What this control covers
The organization shall identify and document the specific purposes for which the PII will be processed. Implementation: Document purposes clearly; include in notices and records (purpose registry). Justification: Demonstrates clarity of processing purpose to PII principals; required for consent and lawful basis.
Why it matters
Risk is the language an executive team understands; this control connects technical reality to board-level decisions and budget allocation.
How to implement
AWS
Codify the policy intent as SCPs, AWS Config conformance packs, and Security Hub standards so the cloud enforces what the document says.
Azure
Codify in Azure Policy initiatives (built-in regulatory compliance for CIS, ISO 27001, SOC 2, HIPAA) and assign at management-group level.
GCP
Use Cloud KMS with customer-managed encryption keys (CMEK) for BigQuery, GCS, and Compute. Sensitive Data Protection (DLP API) inspects/de-identifies PII at scale.
Google Workspace
Enable client-side encryption for Drive/Docs and turn on Drive Labels + DLP rules to prevent external sharing of regulated data classes.
On-premises
Maintain a policy library with a documented review cadence (annual minimum); store in your GRC tool with attestation tracking. Map each policy to controls so an audit pull cites the exact policy clause.
Evidence to collect
policy_document— A signed, version-controlled policy stating leadership intent and the named owner.
Signed policies, procedures, and registers document the safeguard. Focus: Identify and document purpose.
Quick checklist
- Identify And Document — Identify And Document Purpose
- Implement — Identify And Document Purpose
- Document — Identify And Document Purpose
Related articles on this site
- NIST 800-171 3.1.9 Provide privacy and security notices consistent with applicable CUI rules.
- NIST 800-171 3.6.2 Track, document, and report incidents to designated officials and/or authorities both internal and external to the organization.
- CMMC 2.0 AC.2.005 Provide privacy and security notices consistent with applicable CUI rules.
- Ensure CloudWatch Log Groups Have a Retention Policy of Specific Days