EvidenceSheet

P1.1 Privacy notice to data subjects

Data subjects receive notice of the organisation's privacy practices, updated and communicated promptly when practices, including uses of personal information, change. Points of focus: notice covers purpose of collection, choice and consent, types of information collected, collection methods such as cookies and tracking, how information is used, kept and disposed of, how individuals can see it, sharing with third parties, security, quality and the data subject's part in it, and monitoring and enforcement, and names other sources where information is not collected from the individual; notice is given at or before collection or soon after, before a notice change takes effect, and before new uses; the entities and activities covered are described objectively; and the notice is conspicuous and plainly written. The 2022 revision marks privacy points of focus as typical for data controllers, data processors or both, and adds for controllers that the notice is current, dated and easy to find, is reviewed periodically and updated, that data subjects are told of changes and their nature, and that earlier versions are retained as a record of what was communicated.

Source: SOC 2 (2017 Trust Services Criteria), P1.1. 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 SOC 2 (2017 Trust Services Criteria) in the compliance library.

These are criteria, not controls: you design controls that meet them, and which criteria are in scope follows the categories your report covers (Security always; Availability, Confidentiality, Processing Integrity and Privacy only if chosen). A Type 2 report tests that the controls operated across the period, so the evidence asked for is samples across that period, not one copy.

4
artefacts
1
held by a system
2
at each review
moderate
to go live
SIEM / log platform
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

  • Change log showing notice updates communicated before new uses · SIEM / log platform

periodic reviewEvidence produced at each review

  • Evidence notice is presented at collection points (forms, apps) · Data governance / DLP tooling
  • Periodic notice review records and archived prior versions · Data governance / DLP tooling

governing documentDocuments that govern the control

  • Published privacy notice with effective date and version history · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

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

CC9.2 Assessing and managing vendor and business partner risk · P2.1 Choice and consent