7.5.4 Records of PII disclosure to third parties
The organization must record disclosures of personal data to third parties, including what data was disclosed, to whom and at what time, recording disclosures made in the course of normal operations and additional disclo
4
artefacts
2
held by a system
0
at each review
easy
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
- Disclosure log recording what data, to whom and when, for routine and exceptional disclosures alike · SIEM / log platform
- Retention and access controls over the disclosure log · SIEM / log platform
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Source of the disclosure and the authority relied on, recorded per entry · Document repository
- Coverage of investigation and audit disclosures, not commercial sharing only · Policy repository / GRC workspace
First move
Automate the pull from your SIEM / log platform. Retention and alert rules exported from the SIEM; review evidence is the closed-alert record with reviewer and time.
Common gaps auditors find
- Routine disclosures logged while law enforcement and audit disclosures are handled outside any record
- Authority for the disclosure not recorded, so the organization cannot later justify it
- Log recording that a disclosure occurred without identifying what data left
- Disclosures made by individual staff outside the logged route
- Log kept by the function that made the disclosure rather than centrally, so no complete picture exists
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