id: "PT-01" title: "Policy and Procedures" family: "PT" family_name: "PII Processing and Transparency" sort_id: "pt-01" priority: "P2" implementation_level: "organization"


Develop, document, and disseminate to {{ insert: param, pt-1_prm_1 }}:

{{ insert: param, pt-01_odp.03 }} personally identifiable information processing and transparency policy that:

Addresses purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance; and

Is consistent with applicable laws, executive orders, directives, regulations, policies, standards, and guidelines; and

Procedures to facilitate the implementation of the personally identifiable information processing and transparency policy and the associated personally identifiable information processing and transparency controls;

Designate an {{ insert: param, pt-01_odp.04 }} to manage the development, documentation, and dissemination of the personally identifiable information processing and transparency policy and procedures; and

Review and update the current personally identifiable information processing and transparency:

Policy {{ insert: param, pt-01_odp.05 }} and following {{ insert: param, pt-01_odp.06 }} ; and

Procedures {{ insert: param, pt-01_odp.07 }} and following {{ insert: param, pt-01_odp.08 }}.

Guidance

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.

Assessment Objective: a personally identifiable information processing and transparency policy is developed and documented;

Assessment Objective: the personally identifiable information processing and transparency policy is disseminated to {{ insert: param, pt-01_odp.01 }};

Assessment Objective: 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;

Assessment Objective: the personally identifiable information processing and transparency procedures are disseminated to {{ insert: param, pt-01_odp.02 }};

Assessment Objective: the {{ insert: param, pt-01_odp.03 }} personally identifiable information processing and transparency policy addresses purpose;

Assessment Objective: the {{ insert: param, pt-01_odp.03 }} personally identifiable information processing and transparency policy addresses scope;

Assessment Objective: the {{ insert: param, pt-01_odp.03 }} personally identifiable information processing and transparency policy addresses roles;

Assessment Objective: the {{ insert: param, pt-01_odp.03 }} personally identifiable information processing and transparency policy addresses responsibilities;

Assessment Objective: the {{ insert: param, pt-01_odp.03 }} personally identifiable information processing and transparency policy addresses management commitment;

Assessment Objective: the {{ insert: param, pt-01_odp.03 }} personally identifiable information processing and transparency policy addresses coordination among organizational entities;

Assessment Objective: the {{ insert: param, pt-01_odp.03 }} personally identifiable information processing and transparency policy addresses compliance;

Assessment Objective: the {{ insert: param, pt-01_odp.03 }} personally identifiable information processing and transparency policy is consistent with applicable laws, Executive Orders, directives, regulations, policies, standards, and guidelines;

Assessment Objective: the {{ insert: param, pt-01_odp.04 }} is designated to manage the development, documentation, and dissemination of the personally identifiable information processing and transparency policy and procedures;

Assessment Objective: the current personally identifiable information processing and transparency policy is reviewed and updated {{ insert: param, pt-01_odp.05 }};

Assessment Objective: the current personally identifiable information processing and transparency policy is reviewed and updated following {{ insert: param, pt-01_odp.06 }};

Assessment Objective: the current personally identifiable information processing and transparency procedures are reviewed and updated {{ insert: param, pt-01_odp.07 }};

Assessment Objective: the current personally identifiable information processing and transparency procedures are reviewed and updated following {{ insert: param, pt-01_odp.08 }}.

Personally identifiable information processing and transparency policy and procedures

privacy plan

privacy program plan

other relevant documents or records

Organizational personnel with personally identifiable information processing and transparency responsibilities

organizational personnel with information security and privacy responsibilities