NIST SP 800-53 Rev. 5 PT-2 — Authority To Process Personally Identifiable Information

What this control requires

Document the authority that permits the processing of personally identifiable information (PII) and ensure that only authorized processing is allowed. The processing includes creation, collection, use, storage, Maintenance, dissemination, and disposal of PII. Organizations must ensure compliance with relevant laws, executive orders, regulations, and policies, and implement privacy risk assessments to address any privacy risks associated with authorized processing.

In plain English

Document the authority that permits the processing of personally identifiable information (PII) and ensure that only authorized processing is allowed. 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.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

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 Organizational Privacy Policies, the assessor will trace your implementation back to the catalogue reference (Control PT-2) 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.
• Process. Document the trigger, the owner and the cadence.
• Data. Document the trigger, the owner and the cadence.
• Maintenance. Document the trigger, the owner and the cadence.
• Scope: management, information, privacy, only, personally identifiable information, protection, assessments, compliance.

Evidence to collect

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

Signed policy or standard documents the safeguard. Focus: Authority To Process Personally Identifiable Information.

Common pitfalls

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

Related controls in NIST SP 800-53 Rev. 5

• Control SI-12(1) — Limit Personally Identifiable Information Elements
• Control PM-5(1) — Inventory Of Personally Identifiable Information
• Control PT-2(2) — Automation
• Control SA-8(33) — Minimization
• Control SI-19(3) — Release
• Control PT-5 — Privacy Notice

References

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

Topics: governance riskdata protectionprivacy managementpolicy management