched and a privacy notice offered in its place, which is a customer facing document rather than a policy
- Two policies that contradict each other on retention or disclosure
- Policy never reissued after the role determination changed
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 sheet5.3.1 Leadership and commitment · 5.3.3 Organizational roles, responsibilities and authorities