CIS Controls 3.1: Establish and Maintain a Data Management Process

What this means

Data management processes define how your organization classifies, stores, handles, and destroys information based on sensitivity level. This control requires you to establish clear ownership (who is accountable), handling procedures (how data is used and shared), retention schedules (how long you keep it), and disposal methods (how it's securely destroyed). Documentation must be reviewed annually and updated whenever significant business changes occur—such as system migrations, new applications, or reorganizations—that could affect how data flows through your environment.

How to comply

1. 1.Classify all data assets by sensitivity level (public, internal, confidential, restricted) and document classification criteria
2. 2.Assign data owners who are accountable for each data category and define their responsibilities
3. 3.Document handling procedures that specify who can access, modify, and share each data type
4. 4.Establish retention schedules that define how long each data category must be kept based on legal, regulatory, and business requirements
5. 5.Define secure disposal methods (deletion, destruction, encryption) appropriate to each sensitivity level
6. 6.Create a master data management document that consolidates all policies and procedures
7. 7.Schedule annual reviews of the data management process and document any updates made
8. 8.Communicate the process to all employees and require acknowledgment of data handling responsibilities

Evidence auditors look for

• Data classification matrix showing sensitivity levels and criteria for each category
• Data ownership registry listing responsible parties for each data asset or system
• Data handling policy covering access controls, sharing restrictions, and usage guidelines
• Retention schedule linked to legal holds, regulatory requirements, and business needs
• Disposal procedures manual with approved methods for each data type
• Annual policy review documentation with sign-off from management and data stewards
• Employee training records confirming staff understanding of data management expectations
• Change log showing updates made in response to business changes or new systems

Frequently asked questions

GRCWatch automates data inventory collection, tracks data ownership assignments, and enforces annual review reminders—so your team spends hours documenting policy instead of weeks chasing down scattered information across tools.

See how GRCWatch handles this control automatically