6.15.2 Information security reviews
Independent review of information security applies, and where the organization is a processor and individual customer audits are impractical or would increase risk, it should make available to customers, before and durin
5
artefacts
1
held by a system
2
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
- Evidence of monitoring that only permitted processing occurs · SIEM / log platform
periodic reviewEvidence produced at each review
- Independent audit reports or certifications made available to customers before and during contract · Vendor register / contract repository
- Assessment that the report's scope covers anticipated user needs · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Technical compliance review procedures covering tools and components that process personal data · Policy repository / GRC workspace
- Motivated intruder or equivalent testing results where de-identification is relied on · Document repository
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your SIEM / log platform on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Certification offered whose scope excludes the service the customer actually buys
- De-identification relied on as a legal position with no test that it resists re-identification
- Technical review covering infrastructure hardening while the processing logic goes unexamined
- Reports made available at sale and never refreshed during a multi year contract
- Monitoring that detects unauthorised access but not authorised access used for an unpermitted purpose
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 sheet6.15.1 Compliance with legal and contractual requirements · 7.2.1 Identify and document purpose