7.3.4 Providing mechanism to modify or withdraw consent
The organization must provide a mechanism for individuals to modify or withdraw consent, inform them of their rights to withdraw at any time, use a withdrawal mechanism consistent with the one used to obtain consent, tre
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
- Evidence of propagation to internal systems and to third parties who received the data · Vendor register / contract repository
governing documentDocuments that govern the control
- Withdrawal mechanism on the same channel as consent collection · Policy repository / GRC workspace
- Withdrawal records held to the same standard as consent records · Policy repository / GRC workspace
- Defined response time and performance against it · Policy repository / GRC workspace
- Rules preventing further use of results derived from withdrawn consent · Policy repository / GRC workspace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
- Withdrawal accepted centrally and never propagated, so downstream systems keep processing
- Withdrawal harder than consent, for example consent by one click and withdrawal by written request
- Derived artefacts such as profiles and models retained and still used after withdrawal
- Third parties who received the data never told
- No response time defined, so withdrawal is honoured whenever someone gets to it
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 sheet7.3.3 Providing information to PII principals · 7.3.5 Providing mechanism to object to PII processing