P3.1 Personal information is collected consistent with privacy commitments
Limits collection of personal information to what the entity's stated privacy purposes require, obtains it by means reviewed by management as fair and lawful before they are used, confirms that third party sources of per
5
artefacts
0
held by a system
4
at each review
hard
to go live
Document repository
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
- Record of processing showing each purpose and the data elements collected for it · Document repository
- Management review and approval of collection methods before they go live · Policy repository / GRC workspace
- Due diligence records for third party and broker sources of personal information · Vendor register / contract repository
- Data minimisation review of forms, trackers, integrations and log capture · SIEM / log platform
governing documentDocuments that govern the control
- Notices issued to data subjects when the entity derives or acquires further information about them · Document repository
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
- Collection scoped to what the system can capture rather than what the purpose needs
- Collection methods deployed with no documented fairness and lawfulness review
- Enrichment or broker data ingested with no check that the source collected it lawfully
- Derived and inferred attributes never disclosed to the data subject
- Legacy fields still collected after the purpose that justified them ended
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 sheetP2.1 Consent is obtained for the collection, use, and disclosure of personal information · P3.2 Explicit consent is obtained for sensitive personal information