7.3.6 Access, correction and/or erasure
The organization must implement policies, procedures or mechanisms enabling individuals to obtain access to, correct and erase their personal data without undue delay, must define and meet a response time, must dissemina
5
artefacts
1
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
- Request log with dates received and completed, and performance against the response time · SIEM / log platform
periodic reviewEvidence produced at each review
- Evidence corrections and erasures propagated to all systems and to third parties · Vendor register / contract repository
governing documentDocuments that govern the control
- Documented procedures for access, correction and erasure with defined response times · Policy repository / GRC workspace
- Dispute procedure including notification of changes made and reasons for refusal · Policy repository / GRC workspace
- Register of jurisdictional restrictions on these rights · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your SIEM / log platform on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Erasure performed in the primary system while backups, archives, logs and analytics copies retain the data
- Access requests answered from one system because no map exists of where else the person's data sits
- Corrections applied without propagation, so systems disagree about the same person
- Refusals given without reasons, which the standard requires be explained
- Response times defined in policy and not measured in practice
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 sheet7.3.5 Providing mechanism to object to PII processing · 7.3.7 PII controllers' obligations to inform third parties