Information 

Technology & 

Telecommunications 

April l,2019 

Katie MacFarland 

National Institute of Standards and Technology 

100 Bureau Drive, Stop 2000, 

Gaithersburg, MD 20899 

Re: NIST Privacy Framework 

Dear Ms. MacFarland: 

The General Counsel to the Department of Information Technology and Telecommunications ("DoITT") 

and Cyber Command (''NYC3"), the Chief Privacy Officer ("CPO"), and the interim Chief Technology 

Officer ("CTO") of the City of New York, submit this comment in response to the request for information 

issued by the National Institute of Standards and Technology (''NIST") inviting public comment on the 

development of its Privacy Framework. 

The City of New York ("City") recognizes the importance of a.Privacy Framework that manages privacy 

risk for individuals arising from the collection, storage, use, and sharing of their information. Both the 

City and its populace benefit when individuals can seek and access important services with confidence 

that their personal information will be appropriately and responsibly protected. To that end, the City has 

advanced a privacy and security framework to address privacy risks. For NIST' s greater awareness, we 

would like to share a few notable components of the framework. 

First, the City has designated a CPO dedicated to protecting the privacy of New Yorkers· with respect to 

how City agencies and contractors and subcontractors for human services collect and use identifying 

information. Second, the City has established NYC3, headed by the New York City Chief Information 

Security Officer, to address evolving cyber risks and establish an information security framework to 

achieve the City's collective confidentiality goals. Third, the Mayor's Office of the CTO addresses highpriority gaps for which privacy guidelines and standards are needed to increase digitai privacy protections 

for consumers outside of their interactions with local government. 

. The City agrees with recommendations made by other commenters that the Privacy Framework be 

developed and implemented with ongoing.stakeholder engagement. Such a feedback loop can ensure that 

the privacy standards set forth are adaptable across a wide range of sectors. With this in mind, the City 

asks that NIST include state and local government offices and units that have vested interests in 

advancing privacy protection initiatives and best practices, Including such government actors will ensure 

that the Privacy Framework is adaptable across programs that may be unique to the public sector, 

including but not limited to in the context of social services, health and human services, and other such 

areas where personal information must be accessed, transmitted, and retained in order to implement and 

deliver programs and services. 

Michael ·Pastor, General Counsel • 15 Metrotech Center, Brooklyn, NY 11201 • Phone 718-403-8063 • mpastor@doitt.nyc.gov 
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