What evidence do auditors commonly ask for on SI-19(6) De-identification | Differential Privacy?

System and information integrity policy; System and information integrity procedures; Personally identifiable information processing policy; De-identification procedures; System configuration; De-identified datasets.

What is the most common gap auditors find on SI-19(6)?

Reported results of mathematical operations add no noise to prevent PII disclosure

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

`SI-19(6)` De-identification | Differential Privacy

Prevent disclosure of personally identifiable information by adding non-deterministic noise to the results of mathematical operations before the results are reported.

Source: NIST SP 800-53 Rev 5, SI-19(6). 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

periodic reviewEvidence produced at each review

Test of Online query systems; automated mechanisms supporting and/or implementing differential privacy · Data governance / DLP tooling

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
De-identified datasets · Document repository
Differential privacy tools · Policy repository / GRC workspace
System security plan · Policy repository / GRC workspace
Privacy plan · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact 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

Reported results of mathematical operations add no noise to prevent PII disclosure
The privacy budget for differential privacy was never defined or tracked

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(5) De-identification | Statistical Disclosure Control · SI-19(7) De-identification | Validated Algorithms and Software