7.5.3 Records of transfer of PII
The organization must record transfers of personal data to and from third parties and ensure cooperation with those parties to support future requests arising from its obligations to individuals, which includes transfers
4
artefacts
1
held by a system
1
at each review
moderate
to go live
SIEM / log platform
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Transfer log covering transfers both to and from third parties · SIEM / log platform
periodic reviewEvidence produced at each review
- Evidence of minimisation applied to the content of those records · Document repository
governing documentDocuments that govern the control
- Documented cooperation arrangements supporting later individual requests · Document repository
- Retention policy for the transfer records themselves · Policy repository / GRC workspace
First move
Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.
Common gaps auditors find
- Only outbound transfers recorded, so data flowing back after a third party correction is untracked
- Transfer records retained indefinitely, becoming a personal data holding of their own
- Records containing the transferred data rather than a reference to it, which is the opposite of minimisation
- Cooperation assumed rather than agreed, so a later erasure request cannot be propagated
- Logs kept per system, with no way to answer what was transferred about one individual
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 sheet7.5.2 Countries and international organizations to which PII can be transferred · 7.5.4 Records of PII disclosure to third parties