6.4.2 During employment
During employment, management responsibilities, awareness and training, and disciplinary procedures apply, and awareness measures including incident reporting must ensure staff understand the consequences of breaching pr
4
artefacts
0
held by a system
1
at each review
hard
to go live
HR system / LMS
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
- Periodic training records for personnel with access to personal data · HR system / LMS
governing documentDocuments that govern the control
- Awareness and training content covering consequences to the organization, to the staff member and to the individual · HR system / LMS
- Incident reporting instructions inside the awareness material · HR system / LMS
- Disciplinary procedure referencing privacy breaches · HR system / LMS
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
- Consequences framed as regulatory fines only, so staff never see the harm to the person behind the record
- Training delivered at induction and never repeated for staff who handle personal data daily
- Incident reporting route taught for security incidents but not for privacy breaches
- Disciplinary linkage asserted in policy but absent from the actual 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 sheet6.4.1 Prior to employment · 6.4.3 Termination and change of employment