8.2.6 Records related to processing PII
The organization must determine and maintain the records needed to demonstrate compliance with its obligations under the applicable contract for processing carried out on behalf of a customer, recognising that some juris
4
artefacts
0
held by a system
3
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 processing held per customer, covering the categories of processing carried out · Document repository
- Record of transfers to third countries and international organizations · Document repository
- Named owner and evidence of maintenance through change · Document repository
governing documentDocuments that govern the control
- General description of the technical and organizational measures · 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
- Records held at organization level rather than per customer, which is what the obligation asks for
- Transfers by subcontractors omitted from the record
- Security measures described identically for every customer regardless of the service tier they bought
- Records rebuilt for audits rather than maintained, so they describe a past state
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 sheet8.2.5 Customer obligations · 8.3.1 Obligations to PII principals