What this control covers
The controller must embed data protection by design and default, using technical and organizational measures like pseudonymisation to ensure only necessary personal data is processed, minimizing collection, processing, storage, and access while safeguarding data subjects' rights. This control addresses Privacy by Design.
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
Use VPC Service Controls to draw a perimeter around sensitive APIs and a hierarchical Firewall policy at the org/folder level so projects inherit a deny-by-default posture. Front HTTP workloads with the global Cloud Load Balancer + Cloud Armor.
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
infra_scan— See the iCompaas Evidence library for the canonical source for this evidence type.policy_document— A signed, version-controlled policy stating leadership intent and the named owner.
Infrastructure posture tooling (AWS Config, Azure Policy, Nessus) verifies platform hardening. Signed policy or standard documents the safeguard. Focus: Data protection by design and by default.
Quick checklist
- Data — Controller / Rights
- Processor — Controller / Rights
- Security — Controller / Rights