NIST Privacy Framework: A complete guide to privacy risk management
Organizations collect personal information across websites, applications, cloud platforms, employee systems, and third-party services. As data processing grows, so does the risk of using personal information in ways that create privacy problems for individuals or expose the organization to operational and compliance issues.
Managing these risks requires more than a list of privacy requirements. Teams need a way to understand how they process data, identify privacy risks, prioritize what needs attention, and track improvements over time.
The NIST Privacy Framework provides a structured approach for doing this. Developed by the National Institute of Standards and Technology, it is a voluntary tool that helps organizations identify and manage privacy risk while protecting individuals’ privacy.
This guide explains how the NIST Privacy Framework works, its main components, the five Functions in its Core, and how you can use it to build and improve a privacy risk management program.
What is the NIST Privacy Framework?
The NIST Privacy Framework is a voluntary, risk-based tool for helping organizations identify and manage privacy risks. NIST published Version 1.0 in January 2020 after working with public- and private-sector stakeholders to develop the framework.
The framework focuses on privacy risks that can arise from how an organization collects, processes, stores, shares, and otherwise handles data.
Rather than prescribing one set of controls for every organization, the framework provides privacy protection activities and outcomes that organizations can prioritize based on their business or mission needs, data processing activities, and individuals’ privacy needs.
NIST describes the framework as a tool that can support organizations of different sizes and types. The NIST Privacy Framework also supports enterprise risk management. This helps organizations connect privacy risks with other risks they already consider when making business and resource decisions.
How the NIST Privacy Framework is structured
The NIST Privacy Framework has three main components:
| Component | Purpose |
| Core | Organizes privacy protection activities and desired outcomes. |
| Profiles | Helps organizations prioritize the Core outcomes that matter to them. |
| Implementation Tiers | Provides a way to describe how well an organization manages privacy risk. |
These three components work together. The Core provides the activities and outcomes, Profiles help an organization determine priorities, and Implementation Tiers provide context about its privacy risk management practices and resources.
The NIST Privacy Framework Core
The Core provides a common structure for discussing privacy risk management across different levels of an organization. It is divided into Functions, Categories, and Subcategories.
Each Function contains Categories, which are then divided into more specific Subcategories. These provide increasingly detailed privacy protection activities and outcomes. The Core is not intended to be a checklist where every organization must complete every item. NIST specifically explains that organizations should select the activities and outcomes that fit their risk strategy and privacy needs.
The five NIST Privacy Framework Functions
The five Functions provide the highest-level structure of the Core.
- Identify-P: Understand the organization’s data processing environment and privacy risks.
- Govern-P: Establish governance, policies, processes, and responsibilities for managing privacy risk.
- Control-P: Give individuals appropriate control over how their data is processed.
- Communicate-P: Make privacy practices and data processing information understandable and accessible.
- Protect-P: Establish policies, processes, and safeguards for protecting data and managing privacy risks.
These Functions organize privacy activities from understanding the data environment through governance, individual control, communication, and protection.
NIST Privacy Framework Profiles
Profiles help organizations translate the broad Core into priorities that fit their own circumstances.
A Profile is a selection of Functions, Categories, and Subcategories that an organization considers important based on its business or mission needs, privacy risks, data processing activities, and individuals’ needs. Organizations can create different Profiles for different situations.
For example, a company launching a new customer-facing application may prioritize privacy outcomes related to data processing, consent, communication, and data protection. A company reviewing an established privacy program may select a different set of outcomes based on the risks it has identified.
Current and Target Profiles
Two concepts are particularly useful when using Profiles:
- Current Profile: Describes the privacy activities and outcomes an organization currently achieves.
- Target Profile: Describes the privacy activities and outcomes the organization wants to achieve.
For example, suppose an organization has documented its data processing activities but does not consistently communicate those practices to individuals. Its Current Profile could show the outcomes it currently achieves, while its Target Profile could include additional communication-related outcomes.
The gap between the two gives the organization a clearer basis for prioritizing improvement work. NIST describes Profiles as a way to prioritize activities and outcomes based on organizational needs and risks.
Quick link: A guide to data governance frameworks
NIST Privacy Framework Implementation Tiers
Implementation Tiers provide another way to describe an organization’s approach to privacy risk management. The four Tiers are:
- Tier 1: Partial.
- Tier 2: Risk-informed.
- Tier 3: Repeatable.
- Tier 4: Adaptive.
The Tiers describe a progression from informal, reactive approaches to more agile, risk-informed approaches.
The Tiers consider areas such as the organization’s privacy risk management process, privacy risk management program, relationships within the data processing ecosystem, and workforce.
Importantly, reaching Tier 4 is not automatically the objective for every organization. The appropriate approach depends on the organization’s risks, needs, resources, and desired privacy outcomes. The Tiers provide context for decision-making rather than acting as a universal maturity score.
How to implement the NIST Privacy Framework
The framework gives organizations flexibility in how they apply it. A high-level implementation can follow these steps.
1. Define your privacy objectives
Identify your business or mission objectives, the personal data you process, how that data is used, and the privacy needs of individuals. Identify the teams responsible for privacy-related activities.
2. Understand your data processing activities
Map how your organization collects, uses, stores, shares, and deletes personal information. This helps you identify where privacy risks can arise. NIST provides resources for activities such as data processing awareness and PII inventories.
3. Assess your current privacy practices
Use the Core to identify the privacy outcomes and activities your organization currently addresses. Determine which outcomes are relevant to your privacy risks and objectives, and document existing practices and gaps.
4. Create Current and Target Profiles
Use your assessment to create a Current Profile and define the outcomes you want to achieve in a Target Profile. Comparing the two provides a basis for planning improvements.
5. Identify and prioritize gaps
Compare your Current and Target Profiles and prioritize gaps based on factors such as data sensitivity, processing activities, potential impact on individuals, and organizational risk priorities.
6. Assign responsibilities and implement improvements
Assign ownership for addressing prioritized gaps, then establish the processes, timelines, and measures needed to implement and maintain the improvements.
7. Monitor and improve the privacy program
Review privacy practices regularly as products, technologies, vendors, and data processing activities change. Update your Profiles and improvement priorities as needed.
NIST describes the Privacy Framework as a “living” tool intended to evolve with stakeholder needs. The current Privacy Framework 1.1 update is intended to respond to current privacy risk management needs and improve usability.
NIST Privacy Framework 1.0 vs. 1.1
NIST is currently updating the Privacy Framework. Version 1.0 was published in January 2020 and remains the published framework. NIST released an Initial Public Draft of Version 1.1 in April 2025, and the public comment period closed on June 13, 2025. NIST currently lists the final Version 1.1 as coming soon.
The update is intended to:
- Respond to current privacy risk management needs.
- Realign the Privacy Framework with NIST Cybersecurity Framework 2.0.
- Improve usability.
- Update the Core’s Categories and Subcategories.
NIST also published a mapping between the Version 1.0 and 1.1 Cores so organizations can trace changes between the versions.
Until the final 1.1 version is published, organizations should distinguish between the established Version 1.0 framework and the 1.1 Initial Public Draft when describing their privacy program.
How CyberArrow can support NIST Privacy Framework implementation
Putting a privacy risk management framework into practice requires more than documenting requirements. Teams also need to manage risks, assign ownership, monitor controls, collect evidence, and track remediation.
CyberArrow GRC provides capabilities for compliance management, risk management, policy management, internal control monitoring, evidence collection, and reporting. It supports NIST and other standards and frameworks, while its risk management module can automate parts of the risk assessment process.
For organizations using the NIST Privacy Framework as part of your GRC program, CyberArrow can help you:
- Manage risks: Conduct and track risk assessments, assign responsibilities, and monitor mitigation activities.
- Centralize compliance activities: Manage multiple standards and requirements within one GRC environment.
- Collect evidence: Use integrations and automated evidence collection to reduce manual work around control documentation. CyberArrow currently supports more than 80 integrations.
- Monitor controls: Track control performance and receive alerts when controls fall below defined thresholds.
- Track progress: Use dashboards and reporting to monitor implementation status and provide stakeholders with visibility.
Schedule a free demo to learn how CyberArrow can turn those framework outcomes into tracked risks, controls, evidence, and improvement activities.
FAQs
What are the three components of the NIST Privacy Framework?
The three components are the Core, Profiles, and Implementation Tiers. The Core organizes privacy activities and outcomes, Profiles help organizations prioritize them, and Implementation Tiers describe an organization’s approach to managing privacy risk.
Is the NIST Privacy Framework mandatory?
No. The NIST Privacy Framework is voluntary. NIST states that its contents do not have the force or effect of law.
What are the four NIST Privacy Framework Implementation Tiers?
The four Tiers are Tier 1: Partial, Tier 2: Risk Informed, Tier 3: Repeatable, and Tier 4: Adaptive. They describe how an organization approaches privacy risk management and whether it has the processes and resources needed to manage privacy risk.
Is the NIST Privacy Framework a compliance framework?
The NIST Privacy Framework is a voluntary privacy risk management tool, not a mandatory compliance requirement. Organizations can use its outcomes and resources to support privacy programs and work toward meeting applicable requirements.
What is NIST Privacy Framework 1.1?
NIST Privacy Framework 1.1 is an update to the framework that is intended to address current privacy risk management needs, align with NIST CSF 2.0, and improve usability. NIST released an Initial Public Draft in April 2025, and the final version is currently listed as forthcoming.
