CM-13 Data Action Mapping. Develop and document a map of system data actions
Data Action Mapping. Develop and document a map of system data actions.
5
artefacts
0
held by a system
3
at each review
hard
to go live
Cloud console / configuration management
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
- Evidence the map traces data actions across components and to external recipients, not only within one application · Cloud console / configuration management
- Review and update record showing the map was refreshed when a data action changed · Cloud console / configuration management
- Link from the map to the privacy risk assessment that consumed it · Cloud console / configuration management
governing documentDocuments that govern the control
- A documented map of system data actions covering collection, use, retention, disclosure and disposal · Policy repository / GRC workspace
- Identification of which data actions involve personally identifiable information · 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
- Map describes application logic but omits the disclosure to third parties, which is the action of greatest privacy consequence
- Drawn once for a privacy impact assessment and never maintained as the system changes
- Data actions listed without the personally identifiable information elements involved, so the map cannot support privacy analysis
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 sheetCM-12 Information Location. Identify and document the location of [organization-defined] and the specific system components on which the information is processed and stored; Identify and document the users who have access to the system and · CM-14 Signed Components. Prevent the installation of [organization-defined] without verification that the component has been digitally signed using a certificate that is recognized and approved by the organization