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NIST SP 800-53 Rev. 5 · PM-25

Minimization of Personally Identifiable Information Used in Testing, Training, and Research

US National Institute of Standards and Technology (NIST) · cited in 5 of our lessons

Explanation

What it asks for. The organisation must develop and implement policies and procedures for using personally identifiable information in internal testing, training and research, limit or minimise the amount used, authorise its use where it cannot be avoided and review and update the policies periodically.

In practice. This means using synthetic, masked or anonymised data in test and development environments, with documented approval and extra safeguards when real personal data is genuinely needed. Auditors look for the policy, data masking tools or processes and approval records for exceptions. This aligns with GDPR data minimisation and the expectations for training data in AI projects.

Common gaps. Production database copies in test environments with weaker controls are a long-standing problem. Data used to train AI models is often not assessed for personal data.

Open SP 800-53 at NIST
The official text
a. Develop, document, and implement policies and procedures that address the use of personally identifiable information for internal testing, training, and research; b. Limit or minimize the amount of personally identifiable information used for internal testing, training, and research purposes; c. Authorize the use of personally identifiable information when such information is required for internal testing, training, and research; and d. Review and update policies and procedures [Assignment: organization-defined organization-defined frequency]. Discussion: The use of personally identifiable information in testing, research, and training increases the risk of unauthorized disclosure or misuse of such information. Organizations consult with the senior agency official for privacy and/or legal counsel to ensure that the use of personally identifiable information in testing, training, and research is compatible with the original purpose for which it was collected. When possible, organizations use placeholder data to avoid exposure of personally identifiable information when conducting testing, training, and research.

From NIST SP 800-53 Rev. 5, a work of the US government in the public domain.

Lessons that cite it

Real incidents where this item mattered.