A.5.34 "Privacy and Protection of Personal Identifiable Information (PII)" would include:
-
Privacy Policies and Notices: Documentation of clearly defined and communicated privacy policies and notices that explain how personal identifiable information (PII) is collected, used, disclosed, and protected.
-
PII Inventory: Records of the types of PII collected, stored, and processed by the organization, along with their purposes and legal basis.
-
Data Processing Agreements: Evidence of data processing agreements with third parties that handle PII on behalf of the organization, outlining responsibilities and safeguards.
-
Consent Records: Documentation of methods used to obtain consent from individuals for the collection and processing of their PII.
-
Access Controls: Proof of access controls in place to ensure that only authorized personnel have access to PII and that access is based on job roles and responsibilities.
-
Data Minimization: Evidence of practices that ensure only necessary PII is collected and processed, and that data is not retained longer than necessary.
-
Encryption: Documentation of encryption methods applied to PII during storage, transmission, and processing.
-
Secure Storage: Records of secure physical and digital storage methods implemented to protect PII from unauthorized access.
-
Individual Rights: Documentation of procedures for individuals to exercise their rights regarding their PII, including requests for access, correction, deletion, and objection.
-
Data Breach Response Plan: Evidence of a documented data breach response plan that outlines steps to take in case of a breach involving PII.
-
Incident Response Procedures: Documentation of procedures for handling and reporting incidents involving the unauthorized access or disclosure of PII.
-
Vendor Management: Evidence of privacy assessments and due diligence conducted on third-party vendors handling PII.
-
Privacy Impact Assessments (PIAs): Records of PIAs conducted for new projects or systems that involve the processing of PII.
-
Employee Training: Proof of training programs provided to employees on handling PII, privacy policies, and data protection best practices.
-
Data Retention and Deletion: Documentation of policies and practices for retaining and deleting PII once its purpose has been fulfilled.
-
Secure Transmission: Evidence of secure transmission protocols used when sharing or transferring PII.
-
Cross-Border Data Transfer: Documentation of methods to ensure compliance with data protection laws when transferring PII across borders.
-
Consent Management: Records of mechanisms to manage and track individuals' consent for processing their PII.
-
Regular Audits and Assessments: Evidence of regular audits or assessments conducted to ensure compliance with privacy policies and data protection regulations.
-
Privacy by Design: Documentation of practices and considerations to integrate privacy into the design of systems and processes that handle PII.
-
Privacy Officer or Data Protection Officer (DPO): Evidence of a designated individual responsible for overseeing privacy compliance and handling PII-related matters.
-
Documentation of Data Flows: Records of how PII moves through the organization's systems, networks, and processes.
-
User Education and Awareness: Proof of initiatives to educate users (including customers and employees) about data protection, privacy practices, and their rights.
-
Regulatory Compliance: Evidence of compliance with relevant data protection laws and regulations (such as GDPR, CCPA, etc.) applicable to the organization's operations.
By reviewing these types of evidence, an auditor can assess whether the organization has implemented appropriate measures to protect the privacy of individuals' personal identifiable information (PII) and comply with data protection laws and regulations.
- At the highest level, the Information Security Policy has been defined and approved by top management setting out the organization’s approach to managing Privacy including policies on clear statements concerning support for and commitment to complying with PII applicable legal requirements (e.g., laws, regulations, and contracts), clarifying responsibilities between involved parties.
- A Data Protection officer has been appointed to manage a governance and privacy program.
- Awareness of consequences to involved parties of breaching privacy or security rules and procedures.