7.2.5 Privacy impact assessment
The organization must assess whether a privacy impact assessment is needed and carry one out where appropriate whenever new processing of personal data or a change to existing processing is planned, determining the eleme
5
artefacts
0
held by a system
4
at each review
hard
to go live
Data governance / DLP tooling
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
- Documented trigger criteria for when an assessment is required, including the mandated cases · Data governance / DLP tooling
- Screening records showing the need was assessed even where no assessment followed · HR system / LMS
- Completed assessments with data types, storage locations, transfers and data flows · Data governance / DLP tooling
- Evidence assessment findings changed the design or were formally accepted · Data governance / DLP tooling
governing documentDocuments that govern the control
- Link from the change process into the screening step · HR system / LMS
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
- Assessment performed only for projects that reach a funding threshold, so small high risk changes escape
- Screening decisions not recorded, so the absence of an assessment cannot be justified
- Assessment completed after go live, when it can no longer influence anything
- Findings recorded with no owner, so mitigations are never implemented
- Data flows described in prose without identifying transfers out of jurisdiction
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 sheet7.2.4 Obtain and record consent · 7.2.6 Contracts with PII processors