To promote accountability, organizations identify and address gaps in privacy compliance, management, operational, and technical controls by conducting regular assessments (e.g., internal risk assessments). These assessments can be self-assessments or third-party audits that result in reports on compliance gaps identified in programs, projects, and information systems. In addition to auditing for effective implementation of all privacy controls identified in this appendix, organizations assess whether they: (i) implement a process to embed privacy considerations into the life cycle of personally identifiable information (PII), programs, information systems, mission/business processes, and technology; (ii) monitor for changes to applicable privacy laws, regulations, and policies; (iii) track programs, information systems, and applications that collect and maintain PII to ensure compliance; (iv) ensure that access to PII is only on a need-to-know basis; and (v) ensure that PII is being maintained and used only for the legally authorized purposes identified in the public notice(s).
Organizations also: (i) implement technology to audit for the security, appropriate use, and loss of PII; (ii) perform reviews to ensure physical security of documents containing PII; (iii) assess contractor compliance with privacy requirements; and (iv) ensure that corrective actions identified as part of the assessment process are tracked and monitored until audit findings are corrected. The organization Senior Agency Official for Privacy (SAOP)/Chief Privacy Officer (CPO) coordinates monitoring and auditing efforts with information security officials and ensures that the results are provided to senior managers and oversight officials.