nist-pf-communicate

NIST Privacy Framework — COMMUNICATE Function

Overview

The COMMUNICATE function develops and implements appropriate activities to enable organizations and individuals to have a reliable understanding and engage in a dialogue about how data are processed and associated privacy risks. This function is essential for building trust and ensuring transparency with data subjects, regulators, and business partners.

COMMUNICATE Function Subcategories

CM.AW — Awareness

Raising awareness of data processing practices and privacy risks among stakeholders.

Subcategory	Description	Implementation Guidance
CM.AW-P1	Mechanisms (e.g., notices, internal policies) for communicating data processing purposes, practices, and associated privacy risks are established and in service	Publish layered privacy notices. Maintain internal data processing documentation. Establish communication channels for privacy inquiries.
CM.AW-P2	Mechanisms for obtaining feedback from individuals about data processing and associated privacy risks are established and in service	Deploy feedback forms on privacy pages. Monitor privacy-related inquiries through support channels. Conduct periodic privacy perception surveys.
CM.AW-P3	System/product/service design enables data processing visibility	Implement privacy dashboards for data subjects. Provide real-time data processing status. Enable granular consent visibility.
CM.AW-P4	Records of data disclosures and sharing are maintained and can be accessed for review or transmission	Maintain disclosure registers. Enable data subjects to view sharing history. Automate disclosure logging.
CM.AW-P5	Data corrections or deletions can be communicated to individuals or organizations that have received the data	Implement downstream notification workflows. Track data recipients for correction propagation. Automate deletion verification across partners.
CM.AW-P6	Data provenance and lineage are maintained and can be accessed for review or transmission	Document data origins and transformation history. Provide lineage visualization. Enable audit trail access for authorized parties.
CM.AW-P7	Impacted individuals and organizations are notified about a privacy breach or event	Develop breach notification templates. Establish notification timelines per jurisdiction. Maintain contact information for notification delivery.
CM.AW-P8	Individuals are provided with mitigation mechanisms for observed privacy risks	Offer identity protection services post-breach. Provide self-service privacy controls. Communicate available remediation options.

CM.PO — Communication Policies

Policies governing how privacy-related information is communicated.

Subcategory	Description	Implementation Guidance
CM.PO-P1	Transparency policies, processes, and procedures for communicating data processing purposes, practices, associated privacy risks, and options for enabling data subjects' data processing preferences are established and in service	Develop layered transparency framework. Define communication standards for each audience.
CM.PO-P2	Roles and responsibilities for communicating privacy-related information are established	Assign communications ownership. Define approval workflows for external privacy communications.

Transparency Framework

Layered Privacy Notice Architecture

Layer 1: Short Notice (Banner/Summary)
├── Who we are
├── What data we collect
├── Key purposes
├── Core rights
└── Link to full notice

Layer 2: Full Privacy Notice
├── Detailed purposes and legal bases
├── Data categories and sources
├── Recipients and transfers
├── Retention periods
├── Complete rights information
├── Contact information
└── Links to supplementary notices

Layer 3: Supplementary Notices
├── Cookie Policy
├── Children's Privacy Notice
├── Employee Privacy Notice
├── Specific Service Notices
└── Jurisdiction-Specific Addenda

Layer 4: Just-in-Time Notices
├── Collection-point notifications
├── Consent requests with context
├── Purpose-specific explanations
└── Processing change notifications

Communication Channel Matrix

Audience	Channel	Frequency	Content Type	Owner
Data subjects (general)	Website privacy center	Continuous	Notices, policies, FAQs	Privacy Team
Data subjects (customers)	Email, in-app notifications	Event-driven	Consent changes, updates	Marketing + Privacy
Data subjects (employees)	Intranet, HR portal	Semi-annual + event	Employee privacy info	HR + Privacy
Regulators	Formal correspondence	As required	Compliance reports, notifications	Legal + DPO
Business partners	Contract addenda, portal	Annual + event	Processing terms, audit rights	Legal + Procurement
Board/executives	Dashboards, presentations	Quarterly	Risk reports, KPIs	CPO
Internal teams	Confluence, training	Monthly	Guidelines, best practices	Privacy Champions

Privacy Notice Content Requirements

Mandatory Elements by Regulation

Element	GDPR Art. 13/14	CCPA/CPRA	LGPD	PIPEDA
Controller identity	Required	Required	Required	Required
DPO contact	Required	N/A	Required (DPO equivalent)	N/A
Processing purposes	Required	Required	Required	Required
Legal basis	Required	N/A	Required	N/A
Data categories	Required	Required	Required	Required
Recipients	Required	Required	Required	Required
International transfers	Required	N/A	Required	Required
Retention periods	Required	Disclosed on request	Required	Required
Data subject rights	Required	Required	Required	Required
Right to complain	Required	N/A	Required	Required
Automated decision-making	Required	CPRA: Required	Required	N/A
Data source (indirect collection)	Required	Required	Required	Required
Sale/sharing opt-out	N/A	Required	N/A	N/A
Financial incentive terms	N/A	Required	N/A	N/A

Stakeholder Engagement Workflows

Data Subject Inquiry Handling

Inquiry Received
    |
    v
Classify Inquiry Type
├── General Privacy Question → FAQ/Knowledge Base → Respond within 5 business days
├── Data Subject Request → Route to DSR Workflow → Respond within regulatory deadline
├── Complaint → Escalate to DPO → Investigate → Respond within 15 business days
├── Breach Inquiry → Route to Incident Team → Coordinate response
└── Consent Change → Process immediately → Confirm within 24 hours

Privacy Communication Approval Workflow

Communication Type	Drafting	Review	Approval	Distribution
Privacy policy update	Privacy Team	Legal	CPO + General Counsel	Web team
Breach notification	Incident Lead	Legal + DPO	CEO + General Counsel	Communications
Regulatory response	DPO	Legal	General Counsel	DPO
Marketing consent request	Marketing	Privacy Team	CPO	Marketing
Internal policy update	Privacy Team	Stakeholders	CPO	Internal comms

Feedback Mechanisms

Privacy Perception Survey Template (Annual)

1. How aware are you of our privacy practices? (1-5 scale)
2. How easy is it to find information about how we use your data? (1-5 scale)
3. How confident are you that we protect your personal data? (1-5 scale)
4. Have you exercised any privacy rights in the past 12 months? (Yes/No, which ones)
5. How satisfied were you with the response? (1-5 scale, if applicable)
6. What privacy improvements would you like to see? (Open text)
7. How likely are you to recommend us based on our privacy practices? (0-10 NPS)

Control Mapping

NIST PF COMMUNICATE	ISO 27701	GDPR Article	APEC CBPR
CM.AW-P1	A.7.3.2	Art. 12, 13, 14	Principle 5
CM.AW-P2	A.7.3.8	Art. 77	Principle 9
CM.AW-P3	A.7.2.5	Art. 12(1)	Principle 5
CM.AW-P4	A.7.5.3	Art. 19	Principle 7
CM.AW-P7	A.7.3.9	Art. 34	Principle 8
CM.PO-P1	A.7.3.2	Art. 12	Principle 5
CM.PO-P2	5.3	Art. 37-39	Principle 9

References

• NIST Privacy Framework Version 1.0 (January 16, 2020)
• Article 29 Working Party WP260 — Guidelines on Transparency
• EDPB Guidelines 04/2022 on Calculation of Administrative Fines
• ISO/IEC 29100:2011 — Privacy Framework (Privacy Principles)