8.5.5 Legally binding PII disclosures
The organization must reject requests for disclosure of personal data that are not legally binding, must consult the corresponding customer before making any disclosure, and must accept contractually agreed disclosure re
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
- Documented rule that non binding requests are rejected, with the assessment step that decides bindingness · Document repository
- Evidence of customer consultation before disclosure · Document repository
governing documentDocuments that govern the control
- Register of requests with the outcome and the reasoning · Policy repository / GRC workspace
- Contract terms covering how consultation and authorisation work · 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
- Informal requests from authorities complied with voluntarily, which the control expressly prohibits
- Bindingness judged by operations staff with no legal input
- Customer consulted after disclosure rather than before
- Cross border requests accepted without checking whether the authority has jurisdiction over the organization
- No register, so a pattern of requests about one customer is invisible
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 sheet8.5.4 Notification of PII disclosure requests · 8.5.6 Disclosure of subcontractors used to process PII