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NIST SP 800-53 Learning Center

PT-1 — Policy and Procedures

Read the official control and assessment content, then use the separately labeled Bare Metal Cyber perspective to connect the requirement to implementation, evidence, and sustained operation.

0Enhancements
9Parameters
1Baseline memberships
2Assessment methods

PT — Personally Identifiable Information Processing and Transparency · NIST SP 800-53 Release 5.2.0

Privacy
Official NIST control content

Control statement

  1. a.Develop, document, and disseminate to [Organization-defined: organization-defined personnel or roles]:
    1. 1.[Organization-defined: pt-01_odp.03] personally identifiable information processing and transparency policy that:
      1. (a)Addresses purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance; and
      2. (b)Is consistent with applicable laws, executive orders, directives, regulations, policies, standards, and guidelines; and
    2. 2.Procedures to facilitate the implementation of the personally identifiable information processing and transparency policy and the associated personally identifiable information processing and transparency controls;
  2. b.Designate an [Organization-defined: official] to manage the development, documentation, and dissemination of the personally identifiable information processing and transparency policy and procedures; and
  3. c.Review and update the current personally identifiable information processing and transparency:
    1. 1.Policy [Organization-defined: frequency] and following [Organization-defined: events] ; and
    2. 2.Procedures [Organization-defined: frequency] and following [Organization-defined: events].
Official NIST discussion

Discussion

Personally identifiable information processing and transparency policy and procedures address the controls in the PT family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of personally identifiable information processing and transparency policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to personally identifiable information processing and transparency policy and procedures include assessment or audit findings, breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.

Official OSCAL parameters

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.

organization-defined personnel or roles
personnel or rolespersonnel or roles to whom the personally identifiable information processing and transparency policy is to be disseminated is/are defined;
personnel or rolespersonnel or roles to whom the personally identifiable information processing and transparency procedures are to be disseminated is/are defined;
pt-01_odp.03
officialan official to manage the personally identifiable information processing and transparency policy and procedures is defined;
frequencythe frequency at which the current personally identifiable information processing and transparency policy is reviewed and updated is defined;
eventsevents that would require the current personally identifiable information processing and transparency policy to be reviewed and updated are defined;
frequencythe frequency at which the current personally identifiable information processing and transparency procedures are reviewed and updated is defined;
eventsevents that would require the personally identifiable information processing and transparency procedures to be reviewed and updated are defined;
Original Bare Metal Cyber perspective

From control text to operational evidence

Use Policy and Procedures 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 privacy authority, purpose, transparency, consent, individual rights, and data-processing governance.

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

  • privacy notices and consent records
  • authority and purpose documentation
  • data-processing inventories
  • individual request and redress records

Common failure patterns

  • collection justified by convenience rather than authority
  • notices do not reflect actual processing
  • secondary use expands without review
  • retention and deletion commitments not enforced

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?
Official NIST SP 800-53A content

Assessment objectives and methods

Show the assessment objective
  1. PT-01a.
    1. PT-01a.[01]a personally identifiable information processing and transparency policy is developed and documented;
    2. PT-01a.[02]the personally identifiable information processing and transparency policy is disseminated to [Organization-defined: personnel or roles];
    3. PT-01a.[03]personally identifiable information processing and transparency procedures to facilitate the implementation of the personally identifiable information processing and transparency policy and associated personally identifiable information processing and transparency controls are developed and documented;
    4. PT-01a.[04]the personally identifiable information processing and transparency procedures are disseminated to [Organization-defined: personnel or roles];
    5. PT-01a.01
      1. PT-01a.01(a)
        1. PT-01a.01(a)[01]the [Organization-defined: pt-01_odp.03] personally identifiable information processing and transparency policy addresses purpose;
        2. PT-01a.01(a)[02]the [Organization-defined: pt-01_odp.03] personally identifiable information processing and transparency policy addresses scope;
        3. PT-01a.01(a)[03]the [Organization-defined: pt-01_odp.03] personally identifiable information processing and transparency policy addresses roles;
        4. PT-01a.01(a)[04]the [Organization-defined: pt-01_odp.03] personally identifiable information processing and transparency policy addresses responsibilities;
        5. PT-01a.01(a)[05]the [Organization-defined: pt-01_odp.03] personally identifiable information processing and transparency policy addresses management commitment;
        6. PT-01a.01(a)[06]the [Organization-defined: pt-01_odp.03] personally identifiable information processing and transparency policy addresses coordination among organizational entities;
        7. PT-01a.01(a)[07]the [Organization-defined: pt-01_odp.03] personally identifiable information processing and transparency policy addresses compliance;
      2. PT-01a.01(b)the [Organization-defined: pt-01_odp.03] personally identifiable information processing and transparency policy is consistent with applicable laws, Executive Orders, directives, regulations, policies, standards, and guidelines;
  2. PT-01b.the [Organization-defined: official] is designated to manage the development, documentation, and dissemination of the personally identifiable information processing and transparency policy and procedures;
  3. PT-01c.
    1. PT-01c.01
      1. PT-01c.01[01]the current personally identifiable information processing and transparency policy is reviewed and updated [Organization-defined: frequency];
      2. PT-01c.01[02]the current personally identifiable information processing and transparency policy is reviewed and updated following [Organization-defined: events];
    2. PT-01c.02
      1. PT-01c.02[01]the current personally identifiable information processing and transparency procedures are reviewed and updated [Organization-defined: frequency];
      2. PT-01c.02[02]the current personally identifiable information processing and transparency procedures are reviewed and updated following [Organization-defined: events].

Examine

  • Personally identifiable information processing and transparency policy and procedures
  • privacy plan
  • privacy program plan
  • other relevant documents or records

Interview

  • Organizational personnel with personally identifiable information processing and transparency responsibilities
  • organizational personnel with information security and privacy responsibilities
Source record

Authoritative sources

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