NIST PRIVACY FRAMEWORK

WEBINAR: READY, SET, ADOPT

VERSION 1.0

JANUARY 29, 2020
Collaborative Development

Starting Point

Attributes Preliminary 

Draft

Version 

1.0 

2 3 5

public 

workshops

public 

comment 

periods

webinars

Discussion 

Outline Draft
Value Proposition

Fulfilling current 

compliance 

obligations

Building 

customer 

trust

Facilitating 

communication

Privacy Framework supports:
Relationship Between Cybersecurity and 

Privacy Risk

Data: A representation of information, 

including digital and non-digital formats

Privacy Event: The occurrence or 

potential occurrence of problematic data 

actions

Data Processing: The collective set of 

data actions (i.e., the complete data life 

cycle, including, but not limited to 

collection, retention, logging, generation, 

transformation, use, disclosure, sharing, 

transmission, and disposal)

Privacy Risk: The likelihood that 

individuals will experience problems 

resulting from data processing, and the 

impact should they occur

Cybersecurity 

Risks 

Privacy 

Risks

associated with 

cybersecurity 

incidents arising from 

loss of confidentiality, 

integrity, or 

availability

associated with 

privacy events 

arising from data 

processing

cyber

securityrelated 

privacy 

events
Privacy Risk and Organizational Risk

Problem Individual

arises from data 

processing

experiences direct 

impact

(e.g., embarrassment, 

discrimination, 

economic loss)

Organization

resulting impact

(e.g., customer abandonment, 

noncompliance costs, harm to 

reputation or internal culture)
Role of Privacy Risk Assessment
Appendix D: Key Privacy Risk 

Management Practices

Organizing 

Preparatory 

Resources

Determining 

Privacy 

Capabilities

Defining Privacy 

Requirements

Conducting 

Privacy Risk 

Assessments

Creating 

Privacy 

Requirements 

Traceability 

Monitoring 

Changing 

Privacy Risks
FRAMEWORK STRUCTURE
Privacy Framework Structure

The Core provides an increasingly granular set of activities 

and outcomes that enable an organizational dialogue 

about managing privacy risk

Profiles are a selection of specific 

Functions, Categories, and Subcategories 

from the Core that the organization has 

prioritized to help it manage privacy risk CURRENT

TARGET

Implementation Tiers help an organization communicate 

about whether it has sufficient processes and resources in 

place to manage privacy risk and achieve its Target Profile
Privacy Framework Core

FUNCTIONS CATEGORIES SUBCATEGORIES

Identify-P

Govern-P

Protect-P

Control-P

Communicate-P
Cybersecurity Framework Alignment

Cybersecurity 

Risks 

Privacy 

Risks

IDENTIFY-P

GOVERN-P

CONTROL-P

COMMUNICATE-P

IDENTIFY

PROTECT

DETECT

RESPOND

RECOVER

Cybersecurityrelated privacy 

events

PROTECT-P

DETECT

RESPOND

RECOVER
Profiles

Consider: • Organizational goals • Role(s) in the data 

processing ecosystem 

or industry sector

• Legal/regulatory 

requirements & 

industry best practices

• Organization’s risk 

management priorities

• Privacy needs of 

individuals

PROFILES

TARGET

CORE

Identify-P

Govern-P

Protect-P

Control-P

Communicate-P

Identify-P

Govern-P

Protect-P

Identify-P

Govern-P

Protect-P

Control-P

Communicate-P

CURRENT
1: Partial

3: Repeatable

4: Adaptive

2: Risk Informed

Implementation Tiers

Where are you in 

terms of having 

resources and 

processes and where 

do you want to be?

Do you have 

sufficient resources 

and processes in 

place to manage 

these risks?

What are the 

privacy risks you 

need to manage 

as an 

organization?

Implementation 

Tiers Resources and 

Processes

Understanding 

Privacy Risks
How to Use the Privacy Framework

Informative 

References

Strengthening 

Accountability

Establishing or Improving 

a Privacy Program

Applying to the 

System Development 

Life Cycle

Using within the Data 

Processing Ecosystem

Informing Buying 

Decisions
Resource Repository

Browse and contribute:

Profiles Guidance & 

Tools

Crosswalks
APPENDIX A:

THE CORE
Identify-P

Function Category Subcategory

IDENTIFY-P (ID-P): 

Develop the 

organizational 

understanding to 

manage privacy 

risk for individuals 

arising from data 

processing.

Inventory and Mapping (ID.IM-P): Data processing 

by systems, products, or services is understood and 

informs the management of privacy risk.

ID.IM-P1: Systems/products/services that process data are inventoried.

ID.IM-P2: Owners or operators (e.g., the organization or third parties such as service 

providers, partners, customers, and developers) and their roles with respect to the 

systems/products/services and components (e.g., internal or external) that process data 

are inventoried.

ID.IM-P3: Categories of individuals (e.g., customers, employees or prospective 

employees, consumers) whose data are being processed are inventoried.

ID.IM-P4: Data actions of the systems/products/services are inventoried.

ID.IM-P5: The purposes for the data actions are inventoried.

ID.IM-P6: Data elements within the data actions are inventoried.

ID.IM-P7: The data processing environment is identified (e.g., geographic location, 

internal, cloud, third parties).

ID.IM-P8: Data processing is mapped, illustrating the data actions and associated data 

elements for systems/products/services, including components; roles of the component 

owners/operators; and interactions of individuals or third parties with the 

systems/products/services.

Business Environment (ID.BE-P): The organization’s 

mission, objectives, stakeholders, and activities are 

understood and prioritized; this information is used 

to inform privacy roles, responsibilities, and risk 

management decisions.

ID.BE-P1: The organization’s role(s) in the data processing ecosystem are identified 

and communicated.

ID.BE-P2: Priorities for organizational mission, objectives, and activities are 

established and communicated.

ID.BE-P3: Systems/products/services that support organizational priorities are identified 

and key requirements communicated.
Identify-P (continued)

Function Category Subcategory

Risk Assessment (ID.RA-P): The organization 

understands the privacy risks to individuals and 

how such privacy risks may create follow-on 

impacts on organizational operations, including 

mission, functions, other risk management 

priorities (e.g., compliance, financial), reputation, 

workforce, and culture.

ID.RA-P1: Contextual factors related to the systems/products/services and the data 

actions are identified (e.g., individuals’ demographics and privacy interests or 

perceptions, data sensitivity and/or types, visibility of data processing to individuals 

and third parties). 

ID.RA-P2: Data analytic inputs and outputs are identified and evaluated for bias.

ID.RA-P3: Potential problematic data actions and associated problems are identified. 

ID.RA-P4: Problematic data actions, likelihoods, and impacts are used to determine 

and prioritize risk.

ID.RA-P5: Risk responses are identified, prioritized, and implemented.

Data Processing Ecosystem Risk Management 

(ID.DE-P): The organization’s priorities, constraints, 

risk tolerance, and assumptions are established 

and used to support risk decisions associated with 

managing privacy risk and third parties within the 

data processing ecosystem. The organization has 

established and implemented the processes to 

identify, assess, and manage privacy risks within 

the data processing ecosystem.

ID.DE-P1: Data processing ecosystem risk management policies, processes, and 

procedures are identified, established, assessed, managed, and agreed to by 

organizational stakeholders.

ID.DE-P2: Data processing ecosystem parties (e.g., service providers, customers, 

partners, product manufacturers, application developers) are identified, prioritized, 

and assessed using a privacy risk assessment process.

ID.DE-P3: Contracts with data processing ecosystem parties are used to implement 

appropriate measures designed to meet the objectives of an organization’s privacy 

program. 

ID.DE-P4: Interoperability frameworks or similar multi-party approaches are used to 

manage data processing ecosystem privacy risks. 

ID.DE-P5: Data processing ecosystem parties are routinely assessed using audits, test 

results, or other forms of evaluations to confirm they are meeting their contractual, 

interoperability framework, or other obligations.
Govern-P

Function Category Subcategory

GOVERN-P (GV-P):

Develop and 

implement the 

organizational 

governance 

structure to enable 

an ongoing 

understanding of 

the organization’s 

risk management 

priorities that 

are informed by 

privacy risk.

Governance Policies, Processes, and Procedures 

(GV.PO-P): The policies, processes, and procedures 

to manage and monitor the organization’s 

regulatory, legal, risk, environmental, and 

operational requirements are understood and 

inform the management of privacy risk.

GV.PO-P1: Organizational privacy values and policies (e.g., conditions on data 

processing such as data uses or retention periods, individuals’ prerogatives with 

respect to data processing) are established and communicated.

GV.PO-P2: Processes to instill organizational privacy values within 

system/product/service development and operations are established and in place.

GV.PO-P3: Roles and responsibilities for the workforce are established with respect to 

privacy. 

GV.PO-P4: Privacy roles and responsibilities are coordinated and aligned with thirdparty stakeholders (e.g., service providers, customers, partners).

GV.PO-P5: Legal, regulatory, and contractual requirements regarding privacy are 

understood and managed.

GV.PO-P6: Governance and risk management policies, processes, and procedures 

address privacy risks.

Risk Management Strategy (GV.RM-P): The 

organization’s priorities, constraints, risk 

tolerances, and assumptions are established and 

used to support operational risk decisions.

GV.RM-P1: Risk management processes are established, managed, and agreed to by 

organizational stakeholders.

GV.RM-P2: Organizational risk tolerance is determined and clearly expressed.

GV.RM-P3: The organization’s determination of risk tolerance is informed by its 

role(s) in the data processing ecosystem.

Awareness and Training (GV.AT-P): The 

organization’s workforce and third parties engaged 

in data processing are provided privacy awareness 

education and are trained to perform their privacyrelated duties and responsibilities consistent with 

related policies, processes, procedures, and 

agreements and organizational privacy values.

GV.AT-P1: The workforce is informed and trained on its roles and responsibilities.

GV.AT-P2: Senior executives understand their roles and responsibilities.

GV.AT-P3: Privacy personnel understand their roles and responsibilities.

GV.AT-P4: Third parties (e.g., service providers, customers, partners) understand their 

roles and responsibilities.
Govern-P (continued)

Function Category Subcategory

Monitoring and Review (GV.MT-P): The policies, 

processes, and procedures for ongoing review of the 

organization’s privacy posture are understood and 

inform the management of privacy risk.

GV.MT-P1: Privacy risk is re-evaluated on an ongoing basis and as key factors, including 

the organization’s business environment (e.g., introduction of new technologies), 

governance (e.g., legal obligations, risk tolerance), data processing, and 

systems/products/services change.

GV.MT-P2: Privacy values, policies, and training are reviewed and any updates are 

communicated. 

GV.MT-P3: Policies, processes, and procedures for assessing compliance with legal 

requirements and privacy policies are established and in place.

GV.MT-P4: Policies, processes, and procedures for communicating progress on 

managing privacy risks are established and in place.

GV.MT-P5: Policies, processes, and procedures are established and in place to receive, 

analyze, and respond to problematic data actions disclosed to the organization from 

internal and external sources (e.g., internal discovery, privacy researchers, professional 

events).

GV.MT-P6: Policies, processes, and procedures incorporate lessons learned from 

problematic data actions.

GV.MT-P7: Policies, processes, and procedures for receiving, tracking, and responding 

to complaints, concerns, and questions from individuals about organizational privacy 

practices are established and in place.
Control-P

Function Category Subcategory

CONTROL-P (CT-P): 

Develop and 

implement 

appropriate 

activities to enable 

organizations or 

individuals to 

manage data with 

sufficient granularity 

to manage privacy 

risks.

Data Processing Policies, Processes, and Procedures 

(CT.PO-P): Policies, processes, and procedures are 

maintained and used to manage data processing 

(e.g., purpose, scope, roles and responsibilities in the 

data processing ecosystem, and management 

commitment) consistent with the organization’s risk 

strategy to protect individuals’ privacy.

CT.PO-P1: Policies, processes, and procedures for authorizing data processing (e.g., 

organizational decisions, individual consent), revoking authorizations, and maintaining 

authorizations are established and in place.

CT.PO-P2: Policies, processes, and procedures for enabling data review, transfer, sharing 

or disclosure, alteration, and deletion are established and in place (e.g., to maintain 

data quality, manage data retention).

CT.PO-P3: Policies, processes, and procedures for enabling individuals’ data processing 

preferences and requests are established and in place.

CT.PO-P4: A data life cycle to manage data is aligned and implemented with the 

system development life cycle to manage systems.

Data Processing Management (CT.DM-P): Data are 

managed consistent with the organization’s risk 

strategy to protect individuals’ privacy, increase 

manageability, and enable the implementation of 

privacy principles (e.g., individual participation, data 

quality, data minimization). 

CT.DM-P1: Data elements can be accessed for review.

CT.DM-P2: Data elements can be accessed for transmission or disclosure.

CT.DM-P3: Data elements can be accessed for alteration.

CT.DM-P4: Data elements can be accessed for deletion.

CT.DM-P5: Data are destroyed according to policy.

CT.DM-P6: Data are transmitted using standardized formats.

CT.DM-P7: Mechanisms for transmitting processing permissions and related data values 

with data elements are established and in place.

CT.DM-P8: Audit/log records are determined, documented, implemented, and 

reviewed in accordance with policy and incorporating the principle of data 

minimization.

CT.DM-P9: Technical measures implemented to manage data processing are tested 

and assessed.

CT.DM-P10: Stakeholder privacy preferences are included in algorithmic design 

objectives and outputs are evaluated against these preferences.
Control-P (continued)

Function Category Subcategory

Disassociated Processing (CT.DP-P): Data processing 

solutions increase disassociability consistent with 

the organization’s risk strategy to protect individuals’ 

privacy and enable implementation of privacy 

principles (e.g., data minimization).

CT.DP-P1: Data are processed to limit observability and linkability (e.g., data actions 

take place on local devices, privacy-preserving cryptography).

CT.DP-P2: Data are processed to limit the identification of individuals (e.g., deidentification privacy techniques, tokenization).

CT.DP-P3: Data are processed to limit the formulation of inferences about individuals’ 

behavior or activities (e.g., data processing is decentralized, distributed architectures).

CT.DP-P4: System or device configurations permit selective collection or disclosure of 

data elements.

CT.DP-P5: Attribute references are substituted for attribute values.
Communicate-P

Function Category Subcategory

COMMUNICATE-P 

(CM-P): Develop and 

implement 

appropriate 

activities to enable 

organizations and 

individuals to have a 

reliable 

understanding and 

engage in a dialogue 

about how data are 

processed and 

associated privacy 

risks.

Communication Policies, Processes, and Procedures 

(CM.PO-P): Policies, processes, and procedures are 

maintained and used to increase transparency of the 

organization’s data processing practices (e.g., 

purpose, scope, roles and responsibilities in the data 

processing ecosystem, and management 

commitment) and associated privacy risks.

CM.PO-P1: Transparency policies, processes, and procedures for communicating data 

processing purposes, practices, and associated privacy risks are established and in place.

CM.PO-P2: Roles and responsibilities (e.g., public relations) for communicating data 

processing purposes, practices, and associated privacy risks are established.

Data Processing Awareness (CM.AW-P): Individuals 

and organizations have reliable knowledge about 

data processing practices and associated privacy 

risks, and effective mechanisms are used and 

maintained to increase predictability consistent with 

the organization’s risk strategy to protect individuals’ 

privacy. 

CM.AW-P1: Mechanisms (e.g., notices, internal or public reports) for communicating 

data processing purposes, practices, associated privacy risks, and options for enabling 

individuals’ data processing preferences and requests are established and in place.

CM.AW-P2: Mechanisms for obtaining feedback from individuals (e.g., surveys or focus 

groups) about data processing and associated privacy risks are established and in place.

CM.AW-P3: System/product/service design enables data processing visibility.

CM.AW-P4: Records of data disclosures and sharing are maintained and can be 

accessed for review or transmission/disclosure.

CM.AW-P5: Data corrections or deletions can be communicated to individuals or 

organizations (e.g., data sources) in the data processing ecosystem.

CM.AW-P6: Data provenance and lineage are maintained and can be accessed for 

review or transmission/disclosure.

CM.AW-P7: Impacted individuals and organizations are notified about a privacy breach 

or event.

CM.AW-P8: Individuals are provided with mitigation mechanisms (e.g., credit 

monitoring, consent withdrawal, data alteration or deletion) to address impacts of 

problematic data actions.
Protect-P

Function Category Subcategory

PROTECT-P (PR-P):

Develop and 

implement 

appropriate data 

processing 

safeguards.

Data Protection Policies, Processes, and 

Procedures (PR.PO-P): Security and privacy 

policies (e.g., purpose, scope, roles and 

responsibilities in the data processing ecosystem, 

and management commitment), processes, and 

procedures are maintained and used to manage 

the protection of data.

PR.PO-P1: A baseline configuration of information technology is created and maintained 

incorporating security principles (e.g., concept of least functionality).

PR.PO-P2: Configuration change control processes are established and in place.

PR.PO-P3: Backups of information are conducted, maintained, and tested.

PR.PO-P4: Policy and regulations regarding the physical operating environment for 

organizational assets are met.

PR.PO-P5: Protection processes are improved.

PR.PO-P6: Effectiveness of protection technologies is shared.

PR.PO-P7: Response plans (Incident Response and Business Continuity) and recovery 

plans (Incident Recovery and Disaster Recovery) are established, in place, and managed.

PR.PO-P8: Response and recovery plans are tested.

PR.PO-P9: Privacy procedures are included in human resources practices (e.g., 

deprovisioning, personnel screening).

PR.PO-P10: A vulnerability management plan is developed and implemented.

Identity Management, Authentication, and 

Access Control (PR.AC-P): Access to data and 

devices is limited to authorized individuals, 

processes, and devices, and is managed consistent 

with the assessed risk of unauthorized access.

PR.AC-P1: Identities and credentials are issued, managed, verified, revoked, and audited 

for authorized individuals, processes, and devices.

PR.AC-P2: Physical access to data and devices is managed.

PR.AC-P3: Remote access is managed.

PR.AC-P4: Access permissions and authorizations are managed, incorporating the 

principles of least privilege and separation of duties.

PR.AC-P5: Network integrity is protected (e.g., network segregation, network 

segmentation).

PR.AC-P6: Individuals and devices are proofed and bound to credentials, and 

authenticated commensurate with the risk of the transaction (e.g., individuals’ security 

and privacy risks and other organizational risks).
Protect-P (continued)

Function Category Subcategory

Data Security (PR.DS-P): Data are managed 

consistent with the organization’s risk strategy to 

protect individuals’ privacy and maintain data 

confidentiality, integrity, and availability.

PR.DS-P1: Data-at-rest are protected.

PR.DS-P2: Data-in-transit are protected.

PR.DS-P3: Systems/products/services and associated data are formally managed 

throughout removal, transfers, and disposition.

PR.DS-P4: Adequate capacity to ensure availability is maintained.

PR.DS-P5: Protections against data leaks are implemented.

PR.DS-P6: Integrity checking mechanisms are used to verify software, firmware, and 

information integrity.

PR.DS-P7: The development and testing environment(s) are separate from the 

production environment.

PR.DS-P8: Integrity checking mechanisms are used to verify hardware integrity.

Maintenance (PR.MA-P): System maintenance 

and repairs are performed consistent with policies, 

processes, and procedures.

PR.MA-P1: Maintenance and repair of organizational assets are performed and 

logged, with approved and controlled tools.

PR.MA-P2: Remote maintenance of organizational assets is approved, logged, and 

performed in a manner that prevents unauthorized access.

Protective Technology (PR.PT-P): Technical 

security solutions are managed to ensure the 

security and resilience of 

systems/products/services and associated data, 

consistent with related policies, processes, 

procedures, and agreements.

PR.PT-P1: Removable media is protected and its use restricted according to policy.

PR.PT-P2: The principle of least functionality is incorporated by configuring systems 

to provide only essential capabilities.

PR.PT-P3: Communications and control networks are protected.

PR.PT-P4: Mechanisms (e.g., failsafe, load balancing, hot swap) are implemented to 

achieve resilience requirements in normal and adverse situations.
NEXT STEPS
Adopt me!

• Lead on privacy

• Provide 

implementation 

feedback

• Contribute resources to 

the NIST’s Resource 

Repository
Roadmap

• Privacy Risk Assessment

• Mechanisms to Provide Confidence

• Emerging Technologies

• De-Identification Techniques and Re-identification Risks

• Inventory and Mapping

• Technical Standards

• Privacy Workforce

• International and Regulatory Aspects, Impacts and Alignment
Resources

Website

https://www.nist.gov/privacyframework

Mailing List 

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