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.

CM.PO — Communication Policies

Policies governing how privacy-related information is communicated.

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

Privacy Notice Content Requirements

Mandatory Elements by Regulation

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

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

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)