7.2.2 Identify lawful basis
The organization must determine, document and comply with the lawful basis for each processing activity against its identified purposes, documenting the basis per activity, including any special categories of personal da
4
artefacts
0
held by a system
0
at each review
hard
to go live
Document repository
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
none for this control
governing documentDocuments that govern the control
- Lawful basis recorded against each processing activity, with the reasoning · Document repository
- Where legitimate interests is relied on, the balancing against obligations to individuals · Document repository
- Classification scheme entries covering special categories, mapped to the jurisdictions that define them · Policy repository / GRC workspace
- Change control showing the basis was re-evaluated when a purpose changed · Document repository
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
- Consent recorded as the basis for processing that is in fact contractual, creating a withdrawal right the organization cannot honour
- Legitimate interests asserted with no balancing recorded
- Special categories identified under one jurisdiction's definition while operating under several
- Purpose extended by a new feature with the legal basis never re-examined
- Basis held at organization level rather than per activity
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 sheet7.2.1 Identify and document purpose · 7.2.3 Determine when and how consent is to be obtained