Control statement
Conduct privacy impact assessments for systems, programs, or other activities before:
- a.Developing or procuring information technology that processes personally identifiable information; and
- b.Initiating a new collection of personally identifiable information that:
- 1.Will be processed using information technology; and
- 2.Includes personally identifiable information permitting the physical or virtual (online) contacting of a specific individual, if identical questions have been posed to, or identical reporting requirements imposed on, ten or more individuals, other than agencies, instrumentalities, or employees of the federal government.
Discussion
A privacy impact assessment is an analysis of how personally identifiable information is handled to ensure that handling conforms to applicable privacy requirements, determine the privacy risks associated with an information system or activity, and evaluate ways to mitigate privacy risks. A privacy impact assessment is both an analysis and a formal document that details the process and the outcome of the analysis. Organizations conduct and develop a privacy impact assessment with sufficient clarity and specificity to demonstrate that the organization fully considered privacy and incorporated appropriate privacy protections from the earliest stages of the organization’s activity and throughout the information life cycle. In order to conduct a meaningful privacy impact assessment, the organization’s senior agency official for privacy works closely with program managers, system owners, information technology experts, security officials, counsel, and other relevant organization personnel. Moreover, a privacy impact assessment is not a time-restricted activity that is limited to a particular milestone or stage of the information system or personally identifiable information life cycles. Rather, the privacy analysis continues throughout the system and personally identifiable information life cycles. Accordingly, a privacy impact assessment is a living document that organizations update whenever changes to the information technology, changes to the organization’s practices, or other factors alter the privacy risks associated with the use of such information technology. To conduct the privacy impact assessment, organizations can use security and privacy risk assessments. Organizations may also use other related processes that may have different names, including privacy threshold analyses. A privacy impact assessment can also serve as notice to the public regarding the organization’s practices with respect to privacy. Although conducting and publishing privacy impact assessments may be required by law, organizations may develop such policies in the absence of applicable laws. For federal agencies, privacy impact assessments may be required by [EGOV](#7b0b9634-741a-4335-b6fa-161228c3a76e) ; agencies should consult with their senior agency official for privacy and legal counsel on this requirement and be aware of the statutory exceptions and OMB guidance relating to the provision.
From control text to operational evidence
Use Privacy Impact Assessments 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 risk framing, threat and vulnerability analysis, impact, criticality, and response 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
- risk assessments and threat models
- vulnerability findings and prioritization records
- supply-chain risk assessments
- risk response and acceptance decisions
Common failure patterns
- risk registers detached from technical evidence
- vulnerability severity treated as business impact
- assessments not updated after material change
- accepted risks have no owner or expiration
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
- RA-08a.privacy impact assessments are conducted for systems, programs, or other activities before developing or procuring information technology that processes personally identifiable information;
- RA-08b.
- RA-08b.[01]privacy impact assessments are conducted for systems, programs, or other activities before initiating a collection of personally identifiable information that will be processed using information technology;
- RA-08b.[02]privacy impact assessments are conducted for systems, programs, or other activities before initiating a collection of personally identifiable information that includes personally identifiable information permitting the physical or virtual (online) contacting of a specific individual, if identical questions have been posed to, or identical reporting requirements imposed on, ten or more individuals, other than agencies, instrumentalities, or employees of the federal government.
Examine
- Risk assessment policy
- security and privacy risk assessment reports
- acquisitions documents
- system security plan
- privacy plan
- other relevant documents or records
Interview
- Organizational personnel with assessment and auditing responsibilities
- system/network administrators
- system developers
- program managers
- legal counsel
- organizational personnel with security and privacy responsibilities
Test
- Organizational processes for assessments and audits
- mechanisms/tools supporting and/or implementing assessments and auditing
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.