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nist-pf-communicate

Security & auditing

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Updated 10-16 09:33

About this skill

NIST Privacy Framework — COMMUNICATE Function

Overview

The COMMUNICATE function develops and implements appropriate activities to enable organizations and individuals to have a reliable understanding and engage in a dialogue about how data are processed and associated privacy risks. This function is essential for building trust and ensuring transparency with data subjects, regulators, and business partners.

COMMUNICATE Function Subcategories

CM.AW — Awareness

Raising awareness of data processing practices and privacy risks among stakeholders.

Subcategory Description Implementation Guidance
CM.AW-P1 Mechanisms (e.g., notices, internal policies) for communicating data processing purposes, practices, and associated privacy risks are established and in service Publish layered privacy notices. Maintain internal data processing documentation. Establish communication channels for privacy inquiries.
CM.AW-P2 Mechanisms for obtaining feedback from individuals about data processing and associated privacy risks are established and in service Deploy feedback forms on privacy pages. Monitor privacy-related inquiries through support channels. Conduct periodic privacy perception surveys.
CM.AW-P3 System/product/service design enables data processing visibility Implement privacy dashboards for data subjects. Provide real-time data processing status. Enable granular consent visibility.
CM.AW-P4 Records of data disclosures and sharing are maintained and can be accessed for review or transmission Maintain disclosure registers. Enable data subjects to view sharing history. Automate disclosure logging.
CM.AW-P5 Data corrections or deletions can be communicated to individuals or organizations that have received the data Implement downstream notification workflows. Track data recipients for correction propagation. Automate deletion verification across partners.
CM.AW-P6 Data provenance and lineage are maintained and can be accessed for review or transmission Document data origins and transformation history. Provide lineage visualization. Enable audit trail access for authorized parties.
CM.AW-P7 Impacted individuals and organizations are notified about a privacy breach or event Develop breach notification templates. Establish notification timelines per jurisdiction. Maintain contact information for notification delivery.
CM.AW-P8 Individuals are provided with mitigation mechanisms for observed privacy risks Offer identity protection services post-breach. Provide self-service privacy controls. Communicate available remediation options.

CM.PO — Communication Policies

Policies governing how privacy-related information is communicated.

Subcategory Description Implementation Guidance
CM.PO-P1 Transparency policies, processes, and procedures for communicating data processing purposes, practices, associated privacy risks, and options for enabling data subjects' data processing preferences are established and in service Develop layered transparency framework. Define communication standards for each audience.
CM.PO-P2 Roles and responsibilities for communicating privacy-related information are established Assign communications ownership. Define approval workflows for external privacy communications.

Transparency Framework

Layered Privacy Notice Architecture

Layer 1: Short Notice (Banner/Summary)
├── Who we are
├── What data we collect
├── Key purposes
├── Core rights
└── Link to full notice

Layer 2: Full Privacy Notice
├── Detailed purposes and legal bases
├── Data categories and sources
├── Recipients and transfers
├── Retention periods
├── Complete rights information
├── Contact information
└── Links to supplementary notices

Layer 3: Supplementary Notices
├── Cookie Policy
├── Children's Privacy Notice
├── Employee Privacy Notice
├── Specific Service Notices
└── Jurisdiction-Specific Addenda

Layer 4: Just-in-Time Notices
├── Collection-point notifications
├── Consent requests with context
├── Purpose-specific explanations
└── Processing change notifications

Communication Channel Matrix

Audience Channel Frequency Content Type Owner
Data subjects (general) Website privacy center Continuous Notices, policies, FAQs Privacy Team
Data subjects (customers) Email, in-app notifications Event-driven Consent changes, updates Marketing + Privacy
Data subjects (employees) Intranet, HR portal Semi-annual + event Employee privacy info HR + Privacy
Regulators Formal correspondence As required Compliance reports, notifications Legal + DPO
Business partners Contract addenda, portal Annual + event Processing terms, audit rights Legal + Procurement
Board/executives Dashboards, presentations Quarterly Risk reports, KPIs CPO
Internal teams Confluence, training Monthly Guidelines, best practices Privacy Champions

Privacy Notice Content Requirements

Mandatory Elements by Regulation

Element GDPR Art. 13/14 CCPA/CPRA LGPD PIPEDA
Controller identity Required Required Required Required
DPO contact Required N/A Required (DPO equivalent) N/A
Processing purposes Required Required Required Required
Legal basis Required N/A Required N/A
Data categories Required Required Required Required
Recipients Required Required Required Required
International transfers Required N/A Required Required
Retention periods Required Disclosed on request Required Required
Data subject rights Required Required Required Required
Right to complain Required N/A Required Required
Automated decision-making Required CPRA: Required Required N/A
Data source (indirect collection) Required Required Required Required
Sale/sharing opt-out N/A Required N/A N/A
Financial incentive terms N/A Required N/A N/A

Stakeholder Engagement Workflows

Data Subject Inquiry Handling

Inquiry Received
    |
    v
Classify Inquiry Type
├── General Privacy Question → FAQ/Knowledge Base → Respond within 5 business days
├── Data Subject Request → Route to DSR Workflow → Respond within regulatory deadline
├── Complaint → Escalate to DPO → Investigate → Respond within 15 business days
├── Breach Inquiry → Route to Incident Team → Coordinate response
└── Consent Change → Process immediately → Confirm within 24 hours

Privacy Communication Approval Workflow

Communication Type Drafting Review Approval Distribution
Privacy policy update Privacy Team Legal CPO + General Counsel Web team
Breach notification Incident Lead Legal + DPO CEO + General Counsel Communications
Regulatory response DPO Legal General Counsel DPO
Marketing consent request Marketing Privacy Team CPO Marketing
Internal policy update Privacy Team Stakeholders CPO Internal comms

Feedback Mechanisms

Privacy Perception Survey Template (Annual)

  1. How aware are you of our privacy practices? (1-5 scale)
  2. How easy is it to find information about how we use your data? (1-5 scale)
  3. How confident are you that we protect your personal data? (1-5 scale)
  4. Have you exercised any privacy rights in the past 12 months? (Yes/No, which ones)
  5. How satisfied were you with the response? (1-5 scale, if applicable)
  6. What privacy improvements would you like to see? (Open text)
  7. How likely are you to recommend us based on our privacy practices? (0-10 NPS)

Control Mapping

NIST PF COMMUNICATE ISO 27701 GDPR Article APEC CBPR
CM.AW-P1 A.7.3.2 Art. 12, 13, 14 Principle 5
CM.AW-P2 A.7.3.8 Art. 77 Principle 9
CM.AW-P3 A.7.2.5 Art. 12(1) Principle 5
CM.AW-P4 A.7.5.3 Art. 19 Principle 7
CM.AW-P7 A.7.3.9 Art. 34 Principle 8
CM.PO-P1 A.7.3.2 Art. 12 Principle 5
CM.PO-P2 5.3 Art. 37-39 Principle 9

References

  • NIST Privacy Framework Version 1.0 (January 16, 2020)
  • Article 29 Working Party WP260 — Guidelines on Transparency
  • EDPB Guidelines 04/2022 on Calculation of Administrative Fines
  • ISO/IEC 29100:2011 — Privacy Framework (Privacy Principles)