What this control covers
The organization shall determine, document and be able to demonstrate compliance with the relevant lawful basis for processing PII. Implementation: Record lawful basis per processing activity; update when purpose changes. Justification: Needed to demonstrate lawfulness per jurisdiction.
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 Cloud KMS with customer-managed encryption keys (CMEK) for BigQuery, GCS, and Compute. Sensitive Data Protection (DLP API) inspects/de-identifies PII at scale.
Google Workspace
Enable client-side encryption for Drive/Docs and turn on Drive Labels + DLP rules to prevent external sharing of regulated data classes.
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 policies, procedures, and registers document the safeguard. Focus: Identify lawful basis.
Quick checklist
- Implement — Identify Lawful Basis
- Document — Identify Lawful Basis
- Record — Identify Lawful Basis
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