7.2.8 Records related to processing PII
The organization must determine and securely maintain the records that support its obligations for processing, typically an inventory of processing activities covering the type of processing, its purposes, the categories
5
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
- Linkage from inventory entries to the corresponding impact assessments · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Processing inventory carrying each required element · Policy repository / GRC workspace
- Named owner accountable for its accuracy and completeness · Document repository
- Evidence the inventory is maintained through change, not rebuilt for audits · Policy repository / GRC workspace
- Secure storage and access control over the inventory itself · 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
- Inventory owned by nobody, so it decays between audits
- Recipient categories recorded without third country recipients, hiding the transfers
- Inventory built from a system list, so processing done in spreadsheets and by suppliers is missing
- Security measures described identically for every activity, which tells a reader nothing
- Inventory itself unprotected despite mapping exactly where the organization's personal data lives
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 sheet7.2.7 Joint PII controller · 7.3.1 Determining and fulfilling obligations to PII principals