What evidence do auditors commonly ask for on SI-19 De-identification?

System and information integrity policy; System and information integrity procedures; Personally identifiable information processing policy; De-identification procedures; System configuration; Datasets with personally identifiable information removed.

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

The PII elements to remove from datasets were never defined

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

`SI-19` De-identification

a. Remove the following elements of personally identifiable information from datasets: organization-defined elements of personally identifiable information; and b. Evaluate organization-defined frequency for effectiveness of de-identification.

Source: NIST SP 800-53 Rev 5, SI-19. 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 supporting and/or implementing the removal of personally identifiable information elements · Document repository

periodic reviewEvidence produced at each review

Privacy impact assessment · 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
Datasets with personally identifiable information removed · 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

The PII elements to remove from datasets were never defined
Effectiveness of de-identification is not evaluated at the defined frequency

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-18(5) Personally Identifiable Information Quality Operations | Notice of Correction or Deletion · SI-19(1) De-identification | Collection