7.4.3 Accuracy and quality
The organization must ensure and document that personal data is as accurate, complete and up to date as the purposes for which it is processed require, throughout the data lifecycle, implementing policies, procedures or
4
artefacts
0
held by a system
0
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
none for this control
governing documentDocuments that govern the control
- Documented accuracy standard, expressed relative to the purpose rather than absolutely · Policy repository / GRC workspace
- Validation and quality mechanisms at capture and through the lifecycle · Document repository
- Procedure for responding to discovered inaccuracy, including downstream correction · Policy repository / GRC workspace
- Quality measurement results · 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
- Accuracy treated as a data quality initiative for reporting rather than an obligation owed to the individual
- Validation applied at capture with no mechanism to detect data going stale
- Inaccuracy corrected where a person complains and nowhere else
- Accuracy requirement identical across purposes, when a marketing list and a credit decision demand different standards
- Corrections not propagated to systems fed from the corrected source
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 sheet