3.2.1 Account data storage is kept to a minimum through implementation of data retention and disposal policies, procedures, and processes that include at least the following: • Coverage for all locations of stored account data.
Account data storage is kept to a minimum through implementation of data retention and disposal policies, procedures, and processes that include at least the following: • Coverage for all locations of stored account data
5
artefacts
1
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
- Data discovery scan results · Vulnerability scanner / patch tooling
periodic reviewEvidence produced at each review
- Quarterly purge job evidence · Data governance / DLP tooling
governing documentDocuments that govern the control
- Retention schedule by data type · Policy repository / GRC workspace
- Secure deletion procedure and logs · Policy repository / GRC workspace
- Legal hold exception register · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your Vulnerability scanner / patch tooling on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Indefinite retention by default
- No deletion proof
- Discovery scans miss locations
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 sheet3.1.2 Roles and responsibilities for performing activities in Requirement 3 are documented, assigned, and understood · 3.3.1 SAD is not stored after authorization, even if encrypted. All sensitive authentication data received is rendered unrecoverable upon completion of the authorization process