An audit log is a record of the activities and events that occur in an information system, such as an
application hosting personal dat
a. An audit log can help to monitor, detect, investigate and prevent unauthorized or malicious access,
use, modification or deletion of personal data. An audit log can also help to demonstrate compliance
with data protection laws and regulations, such as the General Data Protection Regulation (GDPR) or
the California Consumer Privacy Act (CCPA). An audit log should capture the following information
for each event: 9
The date and time of the event
The identity of the user or system that performed the event
The type and description of the event
The outcome or result of the event
The personal data that were accessed, used, modified or deleted
The last user who accessed personal data is the most important information to capture in the audit
log, as it can help to identify who is responsible for any data breach or misuse of personal data. It can
also help to verify that only authorized and legitimate users have access to personal data, and that
they follow the data use policy and the principle of least privilege. The last user who accessed
personal data can also help to support data subjects’ rights, such as the right to access, rectify, erase
or restrict their personal data.
The other options are less important or irrelevant to capture in the audit log of an application hosting
personal data. Server details of the hosting environment are not related to personal data, and they
can be obtained from other sources, such as network logs or configuration files. Last logins of
privileged users are important to capture in a separate audit log for user account management, but
they do not indicate what personal data were accessed or used by those users. Application error
events are important to capture in a separate audit log for system performance and reliability, but
they do not indicate what personal data were affected by those errors.
Reference:
IS Audit Basics: Auditing Data Privacy, section 4: “Audit logs should be maintained for all systems that
process PII.”
Data Protection Audit Manual, section 3.2: “Audit trails should be kept for all processing operations
involving personal data.”
Audit Logging Best Practices, section 2: “An audit log entry should contain enough information to
answer who did what and when.”