What this control covers
Establish and maintain a data management process. In the process, address data sensitivity, data owner, handling of data, data retention limits, and disposal requirements, based on sensitivity and retention standards for the enterprise. Review and update documentation annually, or when significant enterprise changes occur that could impact this Safeguard.
Why it matters
Risk is the language an executive team understands; this control connects technical reality to board-level decisions and budget allocation.
How to implement
AWS
Codify the policy intent as SCPs, AWS Config conformance packs, and Security Hub standards so the cloud enforces what the document says.
Azure
Codify in Azure Policy initiatives (built-in regulatory compliance for CIS, ISO 27001, SOC 2, HIPAA) and assign at management-group level.
GCP
VM Manager (OS patch + config management) and Artifact Registry vulnerability scanning integrate with Cloud Build to block vulnerable images.
GitHub
Dependabot security updates + version updates, plus CodeQL for SAST and a renovate bot for major-version drift management.
On-premises
Maintain a policy library with a documented review cadence (annual minimum); store in your GRC tool with attestation tracking. Map each policy to controls so an audit pull cites the exact policy clause.
Evidence to collect
policy_document— A signed, version-controlled policy stating leadership intent and the named owner.infra_scan— See the iCompaas Evidence library for the canonical source for this evidence type.
Signed policy or standard documents the safeguard. Focus: Establish and Maintain a Data Management Process.
Quick checklist
- Establish And Maintain — Data Management Process / Data Retention
- Address — Data Management Process / Data Retention
Related articles on this site
- Data Retention & Destruction
- NIST 800-171 3.3.4 Alert in the event of an audit logging process failure.
- NIST 800-171 3.3.9 Limit management of audit logging functionality to a subset of privileged users.
- NIST 800-171 3.4.1 Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles.