Control statement
- a.Develop, document, and implement policies and procedures that address the use of personally identifiable information for internal testing, training, and research;
- b.Limit or minimize the amount of personally identifiable information used for internal testing, training, and research purposes;
- c.Authorize the use of personally identifiable information when such information is required for internal testing, training, and research; and
- d.Review and update policies and procedures [Organization-defined: organization-defined frequency].
Discussion
The use of personally identifiable information in testing, research, and training increases the risk of unauthorized disclosure or misuse of such information. Organizations consult with the senior agency official for privacy and/or legal counsel to ensure that the use of personally identifiable information in testing, training, and research is compatible with the original purpose for which it was collected. When possible, organizations use placeholder data to avoid exposure of personally identifiable information when conducting testing, training, and research.
Organization-defined parameters
These values must be resolved through the organization’s tailoring and governance process. Bracketed parameter references in the control text identify where a decision is required.
From control text to operational evidence
Use Minimization of Personally Identifiable Information Used in Testing, Training, and Research as a testable risk decision. Translate the official statement into accountable people, repeatable processes, configured technology, and evidence that demonstrates the outcome over time. In this family, pay particular attention to enterprise program governance, accountability, resources, metrics, and organization-wide risk decisions.
Implementation workflow
- Define the control boundary, responsible owner, inherited portions, and systems or processes in scope.
- Resolve each organization-defined parameter before declaring the control implemented.
- Document how the implementation satisfies every clause of the official control statement.
- Collect evidence as a normal byproduct of operation rather than only before an assessment.
- Review exceptions, changes, and monitoring results on a risk-based cadence.
Evidence examples
- program charters and policies
- governance meeting records
- risk and performance metrics
- resource and responsibility assignments
Common failure patterns
- program metrics count activity instead of outcomes
- system-level risks never reach enterprise governance
- responsibilities assigned without authority or resources
- privacy and security managed in separate silos
Questions practitioners should ask
- What risk decision is this control intended to support in this system?
- Which parts are implemented locally, inherited, shared, or not applicable—and what evidence supports that decision?
- Do the documented narrative, deployed configuration, operating process, and collected evidence agree?
- What event or threshold requires the implementation to be reviewed or changed?
Assessment objectives and methods
Show the assessment objective
- PM-25a.
- PM-25a.[01]policies that address the use of personally identifiable information for internal testing are developed and documented;
- PM-25a.[02]policies that address the use of personally identifiable information for internal training are developed and documented;
- PM-25a.[03]policies that address the use of personally identifiable information for internal research are developed and documented;
- PM-25a.[04]procedures that address the use of personally identifiable information for internal testing are developed and documented;
- PM-25a.[05]procedures that address the use of personally identifiable information for internal training are developed and documented;
- PM-25a.[06]procedures that address the use of personally identifiable information for internal research are developed and documented;
- PM-25a.[07]policies that address the use of personally identifiable information for internal testing, are implemented;
- PM-25a.[08]policies that address the use of personally identifiable information for training are implemented;
- PM-25a.[09]policies that address the use of personally identifiable information for research are implemented;
- PM-25a.[10]procedures that address the use of personally identifiable information for internal testing are implemented;
- PM-25a.[11]procedures that address the use of personally identifiable information for training are implemented;
- PM-25a.[12]procedures that address the use of personally identifiable information for research are implemented;
- PM-25b.
- PM-25b.[01]the amount of personally identifiable information used for internal testing purposes is limited or minimized;
- PM-25b.[02]the amount of personally identifiable information used for internal training purposes is limited or minimized;
- PM-25b.[03]the amount of personally identifiable information used for internal research purposes is limited or minimized;
- PM-25c.
- PM-25c.[01]the required use of personally identifiable information for internal testing is authorized;
- PM-25c.[02]the required use of personally identifiable information for internal training is authorized;
- PM-25c.[03]the required use of personally identifiable information for internal research is authorized;
- PM-25d.
- PM-25d.[01]policies are reviewed [Organization-defined: frequency];
- PM-25d.[02]policies are updated [Organization-defined: frequency];
- PM-25d.[03]procedures are reviewed [Organization-defined: frequency];
- PM-25d.[04]procedures are updated [Organization-defined: frequency].
Examine
- Privacy program plan
- policies and procedures for the minimization of personally identifiable information used in testing, training, and research
- documentation supporting policy implementation (e.g., templates for testing, training, and research
- privacy threshold analysis
- privacy risk assessment)
- data sets used for testing, training, and research
Interview
- Organizational personnel with privacy program responsibilities
- organizational personnel with privacy responsibilities
- system developers
- personnel with IRB responsibilities
Test
- Organizational processes for data quality and personally identifiable information management
- mechanisms supporting data quality management and personally identifiable information management to minimize the use of personally identifiable information
Related controls
These relationships come from the official OSCAL catalog. They indicate useful dependencies or context, not automatic inheritance or equivalence.
Authoritative sources
Bare Metal Cyber is an independent educational publisher and is not affiliated with or endorsed by NIST. Official control requirements and interpretations remain with NIST and the responsible authorizing organization.