PT-3: Personally Identifiable Information Processing Purposes

RMF Control PT-3: Personally Identifiable Information Processing Purposes requires organizations to identify and document the purpose(s) for processing personally identifiable information (PII), describe the purpose(s) in the public privacy notices and policies of the organization, restrict the processing of PII to only that which is compatible with the identified purpose(s), and monitor changes in processing PII and implement mechanisms to ensure that any changes are made in accordance with the identified and documented requirements.

Supplemental Guidance

The Risk Management Framework (RMF) is a cybersecurity framework that provides a process for managing cybersecurity risk to systems and organizations. RMF Control PT-3: Personally Identifiable Information Processing Purposes is one of the controls in the PT family, which addresses privacy.

Personally identifiable information (PII) is any information that can be used to identify an individual. This can include information such as name, social security number, date of birth, address, and phone number.

Organizations that collect, store, or process PII have a responsibility to protect it. One way to do this is to identify and document the purpose(s) for processing PII. This helps to ensure that PII is only processed for legitimate purposes and that it is not used in a way that is inconsistent with those purposes.

Benefits of Implementing RMF Control PT-3

There are a number of benefits to implementing RMF Control PT-3, including:

• Improved privacy posture: By identifying and documenting the purpose(s) for processing PII, organizations can improve their overall privacy posture.
• Reduced risk of privacy violations: Privacy violations can occur when PII is processed for purposes that are not authorized or when it is used in a way that is inconsistent with those purposes. By implementing RMF Control PT-3, organizations can reduce the risk of these privacy violations.
• Improved compliance: Many regulations require organizations to identify and document the purpose(s) for processing PII. By implementing RMF Control PT-3, organizations can improve their compliance with these regulations.

How to Implement RMF Control PT-3

To implement RMF Control PT-3, organizations should:

1. Identify all systems and processes that collect, store, or process PII.
2. For each system and process, identify the purpose(s) for processing PII.
3. Document the purpose(s) for processing PII in a privacy policy or other document.
4. Make the privacy policy or other document publicly available.
5. Restrict the processing of PII to only that which is compatible with the identified purpose(s).
6. Monitor changes in processing PII and implement mechanisms to ensure that any changes are made in accordance with the identified and documented requirements.

Examples of Personally Identifiable Information

Some examples of personally identifiable information (PII) include:

• Name
• Social security number
• Date of birth
• Address
• Phone number
• Email address
• IP address
• Credit card number
• Driver’s license number
• Passport number
• Biometric data (e.g., fingerprints, facial scans)

Conclusion

RMF Control PT-3: Personally Identifiable Information Processing Purposes is an important control that can help organizations to improve their privacy posture, reduce the risk of privacy violations, and improve their compliance. By identifying and documenting the purpose(s) for processing PII, organizations can ensure that PII is only processed for legitimate purposes and that it is not used in a way that is inconsistent with those purposes.

Additional Tips for Implementing RMF Control PT-3

• Involve stakeholders in the PII processing purpose identification and documentation process: Organizations should involve stakeholders, such as IT staff, security staff, and business owners, in the PII processing purpose identification and documentation process. This will help to ensure that the PII processing purposes are aligned with the organization’s business needs and privacy requirements.
• Use a risk-based approach to PII processing purpose identification and documentation: Organizations should use a risk-based approach to PII processing purpose identification and documentation to ensure that the most sensitive PII has the most clearly defined and documented processing purposes.
• Regularly review and update the PII processing purpose identification and documentation: Organizations should regularly review and update the PII processing purpose identification and documentation to ensure that it is effective and up-to-date.