Supplemental Material for NIST Privacy Framework Workshop #3 6/26/2019

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1 Proposed Separated Core

2 Proposed Version of the NIST Privacy Framework Core without Data Security

3 Note to Reviewers

4 This Separated Core is provided for discussion purposes to promote the development of the NIST Privacy 

5 Framework: An Enterprise Risk Management Tool (Privacy Framework). In response to stakeholder 

6 feedback received on the Privacy Framework Discussion Draft (Discussion Draft), released April 30, 2019, 

7 NIST has prepared two different, updated versions of the Core for feedback.

8 The two proposed Cores offer different levels of alignment with the Framework for Improving Critical 

9 Infrastructure Cybersecurity (Cybersecurity Framework). For this Separated Core, NIST has removed the 

10 overlapping Cybersecurity Framework Functions, Categories, Subcategories that pertain to data security. 

11 Organizations that want to manage the data security aspect of privacy risk should use the Cybersecurity 

12 Framework Core. In contrast, for the Integrated Core, NIST has maintained a number of data security 

13 Functions, Categories, and Subcategories that overlap with the Cybersecurity Framework.

14 In addition, each Core contains the same updates based on specific feedback on the Discussion Draft 

15 Core. See below for a summary of material changes. 

16 NIST is particularly interested in feedback on: (i) which proposed Core is preferred by stakeholders, (ii) 

17 why that proposed Core is preferred; and (iii) any additional changes to either of the proposed Cores to 

18 support organizations’ needs with respect to managing privacy risk.

19 Please send feedback on the proposed Core versions to privacyframework@nist.gov. NIST will use 

20 feedback on this document to inform the development of a preliminary draft of the Privacy Framework.

21 Summary of Material Changes from the Discussion Draft Core

22 The Separated Core retains three of the five Functions presented in the Discussion Draft (Identify, 

23 Control, and Communicate), with some modifications: creation of a new Function, Govern, that splits off 

24 some Categories from Identify, and renaming Inform to Communicate. This version removes the 

25 Functions Protect and Respond that support the data security aspect of privacy risk,. Figure 1 was added 

26 to show the general categorical relationships between the Functions. Protect, Detect, Respond, and 

27 Recover from the Cybersecurity Framework are greyed out in this figure as they are not part of the 

28 Privacy Framework, but organizations can find these Functions in the Cybersecurity Framework, and use 

29 them to support the management of the data security aspect of privacy risk. Throughout the Core’s 

30 Categories and Subcategories, NIST added several examples in the form of parentheticals to make the 

31 outcome statements more readily understood by organizations. The table below provides a summary of 

32 material changes only. Clarifying or editorial edits to the text are not included.

33

Function Material Changes

Identify 

(ID-P)

Inventory and Mapping (ID.IM-P)

• Added two Subcategories: ID.IM-P3 and ID.IM-P5 (previously ID.RA-P1)

Business Environment (ID.BE-P)

• Changed use of the term “supply chain risk management” to “data processing

ecosystem” in ID.BE-P1; “data processing ecosystem” is now a defined term in the

updated Glossary
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Function Material Changes

Risk Assessment (ID.RA-P)

• Relocated and modified ID.RA-P2 (previously IN.AW-P7) from Inform

• Relocated ID.RA-P1 to Inventory and Mapping (see above)

Data Processing Ecosystem Risk Management (ID.DE-P)

• Changed use of the term “supply chain” terminology to “data processing 

ecosystem” terminology throughout the Core and changed identifiers from SC to 

DE; “data processing ecosystem” is now a defined term in the updated Glossary

• Added a new Subcategory ID.DE-P4

• Removed previous ID.SC-P5 because it is sufficiently addressed by ID.DE-P5

Govern 

(GV-P)

[New 

Function]

Governance Policies, Processes, and Procedures (GV.PP-P)

• Relocated this Category from Identify (previously Governance [ID.GV-P])

Risk Management Strategy (GV.RM-P)

• Relocated this Category from Identify (previously ID.RM-P)

Awareness and Training (GV.AT-P)

• Relocated this Category from Protect (previously PR.AT-P)

Monitoring (GV.MT-P) [New Category]

• Created new Category statement

• Created seven Subcategories: GV.MT-P1 (previously ID.RA-P6) was relocated from 

Identify; three new Subcategories (GV.MT-P2 through P4); and GV.MT-P5, GV.MTP6, and GV.MT-P7 (previously RS.AN-P5, RS.IM-P1, and RS.RE-P1, respectively)

were relocated from Respond

Protect

(PR-P)

[Removed]

• Removed Protect Function, but relocated Awareness and Training (previously 

PR.AT-P) and Protected Processing (previously PR.PP-P) to Govern and Control, 

respectively

Control

(CT-P)

Data Management Policies, Processes, and Procedures (CT.PO-P)

• Modified CT.PO-P1 to address individual consent and revocation and incorporate

the previous CT.DM-P2

• Relocated and modified CT.PO-P4 (previously PR.DP-P2) from Protect 

Data Management (CT.DM-P)

• Relocated CT.DM-P5 and P8 (previously PR.DP-P6 and PR.PT-P1, respectively) from 

Protect

Data Minimization (CT.MN-P) [New Category]

• Renamed Category (previously Protected Processing [PR.PP-P])

• Created seven Subcategories: CT.MN-P1 through P5 (previously PR.PP-P1 through 

P5) were relocated from Protected Processing in Protect; CT.MN-P6 (previously 

CT.DM-P1) was relocated from Data Management in Control; and CT.MN-P7 

(previously PR.AC-P7) was relocated from Identity Management, Authentication,

and Access Control in Protect 
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Function Material Changes

Communicate

(CM-P)

[Previously

Inform (INP)]

Communication Policies, Processes, and Procedures (CM.PP-P)

• Renamed Category (previously Transparency Processes and Procedures [IN.TP-P])

• Modified CM.PP-P1 to incorporates policies, processes and procedures for 

communicating (previously addressed by two Subcategories, IN.TP-P1 and P2)

• Added new Subcategory CM.PP-P2 to address communication roles and 

responsibilities 

Data Processing Awareness (CM.AW-P)

• Modified CM.AW-P1 (previously IN.AW-P2) to focus on mechanisms for 

communicating and included examples of such mechanisms

• Modified CM.AW-P4 (previously IN.AW-P1) to include records of data disclosures 

can be accessed for review or transmission/disclosure

• Modified CM.AW-P5 and combined two Subcategories (previous IN.AW-P4 and P5) 

to include communication of data corrections or deletions to both individuals and 

organizations (e.g., data sources)

• Modified CM.AW-P6 to add data lineage and capability for access for review or 

transmission/disclosure

• Relocated CM.AW-P7 and P8 (previously RS.CO-P6 and RS.RE-P2, respectively)

from Respond

Respond

(RS-P)

[Removed]

• Removed Respond Function, but relocated some Subcategories to Govern and 

Communicate (see above)

34 Appendix A: Privacy Framework Core

35 This appendix presents the Core: a table of Functions, Categories, and Subcategories that describe 

36 specific privacy activities that can support managing privacy risks when systems, products, and services 

37 are processing data. 

38 Notes to Users

39 Under the Privacy Framework's risk-based approach:

40 1. An organization may not need to achieve every outcome or activity reflected in the Core. It is 

41 expected that an organization will use Profiles to select and prioritize the Functions, Categories, 

42 and Subcategories that best meet its specific needs by considering its organizational or industry 

43 sector goals, legal/regulatory requirements and industry best practices, the organization’s risk 

44 management priorities, and the privacy needs of individuals who are directly or indirectly served 

45 or affected by the organization’s systems, products, or services. Thus, the Subcategories should 

46 not be read as a checklist in isolation from their Categories, which often provide a risk-based 

47 modifier on Subcategory selection.

48 2. It is not obligatory to achieve an outcome in its entirety. An organization may use its Profiles to 

49 express partial achievement of an outcome, as not all aspects of an outcome may be relevant 

50 for the organization to manage privacy risk, or the organization may use a Target Profile to 

51 express an aspect of an outcome that it doesn’t currently have the capability to achieve.

52 1) It may be necessary to consider multiple outcomes in combination in order to appropriately 

53 manage privacy risk. For example, an organization that responds to individuals’ requests for data 

54 access may select for its Profile both the Subcategory: CT.DM-P1: Data elements can be 
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55 accessed for review and the Category: Identity Management, Authentication, and Access Control 

56 (PR.AC-P) to ensure that only the individual to whom the data pertain gets access. 

57 Implementation: The table format of the Core is not intended to suggest a specific implementation 

58 order or imply a degree of importance between the Functions, Categories and Subcategories. 

59 Implementation may be non-sequential, simultaneous, or iterative, depending on the SDLC stage, status 

60 of the privacy program, or scale of the workforce. In addition, the Core is not exhaustive; it is extensible, 

61 allowing organizations, sectors, and other entities to adapt or add additional Functions, Categories and

62 Subcategories to their Profiles.

63 Roles: 

64 • Workforce: Different parts of an organization’s workforce may take responsibility for different 

65 Categories or Subcategories. For example, the legal department may be responsible for carrying 

66 out activities under Governance Processes and Procedures while the IT department is working 

67 on Inventory and Mapping. Ideally, the Core encourages cross-organization collaboration to 

68 develop Profiles and achieve outcomes.

69 • Ecosystem: The Core is intended to be usable by any organization or entity regardless of its role 

70 in the data processing ecosystem. Although the Privacy Framework does not classify ecosystem 

71 roles, an organization should review the Core from its standpoint in the ecosystem. An 

72 organization’s role(s) may be legally codified – for example, some laws classify organizations as 

73 data controllers or data processors – or classifications may be derived from industry 

74 designations. Since Core elements are not assigned by ecosystem role, an organization can use 

75 its Profiles to select Functions, Categories, and Subcategories that are relevant to its role(s).

76 Scalability: Certain aspects of outcomes may be ambiguously worded. For example, outcomes may 

77 include terms like “communicated” or “disclosed” without stating to whom the communications or 

78 disclosures are being made. The ambiguity is intentional to allow for a wide range of organizations with 

79 different use cases to determine what is appropriate or required in a given context.

80 Resource Repository: Additional supporting resources, including informative references that can 

81 provide more guidance on how to achieve an outcome can be found on the NIST website at

82 https://www.nist.gov/privacy-framework.

83 Cybersecurity Framework Alignment: 

84 • Figure 1 shows the general categorical relationships between the Functions: Identify and Govern 

85 are primarily organizational-level or contain foundational outcomes and activities. Control, 

86 Communicate, and Protect are primarily system/product/service-level and contain outcomes 

87 and activities that may not be applicable for all systems, products, and services or to the same 

88 degree, and Detect, Respond, and Recover are primarily incident-related. The Functions Protect, 

89 Detect, Respond, and Recover are greyed out in Figure 1 and Table 1 as they are not part of the 

90 Privacy Framework, but organizations can find these Functions in the Cybersecurity Framework, 

91 and use them to support the management of the data security aspect of privacy risk. 

92 • Certain Functions, Categories, or Subcategories are identical to or have been adapted from the

93 Cybersecurity Framework. The following legend can be used to identify this relationship in Table 

94 2.

95

96 The Category or Subcategory is identical to the Cybersecurity 

Framework.

The Function, Category, or Subcategory aligns with the Cybersecurity 

Framework, but the text has been adapted for the Privacy Framework.
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97 Core Identifiers: For ease of use, each component of the Core is given a unique identifier. Functions and 

98 Categories each have a unique alphabetic identifier, as shown in Table 1. Subcategories within each 

99 Category have a number added to the alphabetic identifier; the unique identifier for each Subcategory is 

100 included in Table 2. 

101 Figure 1: Privacy and Cybersecurity Framework Functions

102

103 Table 1: Privacy and Cybersecurity Framework Function and Category Unique Identifiers

Function 

Unique 

Identifier

Function Category 

Unique 

Identifier

Category

ID-P Identify-P ID.IM-P Inventory and Mapping

ID.BE-P Business Environment

ID.RA-P Risk Assessment

ID.DE-P Data Processing Ecosystem Risk Management

GV-PP Govern-P GV.PP-P Governance Policies, Processes, and 

Procedures

GV.RM-P Risk Management Strategy

GV.AT-P Awareness and Training

GV.MT-P Monitoring

CT-P Control-P CT.PO-P Data Management Policies, Processes, and 

Procedures

CT.DM-P Data Management

CT.MN-P Data Minimization

CM-P Communicate-P CM.PP-P Communication Policies, Processes, and 

Procedures

DETECT RESPOND RECOVER

CONTROL COMMUNICATE

IDENTIFY GOVERN

PROTECT
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CM.AW-P Data Processing Awareness

PR Protect PR.AC Identity Management and Access Control

PR.AT Awareness and Training

PR.DS Data Security

PR.IP Information Protection Processes and 

Procedures

PR.MA Maintenance

PR.PT Protective Technology

DE Detect DE.AE Anomalies and Events

DE.CM Security Continuous Monitoring

DE.DP Detection Processes

RS Respond RS.RP Response Planning

RS.CO Communications

RS.AN Analysis

RS.MI Mitigation

RS.IM Improvements

RC Recover RC.RP Recovery Planning

RC.IM Improvements

RC.CO Communications
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105 Table 2: Privacy Framework Core

Function Category Subcategory

IDENTIFY-P 

(ID-P): 

Develop the 

organizationa

l 

understandin

g to manage 

privacy risk 

for 

individuals 

arising from 

system, 

product, or 

service data 

processing.

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

processing by systems, products, or services 

are understood and inform 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, developers, etc.) 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, second tier customers) 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 understood (e.g., 

geographic location, internal, cloud, third parties).

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

associated data elements by systems/products/services, including 

components (e.g., internal or external); 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 in the data processing ecosystem is 

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 functional requirements 

communicated.

Risk Assessment (ID.RA-P): The 

organization understands the privacy risks 

to individuals and how such privacy risks 

may create secondary impacts on 

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, visibility of data 

processing to individuals and third parties). 
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Function Category Subcategory

organizational operations, including 

mission, functions, other risk management 

priorities (e.g. compliance, financial), 

reputation, workforce, and culture.

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 tolerances, 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 processes 

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 or framework obligations.

GOVERN-P (GVP):

Develop and 

implement the 

organizational 

governance 

structure to 

enable an 

Governance Policies, Processes, and 

Procedures (GV.PP-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.PP-P1: Organizational privacy values and policies (e.g., conditions 

on data processing, individuals’ prerogatives with respect to data 

processing) are established and communicated.

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

system/product/service development and operations are established 

and in place.

GV.PP-P3: Roles and responsibilities for the workforce are 

established with respect to privacy. 
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Function Category Subcategory

ongoing 

understanding 

of the 

organization’s 

risk 

management 

priorities that 

are informed by 

privacy risk.

GV.PP-P4: Privacy roles and responsibilities are coordinated and 

aligned with third-party stakeholders (e.g., service providers, 

customers, partners).

GV.PP-P5: Legal, regulatory, and contractual requirements regarding 

privacy are understood and managed.

GV.PP-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 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 privacy-related 

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.

Monitoring (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, governance 

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

systems/products/services change.

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

are communicated. 

GV.MT-P3: Policies, processes, and procedures for auditing compliance 

with legal requirements and privacy policies are established and in 

place.
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Function Category Subcategory

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).

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 (CTP): Develop and 

implement 

appropriate 

activities to 

enable 

organizations or 

individuals to 

manage data 

with sufficient 

granularity to 

manage privacy 

risks.

Data Management Policies, Processes, and 

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

procedures are maintained and used to 

manage data processing (e.g., purpose, scope, 

roles, responsibilities, management 

commitment, and coordination among 

organizational entities) 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, 

transmission or disclosure, alteration, and deletion are established and

in place.

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

data processing preferences and requests are established and in place.

CT.PO-P4: An information life cycle to manage data is aligned and 

implemented with the system development life cycle to manage 

systems.

Data 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: Metadata containing processing permissions and related 

data values are transmitted with data elements.
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Function Category Subcategory

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

implemented, and reviewed in accordance with policy and 

incorporating the principle of data minimization.

Data Minimization (CT.MN-P): Technical data 

processing solutions increase disassociability

consistent with related policies, processes, 

procedures, and agreements and the 

organization’s risk strategy to protect 

individuals’ privacy.

CT.MN-P1: Data are processed in an unobservable or unlinkable 

manner.

CT.MN-P2: Data are processed to limit the identification of individuals.

CT.MN-P3: Data are processed to restrict the formulation of inferences 

about individuals’ behavior or activities.

CT.MN-P4: Data processing is decentralized.

CT.MN-P5: Data actions take place on local devices.

CT.MN-P6: System or device configurations permit selective collection 

or disclosure of data elements.

CT.MN-P7: Attribute references are substituted for attribute values.

COMMUNICATE

-P (CM-P):

Develop and

implement

appropriate

activities to

enable

organizations

and individuals

to have a

reliable

understanding

about how data

are processed

and associated

privacy risks.

Communication Policies, Processes, and 

Procedures (CM.PP-P): Policies, processes,

and procedures are maintained and used to 

increase transparency of the organization’s 

data processing practices (e.g., purpose, 

scope, roles, responsibilities, management 

commitment, and coordination among 

organizational entities) and associated privacy 

risks.

CM.PP-P1: Transparency policies, processes, and procedures for

communicating data processing purposes, practices, and associated

privacy risks are established and in place.

CM.PP-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 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.
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Function Category Subcategory

CM.AW-P4: Records of data disclosures 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).

CM.AW-P6: Data lineage and provenance 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 to 

address impacts to individuals that arise from data processing.

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