6.11.2 Security in development and support processes
System development and design policies must give guidance on the organization's processing needs based on its obligations to individuals and applicable law, covering privacy principles in the development lifecycle, priva
6
artefacts
0
held by a system
4
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
- Design artefacts showing privacy requirements derived from an impact assessment · Data governance / DLP tooling
- Evidence of privacy checkpoints at project milestones with outcomes · Data governance / DLP tooling
- Developer competence evidence for privacy knowledge · HR system / LMS
- Design evidence that systems facilitate later deletion and minimisation · Physical access / facilities
governing documentDocuments that govern the control
- Development policy carrying each of the required privacy by design elements · Policy repository / GRC workspace
- Outsourced development contracts carrying the same obligations · 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
- Privacy by design asserted as a principle with no checkpoint that can stop a release
- Systems designed with no deletion path, so retention obligations become manual and unreliable
- Default settings that maximise collection, with minimisation available only if a user finds it
- Impact assessment produced after design is frozen, so it changes nothing
- Outsourced development held to security terms while privacy obligations stop at the organization's boundary
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 sheet6.11.1 Security requirements of information systems · 6.11.3 Test data