7.3.2 Determining information for PII principals
The organization must determine and document what information is to be provided to individuals about the processing of their data and when it is to be provided, working out the legal, regulatory and business requirements
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
- Legal review record supporting the content decisions · Document repository
governing documentDocuments that govern the control
- Documented determination of notice content and timing per processing activity · Policy repository / GRC workspace
- Traceability from each required content element to where it appears in the notice · Policy repository / GRC workspace
- Trigger and evidence for updating notices when purposes change · Document repository
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
- Notice content copied from a template, so elements that do not apply are present and elements that do are missing
- Source of indirectly collected data omitted, which is the element most often absent
- Retention period expressed as as long as necessary, which conveys nothing
- Timing never determined, so information is given at account creation and never again
- Automated decision making not disclosed because the business does not think of its scoring as automated
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 sheet7.3.1 Determining and fulfilling obligations to PII principals · 7.3.3 Providing information to PII principals