7.2.4 Obtain and record consent
The organization must obtain and record consent according to its documented process, recording it so that on request it can produce the details of the consent given, including when it was given, the identity of the indiv
4
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
- Evidence consent was freely given, meaning a real alternative existed · Data governance / DLP tooling
governing documentDocuments that govern the control
- Consent records holding timestamp, individual identity and the exact statement consented to · Policy repository / GRC workspace
- The version of the information presented before consent, retained alongside · Policy repository / GRC workspace
- Ability to produce a single individual's consent history on request · 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 recorded as a boolean flag with no record of what wording the person actually saw
- Consent statement changed without versioning, so old consents cannot be interpreted
- Consent obtained as a condition of a service that does not need it, which is not freely given
- Consent stored in a marketing platform outside the retention and access regime
- Pre-ticked or inferred consent recorded as explicit
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 sheet7.2.3 Determine when and how consent is to be obtained · 7.2.5 Privacy impact assessment