EU GDPR
87 records. Direct records match this source; context records explain their connections.
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control · Direct
GDPR-Art12-14 — Transparency and information to data subjects
Transparency and information to data subjects
control · Direct
GDPR-Art15-22 — Data subject rights (access, rectification, erasure, portability, objection, automated decisions)
Data subject rights (access, rectification, erasure, portability, objection, automated decisions)
control · Direct
GDPR-Art24 — Responsibility of the controller
Responsibility of the controller
control · Direct
GDPR-Art25 — Data protection by design and by default
Data protection by design and by default
control · Direct
GDPR-Art28 — Processor obligations and data processing agreements
Processor obligations and data processing agreements
control · Direct
GDPR-Art30 — Records of processing activities (RoPA)
Records of processing activities (RoPA)
control · Direct
GDPR-Art32 — Security of processing
Security of processing
control · Direct
GDPR-Art33 — Notification of a personal data breach to the supervisory authority
Notification of a personal data breach to the supervisory authority
control · Direct
GDPR-Art34 — Communication of a breach to the data subject
Communication of a breach to the data subject
control · Direct
GDPR-Art35 — Data protection impact assessment (DPIA)
Data protection impact assessment (DPIA)
control · Direct
GDPR-Art37-39 — Designation and tasks of the Data Protection Officer
Designation and tasks of the Data Protection Officer
control · Direct
GDPR-Art44-49 — International transfers of personal data
International transfers of personal data
control · Direct
GDPR-Art5 — Principles relating to processing of personal data
Principles relating to processing of personal data
control · Direct
GDPR-Art6 — Lawfulness of processing
Lawfulness of processing
control · Direct
GDPR-Art7 — Conditions for consent
Conditions for consent
control · Direct
GDPR-Art9 — Processing of special categories of data
Processing of special categories of data
risk · Context
Abuse of rights, forged rights, and repudiation of actions
Authorized users or administrators exploit legitimate access beyond permitted scope, fabricate or forge credentials/rights to gain privileges, and repudiate performed actions — undermining accountability and audit-trail integrity.
risk · Context
Unauthorized use of equipment and unauthorized access escalation
Use of systems, networks, or devices without authorization, and users with authorized access reaching resources that exceed their authorization, potentially to exfiltrate data or conduct attacks.
risk · Context
Incomplete asset inventory and classification
No authoritative inventory of information and associated assets, missing ownership, acceptable-use, classification, labelling, or handling rules — preventing effective protection, risk assessment, and secure disposal.
risk · Context
User error and mishandling of sensitive information
Authorized users make mistakes — incorrect data entry, misconfiguration, improper procedures, incorrect privilege settings, or spilling/mishandling sensitive information — causing harm to information assets without malicious intent.
risk · Context
Litigation, investigation and enforcement exposure
Adverse judgments, class actions, contract/IP disputes, government subpoenas, DOJ/FTC/SEC investigations, consent decrees, or deferred-prosecution agreements imposing penalties, remediation, and management distraction.
risk · Context
Sector regulatory non-compliance (financial, healthcare, trade)
Non-compliance with sector regimes — banking prudential rules, consumer-lending laws, payment-network rules, healthcare (FDA/HIPAA/CMS, Anti-Kickback/Stark, False Claims), export controls (EAR/ITAR), antitrust, and environmental/labor rules — triggering fines, sanctions, or loss of license.
risk · Context
Attacks by capable, motivated threat actors
Because capable, motivated threat actors - outsiders, privileged and non-privileged insiders, organized groups, competitors, malicious partners or suppliers, and nation-states - actively target the organization's cyber resources, deliberate attacks are attempted against its systems and data, resulting in compromise, disruption, or theft when defenses are outmatched.
risk · Context
Unauthorized disclosure / breach of sensitive information
Unauthorized disclosure of information to parties not entitled to receive it, whether by insecure controls (insecurity), spillage, or authorized users induced to expose data — resulting in identity theft, economic loss, and loss of trust.
risk · Context
Excessive collection, purpose creep and secondary use
Collecting more personal data than necessary (data-minimization failure) and using it for purposes materially different from those disclosed without fresh notice/consent, expanding attack surface and violating purpose-limitation.
risk · Context
Data exfiltration and theft of information by attackers
Adversary (outsider, insider, nation-state, or competitor) installs malware or sniffers to locate and exfiltrate sensitive/proprietary information, or steals data by external actors — including systems-security losses from hacking.
risk · Context
Undocumented data inventory and unmapped data flows
No authoritative record of what personal data is held, where, who accesses it, and how it flows to processors/sub-processors and across borders — preventing risk assessment, DSR fulfilment, and enforcement of privacy obligations.
risk · Context
Privacy harms: distortion, stigmatization, unwarranted restriction
Processing inaccurate/out-of-context data (distortion), attaching negative social labels (stigmatization), or denying services based on personal data without justification (unwarranted restriction / algorithmic gatekeeping) — causing discrimination and economic loss.
risk · Context
Privacy-program non-compliance (GDPR, CCPA, state laws)
Failure to honour data-subject rights (access, deletion, portability, restriction) on time, missing lawful-basis/consent documentation, defective consent mechanisms, invalid cross-border transfer mechanisms, or inadequate notices — driving fines and private rights of action.
risk · Context
Unlawful retention or premature deletion of records
Retaining personal data beyond necessity/mandated schedules (privacy and breach risk) or deleting records before required retention periods (litigation-hold, regulatory, tax risk); records-management policy not enforced technically.
risk · Context
Inadequate transparency, notice and deceptive privacy communications
Failure to give clear, timely notice of collection, use, retention, and sharing; misleading or dark-pattern consent flows; and failure to disclose automated decision-making — undermining meaningful consent and compounding power imbalance.
risk · Context
Segregation-of-duties conflicts in financial processes
Incompatible duties (initiate, approve, record, and custody) concentrated in one role or via broad system access enable unauthorized or fraudulent transactions to be recorded and concealed.
risk · Context
Missing or insufficient security and privacy policies
Because documented, approved, and enforced security and privacy policies are missing and roles and duties are undefined, personnel operate without guidance on required controls and behaviours, so controls are applied inconsistently and accountability gaps leave violations undetected and unaddressed.
risk · Context
Missing security terms in contracts and no disciplinary process
Employment and supplier contracts omit security/confidentiality obligations, and there is no disciplinary process for security violations — removing legal recourse and the deterrent effect against repeat offenders.
risk · Context
Failure to detect, assess, and notify breaches on time
Failure to detect, assess, and notify affected individuals and regulators of personal-data breaches within required timeframes and content (GDPR Art.33/34, HIPAA breach rule), resulting in sanctions and compounded individual harm.
risk · Context
No security monitoring or supervision of privileged activity
Absence of monitoring mechanisms and supervision of personnel actions (especially privileged users) allows undetected misuse, and no process exists to supervise and escalate detected security breaches.
risk · Context
Client intake, documentation and account-management failures
Missing signed agreements, incomplete legal/ISDA documentation, unretained KYC/AML records, misfiled client files, unauthorized access to client accounts, and negligent loss of client assets held in custody.
risk · Context
Cross-border personal-data transfer without safeguards
Transferring personal data to jurisdictions lacking equivalent protection without SCCs, BCRs, adequacy decisions, or other recognized mechanisms, exposing individuals and the organization to legal risk.
risk · Context
Erosion of individual trust and confidence in data practices
Systemic failure to meet reasonable privacy expectations undermines confidence in products and institutions, causing disengagement, reputational damage, and reduced adoption — an organizational as well as individual harm.
risk · Context
Power imbalance and loss of self-determination over personal data
Structural informational asymmetry (take-it-or-leave-it consent, opaque algorithmic decisions) and inability to correct, delete, or restrict processing deprive individuals of meaningful control over their own data and narrative.
risk · Context
Brand and reputational crisis
Product-safety/quality failures, executive misconduct, data breaches, adverse media, or viral social-media/activist campaigns erode customer trust, investor confidence, partnerships, and brand equity — with long-term value loss exceeding near-term financial impact.
risk · Context
Stakeholder trust and social-license erosion
Gradual loss of trust and social license among customers, employees, investors, regulators, and communities — from perceived values misalignment, poor ESG/governance conduct, or repeated service failures — weakening stakeholder relationships and long-term enterprise value even absent a single acute crisis.
risk · Context
Applications running with excessive privilege / insecure design
Applications or services running under privileged accounts, opening unnecessary network connections, or lacking secure-by-design architecture mean a single compromise grants broad system access and expands attack surface.
risk · Context
Illegal processing of personal or sensitive data
Processing personal or sensitive data without legal authority, consent, or in violation of regulatory requirements — a data-protection breach with legal, privacy, and reputational consequences.
risk · Context
Loss of system maintainability
Loss of the ability to maintain, update, or repair information systems due to missing documentation, tools, skills, or unversioned software — leaving systems unpatchable and increasingly fragile over time.
risk · Context
Third-party compliance failure creating vicarious liability
A vendor, subcontractor, or channel partner violates labor, environmental, anti-bribery (FCPA/UKBA), or data-protection rules, exposing the company to liability and reputational harm; fourth-party/N-tier dependencies are opaque.
risk · Context
Vendor/outsourcing service non-performance and disputes
Outsourced processing, IT, payroll/HR, print/mail, or sub-custodian providers fail to meet service levels, deliver defective software, make incorrect payments, or breach contractual deliverables, causing processing errors, outages, and loss.
risk · Context
Weak supplier security requirements and monitoring
Because supplier contracts omit security requirements and SLAs and third-party service delivery is not monitored, processors and sub-processors operate without equivalent, audited obligations, so third-party weaknesses and breaches propagate into the organization undetected.
risk · Context
Inadequate vulnerability scanning and pre-release testing
Software released without adequate testing, and no regular vulnerability scanning or penetration testing, leaves exploitable defects undiscovered until they manifest — or are exploited — in production.
risk · Context
Exploitation of known, unpatched vulnerabilities
Use of software with publicly known, unpatched flaws (CVEs) that adversaries readily exploit — including recently discovered vulnerabilities exploited before mitigations are in place, and internal-system vulnerability exploitation.
standard · Direct
EU GDPR
EU GDPR — General Data Protection Regulation
unified · Context
UC-ACCESS-05 — Enforce approved authorizations for information and functions
Systems mediate every access attempt through a tamper-resistant, always-invoked enforcement mechanism that applies approved authorizations before granting access to information or functions. Restrictions use roles and security attributes bound to data and subjects, limiting access to sensitive information, source code, and administrative functions to explicitly authorized identities. Enforcement rules are applied consistently across applications, databases, and infrastructure and are tested for effectiveness.
unified · Context
UC-ASSET-02 — Inventory data and document processing activities and flows
Maintain inventories of data and corresponding metadata for designated data types, together with records of processing activities capturing purposes, data categories, recipients, retention periods, and safeguards as required by applicable privacy regulation. Maintain representations of authorized network communications and internal and external data flows, such as data-flow diagrams. Review and update these records upon significant change and at least annually so management relies on complete, quality information.
unified · Context
UC-CONFIG-04 — Build security and privacy into software design and upkeep
Engineer security and data-protection requirements into systems and software from design onward, applying secure coding standards, pre-release security testing, and privacy-preserving defaults such as data minimization and pseudonymization. Maintain software after release by remediating identified vulnerabilities and applying security patches within risk-based timeframes. Replace or remove software that is unsupported or no longer justified by risk.
unified · Context
UC-DATA-01 — Process personal data only under a documented lawful basis
Identify and document the lawful basis and organizational authority for each personal-data processing activity before data is collected or processed. Record the basis (e.g., consent, contract, legal obligation, legitimate interest) in the processing register and collect personal data only for those documented purposes. Review the register at least annually and whenever processing changes.
unified · Context
UC-DATA-02 — Obtain and honor consent for collection, use, and disclosure
Where consent or authorization is the basis for collecting, using, retaining, disclosing, selling, or sharing personal data, present the available choices and their consequences clearly and capture freely given, specific, informed consent before the data is collected or disclosed. Maintain auditable consent records, honor withdrawal and opt-out requests (including opt-out of sale/sharing and limits on sensitive-data use) as easily as consent was given, and use compliant authorization forms where required. Document the basis for any implied consent relied upon.
unified · Context
UC-DATA-04 — Restrict processing of special categories of personal data
Inventory all processing of special categories of personal data (e.g., health, biometric, genetic, race or ethnicity, religion, sexual orientation) and prohibit such processing unless a documented legal exception or explicit consent applies. Apply heightened safeguards to this data and record the exception relied upon for each processing activity.
unified · Context
UC-DATA-05 — Provide privacy notices and transparency to data subjects
Publish and maintain privacy notices that describe, in clear and plain language, the categories of personal data collected, purposes, lawful bases, recipients, retention periods, and data-subject rights, and deliver them at or before the point of collection. Update and re-communicate notices in a timely manner when practices change, and publish any legally required registrations such as system-of-records notices. Retain dated notice versions as evidence.
unified · Context
UC-DATA-08 — Execute deletion and other rights requests within deadlines
Operate a verified rights-request process with designated intake channels, identity verification, and statutory response clocks that executes data-subject rights including erasure/deletion, portability, restriction, objection, and rights related to automated decision-making, and directs service providers to do the same. Do not discriminate or retaliate against individuals for exercising rights, and disclose the material terms of any financial-incentive program with opt-in consent. Track every request end-to-end as evidence.
unified · Context
UC-DATA-11 — Control data flows, leakage, and cross-border transfers
Enforce approved authorizations for information flows within and between systems using technical flow-control mechanisms, and deploy data-leakage-prevention measures on systems and channels that could exfiltrate sensitive data. Transfer personal data across borders only under a valid transfer mechanism (adequacy decision, standard contractual clauses, binding corporate rules, or a documented derogation), with the transfer risk assessed and the safeguard recorded.
unified · Context
UC-GOV-25 — Operate a privacy program with accountable leadership
Establish and maintain a privacy program and program plan defining the technical and organisational measures by which the organization ensures, and is able to demonstrate, compliance with privacy requirements. Designate a qualified, appropriately independent privacy leader (a Data Protection Officer where required) with defined tasks, adequate resources, and direct reporting to the highest level of management. Disseminate privacy program information to the workforce and the public, and report on privacy posture and program effectiveness at defined intervals.
unified · Context
UC-GOV-26 — Enforce personal-data processing principles and minimization
Adopt and enforce policies and procedures requiring that personal data is processed lawfully, fairly, and transparently; collected for specified, explicit purposes; limited to what is necessary; kept accurate through defined quality-management checks and correction procedures; stored no longer than needed; and protected — with accountability demonstrable through documentation. Minimize or use de-identified personally identifiable information in testing, training, and research, applying documented techniques where full data is not required.
unified · Context
UC-IR-08 — Notify authorities and affected parties within deadlines
Maintain a notification matrix of internal stakeholders, regulators, and other external parties with triggers, deadlines, content requirements, and approved communication owners. Require personnel to report suspected incidents to the response capability within defined timeframes, notify authorities and other required external bodies within their statutory windows, and share incident information with designated internal and external stakeholders as the communications plan directs. Notify affected individuals when thresholds are met — for high-risk personal-data breaches, communicate without undue delay in clear and plain language with mitigation advice; for regulated categories of data, notify individuals, media, and regulators within the mandated statutory windows when applicable thresholds are reached, honoring notification duties owed to partner organizations. Retain evidence of every notification's timing, audience, and content.
unified · Context
UC-LOG-06 — Evaluate events and declare incidents against defined criteria
Define written criteria for declaring a security incident, including thresholds that identify a reportable personal-data breach. Evaluate analyzed events against those criteria, declare incidents and initiate the response process when criteria are met, and record the assessment and rationale for every evaluated event. For reportable personal-data breaches, notify the competent regulator within the mandated statutory window with the prescribed content, and document all breaches, their effects, and remediation regardless of whether notification was required.
unified · Context
UC-RISK-16 — Conduct privacy impact assessments for high-risk processing
Privacy / data protection impact assessments are conducted before initiating processing likely to result in high risk to individuals, covering a systematic description of processing, necessity and proportionality analysis, risk assessment, and mitigation measures, with advice from the designated privacy officer and consultation with the competent regulator where required. Assessments are documented, approved, reviewed when processing changes, and retained.
unified · Context
UC-TPRM-03 — Bind vendors to security and privacy terms by contract
Include binding security and privacy requirements in contracts and agreements with vendors, service providers, and processors before access, service delivery, or data exchange begins: required security controls, confidentiality, breach notification, audit rights, subcontractor terms, and data handling, return, and deletion obligations. Document and authorize each information exchange or system interconnection under an appropriate agreement, and review agreements periodically. Ensure agreements satisfy the contractual clause requirements mandated by applicable privacy and security regulations for the data and services involved.
workflow · Context
SOC 2 Trust Services Readiness
Runs on the existing Audit engagement with its system description, service commitments, review period, control and risk registers, and available evidence; assesses CC1–CC9 design readiness and consumes reviewed companion assessments for selected optional Trust Services categories. Delivers the criterion-to-control mapping, criterion-level evidence and design conclusions, owned gap register, and approved SOC 2 readiness disposition to management for remediation and examination planning; Type II testing, management-owned PBC preparation and management assertion remain separate workflows.
workflow · Context
Technical Security Testing & Pentest Engagement
Runs ON an existing Audit item (audit_type: it_audit) that represents the authorized penetration-test engagement — the workflow instance attaches to that record and enriches it (scope, ratings, dates, and the assurance conclusion write back to its fields); it never creates a duplicate engagement record. In scope: authorized technical testing (reconnaissance, discovery, exploitation validation, severity rating, reporting, and retest) of the defined system boundary against its control baseline and assessment objective, with each confirmed finding recorded as an Issue linked to the anchor Audit and its affected Controls. Out of scope: any testing beyond the agreed rules of engagement, and the downstream remediation program itself — confirmed control gaps and open POA&M findings are handed to the Security Control Assessment & POA&M Remediation workflow, and the assurance conclusion to the Cybersecurity Assurance Review workflow. No upstream workflow feeds this engagement; its inputs are the anchor Audit, the in-scope system boundary (Process items), the control baseline (Control items, framework nist-800-53), the assessment objective and signed authorization, and any open Issue items (source: penetration_test / vulnerability_scan) from prior engagements.
workflow · Context
Privileged Access & Authorization Model Management
Standing operator workflow for the quarterly privileged-access recertification cycle, separate-account and utility-program controls, and application allowlisting, paired with role and security-attribute authorization-model maintenance and enforcement spot-testing across applications, databases, and infrastructure. Each quarterly instance runs as the operating cycle of the existing privileged-access Control item in the control library (UC-ACCESS-04, with UC-ACCESS-05 linked) — it enriches that Control's operating-effectiveness record rather than creating a new subject, and reads risk context from the linked Risk item (category cyber_security, domains access_control_identity). Consumes standing account, log, change-queue, and org-change feeds pulled live from IAM/PAM, directory, SIEM, allowlist tooling, and the HR system of record, plus the prior quarter's archived instance for its inventory register and carryover exceptions; it consumes no upstream workflow's handoff package. In scope: privileged and administrative accounts, control-overriding utility programs, the application allowlist, and the role and attribute authorization model with its enforcement points. Out of scope: standard non-privileged joiner-mover-leaver provisioning, network and perimeter controls, and application change management, each handled by its own workflow. Every exception and enforcement gap normalizes to an Issue item linked to the anchor Control, and the archived workflow instance is the cycle's evidence of record — open Issues are the cross-cycle carry-forward. Runs on a routine quarterly cadence, or out of cycle when an audit finding, incident, or major organizational change (reorg, new system, acquisition) requires it; no upstream workflow feeds it and it hands off to no single downstream workflow. Owned by the IAM Operations Lead.
workflow · Context
Cybersecurity Incident Response
Cybersecurity incident-response cycle as a decision-aware workflow spanning detection and validation, scoping, incident declaration and response-plan activation, containment with evidence preservation, eradication and recovery, POA&M updates for the control deficiencies the incident exposed, and a technical lessons-learned retrospective, closed through a disposition decision and archival. The workflow instance runs on the incident record — an Issue item (issue_type=exception, source=management_identified, severity per the org scheme) created at detection, since the schema has no native Incident type — and enriches that one record through to archival rather than creating duplicates. In scope: security events and confirmed incidents affecting the system boundary and its NIST 800-53 IR-family controls — the detection sources (logging/monitoring Control items, UC-LOG-06), affected systems (Process items, UC-ASSET-11), containment and recovery actions, forensic evidence, the deficiency Issues that become the POA&M, and their linked Risk items. Out of scope: the enterprise incident-management ticketing lifecycle and external breach-notification/legal reporting, which run in their own workflows. Where an Incident Management Lifecycle workflow is running, this cycle consumes its handoff package (initial ticket, reporter, affected systems); it hands the closed incident's control-deficiency findings — the open POA&M Issues (issue_type=deficiency) — to the Continuous Controls Monitoring (ISCM) Cycle as shared items it queries directly.
workflow · Context
IT Asset Inventory & Classification Upkeep
Standing operator workflow for the quarterly IT asset inventory reconciliation and the information and asset classification and labeling review. Anchor: each quarterly run is a workflow instance attached to the EXISTING Control item for the IT asset inventory & classification control (domains asset_management_inventory, frequency quarterly, framework including nist-800-53 / iso-27001 — e.g. control_id CM-8 / UC-ASSET-01) as its operating and execution record; enrich that Control, never create a duplicate. In scope: reconciling the authoritative hardware, software, systems, and services inventory against network, endpoint, cloud, and SaaS discovery scans and change records for the in-scope business units, and reviewing the classification, priority, and labeling of information and associated assets including physical media. Out of scope: the remediation engineering behind a decommission or security investigation (handed to those owners) and the downstream security-scoping processes that consume this cycle's outputs. Upstream: no upstream workflow — the cycle runs on the org's live inventory and discovery systems (external ITAM/CMDB, scanners, change/ticketing) plus the prior run's carry-forward Issue items linked to the anchor Control. Converges on two named deliverables — a signed reconciliation record and an updated classification register with an exported extract; that packaged, dual-signed record is the de-facto handoff package that downstream security-scoping processes consume (there is no named downstream workflow).
workflow · Context
Secure Development & Release Security Gate
Each run attaches as a workflow instance to the existing Control item for the secure-development/release-security-gate control (domains: secure_development_sdlc + vulnerability_patch_management) — enrich that Control, never create a duplicate; release runs and the quarterly checkpoint are separate instances on the same anchor Control. This workflow originates on its own artifacts (the release candidate, design artifacts, and the standing portfolio registers) and receives no upstream handoff package. Decision-aware: it branches on trigger type. In scope — for a release or major upgrade entering development, run security-and-privacy-by-design engineering, security test-plan execution, and runtime-hardening verification as parallel evidence streams, then resolve the release security disposition and assemble the release security evidence package with its acceptance-criteria index; for the quarterly portfolio checkpoint, run the vulnerability, patch, and end-of-life software review, publish the portfolio-health dashboard, and log corrective actions. Out of scope — the final production go/no-go, which the separate SDLC gate review workflow owns using the evidence package this workflow hands off to it. The release track and the quarterly track never force each other's steps.
workflow · Context
Network Segmentation & Boundary Rule Management
Network Segmentation & Boundary Rule Management as a decision-aware operator workflow covering trust-zone maintenance, gated rule-change implementation, boundary threat monitoring, the quarterly segmentation and rule-set review, and cross-domain exchange-policy enforcement. This cycle runs on the EXISTING boundary-protection Control item (domains network_communications_security; framework NIST 800-53, NIST CSF 2.0, ISO 27001, SOC 2; frequency quarterly; the boundary control owner as control_owner) — each quarterly run is one workflow instance attached to and enriching that Control, never a new control record. In scope: the trust-zone model, the managed interfaces (firewalls, gateways, proxies) mediating traffic between zones, the external boundary and key internal boundaries, and the cross-domain interconnection points, all under a deny-by-default baseline (NIST 800-53 SC-7, SC-16, SC-46; NIST CSF 2.0 PR.IR-01; ISO 27001 A.8.22; SOC 2 CC6.6). No upstream workflow feeds this cycle; it self-seeds from its own prior-cycle carry-forward — open corrective-action Issue items linked to the Control plus the prior run's closure record and archived rule-change record log. Named deliverables: the reconciled trust-zone model, the verified rule-change record log, the boundary threat-monitoring summary, the cross-domain exchange-policy enforcement report, the quarterly segmentation & rule-set review report, the boundary-posture dashboard, and corrective-action Issues linked to the Control. Downstream, it hands off only to its own next cycle via the carry-forward closure record; a confirmed intrusion is escalated to the incident-response workflow (out of scope), as are host/endpoint controls.
workflow · Context
ISO 27001 SoA Review & Controls Assessment
Review the ISO 27001 Statement of Applicability and assess the controls behind it. Each run attaches to an Audit item created for the review cycle (audit_type = compliance, e.g. "ISO 27001 SoA Review 2026-H2"), which accumulates the scope, the per-control test instances, the assessment package, the approval, and the rating. The workflow locks the assessment workplan, reconciles every Annex A control's applicable/excluded decision and justification against the current risk treatment plan, verifies implementation evidence, assesses the sampled controls for design and operating effectiveness, routes deficiencies to owners, and approves and publishes the version-controlled Statement of Applicability (SoA) — then classifies the disposition and prepares, approves, hands off, and archives the review package. In scope: reconciling and assessing the SoA's Annex A control applicability decisions and their implementation for the ISMS in scope, and publishing the approved SoA version. It consumes the ISMS Risk Assessment & Treatment Cycle's handoff package (the current risk register, the risk treatment decisions, and the required-controls determination) and hands its named deliverable — the approved, version-controlled published SoA and the assessment package — off to the downstream ISO 27001 Certification Readiness workflow. Out of scope: the enterprise risk assessment and treatment decisions that determine which controls are required (owned upstream by the ISMS Risk Assessment & Treatment Cycle) and the certification audit preparation that follows (owned by the downstream ISO 27001 Certification Readiness workflow, which consumes this review's approved package). The trigger is the scheduled SoA review interval or a material change to scope, risk, or the control environment.
workflow · Context
Security Control Assessment & POA&M Remediation
Run this assessment on the EXISTING Audit item for the engagement (audit_type: it_audit or compliance) — enrich that record, never create a duplicate: Audit.scope carries the authorization boundary and Audit.period_start/period_end the assessment window. Consumes, from the upstream SSP-development / system-categorization effort, the approved System Security Plan (SSP), the FIPS 199 system categorization, and the tailored NIST 800-53 baseline (existing Control items, framework: nist-800-53). Assess each in-scope control with 800-53A examine/interview/test methods, record satisfied / other-than-satisfied determinations, open a POA&M Issue for every gap, re-validate remediation, and issue the Security Assessment Report (SAR). In scope: control assessment, determinations, the POA&M lifecycle, and the SAR for the authorization boundary agreed at kickoff. Out of scope: the authorization (ATO) decision itself and the steady-state continuous-monitoring cadence. On completion, the frozen SAR and POA&M package are handed to the NIST RMF System Authorization (ATO) Cycle.
workflow · Context
ISO 27001 Stage 2 Annex A Controls Audit
Attach to the existing Audit engagement, owned by Internal Audit, using its approved Statement of Applicability, risk treatment plan, scope, review period and operating evidence; produce the Stage 2 Annex A Controls Audit report, four signed theme conclusions and finding register for the engagement and remediation owners. Apply the approved Statement of Applicability to ISO/IEC 27001:2022 Annex A.5.1–A.5.37, A.6.1–A.6.8, A.7.1–A.7.14 and A.8.1–A.8.34; document each exclusion and assess direct and inherited responsibilities. This Annex A assessment contributes to the engagement and does not independently establish full ISMS conformity or issue certification. Stage 1 and readiness remain separate workflows; any certification decision remains with the authorized certification body.
workflow · Context
SOC 2 Privacy Criteria Assessment
Design-readiness review of the full SOC 2 privacy series: notice and choice, collection through disposal, data subject access and disclosure, and data quality with dispute monitoring (P1.1–P8.1), concluded with dual sign-off on the criteria-bearing final assessment. Design-readiness assessment limited to the listed SOC 2 criteria. Evidence may include operating examples to assess the design; this module does not provide a SOC 2 Type II opinion. Attach this workflow to the existing audit engagement item; retain evidence and conclusions on its workflow steps.
workflow · Context
Vendor Risk Assessment and Disposition
Runs on one existing System with vendor=true. Uses the supplier record, contracts, assurance/CUECs, access and continuity evidence to produce a reviewed vendor risk assessment and authorized disposition for the business/risk owner and readiness evidence consumers. Two checkpoints retain expert challenge and the owner’s choice of conditions, treatment and monitoring; executor work is recorded in step results and documents, with no collection forms or runtime branches.
workflow · Context
Third-Party Vendor Risk Lifecycle
Operate the third-party vendor risk lifecycle end to end: scope and tier the vendor population, gather and analyze assurance evidence (SOC reports and CUECs, plus C-SCRM controls), embed contractual protections, enroll ongoing monitoring, and reach a governed disposition and approval. The vendor register IS the set of Vendor items — tiered by criticality (tier) and data exposure (data_classification), owned (business_owner, risk_owner), and driven by reassessment_cadence with last/next assessment dates and monitoring_status; each assessment cycle runs as one workflow instance over that register. In scope: vendor and supplier third-party risk assessment, onboarding controls, and periodic reassessment. Out of scope: procurement sourcing and commercial negotiation, and the deeper fieldwork of a Third-Party Vendor Assurance Engagement, to which the approved package is handed off. This workflow is self-initiating and consumes no upstream workflow package.
workflow · Context
Vendor Due Diligence & Contracting Gate
Vendor Due Diligence & Contracting Gate as a modular, decision-aware workflow. Anchor: the vendor's register entry — the Vendor item (slug: vendor). For a net-new engagement the gate creates the Vendor item and populates its tier, data_classification, business_owner, and risk_owner; for a renewal it enriches the existing Vendor item rather than duplicating it (enrich, never recreate). This is the first-line pre-contract gate the vendor-management office runs for every new engagement or renewal - tiering criticality, running proportionate due diligence into the vendor due-diligence report, documenting the risk-acceptance decision and any risk-reducing sourcing conditions, binding the contract to required security, privacy, and regulatory clauses, authorizing the specific information exchange before access begins, and - where personal data is involved - obtaining the signed written privacy commitments and scheduling compliance monitoring and incident-response routing. In scope: pre-contract due diligence, risk acceptance, and contract execution for one vendor engagement, ending with the Vendor item enrolled in monitoring (Vendor.monitoring_status = enrolled). There is no upstream workflow — the engagement trigger (a new prospective vendor or a renewal) is its own entry point. Downstream handoff: the archived gate record exported at close is the handoff package the ongoing third-party risk monitoring / vendor oversight lifecycle picks up to sustain the scheduled compliance checks and incident routing; that linkage is a prose handoff of live controls on the same Vendor item, not a triggered downstream node.
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Incident Management Lifecycle
Run the enterprise incident management lifecycle on a single governed incident record — an Issue item created at intake that every step enriches (there is no separate Incident type; the workflow instance anchors to that Issue). Open the record, analyze scope and impact, anchor the regulatory and remediation notification clocks to the detection date, contain/eradicate/recover, execute severity-based notifications, run lessons-learned and CAPA, classify the disposition, then prepare, hand off, and archive the governance package. Named deliverables: the scope-and-impact assessment, the root-cause analysis, the owned CAPA / remediation action plan, and the final evidence-and-decision governance package. In scope: operational and security incidents from detection through closure, including regulatory-notification clock management and corrective/preventive actions. Upstream: the incident originates on detection itself, but for a security-category incident this workflow consumes the containment-and-forensics handoff package produced by the Cybersecurity Incident Response workflow (linked in at the eradicate-and-recover step) rather than re-running SOC triage. Out of scope: real-time SOC triage and containment mechanics (owned by that Cybersecurity Incident Response workflow) and board-level reporting — the final governance package is handed off to the Quarterly Board & Audit-Committee GRC Reporting workflow, which reports the outcome without re-investigating.
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Privacy Safeguards & Notice Management
Privacy Safeguards & Notice Management as a decision-aware cycle that runs as a workflow instance attached to the standing "Privacy Program" Process item (process_type: business_process, process_owner: the privacy officer) — one archived instance per period is the cycle file. Each run refreshes the privacy requirements inventory, confirms PII-protection accountability over the PII stores (modeled as processing-activity Process items), verifies administrative, technical, and physical safeguards against data volume and sensitivity (the safeguard set is the Control items with control_category administrative|technical|physical and framework gdpr|ccpa|hipaa protecting each store), remediates gaps as tracked Issues, and authors, publishes, and version-retains the privacy notices and registrations (modeled as Policy items) kept accurate to actual processing. In scope: the periodic privacy program cycle over the confirmed PII stores, their safeguard control set, and the published notice and registration population; every run reconciles the affected notices to actual processing — a cycle that skips notice reconciliation is a different workflow. No upstream or downstream workflow feeds or consumes this cycle; its inputs are the organization's own privacy program records, and open remediation, treatment expiries, and deferred drift carry forward as open Issues that seed the next cycle's intake.
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Privacy Breach Assessment & Notification
Personal-data breach response, anchored on a breach-register Issue item created for the breach (issue_type: exception, source: management_identified, identified_date = the awareness timestamp); the workflow instance attaches to that Issue and the breach register is the queryable set of these Issues. Consumes the Incident Management Lifecycle workflow's handoff package (incident record, containment status, investigation timeline) and drives it from handoff to closure: a frozen, dated exposure inventory; a per-jurisdiction notifiability determination against GDPR Article 33, US state (California/CCPA included), and HIPAA clocks; regulator and data-subject notifications with milestone tracking; processor coordination against the processor's Vendor record and DPA; remediation and support Issue items; the Article 33(5) breach-register entry; and a post-breach review that hands off to the DPIA / Privacy Impact Assessment workflow for each affected processing activity. In scope: the notifiability judgment and notification execution downstream of the incident handoff; out of scope: incident containment and forensics, which stay with incident response.
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DSAR Fulfillment (Access & Deletion Requests)
DSAR Fulfillment (Access & Deletion Requests) as a modular, decision-aware workflow that verifies identity, locates and reviews personal data, applies exemptions, and delivers the response inside the statutory deadline. The workflow runs against the EXISTING "DSAR / Data-Subject Request Handling" Process item (process_type: business_process) — enrich it, never recreate it: one workflow instance per inbound request, and the instance itself is the DSAR register entry (there is no native DSAR/privacy-request item type; the register is the set of these instances). In scope: a single inbound data-subject access or deletion request under GDPR, CCPA/CPRA, or HIPAA, with the statutory clock started at receipt, carried from identity verification through data compilation, exemption review, delivery, and archival, with any correction or portability elements handled inline. It consumes the inbound request and identity artifacts uploaded at the first step, the data map / record of processing activities, the exemption playbook and retention schedule (Policy items with the governing documents attached), and the processor register (Vendor items, category: data_processing). Named deliverables: the access disclosure set or deletion certificate, the exemption log and redlined package, the reasoned rejection notice on the failed-verification path, the delivery evidence and completion-metrics record, systemic-finding Issue items routed to the privacy program, and the archived DSAR case file — the exported workflow record. Out of scope: unrelated privacy processes such as breach notification and privacy impact assessments, which run as their own workflows; this workflow takes no upstream handoff and produces no downstream workflow handoff.
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DPIA / Privacy Impact Assessment
GDPR Article 35 data protection impact assessment as a decision-aware workflow, run on the existing Process item (process_type=business_process) that represents the processing activity under assessment — the Process item doubles as the AssureSwarm proxy for the activity's records-of-processing (RoPA) entry, and the instance enriches it rather than creating a duplicate. It draws on upstream evidence — the RoPA extract, the data inventory and data-flow map, the Article 28 processor arrangements and transfer impact assessment from vendor due diligence, and the security risk assessment for the hosting systems — and moves the activity from screening, through necessity and proportionality and privacy-risk treatment, to a residual-risk decision with Article 36 prior consultation where needed and DPO sign-off. The named deliverable is the signed, versioned DPIA package (or, on the screened-out path, a defensible screening memo), registered against the Process item with tracked mitigation actions; close-and-archive hands that package off to records-of-processing maintenance. In scope: one processing activity (or a set of similar operations with comparable risks per Article 35(1)) from screening through sign-off; out of scope: the related workflows it draws on or feeds — vendor due diligence for new processors, transfer impact assessment for third-country transfers, security risk assessment for the hosting systems, and the records-of-processing maintenance that absorbs the outcome.
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Privacy Program Operations (Consent, Complaints & Sharing)
Runs the standing **Privacy Program Operations** process — an existing operational Process item (process_type=operational, process_owner = the privacy officer) — on a recurring cycle: this workflow instance attaches to that Process and IS the cycle record. It enriches what already exists rather than recreating it: the anchor Process, the in-scope RoPA processing-activity Process items, the privacy Control and Policy items, and the still-open Issues carried forward from prior cycles. Three parallel streams run inside the cycle — reconcile consent and preferences against processing activities, resolve privacy complaints with an accounting of disclosures, and govern data-sharing agreements against actual flows — each consuming verifiable extracts (consent-platform events, the disclosure log, integration/transfer logs) and producing named deliverables: the consent reconciliation report, the complaint register (Issue items), executed agreement renewals with any legal-approved interim risk treatments, and the cycle metrics pack, before the cycle is archived to its retention schedule. Self-contained recurring cycle; the approved metrics pack informs downstream privacy governance / committee reporting.
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SOX ITGC Testing
SOX ITGC Testing as a modular, decision-aware workflow. It runs on the existing Audit engagement item for this ITGC cycle (audit_type: sox_testing, period_start/period_end = the test period) — enrich that item, never create a duplicate — while per-control operating-effectiveness results live on Control-hosted SOX testing workflows, one created per in-scope ITGC control per Workflow.customFields.sox.fiscalYear, each hosted directly on the Control under test. It consumes the ICFR scoping handoff package from Annual ICFR Scoping & Risk Assessment, produces the reperformable final ITGC testing package as its named deliverable, and hands the deficiencies off to SOX Deficiency Remediation. In scope: the operating-effectiveness conclusion on the ITGCs protecting in-scope financial systems, reached by referencing the controls-owned NIST 800-53 catalog and its test scripts — not by rebuilding procedures. Out of scope, owned by related workflows: scoping of significant accounts and applications (Annual ICFR Scoping & Risk Assessment), deep completeness-and-accuracy validation of system-generated populations (SOX IPE Validation), and remediation of what fails (SOX Deficiency Remediation, the downstream handoff). It can stand alone, but is designed to exchange handoff packages with these related workflows instead of duplicating repeated work.