PRIV-29 Privacy Scope Assessment

What is this control about?

Implementing the control of ‘Privacy Scope Assessment’ is crucial for organizations to establish a clear and comprehensive understanding of the scope of their privacy practices and data processing activities. This control involves conducting a thorough assessment of the organization’s privacy-related processes, systems, and data flows to identify the extent and boundaries of personal data processing activities.

Available tools in the marketplace

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:

• This template includes a section on the Privacy scope – Privacy Impact Assessment Report

Control implementation

Here are some guidelines to implement a Privacy Scope Assessment program:

• Identify Data Owners and Stakeholders: Begin by identifying key stakeholders and data owners within the organization who are responsible for different data processing activities. These individuals will play a crucial role in providing information about the data they handle.
• Conduct Data Mapping: Collaborate with data owners and stakeholders to map the flow of personal data within the organization. This includes understanding how data is collected, processed, stored, transferred, and disposed of across various systems and departments.
• Create Data Inventory: Develop a comprehensive data inventory that documents the types of personal data collected, the purposes for which it is processed, the data retention periods, and any third parties with whom the data is shared.
• Assess Data Privacy Risks: Analyze the data processing activities to identify potential privacy risks and vulnerabilities. Evaluate the impact and likelihood of each risk to prioritize mitigation efforts.
• Review Legal and Regulatory Requirements: Review relevant privacy laws and regulations that apply to the organization, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA). Ensure that the data processing activities align with these requirements.
• Define Privacy Scope: Clearly define the scope of the organization’s data processing activities that fall within the purview of privacy regulations. This will help in setting boundaries for compliance efforts.
• Document Privacy Scope Assessment: Document the findings of the privacy scope assessment, including data mapping results, identified risks, and alignment with legal requirements. Create a detailed report that can be used as evidence of compliance during audits.
• Implement Remediation Measures: Based on the identified risks, work with data owners and stakeholders to implement appropriate remediation measures to address privacy concerns. This may include revising data handling processes, updating privacy policies, or enhancing data security measures. 

What evidence do auditors look for?

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

• Data Inventory and Mapping: A comprehensive data inventory and data flow mapping document that identifies the types of personal data collected, processed, stored, transferred, and disposed of within the organization. This document should include details about data sources, data owners, data categories, processing purposes, data recipients, and data storage locations.
• Privacy Scope Assessment Report: A comprehensive report summarizing the findings of the privacy scope assessment, including data inventory, risk assessment results, alignment with legal requirements, and any remediation measures proposed.

Evidence example

For the suggested action, an example is provided below:

• Data Inventory and Mapping

Screenshot source

• Privacy Scope Assessment Report:

Privacy Scope AssessmentThis template includes a section on the Privacy scope – Privacy Impact Assessment Report