P3.2 Explicit consent is obtained for sensitive personal information
For information requiring explicit consent, the entity communicates the need for such consent, as well as the consequences of a failure to provide consent for the request for personal information, and obtains the consent.
5
artefacts
0
held by a system
3
at each review
hard
to go live
Data governance / DLP tooling
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
- Evidence of the communication explaining the need for explicit consent and the consequences of failing to provide it · Data governance / DLP tooling
- Evidence of how processing is prevented where explicit consent was not obtained · Data governance / DLP tooling
- Evidence of review where the categories of information collected changed · Data governance / DLP tooling
governing documentDocuments that govern the control
- Identification of the personal information the entity holds that requires explicit consent, and the basis for that determination · Policy repository / GRC workspace
- Records of explicit consent obtained, distinguishable from general consent, with date, scope and method · 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
- Sensitive categories never identified, so explicit consent is never sought for information that requires it
- Explicit consent bundled into a general acceptance, so it is neither explicit nor separable
- Consequences of refusal not communicated, leaving the choice uninformed
- No enforcement, so processing continues for individuals who did not give explicit consent
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 sheetP3.1 Personal information is collected consistent with privacy commitments · P4.1 Personal information is used for purposes identified in privacy commitments