8.4.3 PII transmission controls
The organization must subject personal data transmitted over a data transmission network to controls designed to ensure it reaches its intended destination, typically by ensuring only authorized individuals have access t
4
artefacts
0
held by a system
0
at each review
hard
to go live
Vendor register / contract 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
none for this control
governing documentDocuments that govern the control
- Documented transmission controls covering authorisation, protection and recipient verification · Document repository
- Audit data retained for transmissions of customer personal data · Policy repository / GRC workspace
- Contract terms on transmission requirements where they exist · Vendor register / contract repository
- Evidence of consulting the customer before transmission where the contract is silent · 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
- Transmission performed on the organization's own default standard where the customer had a higher requirement it was never asked about
- Encryption applied with no verification that the recipient was the intended one
- Audit data not retained, so a misdirected transmission cannot be traced
- Ad hoc transfers to customer nominated endpoints arranged over email with no authorisation step
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 sheet8.4.2 Return, transfer or disposal of PII · 8.5.1 Basis for PII transfer between jurisdictions