7.3.1 Determining and fulfilling obligations to PII principals
The organization must determine and document its legal, regulatory and business obligations to the individuals whose data it processes and provide the means to meet them, ensuring those means are accessible and timely, g
4
artefacts
1
held by a system
0
at each review
moderate
to go live
SIEM / log platform
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Contact point on the same channel used for collection, with monitoring evidence · SIEM / log platform
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Register of obligations owed to individuals, by jurisdiction and processing activity · Policy repository / GRC workspace
- Documented mechanism delivering each obligation, with the responsible owner · Document repository
- Published description for individuals of what is fulfilled and how · Document repository
First move
Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.
Common gaps auditors find
- Obligations listed by jurisdiction with no mechanism mapped against them
- Contact point offered by post or telephone when the data was collected online, which is a barrier not a channel
- Means provided but not resourced, so timeliness fails under any real volume
- Business obligations, meaning contractual promises made to customers, omitted from the register
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 sheet7.2.8 Records related to processing PII · 7.3.2 Determining information for PII principals