PM-25 Minimization of Personally Identifiable Information Used in Testing, Training, and Research
Prevents real personal data being handed to suppliers and developers for testing, training or research.
3
artefacts
0
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
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
- Technical controls or masking evidence · Data governance / DLP tooling
- Records of approved exceptions · Document repository
governing documentDocuments that govern the control
- Policy prohibiting production data in test environments · Policy repository / GRC workspace
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
- production data copied to supplier test environments as routine
- masking applied inconsistently
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 sheet