PT-5 Privacy Notice. Provide notice to individuals about the processing of personally identifiable information that: Is available to individuals upon first interacting with an organization, and subsequently at [organization-defined]; Is clear and easy-to-understand, expressing information
Privacy Notice. Provide notice to individuals about the processing of personally identifiable information that: Is available to individuals upon first interacting with an organization, and subsequently at [organization-d.
system holds itEvidence a system already holds
- Version history showing when the notice changed and how individuals were informed · Data governance / DLP tooling
periodic reviewEvidence produced at each review
- Assessment or evidence that the notice is clear and easy to understand, such as a readability or plain language review · Data governance / DLP tooling
governing documentDocuments that govern the control
- The privacy notice text as published, and evidence it is available on first interaction · Policy repository / GRC workspace
- The defined subsequent points at which the notice is provided again · Policy repository / GRC workspace
- Evidence the notice covers the processing described in the internal record · Policy repository / GRC workspace
First move
Common gaps auditors find
- Notice reachable only from a footer link, not presented on first interaction as the control requires
- Written for legal defensibility rather than comprehension, failing the clear and easy to understand test
- Updated silently, so individuals are not informed the terms of processing changed
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 sheetPT-4 Consent. Implement [organization-defined] for individuals to consent to the processing of their personally identifiable information prior to its collection that facilitate individuals' informed decision-making · PT-6 System of Records Notice. For systems that process information that will be maintained in a Privacy Act system of records: Draft system of records notices in accordance with OMB guidance and submit new and