7.5.1 Identify basis for PII transfer between jurisdictions
The organization must identify and document the basis on which personal data is transferred between jurisdictions, documenting compliance with the legislation and regulation that applies depending on the jurisdiction or
4
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 destination jurisdiction requirements · Document repository
- Evidence of supervisory authority review where the jurisdiction requires it · Document repository
governing documentDocuments that govern the control
- Transfer register naming origin, destination and the documented basis for each transfer · Policy repository / GRC workspace
- The transfer instruments themselves, such as contractual clauses or binding rules · 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
- Transfers identified only where data physically moves, missing remote access from another jurisdiction, which is itself a transfer
- One transfer basis assumed adequate for every destination
- Instruments executed and never revisited after the legal landscape changed
- Supervisory review requirements unidentified, leaving the instrument unenforceable
- Onward transfers by recipients not covered by the basis
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 sheet7.4.9 PII transmission controls · 7.5.2 Countries and international organizations to which PII can be transferred