7.2.3 Determine when and how consent is to be obtained
The organization must determine and document a process by which it can demonstrate whether, when and how consent to processing was obtained, clearly documenting when consent is needed and what obtaining it requires, corr
4
artefacts
0
held by a system
0
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
none for this control
governing documentDocuments that govern the control
- Documented consent process covering when consent is required and what valid consent demands · Policy repository / GRC workspace
- Mapping from each purpose to whether and how consent is obtained · Policy repository / GRC workspace
- Analysis of jurisdiction specific consent requirements and how the mechanism meets them · Policy repository / GRC workspace
- Provision for heightened requirements such as children or research collections · 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
- Consent bundled into terms of service acceptance, which several jurisdictions treat as no consent at all
- One consent mechanism for all purposes, so a person cannot agree to one and refuse another
- Age assurance absent where children's data is foreseeably collected
- The process described but never mapped to purposes, so nobody can say which purposes rest on consent
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 sheet7.2.2 Identify lawful basis · 7.2.4 Obtain and record consent