Everything You Need to Know About NIST Privacy Framework 1.1
If you’re a cyber security professional, you’re likely familiar with the NIST Cybersecurity Framework (CSF). Now, there is an important update to its sister framework that you need to pay close attention to - the NIST Privacy Framework.
A draft of Version 1.1 has been released for public comment, and it brings some significant changes that are likely to directly affect your risk management strategy, compliance posture, and how you govern personal data.
Where Has This Come From?
This updated framework is designed to help organisations manage privacy risks more effectively, particularly in today’s environment where data flows through increasingly complex systems. If left unmanaged, these risks could lead to serious consequences for individuals, damage to an organisation’s brand, and disruption to growth plans.
Alignment with the Cyber security Framework 2.0
A major change in this update is its alignment with CSF 2.0. This reflects a growing recognition that privacy and cyber security risks are closely connected. By integrating the two frameworks, organisations now have a way to manage privacy in a way that naturally supports existing cyber security practices.
For teams responsible for both privacy and cyber security, this alignment offers a more efficient, coherent approach to implementing controls, assessing risks, and ensuring systems are resilient to both unauthorised access and inappropriate data use.
Updates to ‘Govern’ and ‘Protect’
NIST has made targeted changes to the core structure and content of the Privacy Framework, focusing especially on the ‘Govern’ and ‘Protect’ functions.
The ‘Govern’ function now includes more specific guidance around organisational strategy, risk tolerance, and leadership accountability. This helps ensure that privacy risk management is a central part of corporate governance.
Meanwhile, the ‘Protect’ function addresses safeguards needed to reduce privacy risks in systems and processes, expanding on how privacy and cyber security protections can work hand in hand to control access, minimise exposure, and prevent harm.
AI and Privacy Risk Management
Artificial intelligence introduces a new layer of complexity to privacy management. The draft framework now includes a dedicated section on AI and privacy risk management, reflecting the growing use of automated decision-making and predictive technologies in business operations.
This section highlights privacy events that may arise specifically from AI and incorporates risk scenarios that stem from data processing at scale. Importantly, it references the NIST AI Risk Management Framework (RMF), giving organisations a structured way to manage AI-related risks while promoting responsible and trustworthy development.
As AI continues to evolve, organisations must assess how it affects data privacy and ensure they are using it in ways that align with ethical standards and public expectations.
Emphasis on Data Governance and Management
Another key enhancement is a stronger focus on data governance. Good data governance is foundational to managing privacy risk, and the framework now offers clearer guidance around data classification, retention, deletion, and accountability throughout the data lifecycle.
For cyber security professionals, this shift reinforces the importance of having comprehensive data inventories and controls that go beyond system security, making sure the right data is used, stored, and shared for the right purposes.
Improved Usability
The framework has been refined to improve its usability. NIST has simplified certain sections and made it easier to map the framework to different organisational structures and maturity levels. Whether you are operating in a regulated industry, building a privacy programme from scratch, or refining existing practices, the updated framework is designed to support practical, scalable implementation.
This improved accessibility makes it easier for cross-functional teams to adopt the framework and embed privacy into design, development, and operational workflows.
Timelines
The NIST Privacy Framework 1.1 is currently in draft form, open for public comment until 13 June 2025, with final publication expected later this year. Organisations don’t need to wait to begin using the draft version. Taking early steps to understand and apply the updated guidance can help you get ahead, particularly in areas like AI, governance, and integrated risk management.
What to Expect
The draft framework supports more effective communication with individuals, business partners, assessors, and regulators. It positions organisations to meet today’s compliance obligations and prepares them for future changes in law, policy, and technology. The emphasis on AI, governance, and integrated privacy and cyber security risk management reflects where the landscape is heading.
If your organisation is reviewing its privacy posture or exploring how to align more closely with NIST guidance, it can help to have a clear plan and the right expertise on hand. Whether you’re building on an existing framework or starting fresh, engaging with the draft now positions you to respond confidently to regulatory and technological changes.
We at Cyro Cyber work with organisations to strengthen privacy and cyber security practices, with experience in risk assessments, compliance alignment, and emerging technologies like AI. If you’re feeling unsure of how to approach these changes, we offer targeted support, including:
Privacy and AI risk assessments
Cyber security maturity assessments
Policy and governance development
Control mapping and gap analysis
vCISO services to guide strategy and governance
Please do get in touch with us below if you'd like to explore how your organisation can respond to the draft NIST Privacy Framework with clarity and confidence.
