6.3.1 Internal organization
The organization must designate a contact point for the customer on matters of processing and, where it is a controller, a contact point for the individuals whose information it processes, and must appoint one or more pe
5
artefacts
0
held by a system
4
at each review
hard
to go live
Document repository
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
- Appointment record for the accountable privacy person or team, with the reporting line stated · Data governance / DLP tooling
- Terms of reference covering independence, involvement, expertise and the advisory role on impact assessments · Identity provider / directory
- Evidence the appointee was actually consulted on processing decisions and impact assessments · Document repository
- Evidence of the appointee acting as the supervisory authority contact · Document repository
governing documentDocuments that govern the control
- Published contact points for customers and for individuals · Document 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
- Appointment made in name only, with the person never consulted before a processing decision
- Independence compromised by reporting into the business function that owns the processing
- Expertise assumed rather than evidenced, most often where the role is added to a security manager's duties
- Contact point for individuals published on a channel different from the one used to collect their data
- Involvement limited to incidents, so design stage advice never happens
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 sheet6.2.1 Management direction for information security · 6.3.2 Mobile devices and teleworking