What this control covers

Ensures personal data processing is lawful based on consent, contract, legal obligation, vital interests, public task, or legitimate interests, with safeguards for further processing. This control addresses Lawful Processing.

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.

Google Workspace

Use Data Export (Takeout-style) and Vault search to scope DSARs. Apply Drive labels + DLP so personal data classes are discoverable.

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.

Signed policy or standard documents the safeguard. Focus: Lawfulness of processing.

Quick checklist

  • Principles — Consent
  • Lawfulness — Consent
  • Data — Consent
  • Safeguards — Consent

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