nist-pf-protect

NIST Privacy Framework — PROTECT Function

Overview

The PROTECT function develops and implements appropriate data processing safeguards to prevent cybersecurity-related privacy events. This function directly bridges the NIST Cybersecurity Framework and Privacy Framework, addressing the overlap where security controls serve privacy objectives. It covers access control, data security, and protective policies.

PROTECT Function Subcategories

PR.AC — Access Control

Managing access to data and systems to protect privacy.

Subcategory	Description	Implementation Guidance
PR.AC-P1	Identities and credentials are issued, managed, verified, revoked, and audited for authorized individuals, processes, and devices	Implement identity lifecycle management. Enforce MFA for systems processing personal data. Conduct quarterly access reviews.
PR.AC-P2	Physical access to data and devices is managed	Restrict physical access to data centers and server rooms. Implement visitor logging. Secure endpoint devices with encryption and remote wipe capability.
PR.AC-P3	Remote access is managed	Enforce VPN for remote access to personal data systems. Implement zero-trust network architecture. Monitor and log all remote sessions.
PR.AC-P4	Access permissions and authorizations are managed with least privilege and separation of duties	Implement role-based access control (RBAC). Enforce separation of duties for sensitive operations. Regular privileged access reviews.
PR.AC-P5	Network integrity is protected	Network segmentation for systems processing personal data. Intrusion detection/prevention systems. Encrypted network communications.
PR.AC-P6	Individuals and devices are proofed and bound to credentials	Implement strong identity verification for data subject account creation. Device certificate management. Biometric authentication where appropriate.

PR.DS — Data Security

Protecting data at rest, in transit, and during processing.

Subcategory	Description	Implementation Guidance
PR.DS-P1	Data-at-rest are protected	AES-256 encryption for stored personal data. Key management with HSM. Database-level encryption (TDE).
PR.DS-P2	Data-in-transit are protected	TLS 1.3 for all data transmissions. Certificate pinning for mobile applications. End-to-end encryption for sensitive communications.
PR.DS-P3	Systems/products/services and associated data are formally managed throughout removal, transfers, and disposition	Secure media sanitization (NIST SP 800-88). Certificate of destruction for physical media. Verified data deletion from cloud services.
PR.DS-P4	Adequate capacity to ensure availability is maintained	Capacity planning for privacy-critical systems. DDoS protection. Redundancy for data subject rights portals.
PR.DS-P5	Protections against data leaks are implemented	DLP solutions monitoring egress points. Email DLP for personal data. Cloud access security broker (CASB) deployment.
PR.DS-P6	Integrity checking mechanisms are used to verify software, firmware, and information integrity	File integrity monitoring for privacy-critical systems. Code signing for privacy-related applications. Checksum verification for data transfers.
PR.DS-P7	The development and testing environment(s) are separate from the production environment	Separate environments with no production personal data in dev/test. Synthetic data generation for testing. Access controls between environments.
PR.DS-P8	Data disclosures are consistent with the purposes for which the data were collected	Technical enforcement of purpose limitation. API-level access controls tied to documented purposes. Automated purpose verification at query time.

PR.PO — Protective Policies

Policies governing protective measures for privacy.

Subcategory	Description	Implementation Guidance
PR.PO-P1	A baseline configuration of information technology/industrial control systems is created and maintained	Establish secure baselines for all systems processing personal data. Configuration management database. Automated compliance scanning.
PR.PO-P2	Configuration change control processes are in place	Change advisory board review for privacy-impacting changes. Impact assessment for configuration changes. Rollback procedures documented.
PR.PO-P3	Backups of information are conducted, maintained, and tested	Encrypted backups of personal data. Regular restoration testing. Backup retention aligned with data retention policies.
PR.PO-P4	Policy and regulations regarding the physical operating environment are met	Environmental controls for data processing facilities. Compliance with data residency requirements. Physical security audits.
PR.PO-P5	Data destruction processes are defined and managed	Documented destruction procedures per data classification. Verification and certification of destruction. Compliant disposal of hardware containing personal data.
PR.PO-P6	Maintenance and repair of organizational assets are performed and logged	Vendor supervision during maintenance. Data sanitization before equipment service. Maintenance activity logging.
PR.PO-P7	Response plans (Incident Response and Business Continuity) and recovery plans (Incident Recovery and Disaster Recovery) are in place and managed	Privacy-integrated incident response plan. Business continuity for privacy-critical services. Regular tabletop exercises.
PR.PO-P8	Response and recovery plans are tested	Annual incident response exercises including privacy scenarios. DR testing with privacy recovery objectives. Post-exercise improvement plans.
PR.PO-P9	Privacy procedures are included in human resources practices	Background checks for privacy-sensitive roles. Confidentiality agreements. Exit procedures including access revocation.
PR.PO-P10	A vulnerability management plan is developed and implemented	Vulnerability scanning for privacy-critical systems. Patch management prioritizing privacy-impacting vulnerabilities. Penetration testing including privacy controls.

Technical Control Architecture

Access Control Architecture

Identity Provider (IdP)
    |
    v
Multi-Factor Authentication
    |
    v
Authorization Engine (RBAC + ABAC)
    |
    +-- Role-Based Access Control
    |   ├── Privacy Administrator
    |   ├── Data Steward
    |   ├── Data Processor
    |   ├── Data Analyst (aggregated only)
    |   └── Data Subject (own data only)
    |
    +-- Attribute-Based Access Control
    |   ├── Purpose attribute (why accessing)
    |   ├── Data classification (sensitivity level)
    |   ├── Time-based restrictions
    |   └── Location-based restrictions
    |
    v
Audit Logging Engine

Encryption Standards

Data State	Minimum Standard	Recommended Standard	Key Management
At Rest	AES-128	AES-256	HSM-managed keys, annual rotation
In Transit	TLS 1.2	TLS 1.3	Certificate management with auto-renewal
In Processing	Application-level encryption	Envelope encryption	Per-session keys
Backup	AES-256	AES-256 + separate key	Offline key escrow
Archive	AES-256	AES-256 + integrity check	Long-term key management

Data Loss Prevention Configuration

Channel	DLP Control	Detection Method	Action
Email	Email gateway DLP	Pattern matching (SSN, CC, IBAN)	Block + notify
Web upload	Web proxy DLP	Content inspection	Block + notify
Cloud storage	CASB	Classification labels	Encrypt + restrict sharing
Endpoint	Endpoint DLP	File content scanning	Prevent copy to removable media
Database	Database activity monitoring	Query analysis	Alert on bulk extraction
API	API gateway	Payload inspection	Rate limit + log

Network Security for Privacy

Segmentation Architecture

Internet
    |
    v
[DMZ / WAF]
    |
    v
[Application Tier] ── TLS 1.3 ── [API Gateway]
    |                                    |
    v                                    v
[Business Logic Tier]            [Privacy Services Tier]
    |                            ├── Consent Manager
    v                            ├── DSR Processor
[Data Tier]                      ├── Anonymization Engine
├── PII Database (encrypted)     └── Audit Logger
├── Analytics Database (aggregated)
└── Backup Storage (encrypted, isolated)

Control Mapping

NIST PF PROTECT	NIST CSF	ISO 27701	GDPR Article
PR.AC-P1	PR.AC-1	A.7.2.2	Art. 32(1)(b)
PR.AC-P4	PR.AC-4	A.7.2.2	Art. 25(2)
PR.DS-P1	PR.DS-1	A.7.4.9	Art. 32(1)(a)
PR.DS-P2	PR.DS-2	A.7.4.9	Art. 32(1)(a)
PR.DS-P5	PR.DS-5	A.7.4.9	Art. 32(1)(b)
PR.DS-P7	PR.DS-7	A.7.4.9	Art. 32(1)(a)
PR.DS-P8	N/A	A.7.2.2	Art. 5(1)(b)
PR.PO-P3	PR.IP-4	A.7.4.9	Art. 32(1)(c)
PR.PO-P5	PR.IP-6	A.7.4.7	Art. 17(1)
PR.PO-P7	PR.IP-9	A.7.2.8	Art. 33, 34
PR.PO-P10	PR.IP-12	A.7.4.9	Art. 32(1)(d)

References

• NIST Privacy Framework Version 1.0 (January 16, 2020)
• NIST Cybersecurity Framework Version 1.1 (April 16, 2018)
• NIST SP 800-53 Rev. 5 — Security and Privacy Controls for Information Systems
• NIST SP 800-88 Rev. 1 — Guidelines for Media Sanitization
• NIST SP 800-175B — Guideline for Using Cryptographic Standards