What evidence do auditors commonly ask for on SI-19(1) De-identification | Collection?

System and information integrity policy; System and information integrity procedures; Personally identifiable information processing policy; De-identification procedures; Procedures for minimizing the collection of personally identifiable information; System configuration.

What is the most common gap auditors find on SI-19(1)?

Datasets are collected with PII that is not needed rather than de-identified at collection

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

`SI-19(1)` De-identification | Collection

De-identify the dataset upon collection by not collecting personally identifiable information.

Source: NIST SP 800-53 Rev 5, SI-19(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.

artefacts

held by a system

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

System configuration · Cloud console / configuration management
Test of Automated mechanisms preventing the collection of personally identifiable information · Document repository

periodic reviewEvidence produced at each review

none for this control

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
De-identification procedures · Policy repository / GRC workspace
Procedures for minimizing the collection of personally identifiable information · Policy repository / GRC workspace
Data collection mechanisms · Document repository
System security plan · Policy repository / GRC workspace
Privacy plan · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 2 system-held artefacts from your Cloud console / configuration management 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

Datasets are collected with PII that is not needed rather than de-identified at collection
No design decision records why PII must be collected for the dataset

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-19 De-identification · SI-19(2) De-identification | Archiving