Safeguard 3.14: Log Sensitive Data Access

Logging sensitive data access fails in two predictable ways: teams log “everything” but can’t answer basic forensic questions, or they log too little and miss the access paths that matter (direct database queries, admin consoles, cloud control planes, third-party support). Safeguard 3.14 focuses you on a narrow outcome: produce reliable records of access to sensitive data so you can detect improper access and investigate quickly. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat this safeguard like a measurable coverage problem. You need (1) a crisp definition of sensitive data aligned to your classification scheme, (2) an inventory of where that data lives and how it is accessed, (3) logging standards for the access events you care about, and (4) repeatable evidence that proves the control operates. ^{1 2}

This page gives requirement-level implementation guidance you can hand to security engineering, IT operations, and application owners, plus audit-ready artifacts you can retain without building a paper mill.

Regulatory text

Framework requirement (excerpt): “CIS Controls v8 safeguard 3.14 implementation expectation (Log Sensitive Data Access).” ^{1 2}

What the operator must do

You must implement logging that records access to sensitive data in a way that supports monitoring and investigation. Practically, that means:

• Identify sensitive data (what qualifies and where it resides).
• Capture access events at the control points that grant access (identity layer, applications, databases, cloud platforms).
• Protect and retain logs so they are reliable for investigation.
• Review logs or alerts to find anomalous or unauthorized access and show that someone is accountable for follow-up. ¹

Plain-English interpretation (what “log sensitive data access” means)

If your organization stores or processes sensitive data, you should be able to answer these questions without guesswork:

1. Who accessed the data (human user, admin, service account, third party identity).
2. What they accessed (dataset, table, object, record set, file path, bucket, CRM object).
3. When access happened (time, timezone, sequence).
4. How/where access occurred (app, API, console, direct query, source IP/device, authentication method).
5. What they did at a minimum level appropriate to your risk (read, export, delete, permission change).

Safeguard 3.14 is not “turn on a SIEM.” It is “generate defensible access records for sensitive data, end-to-end.”

Who it applies to (entity and operational context)

Entity types: Enterprises and technology organizations implementing CIS Controls v8. ¹

Operationally, it applies wherever sensitive data can be accessed, including:

• Business applications: CRM/ERP/HRIS, ticketing, finance systems.
• Data platforms: databases, data warehouses/lakes, analytics tools.
• Cloud storage and SaaS: object storage, collaboration suites, customer support platforms.
• Administrative planes: cloud consoles, database admin tools, privileged access workflows.
• Third party access paths: vendor support portals, managed service providers, outsourced dev/test, consultants with data access.

If you outsource processing, you still need logs (or contractual rights to obtain them) to investigate access to your data by third parties.

What you actually need to do (step-by-step)

Use this as an execution checklist. Each step produces an artifact an auditor can understand.

Step 1: Define “sensitive data” for logging scope

• Map your data classification (e.g., Restricted/Confidential) to a logging scope statement: “Sensitive data includes X, Y, Z.”
• Include customer data, employee data, financial data, credentials/secrets, regulated datasets, and any dataset your risk assessment labels as high impact.
• Decide whether metadata (like document titles or object keys) is sensitive and must be masked in logs.

Output: “Sensitive Data Logging Scope” one-pager owned by Security/GRC, approved by the data owner.

Step 2: Build a coverage map (systems × data × access paths)

Create a table that lists:

• System name (SaaS/app/db/cloud storage)
• Sensitive dataset(s) in that system
• Primary access paths (UI, API, direct query, admin console, ETL pipeline, third party support)
• Current logging capability (native audit logs available?)
• Central collection status (sent to your log platform/SIEM?)

Output: “Sensitive Data Access Logging Coverage Map.”

Step 3: Define minimum logging fields (a standard engineers can implement)

Set a standard for what an “access log event” must contain:

• Actor identity (user ID; service account; role)
• Target object (dataset/table/file/object ID)
• Action (read/query/export/download/delete/admin change)
• Timestamp
• Source context (source IP, device ID if available, application, session ID)
• Outcome (success/failure)

Practical constraint: Don’t log the sensitive payload itself unless you have a clear need and controls for it. Focus on access events and identifiers.

Output: “Sensitive Data Access Logging Standard.”

Step 4: Turn on or instrument audit logging at the right layer

Prioritize the layers that actually prove access:

• Application audit logs for user-level access (reports, exports, record views).
• Database audit logs for direct queries and admin activity.
• Cloud provider audit logs for object access, permission changes, and console actions.
• Identity provider logs to correlate authentication with access sessions.

Avoid a common gap: relying only on perimeter or network logs. Network logs rarely prove “data access.”

Output: Configuration evidence (screenshots/config exports), plus a short implementation note per system.

Step 5: Centralize, protect, and make logs searchable

• Forward audit logs to a centralized logging platform (SIEM or log management).
• Restrict who can modify or delete logs; separate duties from admins who can access sensitive data.
• Validate time sync and consistent timestamps across systems.
• Create saved searches or dashboards for “sensitive data access” events grouped by system/dataset.

Output: Log routing diagram, access control list for the logging platform, and sample queries.

Step 6: Define alerting and review triggers tied to your risk

Pick triggers that reflect real abuse paths:

• Large exports/downloads from sensitive datasets
• Access outside expected geographies or time windows
• Privileged account access to sensitive datasets
• Third party identities accessing sensitive data
• Repeated failed access attempts to sensitive datasets
• Permission changes that expand access to sensitive data

If your tooling supports it, tag “sensitive dataset” and alert on that tag rather than hard-coding object names.

Output: Alert catalog (name, logic, owner, response steps) and review cadence.

Step 7: Operationalize ownership and response

• Assign an owner for each sensitive system (system owner) and an owner for the logging program (Security Operations).
• Document what happens when an alert triggers: ticketing workflow, escalation, evidence capture, closure criteria.
• Run a tabletop: “A contractor exported a sensitive dataset; can we prove it and respond?”

Output: Runbook and a completed tabletop record.

Step 8: Capture recurring evidence (don’t wait for the audit)

Schedule recurring evidence pulls:

• A monthly sample of access events for 2–3 representative systems
• A screenshot/export of active alert rules
• A log retention/configuration attestation

Daydream can help you map Safeguard 3.14 to a documented control narrative and automate recurring evidence requests across system owners, so you always have current proof of operation. ¹

Required evidence and artifacts to retain

Auditors and assessors usually want proof of design and operation. Keep:

• Sensitive Data Logging Scope (approved)
• Sensitive Data Access Logging Standard (fields, event types)
• Coverage Map (systems/datasets/access paths/log status)
• System-level logging configurations (exports/screenshots) for in-scope systems
• Central log ingestion proof (connectors enabled, sample events visible)
• Log retention settings and access controls for the logging platform
• Alert catalog and current alert configurations
• Evidence of review and follow-up (tickets, cases, investigation notes)
• Exception register for systems that cannot log access yet, with compensating controls and remediation plan

Common exam/audit questions and hangups

Expect these, and pre-answer them in your artifacts:

• “What do you define as sensitive data, and who approved that definition?”
• “Show me how you know access to sensitive data is logged in System X.”
• “Does your logging capture privileged access and direct database queries?”
• “How do you prevent log tampering or deletion?”
• “Who reviews these logs/alerts, and what evidence proves the review happened?”
• “How do you handle third party access to sensitive data and related logging?”

A frequent hangup: teams show a SIEM dashboard but can’t tie events to a defined sensitive dataset list. Your coverage map fixes that.

Frequent implementation mistakes (and how to avoid them)

1. Logging authentication only, not data access. Fix: require an access event tied to a dataset/object, not just “user logged in.”
2. Ignoring non-UI access paths (API, ETL, admin tools). Fix: list access paths explicitly in the coverage map and test each.
3. Collecting logs but failing to prove review. Fix: track alerts to tickets and keep closure notes.
4. Storing sensitive payloads in logs. Fix: log identifiers and actions; mask or avoid content unless approved by data owners.
5. No exceptions process. Fix: formalize exceptions with time-bound remediation and compensating monitoring.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite any. The practical risk is still clear: without access logging you may be unable to confirm or refute improper access, scope incidents, or support internal investigations. ¹

Practical 30/60/90-day execution plan

Use phases rather than dated promises. The goal is fast risk reduction with defensible evidence.

First 30 days (stabilize scope and prove one path end-to-end)

• Approve your Sensitive Data Logging Scope.
• Build the first version of the Coverage Map for highest-risk systems.
• Implement access logging for one “crown jewel” system end-to-end (source → central logs → query/alert → ticket).
• Define the logging field standard and publish it to system owners.

Next 60 days (expand coverage and add review discipline)

• Expand logging to the remaining high-risk systems and the most common alternate access paths (API/export/direct query).
• Implement and document core alerts and assign response owners.
• Start recurring evidence capture (log samples + review tickets).
• Add third party access paths to the coverage map and confirm logging availability/rights.

By 90 days (make it audit-ready and resilient)

• Close the largest gaps and document exceptions with remediation plans.
• Validate log integrity controls (restricted admin access, retention settings, change control).
• Run a tabletop for a sensitive data access incident and retain the output.
• Produce a single “Safeguard 3.14 control packet” that includes scope, coverage, configs, samples, and review evidence.

Frequently Asked Questions

What counts as “sensitive data” for Safeguard 3.14?

Use your existing data classification scheme and explicitly list the datasets and systems that contain your highest-impact data. Auditors care less about the label and more about whether your logging scope matches where sensitive data actually resides. ¹

Do we need to log every read of every record?

Log at a level that proves access in your environment, then prioritize higher-risk actions like exports, bulk queries, and privileged access. Your coverage map and logging standard should justify the granularity you chose. ¹

If we have a SIEM, are we automatically compliant?

No. A SIEM helps centralize and analyze logs, but Safeguard 3.14 depends on whether the right systems emit access events for sensitive data and whether you can retrieve them for investigation. ¹

How do we handle third party access to our sensitive data?

Identify third party identities and access methods (support portal, VPN, delegated admin, API keys) and require audit logs for those access paths. If a third party hosts the system, contract for audit log access and retention aligned to your investigation needs. ¹

What evidence is most persuasive in an audit?

A scoped list of sensitive systems, proof that access events flow into centralized logging, and a small set of real tickets showing alerts or reviews with documented follow-up. Pair that with configuration exports to prove logging is enabled. ¹

We can’t enable detailed access logging on one legacy system. What do we do?

Document an exception with a defined owner, compensating monitoring, and a remediation plan, then make sure sensitive data exposure on that system is reduced (access restrictions, segmentation, or migration). Keep the exception register current and reviewed. ¹

Footnotes

1. CIS Controls v8

2. CIS Controls Navigator v8