PRIV- 18 – Personal Data Integrity

What is this control about?

Implementing the control ‘Personal Data Integrity’ is crucial for safeguarding the accuracy, consistency, and reliability of personal data within an organization’s systems and databases. Data integrity ensures that the information remains complete and unaltered throughout its lifecycle, protecting it from unauthorized changes, corruption, or manipulation.

Available tools in the marketplace

Tools:

ManageEngine Safetica Trend Micro

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:

• Data Integrity Policy Template

Control implementation

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

• Identify Personal Data: The first step is to identify all the personal data collected, processed, and stored by the organization. Conduct a thorough data inventory to understand what data is considered personal and sensitive.
• Classify Data Sensitivity Levels: Categorize the identified personal data into different sensitivity levels based on the risk associated with its exposure or alteration. This classification will help prioritize data integrity efforts.
• Assess Current Data Protection Measures: Evaluate the existing data protection measures in place, such as encryption, access controls, and data backup procedures. Identify any gaps in the current security controls that could potentially impact data integrity.
• Implement Data Encryption: Apply encryption to personal data both at rest and in transit. Encryption ensures that even if data is compromised, it remains unreadable and maintains its integrity.
• Establish Access Controls: Implement stringent access controls to limit data access only to authorized personnel. Ensure that individuals with the appropriate permissions can only modify data within their scope of responsibility.
• Data Backup and Recovery: Establish a robust data backup and recovery plan to ensure that in case of data corruption or accidental modification, the organization can restore the original and unaltered data.
• Data Integrity Monitoring: Deploy data integrity monitoring tools that continuously monitor data repositories, databases, and critical systems for any unauthorized changes or alterations. Set up real-time alerts for any suspicious activities.
• Implement Data Auditing: Enable data auditing mechanisms to track and log all data modifications, access attempts, and data transfer activities. Regularly review and analyze these audit logs to identify anomalies.
• Regular Security Testing: Conduct regular security testing, including penetration testing and vulnerability assessments, to identify potential weaknesses that could lead to data integrity compromises.
• Employee Training and Awareness: Train employees on the importance of data integrity and the role they play in ensuring its preservation. Educate them on best practices for handling and protecting personal data.
• Incident Response Plan: Develop and implement an incident response plan that outlines the steps to be taken in case of data integrity breaches. This plan should include containment, investigation, and recovery procedures.
• Regular Review and Update: Data integrity controls should be regularly reviewed and updated to adapt to changes in the organization’s data landscape, industry regulations, and emerging threats.
• Compliance with Regulations: Ensure that the implemented controls align with relevant data protection regulations and industry standards.

What evidence do auditors look for?

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

1. Provide the Data Integrity Policy
2. Provide  configuration of the Data Integrity Monitoring Reports

Evidence example

For the suggested action, an example is provided below:

• Provide the Data Integrity Policy – Use this Data Integrity Policy Template
• Provide  configuration of the Data Integrity Monitoring Reports