1.2.4 Data flow diagram of account data
A current data flow diagram is maintained showing all account data flows across systems and networks.
5
artefacts
0
held by a system
1
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
- Annual review attestation · Vendor register / contract repository
governing documentDocuments that govern the control
- Account data flow diagram with version date · Policy repository / GRC workspace
- Inventory of systems handling PAN · Policy repository / GRC workspace
- Mapping of storage, processing, transmission points · Policy repository / GRC workspace
- Linkage to network diagram · 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
- Flow diagrams missing third-party paths
- No annual refresh
- Tokenisation flows not represented
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 sheet1.2.3 Network diagrams maintained · 1.2.5 Services, protocols, ports inventoried and justified