SOC 2 P7.1: Privacy - Quality of Personal Information
What This Control Requires
The entity collects and maintains accurate, up-to-date, complete, and relevant personal information for the purposes identified in the notice to meet the entity's objectives related to privacy.
In Plain Language
Bad data creates bad outcomes for real people. If your records show the wrong address, the wrong account status, or outdated information, decisions made from that data will be wrong too - and that is a privacy problem, not just a data quality problem.
Keeping personal data accurate, current, complete, and relevant is an ongoing effort. You need validation at the point of collection, ways for individuals to review and correct their own data, periodic quality checks, and a process for cleaning up problems when you find them. Holding onto data that is no longer relevant to any current purpose just increases your exposure for no benefit.
Auditors look for evidence that you have data quality controls in place, that individuals can actually review and correct their records, that you run periodic quality assessments, and that you act on what those assessments reveal.
How to Implement
Put data quality controls at every collection point. Validate inputs for accuracy and completeness when data first enters the system. Check email formats, phone number structures, postal addresses, and date ranges. Implement duplicate detection to prevent multiple records for the same person.
Give individuals self-service tools to review and update their own information. Account settings pages, profile management interfaces, and preference centres are the most scalable way to keep data accurate. If people can fix their own records, they will.
Schedule periodic data quality assessments. Use automated tools to catch common issues: duplicates, outdated records, invalid formats, and orphaned entries. Track data quality metrics over time so you can spot trends rather than just point-in-time problems.
Define validation rules for specific data elements. Verify that email addresses resolve, check mailing addresses against postal databases, confirm phone numbers are valid, and ensure dates fall within reasonable ranges. Apply these rules both during collection and periodically against existing records.
Create a clear remediation process. When quality issues surface, assess severity, prioritise, and correct. Some problems can be fixed automatically (standardising formats). Others need manual review or direct outreach to the individual. Track remediation work and verify corrections propagate across all systems.
Review data for continued relevance. Purposes change and time passes. Some personal data you hold may no longer serve any current legitimate purpose. Identify it, flag it, and apply your retention policies. Accumulating data you do not need is a liability, not an asset.
Evidence Your Auditor Will Request
- Data quality controls at collection points including validation rules and duplicate detection
- Self-service data review and correction mechanisms available to data subjects
- Periodic data quality assessment reports with metrics and identified issues
- Data quality remediation records showing correction of identified issues
- Data relevance review records showing removal of data no longer needed for stated purposes
Common Mistakes
- No input validation at data collection points, allowing inaccurate or incomplete data to enter the system
- Individuals have no way to review or correct their personal information in the system
- Data quality assessments are not conducted, allowing accuracy issues to persist indefinitely
- Duplicate records exist for the same individual across multiple systems without reconciliation
- Personal data that is no longer relevant to any current purpose continues to be retained
Related Controls Across Frameworks
Frequently Asked Questions
How do we balance data quality with data minimization?
How often should we conduct data quality reviews?
What if we discover systemic data quality issues?
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