6.9.3 Backup
The organization must hold a policy covering backup, recovery and restoration of personal data and any further contractual or legal requirements for erasing personal data held in backups, must tell the customer the limit
5
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
- Evidence of integrity assurance following restoration, including how inaccuracy is identified and resolved · Backup / DR tooling
- Evidence of compliance with jurisdiction specific backup and recovery requirements · Backup / DR tooling
governing documentDocuments that govern the control
- Backup policy addressing personal data specifically, including erasure obligations within backups · Policy repository / GRC workspace
- Statement to customers of backup service limits and capabilities · Policy repository / GRC workspace
- Restoration procedure and a restoration log naming the responsible person and describing the data restored · 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
- Erasure performed in production while backups retain the same personal data indefinitely, defeating deletion obligations
- Restoration performed with no log, so nobody can say whose data was reinstated
- Restored data reintroducing records the individual had already had erased
- Customer left to assume backup coverage that the service does not provide
- Backup testing evidenced as a successful job rather than a successful restoration
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 sheet6.9.2 Protection from malware · 6.9.4 Logging and monitoring