NIST 800-53 REV 5 • PERSONALLY IDENTIFIABLE INFORMATION PROCESSING AND TRANSPARENCY
PT-3 — Personally Identifiable Information Processing Purposes
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Supplemental Guidance
Identifying and documenting the purpose for processing provides organizations with a basis for understanding why personally identifiable information may be processed. The term "process" includes every step of the information life cycle, including creation, collection, use, processing, storage, maintenance, dissemination, disclosure, and disposal. Identifying and documenting the purpose of processing is a prerequisite to enabling owners and operators of the system and individuals whose information is processed by the system to understand how the information will be processed. This enables individuals to make informed decisions about their engagement with information systems and organizations and to manage their privacy interests. Once the specific processing purpose has been identified, the purpose is described in the organization’s privacy notices, policies, and any related privacy compliance documentation, including privacy impact assessments, system of records notices, [PRIVACT](#18e71fec-c6fd-475a-925a-5d8495cf8455) statements, computer matching notices, and other applicable Federal Register notices. Organizations take steps to help ensure that personally identifiable information is processed only for identified purposes, including training organizational personnel and monitoring and auditing organizational processing of personally identifiable information. Organizations monitor for changes in personally identifiable information processing. Organizational personnel consult with the senior agency official for privacy and legal counsel to ensure that any new purposes that arise from changes in processing are compatible with the purpose for which the information was collected, or if the new purpose is not compatible, implement mechanisms in accordance with defined requirements to allow for the new processing, if appropriate. Mechanisms may include obtaining consent from individuals, revising privacy policies, or other measures to manage privacy risks that arise from changes in personally identifiable information processing purposes.
Practitioner Notes
You must clearly define and document the specific purposes for which you process PII. People should know why you have their data, and you should only use it for those stated purposes.
Example 1: In your privacy notices and system documentation, state each purpose plainly: 'We collect your name and email to fulfill your service request. We collect your mailing address to ship your order.' Avoid vague purposes like 'business operations' or 'improving our services.'
Example 2: Build a purpose specification matrix in your data governance documentation. List each PII element (name, SSN, address, etc.), the systems that store it, and the specific purpose for each. Review annually with your privacy officer to ensure purposes are still valid and data is not being used for unauthorized purposes.