Tips for Identifying What Data You Hold under the NIST Privacy Framework

The NIST Privacy Framework is a voluntary tool designed to help organizations manage privacy risks and build effective privacy programs. Developed by the National Institute of Standards and Technology (NIST), it provides a structured approach to identifying, assessing, and mitigating privacy risks. By aligning privacy practices with the NIST Privacy Framework, organizations can enhance their ability to protect personal data, comply with regulatory requirements, and build trust with stakeholders. The framework’s flexibility makes it applicable to organizations of all sizes and across industries, making it a valuable resource for any entity seeking to strengthen its privacy posture.

The framework covers five key functions organizations must be able to perform in order to manage data in compliance with privacy regulations:

• Identify what data they hold
• Govern that data effectively
• Control how the data is accessed and used
• Communicate with customers and others about their data practices
• Protect the data against security incidents

Data Inventory and Mapping

• Catalogue all data processing activities, including collection, storage, and sharing of personal data.
• Identify all data sources, storage locations, and data flow pathways within the organization.
• Evaluate and prioritize risks for each data activity to ensure critical areas receive focused attention.
• Ensure the inventory is regularly updated to reflect changes in data processing activities.

Business Environment Understanding

• Identify organizational roles and responsibilities related to data handling.
• Understand the context in which personal data is processed, including business objectives, regulatory environment, and stakeholder expectations.
• Document data ownership and access controls for each data set.

Privacy Risk Assessment

• Conduct a privacy risk assessment to evaluate the potential impact of data processing activities on
  individual privacy.
• Identify and document the risks associated with each data processing activity.
• Prioritize risks based on their potential impact and likelihood of occurrence.

Regulatory Compliance

• Identify and document all applicable privacy laws and regulations that affect your organization’s data processing activities.
• Ensure that your data processing practices are aligned with these requirements.
• Monitor changes in regulations and update your practices accordingly.

How Technology Can Help

To maintain an up-to-date inventory of personal data, Data Discovery tools can be essential. These tools automate the identification, classification, and mapping of data across various systems, ensuring that the data inventory reflects real-time conditions. This reduces the risk of missing critical data elements that could lead to compliance failures. Automating these tasks provides organizations with continuous visibility into how personal data is collected, stored, and shared, simplifying the tracking of data flows.

In addition, Privacy Risk Assessment Tools automate the evaluation of privacy risks, helping organizations prioritize based on impact and likelihood. This is critical for identifying potential privacy concerns and ensuring that high-risk data processing activities are closely monitored. By automating risk assessments, organizations can streamline their governance and ensure alignment with regulatory requirements while improving overall data management and privacy governance.

Want the full NIST Privacy Framework Action Plan? Download it today!