NIST SP 800-53 Rev. 5 SI-19(1) — Collection

What this control requires

De-identify datasets during collection by excluding personally identifiable information (PII) that is not required. This approach minimizes privacy risks by ensuring unnecessary personal data is not collected in the first place. This control supports the Data Governance, Privacy Risk Management capability within the System and Information Integrity family.

In plain English

De-identify datasets during collection by excluding personally identifiable information (PII) that is not required. 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 System and Information Integrity, the assessor will trace your implementation back to the catalogue reference (Control SI-19(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.
• Protection. Document the trigger, the owner and the cadence.
• System. Document the trigger, the owner and the cadence.
• Scope: management, information, privacy, system, personally identifiable information, protection, capability, policy.

Evidence to collect

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

Signed policy or standard documents the safeguard. Focus: Collection.

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.

• SOC 2 (2017 TSC) P2.1 — Communication of Data Subject Choices and Consequences
• GDPR Article 14 — Information to be provided where personal data have not been obtained from the data subject
• India DPDP Act 2023 LB-005 — Employee Privacy Notice & HR Data Governance
• BSI C5:2020 AM-02 — Acceptable Use and Safe Handling of Assets Policy

Related controls in NIST SP 800-53 Rev. 5

• Control SI-18(3) — Collection
• Control SI-18(1) — Automation Support
• Control SI-19 — De-Identification
• Control SI-19(2) — Archiving
• Control SI-19(3) — Release
• Control SI-18(5) — Notice Of Correction Or Deletion

References

• NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
• Catalogue identifier: Control SI-19(1)

Topics: governance riskdata protectionprivacy managementpolicy management