DAT-01 · Data and Privacy

Data inventory and classification

Data held is inventoried, classified and assigned an owner.

6frameworks fully address it
2partially
0leave it out
SOC 2 ISO 27001 NIST CSF PCI DSS HIPAA GDPR EU AI Act NIST AI RMF
1Where each framework asks for it
  • SOC 2FullCC6.1
  • ISO 27001FullA.5.9
  • NIST CSFFullID.AM-07
  • PCI DSSFull12.5.1
  • HIPAAPartial164.310(d)(2) Media and device accountability rather than a data map.
  • GDPRFullArt. 30
  • EU AI ActPartialArt. 10 Data governance applies to training and testing data.
  • NIST AI RMFFullMAP 2.1

Build the control once against this objective and cite the clause each auditor asks about. A partial mapping says what the framework leaves out; an absence is a finding about the framework, not a gap in your program.

2What usually proves it

Data map, classification scheme, owner assignment.

?Why it exists

Everything downstream depends on knowing what you hold.

For a smaller organizationA single sheet listing systems, data types and owners.