What is the most common gap auditors find on ID.AM-07?

Unstructured stores omitted from inventory

`ID.AM-07` Inventories of data and corresponding metadata for designated data types are maintained

Q: What evidence do auditors commonly ask for on ID.AM-07 Inventories of data and corresponding metadata for designated data types are maintained?

Data inventory with classification and location; Metadata tagging policy enforced in storage; Records of processing activities updated routinely; Discovery scans for unstructured data; Annual data inventory attestation.

Inventories of data and corresponding metadata for designated data types are maintained

Source: NIST CSF 2.0, ID.AM-07. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open NIST CSF 2.0 in the compliance library.

artefacts

held by a system

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. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Records of processing activities updated routinely · Document repository
Annual data inventory attestation · Vendor register / contract repository

governing documentDocuments that govern the control

Data inventory with classification and location · Policy repository / GRC workspace
Metadata tagging policy enforced in storage · Policy repository / GRC workspace
Discovery scans for unstructured data · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Unstructured stores omitted from inventory
Tagging inconsistent across regions
ROPA outdated
Discovery scans limited to sanctioned platforms

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

ID.AM-05 Assets are prioritized based on classification, criticality, resources, and impact on the mission · ID.AM-08 Systems, hardware, software, services, and data are managed throughout their life cycles