PM-25 Minimization of Personally Identifiable Information Used in Testing, Training, and Research
a. Develop, document, and implement policies and procedures that address the use of personally identifiable information for internal testing, training, and research; b. Limit or minimize the amount of personally identifiable information used for internal testing, training, and research purposes; c. Authorize the use of personally identifiable information when such information is required for internal testing, training, and research; and d. Review and update policies and procedures organization-defined frequency.
Source: NIST SP 800-53 Rev 5, PM-25. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open NIST SP 800-53 Rev 5 in the compliance library.
Base controls and their enhancements. Which apply follows the baseline you are assessed against (for example FedRAMP Moderate or High, or the low, moderate and high baselines of SP 800-53B). Text in square brackets is a parameter your organisation sets.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Privacy threshold analysis · Data governance / DLP tooling
- Privacy risk assessment) · Data governance / DLP tooling
- Test of Organizational processes for data quality and personally identifiable information management; mechanisms supporting data quality management and personally identifiable information management to minimize the use of personally identifiable information · Document repository
governing documentDocuments that govern the control
- Privacy program plan · Policy repository / GRC workspace
- Policies and procedures for the minimization of personally identifiable information used in testing, training, and research · HR system / LMS
- Documentation supporting policy implementation (e.g., templates for testing, training, and research · HR system / LMS
- Data sets used for testing, training, and research · HR system / LMS
First move
Common gaps auditors find
- No policies govern using PII for internal testing, training and research
- The amount of PII used for testing, training and research is not minimized
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
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