6.11.3 Test data
Personal data must not be used for testing; false or synthetic data must be used instead, and where using personal data for testing is unavoidable the technical and organizational measures of the production environment m
4
artefacts
0
held by a system
3
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
- Where personal data is used, the authorisation, the equivalence of controls applied, and the risk assessment behind any shortfall · Data governance / DLP tooling
- Evidence of synthetic data generation capability · Document repository
- Periodic check that test environments hold no unauthorised personal data · Cloud console / configuration management
governing documentDocuments that govern the control
- Test data standard requiring synthetic or false data · 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
- Production data copied to test as the default because synthetic data generation was never built
- De-identification applied to obvious fields while free text and attachments retain identifying content
- Test environments protected below production while holding the same data
- No periodic sweep, so old production extracts persist in test long after the project ended
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 sheet6.11.2 Security in development and support processes · 6.12.1 Information security in supplier relationships