EvidenceSheet
NIST SP 800-53 Rev 5 · PT - PII Processing and Transparency

PT-3(1) Personally Identifiable Information Processing Purposes | Data Tagging

Attach data tags containing the following purposes to organization-defined elements of personally identifiable information: organization-defined processing purposes.

Source: NIST SP 800-53 Rev 5, PT-3(1). 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.

6
artefacts
1
held by a system
1
at each review
hard
to go live
Document repository
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

  • Data extracts with corresponding data tags · Document repository

periodic reviewEvidence produced at each review

  • Test of Organizational processes for authorizing the processing of personally identifiable information; mechanisms supporting and/or implementing data tagging · Document repository

governing documentDocuments that govern the control

  • Personally identifiable information processing and transparency policy and procedures · Policy repository / GRC workspace
  • Documented description of how data tags are used to identify personally identifiable information data elements and their authorized uses · Document repository
  • Data tag schema · Document repository
  • Privacy plan · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Document repository on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

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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PT-3 Personally Identifiable Information Processing Purposes · PT-3(2) Personally Identifiable Information Processing Purposes | Automation