CM-13 Data Action Mapping
Maps the actions taken on organizational data, including by suppliers and processors, so exposure is visible.
Source: NIST SP 800-161 Rev 1 (supply chain), CM-13. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open NIST SP 800-161 Rev 1 (supply chain) in the compliance library.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Review on change · Document repository
governing documentDocuments that govern the control
- Mapping of data actions to systems and parties · Document repository
- Identification of supplier processing actions · Vendor register / contract repository
First move
Common gaps auditors find
- supplier processing described only in commercial terms
- mapping never updated after integration changes
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.
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