RA-8 Privacy Impact Assessments
Conduct privacy impact assessments for systems, programs, or other activities before: a. Developing or procuring information technology that processes personally identifiable information; and b. Initiating a new collection of personally identifiable information that: 1. Will be processed using information technology; and 2. Includes personally identifiable information permitting the physical or virtual (online) contacting of a specific individual, if identical questions have been posed to, or identical reporting requirements imposed on, ten or more individuals, other than agencies, instrumentalities, or employees of the federal government.
Source: NIST SP 800-53 Rev 5, RA-8. 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
- Security and privacy risk assessment reports · Data governance / DLP tooling
- Test of Organizational processes for assessments and audits; mechanisms/tools supporting and/or implementing assessments and auditing · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Risk assessment policy · Policy repository / GRC workspace
- Acquisitions documents · Policy repository / GRC workspace
- System security plan · Policy repository / GRC workspace
- Privacy plan · Policy repository / GRC workspace
First move
Common gaps auditors find
- No privacy impact assessment was conducted before procuring technology that processes PII
- New PII collections began without a privacy impact assessment
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.
Build my evidence sheet