NIST SP 800-53 Rev. 5 PT-2(1) — Data Tagging

What this control requires

Attach data tags containing authorized processing information to elements of personally identifiable information (PII). These tags help track and enforce authorized processing by indicating the types of processing permitted for PII elements within the system. Data tagging may also assist in utilizing automated tools to ensure compliance with data processing requirements.

In plain English

Attach data tags containing authorized processing information to elements of personally identifiable information (PII). In practice, this means you can prove you policy management-level controls on a defined cadence.

Why it matters

SP 800-53 is the catalogue every U.S. federal authorisation (FedRAMP, FISMA, CMMC) and most regulated industries point at. A missing control surfaces as a Plan of Action & Milestones (POA&M) item that an Authorizing Official must approve before the Authority To Operate is granted or renewed.

What an auditor looks for

A 3PAO (FedRAMP) or Independent Assessor (NIST RMF) tests against NIST SP 800-53A assessment procedures. For each control they expect a documented implementation that addresses every assessment objective (Examine, Interview, Test) and an implementation summary in the System Security Plan.

Within PII Data Elements, the assessor will trace your implementation back to the catalogue reference (Control PT-2(1)) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

• Policy. Document the trigger, the owner and the cadence.
• Information. Document the trigger, the owner and the cadence.
• Data. Document the trigger, the owner and the cadence.
• System. Document the trigger, the owner and the cadence.
• Compliance. Document the trigger, the owner and the cadence.
• Scope: management, information, privacy, system, personally identifiable information, compliance, tools, authorized.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policy or standard documents the safeguard. Focus: Data Tagging.

Common pitfalls

• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• HIPAA (45 CFR Part 164) 164.502(j)(2) — Disclosures by workforce members who are victims of a crime
• ISO/IEC 27001:2022 A.8.26 — Application security requirements

Related controls in NIST SP 800-53 Rev. 5

• Control PT-3(1) — Data Tagging
• Control PT-2(2) — Automation
• Control SI-18 — Personally Identifiable Information Quality Operations
• Control PT-7 — Specific Categories Of Personally Identifiable Information
• Control SI-18(1) — Automation Support
• Control SI-18(5) — Notice Of Correction Or Deletion

References

• NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
• Catalogue identifier: Control PT-2(1)

Topics: governance riskpolicy managementprivacy management