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id: "SI-19(02)" title: "Archiving" family: "SI" family_name: "System and Information Integrity" sort_id: "si-19.02" priority: "P1" implementation_level: "system" parent: "SI-19" enhancement: True

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Statement

Prohibit archiving of personally identifiable information elements if those elements in a dataset will not be needed after the dataset is archived.

Guidance

Datasets can be archived for many reasons. The envisioned purposes for the archived dataset are specified, and if personally identifiable information elements are not required, the elements are not archived. For example, social security numbers may have been collected for record linkage, but the archived dataset may include the required elements from the linked records. In this case, it is not necessary to archive the social security numbers.

Assessment Objective

the archiving of personally identifiable information elements is prohibited if those elements in a dataset will not be needed after the dataset is archived.

System and information integrity policy

system and information integrity procedures

personally identifiable information processing policy

de-identification procedures

system configuration documentation

data archiving mechanisms

system security plan

privacy plan

privacy impact assessment

privacy risk assessment documentation

other relevant documents or records

Organizational personnel responsible for de-identifying the dataset

organizational personnel with dataset archival responsibilities

organizational personnel with information security and privacy responsibilities

Automated mechanisms prohibiting the archival of personally identifiable information elements