6.10.2 Information transfer
Information transfer policies and procedures must include procedures ensuring that the rules governing the processing of personal data are enforced throughout and outside the system where applicable, and individuals oper
4
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
- Signed confidentiality obligations for everyone with access to personal data, stating the duration · Data governance / DLP tooling
governing documentDocuments that govern the control
- Transfer policies and procedures showing how processing rules follow the data outside the system · Policy repository / GRC workspace
- Coverage of contractors and agents, not employees only · HR system / LMS
- Transfer agreements and messaging controls · 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
- Rules enforced inside the application and lost the moment data is exported to a spreadsheet
- Confidentiality agreements with no stated duration, so the obligation is arguably spent at exit
- Agents and contractors relied on through the supplier's own terms, never verified
- Electronic messaging used to move personal data outside any transfer procedure
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 sheet6.10.1 Network security management · 6.11.1 Security requirements of information systems