NIST Privacy Framework: A Tool for Improving Privacy through Enterprise Risk Management

The NIST Privacy Framework (PF) is a voluntary tool developed by the US National Institute of Standards and Technology in collaboration with industry, government, and consumer stakeholders. Version 1.0 was published on January 16, 2020.

Its purpose is to help organizations identify and manage privacy risk so they can build innovative products and services while protecting individuals’ privacy. Like the NIST Cybersecurity Framework (CSF), it is technology- and sector-agnostic and is designed to be adapted to an organization’s specific context, risk tolerance, and resources.

Unlike GDPR, the Privacy Framework is not a compliance regulation. It is a risk management tool that helps organizations think through privacy systematically — useful both for organizations subject to GDPR or other regulations, and for those seeking to build privacy into products proactively.

Brief History

  • January 2020: Privacy Framework Version 1.0 published — NIST.CSWP.01162020
  • 2020–2024: Crosswalk documents published mapping the PF to GDPR, ISO/IEC 29100, and NIST SP 800-53
  • 2024: Privacy Framework Version 1.1 Initial Public Draft released, aligning more closely with the updated CSF 2.0

The Five Core Functions

The framework organizes privacy management around five functions. Each carries a -P suffix to distinguish it from overlapping functions in the NIST Cybersecurity Framework.

Function Purpose
IDENTIFY-P Develop an organizational understanding of privacy risk to systems, people, assets, and data. Includes data inventory and mapping, understanding data processing roles, and privacy risk assessment.
GOVERN-P Develop and implement organizational governance structures for privacy. Covers privacy policies, roles and accountability, legal basis for data processing, and privacy risk management strategy.
CONTROL-P Develop and implement activities that allow individuals and organizations to manage data with sufficient granularity to manage privacy risks. Includes data minimization, purpose limitation, consent mechanisms, and individual rights support.
COMMUNICATE-P Develop and implement activities that enable organizations and individuals to have a reliable understanding of how data are processed and associated risks. Covers privacy notices, transparency reporting, and stakeholder engagement.
PROTECT-P Develop and implement appropriate safeguards for data processing to prevent privacy risks from materializing. Includes data security controls, access management, and data lifecycle management.

GOVERN-P is the cross-cutting function: governance structures inform and shape decisions across IDENTIFY-P, CONTROL-P, COMMUNICATE-P, and PROTECT-P.

Key Concepts

Privacy risk in the framework’s terms: the likelihood that the processing of personal information could cause problematic data actions, resulting in adverse consequences for individuals — such as embarrassment, discrimination, economic harm, or loss of autonomy.

Data processing ecosystem: the framework explicitly addresses not just an organization’s internal processing but the full ecosystem of vendors, processors, and partners involved in handling personal data. This aligns with the controller/processor distinction in GDPR and supply chain risk management in NIST SP 800-53.

Profiles and Tiers: Like the CSF, the PF uses Profiles (current vs. target state) and Implementation Tiers (from partial/ad-hoc to adaptive) to help organizations assess maturity and prioritize improvements.

Quality Attributes Emphasized

Quality Attribute Relevance in NIST Privacy Framework
Privacy The central focus of the framework: structured risk management for the entire personal data lifecycle, from collection through deletion.
Confidentiality PROTECT-P requires safeguards to prevent unauthorized access or disclosure of personal information throughout processing.
Compliance GOVERN-P addresses legal bases for processing and alignment with applicable privacy regulations; crosswalks map the PF directly to GDPR and ISO 29100.
Transparency COMMUNICATE-P requires organizations to disclose data practices reliably and enable informed engagement from individuals.
Accountability GOVERN-P establishes clear ownership of privacy responsibilities; accountability for processing decisions is a core governance requirement.
Traceability IDENTIFY-P requires data inventory and mapping — understanding what data is collected, where it flows, who processes it, and for what purpose.
Security PROTECT-P overlaps with cybersecurity controls; NIST publishes an official crosswalk to SP 800-53 security and privacy controls.
Fairness CONTROL-P addresses data minimization and purpose limitation — ensuring individuals’ data is not used in ways they would not reasonably expect.

Relationship to Other Standards

Standard Relationship
GDPR GDPR is a binding regulation; the Privacy Framework is a voluntary risk management tool. NIST publishes an official crosswalk mapping PF categories to GDPR articles. Organizations use the PF to operationalize GDPR compliance systematically rather than treating it as a pure checklist.
ISO/IEC 29100 ISO 29100 provides privacy principles and a terminology framework; the NIST PF provides the operational risk management structure. The two are complementary — ISO 29100 defines what privacy means, the PF defines how to manage it as an organizational risk.
NIST SP 800-53 NIST publishes an official crosswalk between the Privacy Framework and the SP 800-53 privacy controls (the PT control family and others). Organizations already using SP 800-53 can extend it with PF profiles to address privacy risk beyond compliance controls.
ISO/IEC 27001 ISO 27001 focuses on information security management; PROTECT-P draws on the same safeguarding principles. The PF is broader: it addresses privacy risks arising from legitimate data processing, not just security incidents.

What is NIST?

NIST stands for the National Institute of Standards and Technology. It is a non-regulatory agency of the US Department of Commerce responsible for developing standards, guidelines, and voluntary frameworks. NIST frameworks (CSF, AI RMF, Privacy Framework) are widely adopted in US federal agencies, critical infrastructure, and commercial organizations globally.

References

Official NIST Sources