SI-19 De-identification. Remove the following elements of personally identifiable information from datasets: [organization-defined] ; and Evaluate [organization-defined] for effectiveness of de-identification
De-identification. Remove the following elements of personally identifiable information from datasets: [organization-defined] ; and Evaluate [organization-defined] for effectiveness of de-identification.
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Assessment of re-identification risk from remaining quasi-identifiers and from linkage with other available data · Document repository
governing documentDocuments that govern the control
- The defined elements of personally identifiable information removed from datasets, and the de-identification procedure applied · Policy repository / GRC workspace
- Sample de-identified datasets alongside the source, showing what was removed or transformed · Document repository
- The defined evaluation performed for effectiveness of de-identification, and its results · Document repository
- Controls over the de-identification keys or mappings where the process is reversible · Document repository
First move
Common gaps auditors find
- Direct identifiers removed while a combination of remaining attributes still singles individuals out
- Effectiveness never evaluated, which is the second half of the control
- Re-identification mapping retained alongside the de-identified data with the same access controls
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 sheetSI-18 Personally Identifiable Information Quality Operations. Check the accuracy, relevance, timeliness, and completeness of personally identifiable information across the information life cycle [organization-defined] ; and Correct or delete inaccurate or outdated personally identifiable information · SI-20 Tainting. Embed data or capabilities in the following systems or system components to determine if organizational data has been exfiltrated or improperly removed from the organization: [organization-defined]