PRIV- 16 – Personal Data Collection Purpose

What is this control about?

Implementing the control ‘Personal Data Collection Purposes’ is important because it ensures transparency and accountability in the data collection practices of an organization. The control focuses on defining clear and specific purposes for collecting personal data, which is essential for safeguarding individuals’ privacy rights and complying with data protection regulations.

Available tools in the marketplace

Tools:

Alation Axon

Available templates

TrustCloud has a curated list of templates internally or externally sourced to help you get started. Click on the link for a downloadable version:

• N/A- No templates for this section

Control implementation

Here are some guidelines to implement a Personal Data Collection Purposes:

• Understand Data Collection Practices: Begin by understanding the organization’s data collection practices. Collaborate with data owners, data custodians, and relevant stakeholders to identify all personal data collected by the organization.
• Review Legal and Regulatory Requirements: Familiarize yourself with the applicable data protection laws and regulations that govern personal data collection in the organization’s operating jurisdictions. This step will help ensure that data collection practices comply with legal requirements.
• Define Purposes for Data Collection: Work with business units to clearly define the specific purposes for which personal data is collected. These purposes should align with the organization’s legitimate business needs and should be documented in a formal and comprehensive manner.
• Create Data Collection Purpose Documentation: Develop a standard template or format for documenting the purposes of data collection. This documentation should include details such as the type of data collected, the legal basis for collection, the intended use of the data, and the retention period.
• Establish Data Collection Review Process: Implement a review process that ensures any new data collection activities undergo an assessment for compliance with the defined purposes. This process should involve data owners, legal teams, and privacy officers to evaluate the necessity and appropriateness of new data collection activities.
• Educate Employees and Stakeholders: Conduct training sessions and awareness programs for employees and relevant stakeholders to educate them about the importance of defining data collection purposes and how to implement this control effectively.
• Monitor and Audit Data Collection Practices: Regularly monitor and audit data collection practices to ensure ongoing compliance with the defined purposes. As an IT auditor, you can conduct periodic reviews to assess whether data collection aligns with the documented purposes.
• Update Data Collection Purpose Documentation: As the organization evolves, ensure that the data collection purpose documentation is kept up-to-date. Any changes to data collection practices should be reflected in the documentation, and stakeholders should be informed.
• Implement Data Governance and Privacy Tools: Consider using data governance and privacy management software to facilitate the documentation and monitoring of data collection purposes. These tools can help streamline the control implementation process.
• Report Findings and Recommendations: As an IT auditor, report your findings and recommendations to senior management and the board of directors. This will help drive accountability and ensure that data collection is done in a transparent and compliant manner.

What evidence do auditors look for?

Most auditors, at a minimum, are looking for the below-suggested action:

• Data Collection Purpose Documentation: This should include a formal and comprehensive record of the specific purposes for which personal data is collected. The documentation should clearly outline the type of data collected, the legal basis for collection, the intended use of the data, and the retention period. It should be readily accessible and up-to-date.

Evidence example

For the suggested action, an example is provided below:

• Data Collection Purpose Documentation