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SI-18(3)Collection

>Control Description

Collect personally identifiable information directly from the individual.

>Cross-Framework Mappings

>Supplemental Guidance

Individuals or their designated representatives can be sources of correct personally identifiable information. Organizations consider contextual factors that may incentivize individuals to provide correct data versus false data. Additional steps may be necessary to validate collected information based on the nature and context of the personally identifiable information, how it is to be used, and how it was obtained.

The measures taken to validate the accuracy of personally identifiable information used to make determinations about the rights, benefits, or privileges of individuals under federal programs may be more comprehensive than the measures taken to validate less sensitive personally identifiable information.

>Assessment Interview Topics

Questions assessors commonly ask

Process & Governance:

  • What policies and procedures govern collection?
  • Who is responsible for monitoring system and information integrity?
  • How frequently are integrity monitoring processes reviewed and updated?

Technical Implementation:

  • What technical controls detect and respond to collection issues?
  • How are integrity violations identified and reported?
  • What automated tools support system and information integrity monitoring?

Evidence & Documentation:

  • Can you provide recent integrity monitoring reports or alerts?
  • What logs demonstrate that SI-18(3) is actively implemented?
  • Where is evidence of integrity monitoring maintained and for how long?

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