8.2.4 Infringing instruction
The organization must inform the customer if, in its opinion, a processing instruction infringes applicable legislation or regulation, recognising that its ability to judge that depends on the technological context, on t
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
- Records of instructions challenged and the outcome · Document repository
- Competence evidence for whoever judges whether an instruction infringes · HR system / LMS
governing documentDocuments that govern the control
- Documented route for raising an instruction concern, with the decision authority named · Document repository
- Contract terms preserving the ability to raise the concern · Vendor register / contract 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
- No route exists, so a questionable instruction is executed because refusing it has no defined path
- Route exists but sits with account management, whose incentive is to keep the customer
- Concerns raised verbally with no record, so a pattern of them is invisible
- Contract silent, leaving the organization exposed if it declines an instruction
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 sheet8.2.3 Marketing and advertising use · 8.2.5 Customer obligations