CIS Controls v8 3.8 — Document Data Flows

What this control requires

Document data flows. Data flow documentation includes service provider data flows and should be based on the enterprise's data management process. Review and update documentation annually, or when significant enterprise changes occur that could impact this Safeguard.

In plain English

Document data flows. In practice, this means you can prove you document data management process-level controls on a defined cadence.

Why it matters

The CIS Controls are an industry-vetted, prioritised defence: skipping a safeguard widens the attack surface that the safeguards above and below it assume is closed. Audit frameworks (FedRAMP, PCI DSS, HIPAA) all cite CIS as evidence of due care.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A CIS-aligned reviewer wants to see (a) which Implementation Group you are targeting, (b) a documented owner for the safeguard, and (c) a tooling or process artefact (config, scan output, ticket) that proves the safeguard runs on the cadence the control demands.

Within Identify, the assessor will trace your implementation back to the catalogue reference (Control 3.8) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

• Document. Document the trigger, the owner and the cadence.
• Scope: data management process, data flows, service, enterprise.

Evidence to collect

• Vendor Risk Management. vendor_risk_management evidence
• Policy Document. A signed and version-controlled policy / standard / procedure document.

Third-party risk management evidence (assessments, contracts, due diligence) shows supplier oversight. Signed policy or standard documents the safeguard. Focus: Document Data Flows.

Common pitfalls

• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• ISO/IEC 27001:2022 A.5.19 — Information security in supplier relationships
• NIST SP 800-171 Rev. 3 3.16.3 — External System Services
• BSI C5:2020 SSO-01 — Policies and instructions for controlling and monitoring third parties
• GDPR Article 28 — Processor
• SOC 2 (2017 TSC) CC9.2 — Vendor Risk Management

Related controls in CIS Controls v8

• Control 3.2 — Establish and Maintain a Data Inventory
• Control 15.1 — Establish and Maintain an Inventory of Service Providers
• Control 3.1 — Establish and Maintain a Data Management Process
• Control 15.2 — Establish and Maintain a Service Provider Management Policy
• Control 3.5 — Securely Dispose of Data
• Control 7.1 — Establish and Maintain a Vulnerability Management Process

References

• Center for Internet Security — CIS Controls v8
• Catalogue identifier: Control 3.8

Topics: governance riskvendor riskvendor managementpolicy managementsupply chain securitypatch management