8.2.2 Organization’s purposes
The organization must ensure that personal data processed on behalf of a customer is processed only for the purposes expressed in that customer's documented instructions, with the contract stating the objective and time
5
artefacts
0
held by a system
1
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
- A means for the customer to verify purpose compliance, and evidence it has been offered or used · Document repository
governing documentDocuments that govern the control
- Documented customer instructions per engagement, with a change route · Document repository
- Contract terms stating the objective and time frame of the service · Vendor register / contract repository
- Controls preventing processing outside the instructions, including by subcontractors · Document repository
- Distinction recorded between method decisions taken technically and purpose decisions, which are the customer's · 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
- Customer data used to improve the organization's own products or models, which is a purpose the customer never instructed
- Instructions held as a contract clause with no operational mechanism keeping processing inside it
- Subcontractors processing under the organization's general practice rather than the customer's instructions
- No verification means offered, so the customer must take the position on trust
- Method decisions drifting into purpose decisions with no record of who decided what
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 sheet8.2.1 Customer agreement · 8.2.3 Marketing and advertising use