NIST 800-53 and data security guidelines

NIST 800-53 outlines security and privacy controls for federal information systems, including those related to third-party service providers. While it doesn't explicitly mandate disclosure of third-party data exchanges, it emphasizes controls that ensure proper oversight and transparency when sharing sensitive information with third parties. Here are some key controls relevant to disclosing third-party data exchanges:

1. SA-9 (External Information System Services)

- Requires organizations to document and manage risks related to external service providers. Specifically, it states that contracts or agreements with third parties must include security controls that align with the organization's policies. While it does not explicitly require disclosure, this control ensures that third-party service agreements are managed and documented, highlighting the need for transparency.

2. AC-20 (Use of External Information Systems)

- This control requires organizations to limit and manage the use of external information systems to ensure sensitive data is protected. This often implies that companies need to understand and document which third-party systems are involved in data exchanges.

3. RA-3 (Risk Assessment)

- Mandates organizations to assess risks to the security of their systems, which includes evaluating the risks associated with third-party data exchanges. This risk assessment process would often necessitate understanding and documenting which third parties are involved and what data is being exchanged.

4. SI-12 (Information Handling and Retention)

- Relates to the protection of data as it is processed, stored, or transmitted, including in third-party systems. Organizations must ensure that third-party systems meet the same security standards, requiring them to disclose where sensitive data goes.

5. CA-3 (System Interconnections)

- Requires organizations to authorize, monitor, and manage system interconnections between their system and third parties, which indirectly involves identifying and disclosing data flow between internal and third-party systems.

6. PM-8 (Critical Infrastructure Plan)

- Requires organizations to include third-party service providers in their critical infrastructure plans, ensuring that third-party dependencies are clearly defined and documented.

7. SR-6 (Supply Chain Transparency)

- While focused on supply chain risk management, this control requires organizations to maintain visibility into their supply chain partners, including third-party data processors, implying the need for disclosure and tracking.

These controls collectively emphasize the importance of documenting third-party interactions and managing risks associated with sharing sensitive data. Organizations following NIST 800-53 are encouraged to maintain thorough records of third-party service providers and data exchanges, even if the standard doesn't mandate a direct disclosure requirement for end-user data.

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