What this control covers
Develop, document, and disseminate a personally identifiable information (PII) processing and transparency policy that defines roles, responsibilities, and compliance, ensuring alignment with applicable laws and regulations. Procedures should facilitate implementation of the policy and associated controls. Designate an official to manage policy development and regular updates. Review and revise the policy and procedures as required.
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.
GitHub
Apply branch protection on default and release branches: require PR review, status checks, signed commits, linear history, and dismiss stale reviews on new commits. Use CODEOWNERS for required reviewers, Dependabot + CodeQL for SAST, and the Dependency graph / SBOM export for vendor disclosures.
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: Policy And Procedures.
Quick checklist
- Policy — Procedures / Management
- Information — Procedures / Management
- Security — Procedures / Management
- Review — Procedures / Management
- Compliance — Procedures / Management
- Updates — Procedures / Management
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