Introduction

The National Institute of Standards and Technology (popularly called NIST) is a U.S. government agency that develops technology, standards, and guidelines, particularly in areas of cybersecurity and privacy. NIST plays a crucial role in helping organizations across various industries protect their systems and data through well-established frameworks. One such framework is the NIST Cybersecurity Privacy Framework, which provides a structured approach for managing and improving data protection and privacy practices.

Mapping to the NIST Cybersecurity Privacy Framework controls is essential for organizations aiming to strengthen their data protection and privacy protocols. This blog delves into the specifics of how businesses can align their privacy strategies with the NIST map, enhancing both security and regulatory compliance.

Throughout the blog, we explore how the NIST map guides the identification of privacy risks, the implementation of proper safeguards, and continuous monitoring of privacy practices. Additionally, we provide a detailed approach to integrating the NIST map into your organization's processes, ensuring data is managed efficiently and securely.

NIST Privacy Framework - A Brief Overview

The NIST Privacy Framework offers companies guidance on implementing vital privacy measures and processes, enabling them to manage data usage, monitor privacy controls, and respond effectively to privacy incidents. It supports organizations in evaluating the privacy impact of their assets and services.

The initial edition of the Privacy Framework was released in January 2020, featuring three key components: the Core, which provides the overall structure, the Profiles, which demonstrate how assessments are conducted, and the Implementation Tiers, which help ensure accountability across the board. These elements are designed to assist any organization, whether it’s a government body, a private business, or a non-profit handling personal data.

Another key document in this area is NIST Special Publication (SP) 800-53, titled Security and Privacy Controls for Information Systems and Organizations. SP 800-53 builds upon the broader concepts and methodologies found in the Cybersecurity Framework (CSF) and translates them into specific, actionable controls. To effectively map CSF controls, it often involves connecting SP 800-53 controls with other frameworks.

Components of the NIST Privacy Framework

The NIST Privacy Framework includes three main elements: Core, Profiles, and Implementation Tiers. As a voluntary tool, it enhances privacy risk management by connecting business objectives, organizational roles and responsibilities, and the identification of privacy risks.

Core

The Core is made up of various activities and outcomes centered around privacy protection. It enables communication from the executive level down to the operational and implementation stages within an organization.

Profiles

Profiles are a tailored selection of Functions, Categories, and Subcategories from the Core. They help to define the current status of privacy-related activities and outline the desired future state, offering organizations a pathway to align their privacy practices with business goals.

Implementation Tiers

The Implementation Tiers provide a way to evaluate and manage privacy risks by reviewing systems, processes, and resources across four levels:

• Partial (Tier 1): Limited understanding and implementation of privacy controls, with basic awareness of privacy risks.

• Risk-Informed (Tier 2): Moderate awareness and integration of privacy risk management practices informed by risk assessments.

• Repeatable (Tier 3): Consistent application of privacy controls, with established processes for risk management and response.

• Adaptive (Tier 4): Advanced, flexible approach to managing privacy risks, with continuous improvement and dynamic practices.

Next, we discuss the principles of the NIST privacy framework.

What are the Principles of the NIST Privacy Framework?

The NIST Privacy Framework is built on five main principles that form the foundation for effective privacy and cybersecurity risk management. These pillars help organizations develop robust strategies to manage privacy risks at a high level.

Identify

This principle focuses on understanding and addressing cyber risks related to people, systems, data assets, and capabilities. It ensures that organizations track and manage all personal data being collected, processed, or stored. As a critical first step, it includes documenting data processing activities, acknowledging individuals' privacy rights, and performing risk assessments to understand the operational landscape and prioritize privacy risks.

Govern

Governance emphasizes the importance of aligning privacy values such as transparency and data control with the organization’s privacy risk assessment. By doing so, companies can build trust in their products and services. This principle involves establishing a governance structure that enables a continuous understanding of privacy risk priorities, setting privacy policies, complying with legal requirements, and determining the organization’s risk tolerance.

Control

The Control principle addresses the management of data processing from both organizational and individual perspectives. It involves assessing whether data being collected, shared, or retained is necessary, and ensuring policies allow organizations and individuals to maintain appropriate control over data. Organizations should implement activities that allow for granular management of data to reduce privacy risks.

Communicate

This principle involves developing clear communication policies about data processing activities, both internally and externally. It enhances transparency and customer understanding by providing accessible notices and reports. Additionally, organizations should implement tools like alerts or notifications to keep individuals informed about how their data is being processed.

Protect

The Protect principle focuses on safeguarding personal and sensitive data through security measures, risk mitigation, and consistent policies. This helps prevent privacy incidents by addressing the intersection between privacy and cybersecurity risk management, ensuring that data is consistently protected from breaches or misuse.

Mapping NIST SP 800-171 to the NIST Cybersecurity Framework

NIST SP 800-171 and the NIST Cybersecurity Framework (CSF) are two important guidelines that play distinct yet complementary roles in securing sensitive information. Mapping NIST SP 800-171 to the NIST CSF helps organizations better align their cybersecurity efforts while simplifying compliance with federal standards.

Understanding the Relationship

NIST SP 800-171 focuses specifically on protecting Controlled Unclassified Information (CUI) within non-federal systems. It establishes security requirements for handling, storing, and transmitting CUI to prevent unauthorized access. On the other hand, the NIST Cybersecurity Framework provides a broader set of voluntary guidelines designed to help organizations of all sizes manage and reduce cybersecurity risks.

By mapping NIST SP 800-171 to the CSF, businesses can take a more comprehensive approach to security while ensuring they meet specific regulatory requirements. The CSF’s five core functions—Identify, Protect, Detect, Respond, and Recover—can be directly aligned with NIST SP 800-171’s security controls.

How Mapping Works

The controls outlined in NIST SP 800-171 can be categorized into the CSF’s core functions. For instance:

• Identify: SP 800-171 controls related to asset management and risk assessment can map to the Identify function.

• Protect: Controls dealing with access control, awareness training, and system maintenance align with the Protect function.

• Detect: Monitoring and detecting cybersecurity events outlined in SP 800-171 map directly to the CSF’s Detect function.

• Respond: Incident response requirements in SP 800-171 can be mapped to the Respond function of the CSF.

• Recover: Recovery controls, such as contingency planning, fit within the CSF’s Recover function.

Benefits of Mapping

Mapping NIST SP 800-171 to the CSF provides several benefits:

• Enhanced Security Posture: By incorporating broader CSF guidelines, organizations can improve their overall cybersecurity framework while still adhering to federal standards.

• Streamlined Compliance: Mapping ensures that organizations can meet multiple regulatory requirements more efficiently, reducing the complexity of managing security programs.

• Risk Management: Using the CSF’s risk-based approach helps organizations prioritize cybersecurity measures based on their specific vulnerabilities and threats.

How to Implement the NIST Map for Privacy Framework?

Integrating privacy into your processes from the start can reduce the chances of data breaches and other security risks.

The following eight steps are crucial to implement the NIST map for Privacy Framework.

1. Identify Data Types

The first step of the NIST Privacy Framework application is to assess the types of data an organization handles. Begin by reviewing your data infrastructure to understand what data is being collected, stored, shared, and maintained. 

By doing this, you can identify personal, financial, or business-related information, allowing you to manage privacy risks more effectively. This understanding becomes the foundation for developing privacy policies and procedures, tailored to the specific data types in question.

2. Conduct a Privacy Risk Assessment

The most effective approach to implementing the aforementioned step is to perform a privacy risk assessment. This helps map out data and identify how data processing activities could potentially create issues for individuals or result in financial losses.

Next, consider the impact these problems could have on your organization, such as loss of customer trust or damage to your reputation, which could negatively affect your business.

However, it is important to recognize that manually evaluating your current privacy practices can be daunting. For this reason, leveraging automation tools is a smart way to streamline the process and manage it efficiently.

Seezo is one platform that can help you carefully analyze risks, understand privacy impact, and encourage you to take precise actions from the very first line of coding.

Seezo offers comprehensive insights into three main areas:

• General security requirements that development teams need to account for during the feature development process.

• Tailored, company-specific requirements, such as those related to API gateways and notification systems.

• The capability to analyze technical specification document diagrams and generate concise summaries based on the visual content.

3. Implement Proper Controls and Safeguards

The third step focuses on establishing the necessary controls and safeguards to shield the integrity, confidentiality, and availability of personal data. This involves introducing security measures like encryption, access restrictions, and authentication protocols to prevent unauthorized access to sensitive information.

4. Develop a Privacy Program

Creating a NIST-compliant privacy program involves defining a series of policies, procedures, and controls to manage and protect personal data within your organization. The program should be customized to address your organization's specific risks and regulatory requirements, such as GDPR or CCPA.

Keep in mind that the NIST Privacy Framework is adaptable, allowing organizations to set goals and compliance levels that align with their needs. For example, if your business only needs to comply with GDPR and not CCPA, you can prioritize GDPR-specific requirements.

Key components of a privacy program include:

• Privacy Policies: Detailed guidelines on how personal data is collected, used, retained, and shared within the organization.

• Privacy Controls: Technical and administrative measures, such as encryption, access controls, filtering, and incident response processes, used to protect personal data.

• Privacy Training: Employee education programs that cover the organization’s privacy policies, procedures, and best practices for handling personal data.

• Data Protection Procedures: Methods for managing data protection, including controls over storage, access, retention, and secure disposal.

5. Draft Clear Privacy Notices

A privacy notice is a public-facing document that informs clients, customers, website visitors, authorities, and other stakeholders about how your organization handles personal data. According to the NIST Privacy Framework, it is important to create transparent and easily understandable privacy notices. These notices generally include the following:

• Categories of Personal Data: Clearly state the types of personal data being collected. These can be names, contact details, financial information, etc.

• Legal Basis: Explain the lawful grounds for processing personal data, whether it's consent, contractual necessity, legal obligations, legitimate interests, or another lawful justification.

• Data Sharing: Specify whether personal data is shared with third parties, the purpose of sharing, and details about any cross-border data transfers.

• Rights of Data Subjects: Inform individuals of their rights concerning their personal data, including the rights to access, correct, delete, restrict processing, and object to processing.

• Data Retention: Outline how long personal data will be kept and the criteria used to establish the retention period.

• Contact Information: Provide contact details for individuals to submit inquiries or requests regarding their personal data.

6. Train Your Employees on Privacy Practices

Providing privacy training equips employees with knowledge of relevant privacy laws and company policies, ensuring that they adhere to the guidelines both within and outside the organization. It's crucial to distinguish between data security and privacy during these sessions. Promoting a privacy-focused culture and raising awareness can help prevent costly incidents, protect the organization’s reputation, and avoid regulatory penalties.

7. Establish an Incident Response Plan

An incident response plan is a documented strategy that envisions how an organization responds to a security breach. It specifies key personnel, their roles, the steps to take during an incident, and the communication protocol to follow.

8. Commit to Ongoing Monitoring of Privacy Controls

Implementing privacy controls is not a one-time task. As risks evolve over time, it’s crucial to continually monitor and assess your privacy controls. Regular evaluations ensure that your privacy policies and procedures remain effective and up to date.

Read: Understanding Application Security Software: Types, Tools and Techniques

Conclusion

Implementing effective data privacy practices is crucial, and utilizing a reliable resource like NIST map, which is backed by numerous experts, is highly recommended. However, correctly applying the framework can be a complex task. Thankfully, automated security design reviews with Seezo.io make the process much more efficient and manageable.

Seezo simplifies threat modeling through GenAI. It processes documentation like JIRA tickets, Google Docs, and architecture diagrams to identify potential threats and generate the necessary security requirements to prevent them from being introduced.

To learn more about how Seezo can help your organization meet NIST map requirements, book a demo today!