PT-2_authority-to-process-personally-identifiable-information

PT-2 Authority to Process Personally Identifiable Information

High-Level Description

Family: Personally Identifiable Information Processing and Transparency (PT) Framework: NIST SP 800-53 Rev 5

The processing of personally identifiable information is an operation or set of operations that the information system or organization performs with respect to personally identifiable information across the information life cycle. Processing includes but is not limited to creation, collection, use, processing, storage, maintenance, dissemination, disclosure, and disposal. Processing operations also include logging, generation, and transformation, as well as analysis techniques, such as data mining.

Organizations may be subject to laws, executive orders, directives, regulations, or policies that establish the organization’s authority and thereby limit certain types of processing of personally identifiable information or establish other requirements related to the processing. Organizational personnel consult with the senior agency official for privacy and legal counsel regarding such authority, particularly if the organization is subject to multiple jurisdictions or sources of authority. For organizations whose processing is not determined according to legal authorities, the organization’s policies and determinations govern how they process personally identifiable information. While processing of personally identifiable information may be legally permissible, privacy risks may still arise. Privacy risk assessments can identify the privacy risks associated with the authorized processing of personally identifiable information and support solutions to manage such risks.

Organizations consider applicable requirements and organizational policies to determine how to document this authority. For federal agencies, the authority to process personally identifiable information is documented in privacy policies and notices, system of records notices, privacy impact assessments, PRIVACT statements, computer matching agreements and notices, contracts, information sharing agreements, memoranda of understanding, and other documentation.

Organizations take steps to ensure that personally identifiable information is only processed for authorized purposes, including training organizational personnel on the authorized processing of personally identifiable information and monitoring and auditing organizational use of personally identifiable information.

What to Check

• Verify PT-2 Authority to Process Personally Identifiable Information is documented in SSP
• Validate all 2 control requirements are implemented
• Confirm control is operating effectively
• Review evidence of continuous monitoring for PT-2

How to Test

Step 1: Review Documentation

Examine the System Security Plan (SSP) and related artifacts for PT-2 implementation details. Verify the organization has documented how this control is satisfied.

Step 2: Validate Implementation

# For cloud environments, use cloud-audit-mcp tools
# For on-premises, review system configurations directly

# Example: Check if account management policies exist
grep -r "account.management\|access.control" /etc/security/ 2>/dev/null

Step 3: Test Operating Effectiveness

Verify the control is actively functioning, not just documented. Check logs, configurations, and operational evidence.

Tools

Remediation Guide

Control Statement

Determine and document the [organization-defined] that permits the [organization-defined] of personally identifiable information; and Restrict the [organization-defined] of personally identifiable information to only that which is authorized.

Implementation Guidance

The processing of personally identifiable information is an operation or set of operations that the information system or organization performs with respect to personally identifiable information across the information life cycle. Processing includes but is not limited to creation, collection, use, processing, storage, maintenance, dissemination, disclosure, and disposal. Processing operations also include logging, generation, and transformation, as well as analysis techniques, such as data mining.

Organizations may be subject to laws, executive orders, directives, regulations, or policies that establish the organization’s authority and thereby limit certain types of processing of personally identifiable information or establish other requirements related to the processing. Organizational personnel consult with the senior agency official for privacy and legal counsel regarding such authority, particularly if the organization is subject to multiple jurisdictions or sources of authority. For organizations whose processing is not determined according to legal authorities, the organization’s policies and determinations govern how they process personally identifiable information. While processing of personally identifiable information may be legally permissible, privacy risks may still arise. Privacy risk assessments can identify the privacy risks associated with the authorized processing of personally identifiable information and support solutions to manage such risks.

Organizations consider applicable requirements and organizational policies to determine how to document this authority. For federal agencies, the authority to process personally identifiable information is documented in privacy policies and notices, system of records notices, privacy impact assessments, PRIVACT statements, computer matching agreements and notices, contracts, information sharing agreements, memoranda of understanding, and other documentation.

Organizations take steps to ensure that personally identifiable information is only processed for authorized purposes, including training organizational personnel on the authorized processing of personally identifiable information and monitoring and auditing organizational use of personally identifiable information.

Risk Assessment

CWE Categories

References

• NIST SP 800-53 Rev 5 - PT-2
• NIST SP 800-53A Rev 5 (Assessment Procedures)
• NIST SP 800-53 Rev 5 Full Catalog

Checklist

• Control documented in SSP
• Implementation evidence collected
• Operating effectiveness validated
• Continuous monitoring in place
• Related controls (AC-2, AC-3, CM-13, IR-9, PM-9) reviewed