Identify-P (ID-P) | ID.IM-P: Inventory And Mapping | ID.IM-P1: Systems/products/services that process data are inventoried |
ID.IM-P2: Owners or operators (e.g., the organization or third parties such as service providers, partners, customers, and developers) and their roles with respect to the systems/products/services and components (e.g., internal or external) that process data are inventoried |
ID.IM-P3: Categories of individuals (e.g., customers, employees or prospective employees, consumers) whose data are being processed are inventoried |
ID.IM-P4: Data actions of the systems/products/services are inventoried |
ID.IM-P5: The purposes for the data actions are inventoried |
ID.IM-P6: Data elements within the data actions are inventoried |
ID.IM-P7: The data processing environment is identified (e.g., geographic location, internal, cloud, third parties) |
ID.IM-P8: Data processing is mapped, illustrating the data actions and associated data elements for systems/products/services, including components; roles of the component owners/operators; and interactions of individuals or third parties with the systems/products/services |
ID.BE-P: Business Environment | ID.BE-P1: The organization's role(s) in the data processing ecosystem are identified and communicated. |
ID.BE-P2: Priorities for organizational mission, objectives, and activities are established and communicated |
ID.BE-P3: Systems/products/services that support organizational priorities are identified and key requirements communicated |
ID.RA-P: Risk Assessment | ID.RA-P1: Contextual factors related to the systems/products/services and the data actions are identified (e.g., individuals' demographics and privacy interests or perceptions, data sensitivity and/or types, visibility of data processing to individuals and third parties). |
ID.RA-P2: Data analytic inputs and outputs are identified and evaluated for bias |
ID.RA-P3: Potential problematic data actions and associated problems are identified |
ID.RA-P4: Problematic data actions, likelihoods, and impacts are used to determine and prioritize risk |
ID.RA-P5: Risk responses are identified, prioritized, and implemented |
ID.DE-P: Data Processing Ecosystem Risk Management | ID.DE-P1: Data processing ecosystem risk management policies, processes, and procedures are identified, established, assessed, managed, and agreed to by organizational stakeholders |
ID.DE-P2: Data processing ecosystem parties (e.g., service providers, customers, partners, product manufacturers, application developers) are identified, prioritized, and assessed using a privacy risk assessment process |
ID.DE-P3: Contracts with data processing ecosystem parties are used to implement appropriate measures designed to meet the objectives of an organization's privacy program. |
ID.DE-P4: Interoperability frameworks or similar multi-party approaches are used to manage data processing ecosystem privacy risks |
ID.DE-P5: Data processing ecosystem parties are routinely assessed using audits, test results, or other forms of evaluations to confirm they are meeting their contractual, interoperability framework, or other obligations |
Govern-P (GV-P) | GV.PO-P: Governance Policies, Processes, And Procedures | GV.PO-P1: Organizational privacy values and policies (e.g., conditions on data processing such as data uses or retention periods, individuals' prerogatives with respect to data processing) are established and communicated. |
GV.PO-P2: Processes to instill organizational privacy values within system/product/service development and operations are established and in place |
GV.PO-P3: Roles and responsibilities for the workforce are established with respect to privacy |
GV.PO-P4: Privacy roles and responsibilities are coordinated and aligned with third-party stakeholders (e.g., service providers, customers, partners) |
GV.PO-P5: Legal, regulatory, and contractual requirements regarding privacy are understood and managed |
GV.PO-P6: Governance and risk management policies, processes, and procedures address privacy risks |
GV.RM-P: Risk Management Strategy | GV.RM-P1: Risk management processes are established, managed, and agreed to by organizational stakeholders |
GV.RM-P2: Organizational risk tolerance is determined and clearly expressed |
GV.RM-P3: The organization's determination of risk tolerance is informed by its role(s) in the data processing ecosystem. |
GV.AT-P: Awareness And Training | GV.AT-P1: The workforce is informed and trained on its roles and responsibilities |
GV.AT-P2: Senior executives understand their roles and responsibilities |
GV.AT-P3: Privacy personnel understand their roles and responsibilities |
GV.AT-P4: Third parties (e.g., service providers, customers, partners) understand their roles and responsibilities |
GV.MT-P: Monitoring And Review | GV.MT-P1: Privacy risk is re-evaluated on an ongoing basis and as key factors, including the organization's business environment (e.g., introduction of new technologies), governance (e.g., legal obligations, risk tolerance), data processing, and systems/products/services change. |
GV.MT-P2: Privacy values, policies, and training are reviewed and any updates are communicated |
GV.MT-P3: Policies, processes, and procedures for assessing compliance with legal requirements and privacy policies are established and in place |
GV.MT-P4: Policies, processes, and procedures for communicating progress on managing privacy risks are established and in place |
GV.MT-P5: Policies, processes, and procedures are established and in place to receive, analyze, and respond to problematic data actions disclosed to the organization from internal and external sources (e.g., internal discovery, privacy researchers, professional events) |
GV.MT-P6: Policies, processes, and procedures incorporate lessons learned from problematic data actions |
GV.MT-P7: Policies, processes, and procedures for receiving, tracking, and responding to complaints, concerns, and questions from individuals about organizational privacy practices are established and in place |
Control-P (CT-P) | CT.PO-P: Data Processing Policies, Processes, And Procedures | CT.PO-P1: Policies, processes, and procedures for authorizing data processing (e.g., organizational decisions, individual consent), revoking authorizations, and maintaining authorizations are established and in place |
CT.PO-P2: Policies, processes, and procedures for enabling data review, transfer, sharing or disclosure, alteration, and deletion are established and in place (e.g., to maintain data quality, manage data retention) |
CT.PO-P3: Policies, processes, and procedures for enabling individuals' data processing preferences and requests are established and in place. |
CT.PO-P4: A data life cycle to manage data is aligned and implemented with the system development life cycle to manage systems |
CT.DM-P: Data Processing Management | CT.DM-P1: Data elements can be accessed for review |
CT.DM-P2: Data elements can be accessed for transmission or disclosure |
CT.DM-P3: Data elements can be accessed for alteration |
CT.DM-P4: Data elements can be accessed for deletion |
CT.DM-P5: Data are destroyed according to policy |