PM-21 Accounting of Disclosures
Accounts for disclosures made to and through supply chain parties.
3
artefacts
0
held by a system
1
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
- Disclosure records including transfers to providers · Document repository
governing documentDocuments that govern the control
- Retention of the accounting · Policy repository / GRC workspace
- Process for responding to requests · 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
- transfers to processors not treated as disclosures
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 sheetPM-20 Dissemination of Privacy Program Information · PM-22 Personally Identifiable Information Quality Management