7.2.1 Identify and document purpose
The organization must identify and document the specific purposes for which personal data will be processed, documented clearly and in enough detail to be usable in the information given to individuals, in obtaining cons
3
artefacts
0
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
none for this control
periodic reviewEvidence produced at each review
- Review record showing purposes are updated when processing changes · Document repository
governing documentDocuments that govern the control
- Purpose register at the level of the processing activity, not the system · Policy repository / GRC workspace
- Evidence the documented purpose text is the text actually used in notices and consent · 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
- Purposes written as business objectives such as improving service, too vague to test any later processing against
- Purpose documented internally in different words from the notice given to individuals, so the two can drift
- One purpose recorded for a system that in fact serves several
- Purpose register produced for a certification and never maintained
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 sheet6.15.2 Information security reviews · 7.2.2 Identify lawful basis