EvidenceSheet

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.

7
artefacts
0
held by a system
3
at each review
hard
to go live
HR system / LMS
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

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

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

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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PM-24 Data Integrity Board · PM-26 Complaint Management