3.2: Establish and Maintain a Data Inventory

Establish and maintain a data inventory, based on the enterprise’s data management process. Inventory sensitive data, at a minimum. Review and update inventory annually, at a minimum, with a priority on sensitive data.

Asset Type

Security Function

Implementation Groups

Data

Identify

1, 2, 3

Dependencies

  • Sub-control 1.1: Establish and Maintain Detailed Enterprise Asset Inventory

Inputs

  1. GV11: Portion of data management process addressing data sensitivity

  2. GV12: Data Inventory consisting of the data set of sensitive information for which the enterprise is responsible

  3. GV1: Enterprise asset inventory

  4. Date of last update to the sensitive data inventory

Operations

  1. Use GV11 to map Input 2 to sensitivity per the guidance in the data management process
    1. Identify and enumerate items in the data set that have a mapping (M2)

    2. Identify and enumerate items in the data set that do not have a mapping (M3)

  2. Use GV1 and M2 from Operation 1 to map the data set to assets storing data
    1. Identify and enumerate items that have complete and correct mapping to asset and sensitivity (M4)

    2. Identify and enumerate items that have partial mapping to sensitivity (M5)

  3. Use: code:GV1 and M3 from Operation 2 to map the data set, without sensitivity mapping, to assets storing data
    1. Identify and enumerate items that have partial mapping to assets (M6)

    2. Identify and enumerate items that have no mapping at all (M7)

  4. Compare current date to Input 4 and capture timeframe in months (M8)

Measures

  • M1 = GV11

  • M2 = Count of sensitive data addressed in GV11

  • M3 = Count of sensitive data not addressed in GV11

  • M4 = Count of data with complete sensitivity and asset storage inventory

  • M5 = Count of data with partial mapping to sensitivity

  • M6 = Count of data with partial mapping to assets

  • M7 = Count of data with no mapping to sensitivity or asset

  • M8 = Timeframe since last update to sensitive data inventory in months

  • M9 = Count of items in GV12

Metrics

  • If M1 is 0, this safeguard receives a failing score. The other metrics don’t apply.

  • If M9 is greater than 12 months, this safeguard is scored at zero and receives a failing score. The other metrics don’t apply.

Completeness of sensitive data inventory

Metric

Percentage of data with complete information

Calculation

M4 / M9

Partial completeness of sensitive data inventory

Metric

Percentage of data with partial inventory

Calculation

(M5 + M6) / M9