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NIST Privacy Framework V 1.

0 CORE mapping to the Chapter II - Principles Chapter III- Rights of the Data Subject Chapter IV - Controllers and Processors Chapter V - Transfers
EU Regulation 2016/679 (General Data Protection Regulation)
Mapped elements represent where the GDPR article requires a control that would fall under the NIST Section 1 Section 2 Section 3 Section 4 Section 5 Section 1 Section 2 Section 3 Section 4 Section 5
Core subcategory or a control under the NIST Core subcategory would support activities under the
GDPR article. For instance, inventorying data elements under ID.IM-P6 would be part of the records of Transparency and Modalities Information and Access to Rectification and Erasure Right to object and automated Restrictions General Obligations Security of Personal Data DPIA DPO Certification and Codes of
processing for under Article(30)(1)(c) and would generally help demonstrate compliance Information decision-making Conduct
('accountability') as required by Article (5)(2).

Function Category Subcategory Articles 5-11 Article 12 Articles 13-15 Articles 16-20 Article 21-22 Article 23 Articles 24-31 Articles 32-34 Article 35-36 Articles 37-39 Article 40-43 Articles 44-50
IDENTIFY-P (ID-P): Develop the Inventory and Mapping (ID.IM-P): Data ID.IM-P1: Systems/products/services that Art. 5(2): Accountability Art. 24(1): Responsibilities of Controller Art. 35: DPIA for high risk processing activities
organizational understanding processing by systems, products, or process data are inventoried. Art. 30: Records of Processing
to manage privacy risk for services is understood and informs the
individuals arising from data management of privacy risk. ID.IM-P2: Owners or operators (e.g., the Art. 5(2): Accountability Art. 24(1): Responsibilities of Controller Art. 32(1)(d): Security of Processing - Regular testing of Art. 35(7)(a): Systematic description of the envisaged
processing. organization or third parties such as service Art. 26(1): Responsibilities of joint controllers effectiveness of controls processing operations
providers, partners, customers, and developers) Art. 28(3): Processing based on documented instructions from the Art. 32(2): Security of Processing - Assessing appropriate Art. 35(7)(d): Safeguards, security measures and
and their roles with respect to the controller level of security mechanisms to ensure the protection of personal data
systems/products/services and components Art. 28(4): Engaging subprocessor
(e.g., internal or external) that process data are Art. 30: Records of Processing
inventoried.

ID.IM-P3: Categories of individuals (e.g., Art. 5(2): Accountability Art. 24(1): Responsibilities of Controller Art. 35: DPIA for high risk processing activities
customers, employees or prospective Art. 30: Records of Processing
employees, consumers) whose data are being
processed are inventoried.

ID.IM-P4: Data actions of the Art. 5(2): Accountability Art. 24(1): Responsibilities of Controller
systems/products/services are inventoried. Art. 30: Records of Processing
ID.IM-P5: The purposes for the data actions are Art. 5(2): Accountability Art. 24(1): Responsibilities of Controller Art. 32.4: Security of Processing - individuals with access to Art. 35: DPIA for high risk data processing activites
inventoried. Art. 5(1)(a): Lawful, Fair and Transparent Art. 30: Records of Processing data Art. 36: Prior Consultation
Art. 5(1)(b): Purpose Limitation Art. 28(3)(a): Processor should process based on documented
Art. 5(1)(c): Data Minimization instructions
Art. 5(1)(e): Storage Limitation Art. 28(4): Engaging subprocessor
Art. 29: Processor acting under authority of the controller (or other
processor)

ID.IM-P6: Data elements within the data actions Art. 5(2): Accountability Art. 24(1): Responsibilities of Controller Art. 35: DPIA for high risk data processing activities
are inventoried. Art. 30(1)(c): Records of Processing Art. 36: Prior Consultation
ID.IM-P7: The data processing environment is Art. 5(2): Accountability Art. 24(1): Responsibilities of Controller Art. 32(2): Security of Processing - Assessing appropriate Art. 35: DPIA for high risk data processing activities
identified (e.g., geographic location, internal, Art. 28(3)(h): Processer makes available documentation to controller level of security Art. 36: Prior Consultation
cloud, third parties). Art. 30: Records of Processing

ID.IM-P8: Data processing is mapped, Art. 5(2): Accountability Art. 24(1): Responsibilities of Controller Art. 32(2): Security of Processing - Assessing appropriate Art. 35: DPIA for high risk data processing activities
illustrating the data actions and associated data Art. 28(3)(h): Processer makes available documentation to controller level of security Art. 36: Prior Consultation
elements for systems/products/services, Art. 30: Records of Processing
including components; roles of the component
owners/operators; and interactions of
individuals or third parties with the
systems/products/services.

Business Environment (ID.BE-P): The ID.BE-P1: The organization’s role(s) in the data Art. 5(1)(a): Lawfulness, Fairness and Transparency Art. 12(1): Clear and plain language Art. 13: Notice to data subjects Art. 17(2): Right of Erasure - inform processors, where data Art. 21(4): Notification of right to object Art. 24(3): Controller adherrance to codes of conduct or certification Art. 32(2): Security of Processing - Assessing appropriate Art. 40: Codes of Coduct
organization’s mission, objectives, processing ecosystem are identified and Art. 5(1)(f): Integrity and Confidentiality Art. 12(7): Icons Art. 14: Notice to data subjects released to the public Art. 25(3): DPbDD certification level of security Art. 41: Monitoring codes of conduct
stakeholders, and activities are communicated. Art. 11(2): Processing not requiring identification Art. 15(3): Right of Access - copy of data Art. 28(3)(a): Processor should process based on documented Art. 32(3): Security of Processing - Code of Conduct or Art. 42: Certification
understood and prioritized; this instructions certification
information is used to inform privacy [Note who has oblighations under these articles] Art. 28(3)(e): Processor to assist controller with technical and org.
roles, responsibilities, and risk measures
management decisions. Art. 28(4): Processor use of subprocessor
Art. 28(5): Processor adherance to code of conduct
Art. 28(6): Processor use of standard contract clauses
Art. 28(10): Processor default to controller

ID.BE-P2: Priorities for organizational mission, Art. 5(1)(b): Purpose limitation Art. 32(2): Security of Processing - Assessing appropriate
objectives, and activities are established and level of security
communicated. Art. 32(3): Security of Processing - Code of Conduct or
certification

ID.BE-P3: Systems/products/services that Art. 5(1)(f): Integrity and Confidentiality Art. 28(5): Processor adherance to code of conduct Art. 32(2): Security of Processing - Assessing appropriate Art. 40: Codes of Coduct
support organizational priorities are identified level of security Art. 41: Monitoring codes of conduct
and key requirements communicated. Art. 42: Certification

Risk Assessment (ID.RA-P): The ID.RA-P1: Contextual factors related to the Art. 25(1): DPbDD Design Art. 32(2): Security of Processing - Assessing appropriate Art. 35: DPIA for high risk data processing activities
organization understands the privacy risks systems/products/services and the data actions level of security Art. 35(9): DPIA seek views of data subjects or their
to individuals and how such privacy risks are identified (e.g., individuals’ demographics representatives
may create follow-on impacts on and privacy interests or perceptions, data
organizational operations, including sensitivity and/or types, visibility of data
mission, functions, other risk processing to individuals and third parties).
management priorities (e.g., compliance,
financial), reputation, workforce, and
culture. ID.RA-P2: Data analytic inputs and outputs are Art. 5(1)(a): Lawfulness, Fairness and Transparency Art. 13(2)(f): Notification of automated decision making Art. 22: Automated decision making Art. 25(1): DPbDD Design Art. 35: DPIA for high risk data processing activities
identified and evaluated for bias. Art. 14(2)(g): Notification of automated decision making
ID.RA-P3: Potential problematic data actions Art. 6: Lawfulness of Processing Art. 22: Automated decision making Art. 24(1): Responsibilities of Controller Art. 32(2): Security of Processing - Assessing appropriate
and associated problems are identified. Art. 25(1): DPbDD Design level of security
ID.RA-P4: Problematic data actions, likelihoods, Art. 6: Lawfulness of Processing Art. 24(1): Responsibilities of Controller Art. 32(2): Security of Processing - Assessing appropriate Art. 35: DPIA for high risk data processing activities
and impacts are used to determine and Art. 25(1): DPbDD Design level of security
prioritize risk.
ID.RA-P5: Risk responses are identified, Art. 24(1): Responsibilities of Controller Art. 32(2): Security of Processing - Assessing appropriate Art. 35: DPIA for high risk data processing activities
prioritized, and implemented. Art. 25(1): DPbDD Design level of security
Data Processing Ecosystem Risk ID.DE-P1: Data processing ecosystem risk Art. 5(2): Accountability Art. 24(1): Responsibilities of Controller Art. 32(1)(d): Security of Processing - Regular testing of Art. 35: DPIA for high risk data processing activities
Management (ID.DE-P): The management policies, processes, and Art. 24(2): Responsibilities of Controller - data protection policies effectiveness of controls
organization’s priorities, constraints, risk procedures are identified, established, assessed, Art. 32(2): Security of Processing - Assessing appropriate
tolerance, and assumptions are managed, and agreed to by organizational level of security
established and used to support risk stakeholders.
decisions associated with managing
privacy risk and third parties within the ID.DE-P2: Data processing ecosystem parties Art. 28(1): Controller to use processors providing sufficient guarantees Art. 32(1)(d): Security of Processing - Regular testing of
data processing ecosystem. The (e.g., service providers, customers, partners, effectiveness of controls
organization has established and product manufacturers, application developers) Art. 32(2): Security of Processing - Assessing appropriate
implemented the processes to identify, are identified, prioritized, and assessed using a level of security
assess, and manage privacy risks within privacy risk assessment process.
the data processing ecosystem.
ID.DE-P3: Contracts with data processing Art. 5(1)(f): Integrity and Confidentiality Art. 26: Joint Controllers Art. 32(1)(b): Security of Processing - ensure ongoing CIA Art. 35(1): DPIA High Risk assessment
ecosystem parties are used to implement Art. 5(2): Accountability Art. 28(1,3, 4,6 &9): Processors governed by contract
appropriate measures designed to meet the Art. 30(2)(d): Records of processing - processor to maintain records of
objectives of an organization’s privacy program. security measures

ID.DE-P4: Interoperability frameworks or similar Art. 32: Security of Processing


multi-party approaches are used to manage Art. 32(2): Security of Processing - Assessing appropriate
data processing ecosystem privacy risks. level of security

ID.DE-P5: Data processing ecosystem parties are Art. 5(1)(f): Integrity and Confidentiality Art. 24(1): Responsibilities of Controller Art. 32(1)(b): Security of Processing - Ensure ongoing CIA Art. 35(11): DPIA - Periodic review of DPIA
routinely assessed using audits, test results, or Art. 5(2): Accountability Art. 28(1,3,4 &9): Processors governed by contract
other forms of evaluations to confirm they are Art. 30(2)(d): Records of processing - processor to maintain records of
meeting their contractual, interoperability security measures
framework, or other obligations.

GOVERN-P (GV-P): Develop and Governance Policies, Processes, and GV.PO-P1: Organizational privacy values and Art. 6: Lawfulness of Processing Art. 24(2): Controller - appropriate data protection policies
implement the organizational Procedures (GV.PO-P): The policies, policies (e.g., conditions on data processing
governance structure to enable processes, and procedures to manage and such as data uses or retention periods,
an ongoing understanding of monitor the organization’s regulatory, individuals’ prerogatives with respect to data
the organization’s risk legal, risk, environmental, and operational processing) are established and communicated.
management priorities that requirements are understood and inform
are informed by privacy risk. the management of privacy risk.
GV.PO-P2: Processes to instill organizational Art. 25(1): DPbDD Design
privacy values within system/product/service
development and operations are established
and in place.

GV.PO-P3: Roles and responsibilities for the Art. 5(2): Accountability Art. 27: Representatives Art. 37: Data Protection Officer
workforce are established with respect to Art. 38: DPO qualifications
privacy. Art. 39: Tasks of a DPO

GV.PO-P4: Privacy roles and responsibilities are Art. 5(1)(f): Integrity and Confidentiality Art. 28(1,3,4 &9): Processors governed by contract Art. 32(1)(b): Security of Processing - ensure ongoing CIA
coordinated and aligned with third-party Art. 5(2): Accountability Art. 30(2)(d): Records of processing - processor to maintain records of
stakeholders (e.g., service providers, customers, security measures
partners).

GV.PO-P5: Legal, regulatory, and contractual Art. 5(1)(f): Integrity and Confidentiality Art. 23: Restrictions Art. 24(3): Controller adherrance to codes of conduct or certification Art. 32(1)(b): Security of Processing - Ensure ongoing CIA Art. 40: Codes of Coduct
requirements regarding privacy are understood Art. 6: Lawfulness of Processing Art. 25(3): DPbDD certification Art. 32(2): Security of Processing - Assessing appropriate Art. 41: Monitoring codes of conduct
and managed. Art. 28(3): Processors governed by contract level of security Art. 42: Certification
Art. 28(4): Processor use of subprocessor Art. 32(3): Security of Processing - Code of Conduct or
Art. 28(5): Processor adherance to code of conduct certification
Art. 28(6): Processor use of standard contract clauses
Art. 28(10): Processor default to controller

GV.PO-P6: Governance and risk management Art. 24(2): Responsibilities of Controller - data protection policies Art. 32(1)(d): Security of Processing - Regular testing of
policies, processes, and procedures address effectiveness of controls
privacy risks. Art. 32(2): Security of Processing - Assessing appropriate
level of security

Risk Management Strategy (GV.RM-P): GV.RM-P1: Risk management processes are Art. 32(2): Security of Processing - Assessing appropriate
The organization’s priorities, constraints, established, managed, and agreed to by level of security
risk tolerances, and assumptions are organizational stakeholders.
established and used to support
operational risk decisions. GV.RM-P2: Organizational risk tolerance is Art. 32(2): Security of Processing - Assessing appropriate
determined and clearly expressed. level of security
GV.RM-P3: The organization’s determination of Art. 24(1): Responsibilities of Controller Art. 32(2): Security of Processing - Assessing appropriate
risk tolerance is informed by its role(s) in the level of security
data processing ecosystem.
Awareness and Training (GV.AT-P): The GV.AT-P1: The workforce is informed and Art. 27: Representatives Art. 37: Data Protection Officer
organization’s workforce and third parties trained on its roles and responsibilities. Art. 38: DPO qualifications
engaged in data processing are provided Art. 39: Tasks of a DPO
privacy awareness education and are
trained to perform their privacy-related GV.AT-P2: Senior executives understand their Art. 27: Representatives Art. 37: Data Protection Officer
duties and responsibilities consistent with roles and responsibilities. Art. 38: DPO qualifications
related policies, processes, procedures, Art. 39: Tasks of a DPO
and agreements and organizational
privacy values. GV.AT-P3: Privacy personnel understand their Art. 27: Representatives Art. 37: Data Protection Officer
roles and responsibilities. Art. 38: DPO qualifications
Art. 39: Tasks of a DPO

GV.AT-P4: Third parties (e.g., service providers, Art. 5(1)(f): Integrity and Confidentiality Art. 12(1): Clear and plain language Art. 15(3): Right of Access - copy of data Art. 17(2): Right of Erasure - inform processors, where data Art. 21(4): Notification of right to object Art. 24(2): Controller - appropriate data protection policies Art. 32(1)(b): Security of Processing - ensure ongoing CIA Art. 35(1): DPIA High risk assessment
customers, partners) understand their roles and Art. 5(2): Accountability Art. 12(7): Icons released to the public Art. 28(1,3,4 &9): Processors governed by contract
responsibilities. Art. 11(2): Processing not requiring identification

Monitoring and Review (GV.MT-P): The GV.MT-P1: Privacy risk is re-evaluated on an Art. 32(2): Security of Processing - Assessing appropriate Art. 35(11): DPIA - Periodic review of DPIA
policies, processes, and procedures for ongoing basis and as key factors, including the level of security
ongoing review of the organization’s organization’s business environment (e.g.,
privacy posture are understood and introduction of new technologies), governance
inform the management of privacy risk. (e.g., legal obligations, risk tolerance), data
processing, and systems/products/services
change.

GV.MT-P2: Privacy values, policies, and training Art. 27: Representatives Art. 37: Data Protection Officer
are reviewed and any updates are Art. 38: DPO qualifications
communicated. Art. 39: Tasks of a DPO

GV.MT-P3: Policies, processes, and procedures Art. 32(1)(d): Security of Processing - Regular testing of
for assessing compliance with legal effectiveness of controls
requirements and privacy policies are Art. 32(2): Security of Processing - Assessing appropriate
established and in place. level of security

GV.MT-P4: Policies, processes, and procedures Art. 32(1)(d): Security of Processing - Regular testing of
for communicating progress on managing effectiveness of controls
privacy risks are established and in place. Art. 32(2): Security of Processing - Assessing appropriate
level of security

GV.MT-P5: Policies, processes, and procedures


are established and in place to receive, analyze,
and respond to problematic data actions
disclosed to the organization from internal and
external sources (e.g., internal discovery,
privacy researchers, professional events).

GV.MT-P6: Policies, processes, and procedures


incorporate lessons learned from problematic
data actions.
GV.MT-P7: Policies, processes, and procedures Art. 12(3-6): Right to notice Art. 15: Right of Access Art. 17(2): Right of Erasure - inform processors, where data Art. 28(3)(e): Processor to assist controller with technical and org. Art. 38(4): DPO as a point of contact to for data subjects.
for receiving, tracking, and responding to released to the public measures
complaints, concerns, and questions from
individuals about organizational privacy
practices are established and in place.

CONTROL-P (CT-P): Develop Data Processing Policies, Processes, and CT.PO-P1: Policies, processes, and procedures Art. 5(1)(a): Lawful, Fair and Transparent Art. 12(2): Controller obligation to fulfill rights of data Art. 17(3): Exemptions for right to erasure Art. 22: Automated decision making Art. 28(3)(a): Processor processing only on documented instruction Art. 32(4): Security of processing supervision of person Art. 35: DPIA for high risk data processing activities
and implement appropriate Procedures (CT.PO-P): Policies, processes, for authorizing data processing (e.g., Art. 5(1)(b): Purpose Limitation subject (especially around revocation of authorization) Art. 18(2): Exception to right to restriction of processing Art. 29: Processing under authority of controller or processor under control of controller
activities to enable and procedures are maintained and used organizational decisions, individual consent), Art. 6: Lawfulness of Processing
organizations or individuals to to manage data processing (e.g., purpose, revoking authorizations, and maintaining Art. 7: Conditions of Consent
manage data with sufficient scope, roles and responsibilities in the authorizations are established and in place. Art. 8: Child's cosent
granularity to manage privacy data processing ecosystem, and Art. 9: Processing special categories of data
risks. management commitment) consistent Art. 10: Processing criminal data
with the organization’s risk strategy to
protect individuals’ privacy.
CT.PO-P2: Policies, processes, and procedures Art. 5(1)(d): Accuracy Art. 12(2): Controller obligation to fulfill rights of data Art. 13(2)(b): Notification of right to rectification or erasure Art. 16: Right to rectification Art. 21: Right to Object Art. 28: Processor obligations Art. 44: Crossborder transfers
for enabling data review, transfer, sharing or Art. 5(2): Accountability subject, Art. 13(2)(c): Notification of right to withdraw consent Art. 17: Right of Erasure Art. 22: Automated decision making Art. 28(3)(e): Processor to assist controller with technical and Art. 45: Transfers based on adequacy
disclosure, alteration, and deletion are Art. 7(3): Right to withdraw consent Art. 13(2)(f): Notification of automated decision making Art. 18: Right to Restriction of Processing organizational measures Art. 46: Transfers based on appropriate safeguards
established and in place (e.g., to maintain data Art. 14(2)(c): Notification of right to rectification or erasure Art. 20: Right to Data Portability Art. 30(1)(d): Records of processing categories of recipients Art. 47: Transfers based on BCRs
quality, manage data retention). Art. 14(2)(d): Notification of right to withdraw consent Art. 30(1)(e): Records of processing by controller: transfers Art. 48: Transfers not authorized by law
Art. 14(2)(g): Notification of automated decision making Art. 30(2)(c): Records of processing by processors: transfers Art. 49: Derogation for transfers
Art. 15: Right of access

CT.PO-P3: Policies, processes, and procedures Art. 7(3): Right to withdraw consent Art. 12(2): Controller obligation to fulfill rights of data Art. 13(2)(f): Notification of automated decision making Art. 16: Right to rectification Art. 21: Right to Object Art. 28(3)(e): Processor to assist controller with technical and org.
for enabling individuals’ data processing subject Art. 13)(2)(b): Notification of right to erasure Art. 17: Right of Erasure Art. 22: Automated decision making measures
preferences and requests are established and in Art. 13(2)(c): Notification of right to withdraw consent Art. 18: Right to Restriction of Processing
place. Art. 14(2)(c): Notification of right to erasure Art. 20: Right to Data Portability
Art. 14(2)(d): Notification of right to withdraw consent
Art. 14(2)(g): Notification of automated decision making
Art. 15(3): Right of Access - copy of data
Art. 15(4): Right of access - not infringe rights of others

CT.PO-P4: A data life cycle to manage data is Art. 25(1): DPbDD Design
aligned and implemented with the system
development life cycle to manage systems.
Data Processing Management (CT.DM-P): CT.DM-P1: Data elements can be accessed for Art. 5(1)(d): Accuracy Art. 15(3): Right of Access - copy of data Art. 16: Right to rectification Art. 28(3)(e): Processor to assist controller with technical and org.
Data are managed consistent with the review. Art. 17: Right of Erasure measures
organization’s risk strategy to protect Art. 30: Records of Processing Activities
individuals’ privacy, increase
manageability, and enable the CT.DM-P2: Data elements can be accessed for Art. 5(1)(d): Accuracy Art. 15(3): Right of Access - copy of data Art. 16: Right to rectification Art. 28(3)(e): Processor to assist controller with technical and org.
implementation of privacy principles (e.g., transmission or disclosure. Art. 17: Right of Erasure measures
individual participation, data quality, data Art. 20: Right to Data Portability
minimization).
CT.DM-P3: Data elements can be accessed for Art. 5(1)(d): Accuracy Art. 15(3): Right of Access - copy of data Art. 16: Right to rectification Art. 28(3)(e): Processor to assist controller with technical and org.
alteration. measures

CT.DM-P4: Data elements can be accessed for Art. 5(1)(c): Data Minimization Art. 15(3): Right of Access - copy of data Art. 16: Right to rectification Art. 28(3)(e): Processor to assist controller with technical and org.
deletion. Art. 5(1)(d): Accuracy Art. 17: Right of Erasure measures

CT.DM-P5: Data are destroyed according to Art. 5(1)(c): Data Minimization Art. 28(3)(a): Processor should process based on documented
policy. instructions
Art. 28(3)(g): Processor obligation to delete data at end of contract

CT.DM-P6: Data are transmitted using Art. 5(1)(f): Integrity and Confidentiality Art. 15(3): Right of Access - copy of data Art. 17(2): Right of Erasure - inform processors, where data Art. 28(3)(e): Processor to assist controller with technical and org. Art. 32(1)(b): Ensure ongoing confidentiality, integrity and
standardized formats. Art. 5(1)(d): Accuracy released to the public measures availability.
Art. 20: Right to Data Portability

CT.DM-P7: Mechanisms for transmitting Art. 5(1)(b): Purpose Limitation Art. 28(3)(g): Processor obligation to delete data at end of contract
processing permissions and related data values Art. 5(1)(c): Data Minimization Art. 30(1)(f): Records of processing- data retention/deletion schedule
with data elements are established and in place. Art. 5(1)(e): Storage Limitation
Art. 5(1)(f): Integrity and Confidentiality

CT.DM-P8: Audit/log records are determined, Art. 5(1)(f): Integrity and Confidentiality Art. 24(1): Responsibilities of Controller Art. 32(1)(b): Ensure ongoing confidentiality, integrity and
documented, implemented, and reviewed in Art. 5(2): Accountability Art. 24(2): Controller - appropriate data protection policies availability.
accordance with policy and incorporating the
principle of data minimization.

CT.DM-P9: Technical measures implemented to Art. 32(1)(b): Security of Processing - Ensure ongoing CIA
manage data processing are tested and
assessed.
CT.DM-P10: Stakeholder privacy preferences Art. 22: Automated decision making Art. 32(1)(b): Ensure ongoing confidentiality, integrity and
are included in algorithmic design objectives availability.
and outputs are evaluated against these
preferences.

Disassociated Processing (CT.DP-P): Data CT.DP-P1: Data are processed to limit Art. 5(1)(c): Data Minimization Art. 32(1)(b): Ensure ongoing confidentiality, integrity and Art. 35: DPIA for high risk data processing activities
processing solutions increase observability and linkability (e.g., data actions Art. 5(1)(e): Storage Limitation availability.
disassociability consistent with the take place on local devices, privacy-preserving
organization’s risk strategy to protect cryptography).
individuals’ privacy and enable
implementation of privacy principles (e.g., CT.DP-P2: Data are processed to limit the Art. 5(1)(c): Data Minimization Art. 25(2): DPbDD Default
data minimization). identification of individuals (e.g., de- Art. 5(1)(e): Storage Limitation
identification privacy techniques, tokenization). Art. 11(1): Processing not requiring identification

CT.DP-P3: Data are processed to limit the Art. 5(1)(a): Lawful, Fair and Transparent Art. 25(2): DPbDD Default Art. 32(4): Security of processing supervision of person
formulation of inferences about individuals’ Art. 5(1)(b): Purpose Limitation Art. 28(3)(a): Processor to process under instructions of controller under control of controller
behavior or activities (e.g., data processing is Art. 5(1)(c): Data Minimization Art. 28(3)(h): Processor to demonstrate compliance with instructions
decentralized, distributed architectures). Art. 5(1)(e): Storage Limitation

CT.DP-P4: System or device configurations Art. 5(1)(b): Purpose Limitation Art. 25(2): DPbDD Default
permit selective collection or disclosure of data Art. 5(1)(c): Data Minimization
elements.
CT.DP-P5: Attribute references are substituted Art. 5(1)(c): Data Minimization Art. 32(1)(a): Security of Processing - Pseudonymization
for attribute values. Art. 5(1)(e): Storage Limitation
Art. 11(1): Processing not requiring identification

COMMUNICATE-P (CM-P): Communication Policies, Processes, and CM.PO-P1: Transparency policies, processes, Art. 11(2): Where, in cases referred to in paragraph 1 of this Art. 12(1): Clear and plain language Art. 13: Notification where data collected from data subject Art. 17(2): Right of Erasure - inform processors, where data Art. 21(4): Notification of right to object Art. 28(3)(e): Processor to assist controller with technical and org.
Develop and implement Procedures (CM.PO-P): Policies, and procedures for communicating data Article, the controller is able to demonstrate that it is not in a Art. 12(7): Icons Art. 14: Notification where data collected not from data released to the public measures
appropriate activities to enable processes, and procedures are maintained processing purposes, practices, and associated position to identify the data subject, the controller shall subject Art. 18(3): Right of Restriction, right to be informed before
organizations and individuals to and used to increase transparency of the privacy risks are established and in place. inform the data subject accordingly, if possible. In such Art. 15: Right of Access restriction is lifted
have a reliable understanding organization’s data processing practices cases, Articles 15 to 20 shall not apply except where the data
and engage in a dialogue about (e.g., purpose, scope, roles and subject, for the purpose of exercising his or her rights under
how data are processed and responsibilities in the data processing those articles, provides additional information enabling his or
associated privacy risks. ecosystem, and management her identification.
commitment) and associated privacy risks.

CM.PO-P2: Roles and responsibilities (e.g., Art. 11(2): Where, in cases referred to in paragraph 1 of this Art. 12(1): Clear and plain language Art. 13: Notification where data collected from data subject Art. 17(2): Right of Erasure - inform processors, where data Art. 21(4): Notification of right to object Art. 27: Representatives Art. 37: Data Protection Officer
public relations) for communicating data Article, the controller is able to demonstrate that it is not in a Art. 12(7): Icons Art. 14: Notification where data collected not from data released to the public Art. 28(3)(e): Processor to assist controller with technical and org. Art. 38: DPO qualifications
processing purposes, practices, and associated position to identify the data subject, the controller shall subject Art. 18(3): Right of Restriction, right to be informed before measures Art. 39: Tasks of a DPO
privacy risks are established. inform the data subject accordingly, if possible. In such Art. 15: Right of Access restriction is lifted
cases, Articles 15 to 20 shall not apply except where the data
subject, for the purpose of exercising his or her rights under
those articles, provides additional information enabling his or
her identification.

Data Processing Awareness (CM.AW-P): CM.AW-P1: Mechanisms (e.g., notices, internal Art. 7: Conditions of Consent Art. 12(1): Clear and plain language Art. 13: Notification where data collected from data subject Art. 17(2): Right of Erasure - inform processors, where data Art. 21(4): Notification of right to object Art. 28(3)(e): Processor to assist controller with technical and org.
Individuals and organizations have reliable or public reports) for communicating data Art. 11(2): Where, in cases referred to in paragraph 1 of this Art. 12(7): Icons Art. 14: Notification where data collected not from data released to the public measures
knowledge about data processing processing purposes, practices, associated Article, the controller is able to demonstrate that it is not in a subject Art. 18(3): Right of Restriction, right to be informed before
practices and associated privacy risks, and privacy risks, and options for enabling position to identify the data subject, the controller shall Art. 15: Right of Access restriction is lifted
effective mechanisms are used and individuals’ data processing preferences and inform the data subject accordingly, if possible. In such
maintained to increase predictability requests are established and in place. cases, Articles 15 to 20 shall not apply except where the data
consistent with the organization’s risk subject, for the purpose of exercising his or her rights under
strategy to protect individuals’ privacy. those articles, provides additional information enabling his or
her identification.

CM.AW-P2: Mechanisms for obtaining feedback Art. 5(1)(f): processed in a manner that ensures appropriate Art. 12: Controller obligations to notice (data subject Art. 15: Right of Access Art. 28(3)(e): Processor to assist controller with technical and org. Art. 35(9): DPIA seek views of data subjects or their
from individuals (e.g., surveys or focus groups) security of the personal data, including protection against exercise of rights) measures representatives
about data processing and associated privacy unauthorised or unlawful processing and against accidental Art. 31: Cooperation with supervisor authorities Art. 36: Prior Consultation
risks are established and in place. loss, destruction or damage, using appropriate technical or
organizational measures ('integrity and confidentiality').

CM.AW-P3: System/product/service design Art. 11(2): Processing not requiring identification [Exception Art. 12(1): Clear and plain language Art. 13: Notification where data collected from data subject Art. 17(2): Right of Erasure - inform processors, where data Art. 21(4): Notification of right to object Art. 28(3)(e): Processor to assist controller with technical and org. Art. 32(1)(b): Ensure ongoing Confidentiality, Integrity and
enables data processing visibility. to data processing visilibity] Art. 12(7): Icons Art. 14: Notification where data collected not from data released to the public measures Availability
subject Art. 18(3): Right of Restriction, right to be informed before
Art. 15: Right of Access restriction is lifted

CM.AW-P4: Records of data disclosures and Art. 28(3): Processing to be governed by contract Art. 48: Transfers or disclosures not authorized by law
sharing are maintained and can be accessed for Art. 30(1)(d): Records of processing categories of receipients
review or transmission/disclosure.
CM.AW-P5: Data corrections or deletions can Art. 11(2): Where, in cases referred to in paragraph 1 of this Art. 12(1): Clear and plain language Art. 13(3): Notice to data subjects of additional processing Art. 17(2): Right of Erasure - inform processors, where data Art. 21(4): Notification of right to object Art. 28(3)(e): Processor to assist controller with technical and org.
be communicated to individuals or Article, the controller is able to demonstrate that it is not in a Art. 12(7): Icons Art. 14(4): Notice to data subjects of additional processing released to the public measures
organizations (e.g., data sources) in the data position to identify the data subject, the controller shall Art. 15(3): Right of Access - copy of data Art. 19: Notification of obligation of rectification and erasure
processing ecosystem. inform the data subject accordingly, if possible. In such
cases, Articles 15 to 20 shall not apply except where the data
subject, for the purpose of exercising his or her rights under
those articles, provides additional information enabling his or
her identification.

CM.AW-P6: Data provenance and lineage are Art. 5(1)(f): Integrity and Confidentiality Art. 24(1): Responsibility of control to demonstrate compliance Art. 32(2): Security of Processing - Assessing appropriate
maintained and can be accessed for review or Art. 5(2): Accountability Art. 30: Records of processing activities level of security
transmission/disclosure.
CM.AW-P7: Impacted individuals and Art. 28(3): Processor's responsbilities Art. 33: Notification of data breach to supervisory authority
organizations are notified about a privacy Art. 34: Notification of data breach to data subject
breach or event.

CM.AW-P8: Individuals are provided with Art. 5(1)(d): Accuracy Art. 13(2)(b): Notification of right to rectification or erasure Art. 16: Right to Rectification Art. 28(3)(e): Processor to assist controller with technical and org.
mitigation mechanisms (e.g., credit monitoring, Art. 14(2)(c): Notification of right to rectification or erasure Art. 17: Right of Erasure measures
consent withdrawal, data alteration or deletion) Art. 15(3): Right of Access - copy of data
to address impacts of problematic data actions.

PROTECT-P (PR-P): Develop Data Protection Policies, Processes, and PR.PO-P1: A baseline configuration of Art. 5(1)(b): Purpose Limitation Art. 25(2): DPbDD Default
and implement appropriate Procedures (PR.PO-P): Security and information technology is created and Art. 5(1)(c): Data Minimization
data processing safeguards. privacy policies (e.g., purpose, scope, roles maintained incorporating security principles
and responsibilities in the data processing (e.g., concept of least functionality).
ecosystem, and management
commitment), processes, and procedures PR.PO-P2: Configuration change control
are maintained and used to manage the processes are established and in place.
protection of data.
PR.PO-P3: Backups of information are Art. 5(1)(f): Integrity and Confidentiality Art. 32(1)(c): Security of Processing - Ability to restore data
conducted, maintained, and tested.
PR.PO-P4: Policy and regulations regarding the
physical operating environment for
organizational assets are met.
PR.PO-P5: Protection processes are improved. Art. 32(1)(b): Security of Processing - Ensure ongoing CIA
Art. 32(2): Security of Processing - Assessing appropriate
level of security

PR.PO-P6: Effectiveness of protection Art. 11(2): Where, in cases referred to in paragraph 1 of this Art. 12(1): Clear and plain language Art. 13: Notice to data subjects Art. 28(3)(e): Processor to assist controller with technical and org. Art. 32(1)(b): Security of Processing - Ensure ongoing CIA
technologies is shared. Article, the controller is able to demonstrate that it is not in a Art. 12(7): Icons Art. 14: Notice to data subjects measures
position to identify the data subject, the controller shall
inform the data subject accordingly, if possible. In such
cases, Articles 15 to 20 shall not apply except where the data
subject, for the purpose of exercising his or her rights under
those articles, provides additional information enabling his or
her identification.

PR.PO-P7: Response plans (Incident Response Art. 5(1)(f): Integrity and Confidentiality Art. 33: Notification of data breach to supervisory authority
and Business Continuity) and recovery plans Art. 34: Notification of data breach to data subject
(Incident Recovery and Disaster Recovery) are
established, in place, and managed.

PR.PO-P8: Response and recovery plans are Art. 32(1)(b): Security of Processing - Ensure ongoing
tested. confidentiality, integrity, availability
Art. 32(1)(c): Security of Processing - Ability to restore data

PR.PO-P9: Privacy procedures are included in Art. 5(1)(f): Integrity and Confidentiality [requiring Art. 28(3)(b): Processor ensures person processing data are governed by
human resources practices (e.g., deprovisioning, personnell to execute confidentiality agreements] contract or law to the confidentiality of data
personnel screening).
PR.PO-P10: A vulnerability management plan is Art. 32(1)(d): Security of Processing - Regular testing of
developed and implemented. effectiveness of controls
Art. 32(2)(d): Security of Processing - Assess appropriate
level of security

Identity Management, Authentication, PR.AC-P1: Identities and credentials are issued, Art. 5(1)(f): Integrity and Confidentiality
and Access Control (PR.AC-P): Access to managed, verified, revoked, and audited for
data and devices is limited to authorized authorized individuals, processes, and devices.
individuals, processes, and devices, and is
managed consistent with the assessed risk PR.AC-P2: Physical access to data and devices is Art. 5(1)(f): Integrity and Confidentiality
of unauthorized access. managed.
PR.AC-P3: Remote access is managed. Art. 5(1)(f): Integrity and Confidentiality
PR.AC-P4: Access permissions and Art. 5(1)(b): Purpose limitation
authorizations are managed, incorporating the Art. 5(1)(f): Integrity and Confidentiality
principles of least privilege and separation of
duties.

PR.AC-P5: Network integrity is protected (e.g., Art. 5(1)(f): Integrity and Confidentiality Art. 32(1)(a): Security of Processing - Pseudonymization
network segregation, network segmentation). and encryption
PR.AC-P6: Individuals and devices are proofed Art. 5(1)(f): Integrity and Confidentiality
and bound to credentials, and authenticated
commensurate with the risk of the transaction
(e.g., individuals’ security and privacy risks and
other organizational risks).

Data Security (PR.DS-P): Data are PR.DS-P1: Data-at-rest are protected. Art. 5(1)(f): Integrity and Confidentiality Art. 32(1)(a): Security of Processing - Pseudonymization
managed consistent with the and encryption
organization’s risk strategy to protect
individuals’ privacy and maintain data PR.DS-P2: Data-in-transit are protected. Art. 5(1)(f): Integrity and Confidentiality Art. 32(1)(a): Security of Processing - Pseudonymization
confidentiality, integrity, and availability. and encryption
PR.DS-P3: Systems/products/services and Art. 5(1)(c): Data Minimization Art. 28(3)(g): Processor deletion of process at conclusion of contract Art. 32(1)(a): Security of Processing - Pseudonymization
associated data are formally managed Art. 5(1)(e): Storage Limitation Art. 30(1)(f): Data retention/deletion schedule and encryption
throughout removal, transfers, and disposition. Art. 5(1)(f): Integrity and Confidentiality
Art. 6(4)(e): Processing in the public interest
(deidentification of data after primary purpose but further in
public interest)
Art. 11(1): Processing not requiring identification

PR.DS-P4: Adequate capacity to ensure


availability is maintained.
PR.DS-P5: Protections against data leaks are Art. 5(1)(f): Integrity and Confidentiality Art. 32(1)(a): Security of Processing - Pseudonymization
implemented. and encryption
PR.DS-P6: Integrity checking mechanisms are Art. 5(1)(f): Integrity and Confidentiality Art. 32(1)(d): Security of Processing - Regular testing of
used to verify software, firmware, and effectiveness of controls
information integrity. Art. 32(2): Security of Processing - Assessing appropriate
level of security

PR.DS-P7: The development and testing Art. 5(1)(f): Integrity and Confidentiality
environment(s) are separate from the
production environment.
PR.DS-P8: Integrity checking mechanisms are Art. 5(1)(f): Integrity and Confidentiality Art. 32(1)(d): Security of Processing - Regular testing of
used to verify hardware integrity. effectiveness of controls
Art. 32(2): Security of Processing - Assessing appropriate
level of security

Maintenance (PR.MA-P): System PR.MA-P1: Maintenance and repair of Art. 32(1)(b): Security of Processing - Ensure ongoing CIA
maintenance and repairs are performed organizational assets are performed and logged,
consistent with policies, processes, and with approved and controlled tools.
procedures.
PR.MA-P2: Remote maintenance of Art. 5(1)(f): Integrity and Confidentiality
organizational assets is approved, logged, and
performed in a manner that prevents
unauthorized access.

Protective Technology (PR.PT-P): PR.PT-P1: Removable media is protected and its Art. 5(1)(f): Integrity and Confidentiality Art. 32(1)(a): Security of Processing - Pseudonymization
Technical security solutions are managed use restricted according to policy. and encryption
to ensure the security and resilience of
systems/products/services and associated PR.PT-P2: The principle of least functionality is Art. 5(1)(b): Purpose Limitation Art. 25(2): DPbDD Default
data, consistent with related policies, incorporated by configuring systems to provide Art. 5(1)(c): Data Minimization
processes, procedures, and agreements. only essential capabilities. Art. 5(1)(e): Storage Limitation

PR.PT-P3: Communications and control Art. 5(1)(f): Integrity and Confidentiality


networks are protected.
PR.PT-P4: Mechanisms (e.g., failsafe, load Art. 32(1)(b): Security of Processing - Ensure ongoing CIA
balancing, hot swap) are implemented to Art. 32(1)(c): Security of Processing - Ability to restore data
achieve resilience requirements in normal and
adverse situations.

Thanks to those who contributed their comments! Limitations While every effort has been made to be complete and provide as much detail as necessary, no guarantee or warranty is provided on the accuracy or completeness of this mapping. You should use it as a starting point for your own analysis.

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