6.9.1 Operational procedures and responsibilities
Operating procedures must be documented, change managed, capacity managed, and development, test and operational environments kept separate, read as covering the systems that process personal data.
3
artefacts
0
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
none for this control
periodic reviewEvidence produced at each review
- Change records covering those systems · Policy repository / GRC workspace
- Evidence of separation between development, test and operational environments · Cloud console / configuration management
governing documentDocuments that govern the control
- Documented operating procedures for personal data processing systems · 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
- Procedures maintained for infrastructure while application level data handling is tribal knowledge
- Environments separated logically but sharing the same data
- Emergency change route that bypasses the privacy consideration
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 sheet