6.5.3 Media handling
Removable media use for personal data must be documented, encrypted wherever feasible with compensating controls where it is not, disposed of by secure procedures that leave the data inaccessible, and any physical transf
5
artefacts
1
held by a system
1
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
- Physical media transfer log with type, authorised parties, date, time and count · Physical access / facilities
periodic reviewEvidence produced at each review
- Authorisation records for media leaving the premises · Physical access / facilities
governing documentDocuments that govern the control
- Register of removable media used for personal data · Policy repository / GRC workspace
- Encryption standard and evidence of application, with compensating controls documented where encryption was not feasible · Policy repository / GRC workspace
- Secure disposal procedures and disposal records · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your Physical access / facilities 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
- Removable media use prohibited by policy and practised anyway, so nothing is logged
- Unencrypted media used without recording why or what compensating control replaced encryption
- Disposal evidenced by a supplier certificate that does not identify the media disposed of
- Transfer logs recording despatch but not receipt, so loss in transit is undetectable
- Authorisation to remove media delegated to whoever is on shift
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 sheet6.5.2 Information classification · 6.6.1 Business requirements of access control