+SI-12 [P] Information Management and Retention
---+SI-12(01) [P] Limit Personally Identifiable Information Elements
---+SI-12(02) [P] Minimize Personally Identifiable Information in Testing, Training, and Research
---+SI-12(03) [P] Information Disposal

SI-12 [P] Information Management and Retention

Control

Manage and retain information within the system and information output from the system in accordance with applicable laws, executive orders, directives, regulations, policies, standards, guidelines and operational requirements.

Discussion

Information management and retention requirements cover the full life cycle of information, in some cases extending beyond system disposal. Information to be retained may also include policies, procedures, plans, reports, data output from control implementation, and other types of administrative information. The National Archives and Records Administration (NARA) provides federal policy and guidance on records retention and schedules. If organizations have a records management office, consider coordinating with records management personnel. Records produced from the output of implemented controls that may require management and retention include, but are not limited to: All XX-1, [AC-6(9)](#ac-6.9), [AT-4](#at-4), [AU-12](#au-12), [CA-2](#ca-2), [CA-3](#ca-3), [CA-5](#ca-5), [CA-6](#ca-6), [CA-7](#ca-7), [CA-8](#ca-8), [CA-9](#ca-9), [CM-2](#cm-2), [CM-3](#cm-3), [CM-4](#cm-4), [CM-6](#cm-6), [CM-8](#cm-8), [CM-9](#cm-9), [CM-12](#cm-12), [CM-13](#cm-13), [CP-2](#cp-2), [IR-6](#ir-6), [IR-8](#ir-8), [MA-2](#ma-2), [MA-4](#ma-4), [PE-2](#pe-2), [PE-8](#pe-8), [PE-16](#pe-16), [PE-17](#pe-17), [PL-2](#pl-2), [PL-4](#pl-4), [PL-7](#pl-7), [PL-8](#pl-8), [PM-5](#pm-5), [PM-8](#pm-8), [PM-9](#pm-9), [PM-18](#pm-18), [PM-21](#pm-21), [PM-27](#pm-27), [PM-28](#pm-28), [PM-30](#pm-30), [PM-31](#pm-31), [PS-2](#ps-2), [PS-6](#ps-6), [PS-7](#ps-7), [PT-2](#pt-2), [PT-3](#pt-3), [PT-7](#pt-7), [RA-2](#ra-2), [RA-3](#ra-3), [RA-5](#ra-5), [RA-8](#ra-8), [SA-4](#sa-4), [SA-5](#sa-5), [SA-8](#sa-8), [SA-10](#sa-10), [SI-4](#si-4), [SR-2](#sr-2), [SR-4](#sr-4), [SR-8](#sr-8).

Assessment Objective

  1. information within the system is managed in accordance with applicable laws, Executive Orders, directives, regulations, policies, standards, guidelines, and operational requirements;
  2. information within the system is retained in accordance with applicable laws, Executive Orders, directives, regulations, policies, standards, guidelines, and operational requirements;
  3. information output from the system is managed in accordance with applicable laws, Executive Orders, directives, regulations, policies, standards, guidelines, and operational requirements;
  4. information output from the system is retained in accordance with applicable laws, Executive Orders, directives, regulations, policies, standards, guidelines, and operational requirements.

Assessment Method

Examine

System and information integrity policy system and information integrity procedures personally identifiable information processing policy records retention and disposition policy records retention and disposition procedures federal laws, Executive Orders, directives, policies, regulations, standards, and operational requirements applicable to information management and retention media protection policy media protection procedures audit findings system security plan privacy plan privacy program plan personally identifiable information inventory privacy impact assessment privacy risk assessment documentation other relevant documents or records

Interview

Organizational personnel with information and records management, retention, and disposition responsibilities organizational personnel with information security and privacy responsibilities network administrators

1. Oversigt

SI-12(01) [P] Limit Personally Identifiable Information Elements

Control

Limit personally identifiable information being processed in the information life cycle to the following elements of personally identifiable information: [Assignement: elements of personally identifiable information].

Discussion

Limiting the use of personally identifiable information throughout the information life cycle when the information is not needed for operational purposes helps to reduce the level of privacy risk created by a system. The information life cycle includes information creation, collection, use, processing, storage, maintenance, dissemination, disclosure, and disposition. Risk assessments as well as applicable laws, regulations, and policies can provide useful inputs to determining which elements of personally identifiable information may create risk.

Assessment Objective

personally identifiable information being processed in the information life cycle is limited to [Assignement: elements of personally identifiable information].

Assessment Method

Examine

System and information integrity policy system and information integrity procedures personally identifiable information processing policy personally identifiable information processing procedures records retention and disposition policy records retention and disposition procedures federal laws, Executive Orders, directives, policies, regulations, standards, and operational requirements applicable to limiting personally identifiable information elements personally identifiable information inventory system audit records audit findings system security plan privacy plan privacy program plan privacy impact assessment privacy risk assessment documentation data mapping documentation other relevant documents or records

Interview

Organizational personnel with information and records management, retention, and disposition responsibilities organizational personnel with security and privacy responsibilities network administrators
SI-12(02) [P] Minimize Personally Identifiable Information in Testing, Training, and Research

Control

Use the following techniques to minimize the use of personally identifiable information for research, testing, or training: [Assignement: organization-defined techniques].

Discussion

Organizations can minimize the risk to an individual’s privacy by employing techniques such as de-identification or synthetic data. Limiting the use of personally identifiable information throughout the information life cycle when the information is not needed for research, testing, or training helps reduce the level of privacy risk created by a system. Risk assessments as well as applicable laws, regulations, and policies can provide useful inputs to determining the techniques to use and when to use them.

Assessment Objective

  1. [Assignement: techniques] are used to minimize the use of personally identifiable information for research;
  2. [Assignement: techniques] are used to minimize the use of personally identifiable information for testing;
  3. [Assignement: techniques] are used to minimize the use of personally identifiable information for training.

Assessment Method

Examine

System and information integrity policy system and information integrity procedures personally identifiable information processing policy personally identifiable information processing procedures federal laws, Executive Orders, directives, policies, regulations, standards, and operational requirements applicable to minimizing the use of personally identifiable information in testing, training, and research policy for the minimization of personally identifiable information used in testing, training, and research procedures for the minimization of personally identifiable information used in testing, training, and research documentation supporting minimization policy implementation (e.g., templates for testing, training, and research) data sets used for testing, training, and research system security plan privacy plan privacy impact assessment privacy risk assessment documentation other relevant documents or records

Interview

Organizational personnel with information and records management, retention, and disposition responsibilities organizational personnel with information security and privacy responsibilities network administrators system developers personnel with IRB responsibilities
SI-12(03) [P] Information Disposal

Control

Use the following techniques to dispose of, destroy, or erase information following the retention period: [Assignement: organization-defined techniques].

Discussion

Organizations can minimize both security and privacy risks by disposing of information when it is no longer needed. The disposal or destruction of information applies to originals as well as copies and archived records, including system logs that may contain personally identifiable information.

Assessment Objective

  1. [Assignement: techniques] are used to dispose of information following the retention period;
  2. [Assignement: techniques] are used to destroy information following the retention period;
  3. [Assignement: techniques] are used to erase information following the retention period.

Assessment Method

Examine

System and information integrity policy system and information integrity procedures personally identifiable information processing policy personally identifiable information processing procedures records retention and disposition policy records retention and disposition procedures laws, Executive Orders, directives, policies, regulations, standards, and operational requirements applicable to information disposal media protection policy media protection procedures system audit records audit findings information disposal records system security plan privacy plan privacy impact assessment privacy risk assessment documentation other relevant documents or records

Interview

Organizational personnel with information and records management, retention, and disposition responsibilities organizational personnel with information security and privacy responsibilities network administrators

1.1 Referencer

1.2 Identificerede krav

1.3 Relaterede reguleringer

2. Identificerede krav

Krav

3. Relaterede reguleringer

Reguleringer

Linkede sager

Sagslinks
is blocked by SI-12 [P] Information Management and Retention – Assessment Procedure
is blocked by Media & Data Retention
is blocked by Personal Data (PD) Retention & Disposal