PT-3(1)_data-tagging

PT-3(1) Data Tagging

Enhancement of: PT-3

High-Level Description

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

Data tags support the tracking of processing purposes by conveying the purposes along with the relevant elements of personally identifiable information throughout the system. By conveying the processing purposes in a data tag along with the personally identifiable information as the information transits a system, a system owner or operator can identify whether a change in processing would be compatible with the identified and documented purposes. Data tags may also support the use of automated tools.

What to Check

• Verify PT-3(1) Data Tagging is documented in SSP
• Confirm control is operating effectively
• Review evidence of continuous monitoring for PT-3(1)
• Verify enhancement builds upon base control PT-3

How to Test

Step 1: Review Documentation

Examine the System Security Plan (SSP) and related artifacts for PT-3(1) 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

Attach data tags containing the following purposes to [organization-defined]: [organization-defined].

Implementation Guidance

Data tags support the tracking of processing purposes by conveying the purposes along with the relevant elements of personally identifiable information throughout the system. By conveying the processing purposes in a data tag along with the personally identifiable information as the information transits a system, a system owner or operator can identify whether a change in processing would be compatible with the identified and documented purposes. Data tags may also support the use of automated tools.

Risk Assessment

CWE Categories

References

• NIST SP 800-53 Rev 5 - PT-3(1)
• 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 (CA-6, CM-12, PM-5, PM-22, SC-16) reviewed