RA-8 Privacy Impact Assessments. Conduct privacy impact assessments for systems, programs, or other activities before: Developing or procuring information technology that processes personally identifiable information; and Initiating a new collection of personally identifiable information that:
Privacy Impact Assessments. Conduct privacy impact assessments for systems, programs, or other activities before: Developing or procuring information technology that processes personally identifiable information; and Ini.
5
artefacts
0
held by a system
4
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
- Completed privacy impact assessments for systems, programs and activities in scope · Data governance / DLP tooling
- Evidence each assessment was conducted before developing or procuring technology that processes personally identifiable information · Policy repository / GRC workspace
- Evidence of assessment before initiating a new collection of personally identifiable information · Policy repository / GRC workspace
- Records showing the assessment was revisited when the processing changed · Policy repository / GRC workspace
governing documentDocuments that govern the control
- The privacy risks identified and the mitigations agreed, with owners · 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
- Assessment completed after the system is built, when the design decisions it should influence are already fixed
- New collections added to an existing system with no fresh assessment
- Mitigations agreed in the assessment never tracked to implementation
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