DSP-03: Data Inventory

CSF v1.1 References:

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Control is new to this version of the control set.

Control Statement

Create and maintain a data inventory, at least for any sensitive data and personal data.

Implementation Guidance

The data inventory should provide visibility into the location, volume, and context of all sensitive data and PII through data discovery activities that result in a data inventory. Continuously support the classification process using discovery.

Auditing Guidance

  1. Examine the organization's procedures and technical requirements for the population and management of its data inventory. Establish that this process and key controls comply with the organization's data privacy and security policy. Establish whether the organization has documented the roles and responsibilities for this process.
  2. Select a sample of entries to ensure they have been recorded correctly on the inventory. The sample must include a proportion of sensitive and personal data entries.
  3. Assess whether management of the data inventory meets the organization's expectations.
  4. Examine measure(s) that evaluate(s) this process and determine if the measure(s) address(es) implementation of the process/control requirement(s) as stipulated. Reviews, tests, or audits should be completed periodically by the organization to measure the effectiveness of the implemented controls and to verify that non-compliance and opportunities for improvement are identified, evaluated for risk, reported, and corrected in a timely manner.
  5. Obtain and examine supporting documentation maintained as evidence of these metrics to determine if the office or individual responsible reviews the information and if identified issues were investigated and corrected. Determine if the individual or office is able to correct issues without the need to routinely escalate the issues to the next level of management. Examine related records to determine if the individual or office conducted any follow-ups on the deviations to verify they were corrected as intended.

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