P6.7 Accounting of personal information held and disclosed
On request, data subjects receive a report of what personal information is held about them and its disclosures. Points of focus: the types of personal and sensitive personal information, and the processes, systems and third parties that handle them, are identified; and requests for an accounting are captured and answered. The 2022 revision adds, for data processors, answering data controllers when they ask what personal information the processor holds, in line with service agreements.
Source: SOC 2 (2017 Trust Services Criteria), P6.7. 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.
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
- Log of accounting requests and responses · SIEM / log platform
- Log of requests from controller customers asking what personal data is held, with responses (processor role) · Identity provider / directory
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Data map of personal information across systems and third parties · Vendor register / contract repository
First move
Common gaps auditors find
- Data map incomplete so accounting responses miss systems
- Requests not tracked
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 sheetP6.6 Notifying breaches and incidents · P7.1 Quality of personal information