NIST SP 800-161 Rev 1 (supply chain) · C-SCRM Family: Personally Identifiable Information Processing and Transparency
PT-1 Policy and Procedures
Extends personally identifiable information processing and transparency policy to processing performed across the supply chain.
3
artefacts
0
held by a system
1
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
- Review records · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Policy covering third-party processing and transparency · Vendor register / contract repository
- Procedures for provider processing arrangements · 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
- policy assumes the organization is the only processor
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 sheetPS-7 External Personnel Security · RA-1 Policy and Procedures