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PT-6(1)—Routine Uses

PRIVACY

>Control Description

Review all routine uses published in the system of records notice at ⚙organization-defined frequency to ensure continued accuracy, and to ensure that routine uses continue to be compatible with the purpose for which the information was collected.

>Cross-Framework Mappings

SCF

PRI-02.5
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>Supplemental Guidance

A PRIVACT routine use is a particular kind of disclosure of a record outside of the federal agency maintaining the system of records. A routine use is an exception to the PRIVACT prohibition on the disclosure of a record in a system of records without the prior written consent of the individual to whom the record pertains. To qualify as a routine use, the disclosure must be for a purpose that is compatible with the purpose for which the information was originally collected.

The PRIVACT requires agencies to describe each routine use of the records maintained in the system of records, including the categories of users of the records and the purpose of the use. Agencies may only establish routine uses by explicitly publishing them in the relevant system of records notice.

>Assessment Interview Topics

Questions assessors commonly ask

Process & Governance:

  • •What policies govern routine uses in organizational systems?
  • •Who is responsible for implementing and overseeing routine uses controls?
  • •How does the organization ensure routine uses complies with privacy laws and regulations?
  • •What process exists for documenting and maintaining routine uses?
  • •What governance exists for monitoring and enforcing routine uses requirements?

Technical Implementation:

  • •What systems or tools technically implement routine uses?
  • •How are routine uses requirements enforced in PII processing systems?
  • •What privacy-enhancing technologies support routine uses?
  • •How is routine uses integrated with data governance and privacy tools?
  • •What technical controls prevent violations of routine uses requirements?

Evidence & Documentation:

  • •Provide documented policies and procedures for routine uses.
  • •Provide evidence of routine uses implementation in PII systems.
  • •Provide documentation demonstrating compliance with routine uses requirements.
  • •Provide records of routine uses reviews and updates.
  • •Provide privacy impact assessments or other documentation addressing routine uses.

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