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Governance 6 min read Published Updated Credibility 40/100

NIST Privacy Framework 1.1: Elevating Roles and Third‑Party Risk Management

NIST’s draft Privacy Framework 1.1 adds new categories for Roles, Responsibilities and Authorities and Data Processing Ecosystem Risk Management, aligning the framework with modern privacy challenges and AI governance【547057639634210†L2610-L2634】. This brief explains the updates and offers implementation guidance.

Zeph Tech Research Lead

Research lead, Zeph Tech

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The NIST Privacy Framework is a voluntary tool that helps organisations identify, assess and manage privacy risks while fostering innovation and trust【547057639634210†L109-L121】. Version 1.1, released as a draft in April 2025, responds to evolving privacy challenges, aligns with the forthcoming NIST Cybersecurity Framework 2.0 and aims to improve usability【547057639634210†L169-L177】. The framework is structured around three functions—Identify–Govern (ID.G), Protect–Develop (PR.D) and Communicate (CM)—which provide high‑level outcomes for organisational privacy programs.

Key updates in Version 1.1

NIST’s 2025 update introduces two new categories and clarifies existing ones to address emerging technologies and organisational realities:

  • Roles, Responsibilities and Authorities: This new category within the Identify–Govern function emphasises establishing and communicating privacy roles and responsibilities across the workforce and external stakeholders, ensuring leadership accountability and allocating resources【547057639634210†L2610-L2634】. It encourages organisations to assign clear authority for privacy decision‑making and to incorporate privacy into performance assessments and continuous improvement.
  • Data Processing Ecosystem Risk Management: Recognising that modern services rely on complex supply chains, this category focuses on establishing policies, standards and contracts with data processing partners and routinely assessing third‑party compliance【547057639634210†L2630-L2653】. It underscores the need to evaluate vendors’ privacy practices, require comparable safeguards, and manage risks when data is shared across borders or stored in the cloud.
  • Alignment with AI and cybersecurity frameworks: Version 1.1 enhances interoperability with the NIST Cybersecurity Framework 2.0 and addresses privacy implications of artificial intelligence and machine learning. It promotes integrating privacy considerations into AI governance, data minimisation and transparency efforts.

Implementation considerations

Organisations adopting Privacy Framework 1.1 should first perform a privacy risk assessment to understand data processing activities, legal obligations and stakeholder expectations. Establish a data inventory and classify personal data by sensitivity and purpose. Assign privacy leadership roles, such as a Chief Privacy Officer, and ensure responsibilities are documented and communicated. Embed privacy considerations into procurement and vendor management by requiring third parties to adopt comparable privacy practices and participate in regular assessments. Integrate privacy risk management with cybersecurity and AI risk management, aligning controls and reporting structures.

Implications and recommended actions

Zeph Tech recommends the following actions:

  • Define governance structures: Update privacy charters and board mandates to reflect the Roles, Responsibilities and Authorities category; assign accountable leadership and integrate privacy metrics into performance dashboards.
  • Strengthen vendor oversight: Develop and enforce contract clauses requiring processors and sub‑processors to implement appropriate privacy controls; routinely audit third‑party practices; consider data localisation and encryption when exporting data.
  • Integrate AI and privacy risk management: Align privacy practices with AI governance by evaluating data minimisation strategies, documenting model training data sources and implementing transparency and explainability mechanisms.
  • Foster a privacy‑aware culture: Provide training and awareness programs for employees, emphasising the ethical and legal dimensions of personal data handling.

Zeph Tech analysis

Privacy Framework 1.1 reflects the maturation of privacy risk management and its convergence with cybersecurity and AI governance. By introducing categories for roles and ecosystem risk management, NIST underscores that privacy cannot be an afterthought—it requires clear accountability and supply‑chain diligence. Organisations should view the framework as both a roadmap for continuous improvement and a bridge between compliance obligations and ethical data stewardship. Zeph Tech advises aligning privacy governance with enterprise risk management, investing in vendor oversight capabilities and participating in the NIST public comment process to shape the final version.

Implementation timeline

Organizations should establish clear milestones for addressing the requirements introduced by this development. Key phases typically include:

  • Immediate (0-30 days): Conduct gap analysis comparing current capabilities against new requirements. Brief executive leadership and board members on obligations and potential compliance paths. Identify internal stakeholders who will own implementation workstreams.
  • Near-term (1-3 months): Update policies, procedures, and technical controls to align with new standards. Designate accountable roles and begin staff training. Engage external advisors where specialized expertise is required.
  • Medium-term (3-12 months): Complete implementation of required changes, conduct internal audits, and establish ongoing monitoring mechanisms. Document lessons learned and refine processes based on initial operational experience.
  • Long-term (12+ months): Integrate requirements into regular compliance cycles, update vendor contracts, and participate in industry working groups to track evolving interpretations. Plan for periodic reassessments as regulatory guidance matures.

Organizations with mature governance programs may accelerate these timelines by leveraging existing control frameworks and cross-functional teams. Those building capabilities from scratch should budget additional time for foundational work and stakeholder alignment.

Compliance considerations

Legal and compliance teams should assess how this development interacts with other regulatory obligations. Key areas to evaluate include:

  • Regulatory overlap: Identify where requirements overlap with existing frameworks (e.g., data protection laws, sector-specific regulations) and establish unified control implementations. Map common controls to reduce duplication and streamline audit evidence collection.
  • Documentation requirements: Determine what evidence will satisfy auditors and regulators. Develop templates for required documentation and establish retention policies. Implement version control and change management procedures for compliance artifacts.
  • Third-party assurance: Evaluate whether external certifications or attestations will strengthen compliance posture and facilitate customer trust. Consider industry-recognized frameworks that provide portable evidence across multiple regulatory contexts.
  • Cross-border implications: For multinational organizations, assess how requirements apply across different jurisdictions and whether harmonized or jurisdiction-specific approaches are necessary. Monitor regulatory cooperation agreements that may affect enforcement coordination.

Regular consultation with external counsel may be warranted as enforcement practices and regulatory guidance evolve. Organizations should establish clear escalation paths for novel compliance questions that arise during implementation.

  • Executive leadership: Board members and C-suite executives must understand strategic implications, resource requirements, and reputational considerations. They should ensure appropriate governance structures exist to oversee implementation and ongoing compliance. Executive sponsors should be designated to champion implementation efforts and resolve cross-functional conflicts.
  • Legal and compliance teams: These functions bear primary responsibility for interpreting requirements, mapping them to existing obligations, and advising business units on permissible activities. They should coordinate closely with external counsel on novel questions. Compliance teams should establish monitoring programs to track adherence and identify emerging issues before they escalate.
  • Technology teams: Engineering, architecture, and IT operations groups must assess technical feasibility, system changes, and integration requirements. They should plan for testing, deployment, and ongoing maintenance of compliance-related technical controls. Security teams should evaluate how changes affect the organization's security posture and threat landscape.
  • Business operations: Product managers, customer-facing teams, and operational units need to understand how requirements affect day-to-day activities, customer interactions, and service delivery. Training and process documentation should address their specific workflows. Change management programs should support smooth transitions without disrupting business continuity.
  • Third-party relationships: Procurement, vendor management, and partnership teams should evaluate how requirements flow down to suppliers, contractors, and business partners. Contract amendments and ongoing monitoring may be necessary. Due diligence processes should be enhanced to verify third-party compliance postures.

Effective implementation requires coordination across these stakeholder groups, with clear communication channels and escalation procedures for cross-functional issues. Regular status updates and governance checkpoints help maintain alignment and momentum throughout the implementation lifecycle.

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