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Data Security โ€‹

This section defines controls related to the protection, classification, and management of data stored within Salesforce environments. These controls ensure that organizations maintain visibility over sensitive data locations, implement appropriate safeguards for regulated information, and establish processes to support privacy compliance and breach response capabilities.

SBS-DATA-001: Implement Mechanisms to Detect Regulated Data in Long Text Area Fields โ€‹

Control Statement: The organization must implement a mechanism that continuously or periodically analyzes the contents of all Long Text Area fields to identify the presence of regulated or personal data.

Description:
Salesforce organizations must employ a technical or procedural mechanism to inspect the stored values of all Long Text Area (LTA) fields for regulated data, including PII, PHI, or GDPR-governed attributes. For example, a sales representative may enter customer phone numbers, email addresses, or even payment card details into an Opportunity "Follow-Up Notes" field, creating unstructured storage of regulated data that is difficult to detect without systematic scanning.

Rationale:
LTA fields often contain unstructured, user-entered information that may include sensitive personal data. Failure to detect regulated data in these fields prevents the organization from identifying where such data resides, which in turn obstructs compliance with obligations such as GDPR Right to Erasure and inhibits breach impact assessments. If an incident occurs and the organization cannot determine which LTA fields contain personal information, it becomes impossible to accurately assess exposure or determine the scope of compromised records.

Audit Procedure:

  1. Identify all Long Text Area fields using Salesforce metadata.
  2. Determine whether the organization has a mechanism that scans the contents of each LTA field for regulated data.
  3. Confirm that scanning occurs continuously or on a defined recurring schedule.
  4. Review scan logs, detection outputs, or configuration details to verify that the mechanism is operational.
  5. Validate that all LTA fields across all objects are included in scope.
  6. Determine compliance based on whether such a mechanism exists and is functioning.

Remediation:

  1. Deploy or configure a tool, script, or process capable of analyzing the contents of LTA fields for regulated data.
  2. Ensure scans run continuously or on a recurring schedule.
  3. Confirm all applicable fields across all objects are included.
  4. Document the scanning process and store execution evidence for audit support.

Default Value:
Salesforce does not natively scan the contents of Long Text Area fields for regulated data.

References:

  • NIST SP 800-53: RA-5, SI-4
  • GDPR Articles 5 and 30
  • HIPAA ยง164.308(a)(1)(ii)(A)
  • CIS Controls v8: Control 3

SBS-DATA-002: Maintain an Inventory of Long Text Area Fields Containing Regulated Data โ€‹

Control Statement: The organization must maintain an up-to-date inventory of all Long Text Area fields that are known or detected to contain regulated or personal data.

Description:
Organizations must maintain a documented inventory listing each Long Text Area field that contains or is reasonably expected to contain regulated data, based on scanning outputs or operational use. For example, if a Case "Internal Comments" field routinely includes client account numbers or health-related information entered by support agents, that field must appear in the inventory and be tracked accordingly.

Rationale:
Without a current inventory of fields containing regulated data, an organization cannot apply appropriate protection, retention, or access controls. This gap prevents compliance with privacy obligations such as GDPR's Right to Erasure, where organizations must know all locations in which personal data is stored. During a security incident, the absence of such an inventory makes it impossible to determine which data fields were exposed, significantly impairing breach analysis, notification decisions, and containment.

Audit Procedure:

  1. Obtain the organization's documented inventory of Long Text Area fields containing regulated data.
  2. Compare the inventory against Salesforce metadata to confirm all relevant fields are included.
  3. Review scan results or administrative evidence demonstrating how fields were identified.
  4. Verify that the inventory includes object name, field API name, data classification, and last review date.
  5. Determine whether the inventory is maintained and current; missing, outdated, or incomplete inventories indicate noncompliance.

Remediation:

  1. Generate an inventory using scan results, administrative review, and metadata analysis.
  2. Document all LTA fields containing regulated data and classify the associated data types.
  3. Establish a recurring review cycle to update the inventory.
  4. Integrate the inventory into governance functions such as retention, DLP, access reviews, and breach response planning.

Default Value:
Salesforce does not maintain or provide an inventory of Long Text Area fields containing regulated data.

References:

  • NIST SP 800-53: PM-5, PL-8
  • GDPR Article 30
  • CIS Controls v8: Control 3