EvidenceSheet
NIST SP 800-53 Rev 5 · SI - System and Information Integrity

SI-12(2) Information Management and Retention | Minimize Personally Identifiable Information in Testing, Training, and…

Use the following techniques to minimize the use of personally identifiable information for research, testing, or training: organization-defined techniques.

Source: NIST SP 800-53 Rev 5, SI-12(2). 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.

10
artefacts
0
held by a system
1
at each review
hard
to go live
Policy repository / GRC workspace
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

  • Test of Organizational processes for the minimization of personally identifiable information used in testing, training, and research; automated mechanisms supporting and/or implementing the minimization of personally identifiable information used in testing, training, and research · HR system / LMS

governing documentDocuments that govern the control

  • System and information integrity policy · Policy repository / GRC workspace
  • System and information integrity procedures · Policy repository / GRC workspace
  • Personally identifiable information processing policy · Policy repository / GRC workspace
  • Personally identifiable information processing procedures · Policy repository / GRC workspace
  • Federal laws, Executive Orders, directives, policies, regulations, standards, and operational requirements applicable to minimizing the use of personally identifiable information in testing, training, and research · HR system / LMS
  • List of approved minimisation techniques (masking, tokenisation, synthetic data, de-identification) with the data sets each applies to · Policy repository / GRC workspace
  • Procedures for the minimization of personally identifiable information used in testing, training, and research · HR system / LMS
  • Documentation supporting minimization 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.

Build my evidence sheet

SI-12(1) Information Management and Retention | Limit Personally Identifiable Information Elements · SI-12(3) Information Management and Retention | Information Disposal