7.4.4 PII minimization objectives
The organization must define and document data minimisation objectives and the mechanisms used to meet them, identifying how the specific data and the amount collected and processed is limited relative to the identified
5
artefacts
0
held by a system
2
at each review
hard
to go live
Document repository
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
- Assessment of the residual re-identification risk of the techniques chosen · Document repository
- Evidence the mechanisms operate on a timely basis rather than on request · Document repository
governing documentDocuments that govern the control
- Documented minimisation objectives, expressed measurably · Policy repository / GRC workspace
- Description of the mechanisms and techniques used, including technical configurations · Document repository
- Justification where processing requires data that is not de-identified · 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
- Minimisation objectives stated as principles with no measure, so achievement cannot be shown
- De-identification claimed on the basis of removing direct identifiers alone, leaving a readily re-identifiable dataset
- Technique chosen without assessing whether it withstands linkage against other holdings
- Objectives defined and the mechanisms never implemented, so nothing changes in practice
- Timeliness unaddressed, so identifiable data persists long after de-identification became possible
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 sheet7.4.3 Accuracy and quality · 7.4.5 PII de-identification and deletion at the end of processing