PT-4(2)—Just-In-Time Consent
>Control Description
>Cross-Framework Mappings
>Supplemental Guidance
Just-in-time consent enables individuals to participate in how their personally identifiable information is being processed at the time or in conjunction with specific types of data processing when such participation may be most useful to the individual. Individual assumptions about how personally identifiable information is being processed might not be accurate or reliable if time has passed since the individual last gave consent or the type of processing creates significant privacy risk. Organizations use discretion to determine when to use just-in-time consent and may use supporting information on demographics, focus groups, or surveys to learn more about individuals' privacy interests and concerns.
>Related Controls
>Assessment Interview Topics
Questions assessors commonly ask
Process & Governance:
- •What policies govern just-in-time consent in organizational systems?
- •Who is responsible for implementing and overseeing just-in-time consent controls?
- •How does the organization ensure just-in-time consent complies with privacy laws and regulations?
- •What process exists for documenting and maintaining just-in-time consent?
- •What governance exists for monitoring and enforcing just-in-time consent requirements?
Technical Implementation:
- •What systems or tools technically implement just-in-time consent?
- •How are just-in-time consent requirements enforced in PII processing systems?
- •What privacy-enhancing technologies support just-in-time consent?
- •How is just-in-time consent integrated with data governance and privacy tools?
- •What technical controls prevent violations of just-in-time consent requirements?
Evidence & Documentation:
- •Provide documented policies and procedures for just-in-time consent.
- •Provide evidence of just-in-time consent implementation in PII systems.
- •Provide documentation demonstrating compliance with just-in-time consent requirements.
- •Provide records of just-in-time consent reviews and updates.
- •Provide privacy impact assessments or other documentation addressing just-in-time consent.
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