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Governance Authority
Category: Privacy and Cybersecurity

Communicate-P

Also known as: CM-P, Communicate-P Function
Simply put

Communicate-P is one of the core Functions in the NIST Privacy Framework. It reflects the idea that both organizations and the individuals whose data are handled may need reliable information about how data are processed in order to understand and manage privacy risk.

Formal definition

Communicate-P (CM-P) is a Function within the NIST Privacy Framework, a voluntary, non-binding framework intended to help organizations manage privacy risk. The Function addresses the organization's development and implementation of appropriate activities to enable a shared understanding of how data are processed and the associated privacy risks, supporting dialogue between the organization and relevant stakeholders, including affected individuals. As a framework Function rather than a legal requirement, its adoption and specific implementation depend on an organization's context, risk posture, and applicable jurisdictional obligations. This entry is educational and not legal, audit, or compliance advice; the precise subcategories and outcomes are defined in the NIST Privacy Framework itself, and further detail beyond the evidence provided is out of scope.

Why it matters

Privacy risk cannot be managed in isolation by any single party. The Communicate-P Function reflects a foundational insight of the NIST Privacy Framework: both the organization processing data and the individuals whose data are processed may need reliable information about how that processing occurs in order to understand and manage privacy risk. Without a shared understanding, organizations may struggle to align internal stakeholders around privacy objectives, and individuals may be unable to make informed decisions or exercise choices about their data. Communicate-P addresses this gap by focusing on activities that enable dialogue and transparency between the organization and relevant stakeholders.

For governance and compliance leaders, Communicate-P is significant because it treats communication as a deliberate, structured component of a privacy risk management program rather than an afterthought. Effective privacy communication supports informed decision-making internally, among management, assurance functions, and the board, and externally, with the individuals affected by data processing. It is important to note, however, that the NIST Privacy Framework is voluntary and non-binding; adopting Communicate-P does not, by itself, satisfy any particular legal transparency or notice obligation, which vary by jurisdiction, sector, and entity type.

Because this entry is educational and not legal, audit, or compliance advice, organizations should treat Communicate-P as a way to organize and mature their communication practices around privacy, while separately confirming their binding obligations under applicable law. The precise value of the Function depends on an organization's context, risk posture, and how it maps its own communication activities to the framework's outcomes.

Who it's relevant to

Chief Privacy Officers and Privacy Teams
Privacy leaders responsible for designing and operating a privacy risk management program may use Communicate-P to structure how the organization enables a shared understanding of data processing among internal stakeholders and affected individuals. It helps frame communication as a defined element of the program, though it does not replace an assessment of binding legal notice and transparency requirements.
Compliance Officers
Compliance professionals may reference Communicate-P when evaluating how transparency and stakeholder communication practices are organized. Because the framework is voluntary and non-binding, they should separately confirm the specific disclosure and notice obligations that apply under relevant statutes and regulations in each applicable jurisdiction.
Boards and Board Committees
Directors and committees with privacy or risk oversight responsibilities may find Communicate-P useful in understanding whether management has established structured mechanisms for communicating about data processing and privacy risk. The board's role here is generally oversight, while the design and operation of these communication activities typically sit with management.
Internal Audit and Assurance Functions
Assurance providers may use the Function as a reference point when assessing whether an organization's stated communication practices are designed and operating as intended. Any such assessment should be grounded in the framework's specific defined outcomes and the organization's own documented objectives, not in an assumption that Communicate-P is legally mandatory.

Inside CM-P

Communicate-P Function (overview)
Communicate-P is one of the five Functions in the NIST Privacy Framework, a voluntary, non-binding tool published by the U.S. National Institute of Standards and Technology to help organizations manage privacy risk. It is not a statute or regulation and imposes no legal requirement; organizations adopt it at their discretion. The Communicate-P Function centers on developing and implementing appropriate activities to enable organizations and individuals to have a reliable understanding about how data are processed and about associated privacy risks.
Position within the Privacy Framework Core
The Privacy Framework Core is organized into Functions, Categories, and Subcategories. Communicate-P sits alongside the other Functions (commonly identified as Identify-P, Govern-P, Control-P, Communicate-P, and Protect-P). Communicate-P is distinct from Govern-P, which addresses governance structures and organizational risk management priorities, and from Control-P, which addresses data processing management to enable privacy risk decisions. Practitioners should not conflate the communication-focused Function with the governance or control Functions.
Categories and Subcategories
Under the Privacy Framework, each Function is broken down into Categories and then Subcategories that describe specific outcomes. Communicate-P typically encompasses outcomes related to communication policies and processes and to informing data processing awareness. The Framework describes desired outcomes rather than prescribing specific controls, leaving implementation to the adopting organization's judgment and context.
Purpose: transparency and shared understanding
The core purpose of Communicate-P is to support transparency so that both the organization and affected individuals can reliably understand data processing activities and the privacy risks arising from them. This supports informed decision-making by individuals and by the organization, but it is an outcome-oriented objective, not a mandated disclosure format.
Relationship to accountability and assurance
Communicate-P outcomes support, but do not by themselves establish, accountability for privacy risk. The Framework is designed to complement, not replace, applicable privacy laws and an organization's broader governance and assurance arrangements. How communication responsibilities are assigned among the board, management, and privacy or compliance functions depends on the organization's own structure and is out of scope of the Framework's technical outcomes.

Common questions

Answers to the questions practitioners most commonly ask about CM-P.

Is Communicate-P just a general instruction to keep stakeholders informed, or does it have a defined meaning?
Communicate-P is not a generic communications directive. It is one of the named Functions in the NIST Privacy Framework, where it refers to the activities that enable an organization and its stakeholders to have a reliable understanding of, and engage in a dialogue about, how data are processed and associated privacy risks are managed. Treating it as an informal 'keep people posted' concept understates its role as a structured Function with associated Categories and Subcategories. Note that the NIST Privacy Framework is a voluntary tool, not a binding legal requirement, and organizations tailor its use to their own context.
Does Communicate-P mean the same thing as the transparency or notice obligations found in privacy laws?
Not exactly. Communicate-P is a Function within a voluntary framework and should not be conflated with specific legal obligations such as statutory notice, disclosure, or transparency requirements that vary by jurisdiction and entity type. While using Communicate-P can support an organization in meeting such obligations, the Function itself is a framework construct focused on enabling shared understanding and dialogue about data processing and privacy risk. Whether any particular legal requirement is satisfied depends on the applicable law and the facts, and this entry is educational rather than legal advice.
Who within an organization is typically accountable for the activities grouped under Communicate-P?
Accountability generally sits with management, which owns the operational design and execution of privacy communications, often coordinated through a privacy office, data protection function, or compliance team. The board or a relevant committee typically exercises oversight rather than performing the activities directly. Assurance functions may separately evaluate whether the related controls are designed and operating effectively. As with any framework, the precise allocation of responsibility depends on the organization's structure, size, and governance model, so roles should be mapped explicitly rather than assumed.
How does an organization begin implementing the Communicate-P Function in practice?
Implementation typically starts by reviewing the Categories and Subcategories that NIST associates with Communicate-P and assessing current-state practices against them, often using the framework's Profiles to describe current and target states. Organizations generally identify who processes data, what stakeholders need to understand, and through what mechanisms that understanding is enabled. Because the framework is voluntary and outcome-oriented, the specific mechanisms are left to the organization's judgment and should be prioritized according to identified privacy risk. Scope and depth of implementation depend on organizational context.
How should Communicate-P be coordinated with risk management and compliance activities?
Communicate-P is generally most effective when linked to the organization's broader privacy risk management process, so that what is communicated reflects the risks actually identified and how they are being addressed. It should be distinguished from, but coordinated with, compliance monitoring, which checks conformance with applicable requirements. The Function supports informed dialogue; it does not by itself constitute risk assessment or compliance testing. Clear hand-offs between the privacy, risk, and compliance functions help avoid conflating enabling understanding with assessing or assuring it.
How can an organization tell whether its Communicate-P activities are effective?
Evaluation typically distinguishes control design from operating effectiveness: whether the communication mechanisms are appropriately designed to enable stakeholder understanding, and whether they function as intended over time. Organizations may use Profiles to compare current practices against a target state and identify gaps. Assurance functions can independently assess these controls. Because the framework is outcome-based and voluntary, there is no single mandated measure of effectiveness; the appropriate indicators depend on the organization's objectives, risk profile, and professional judgment.

Common misconceptions

Communicate-P is a legal requirement that organizations must implement.
Communicate-P is a Function within the NIST Privacy Framework, which is a voluntary, non-binding tool. It is not itself law and does not create legal obligations. Actual disclosure and communication duties arise from applicable privacy statutes and regulations, which vary by jurisdiction, sector, and entity type; the Framework can support compliance but does not substitute for it.
Communicate-P is interchangeable with the governance or control Functions of the Privacy Framework.
Communicate-P is a distinct Function focused on enabling reliable understanding of data processing and privacy risks. Governance structures and risk priorities are generally addressed under Govern-P, and data processing management is generally addressed under Control-P. Treating these Functions as interchangeable obscures where specific outcomes and accountability sit.
Adopting Communicate-P prescribes a specific set of notices, policies, or controls an organization must deploy.
The Privacy Framework is outcome-oriented and describes desired results through Categories and Subcategories rather than mandating particular controls or formats. Implementation choices depend on the organization's context, risk profile, and professional judgment.

Best practices

Treat Communicate-P as a voluntary framework Function that supports, but does not replace, an assessment of binding privacy laws applicable to your jurisdictions, sectors, and data processing activities.
Map Communicate-P outcomes explicitly against the other Privacy Framework Functions so that communication responsibilities are not confused with governance (Govern-P) or data processing control (Control-P) responsibilities.
Clarify and document who owns communication-related outcomes, distinguishing management's operational responsibility for transparency activities from any board or committee oversight role, consistent with your organization's governance structure.
Use the Framework's Categories and Subcategories as a checklist of desired outcomes, then exercise professional judgment to select communication methods appropriate to your risk profile rather than assuming any single format is required.
Coordinate Communicate-P activities with legal, compliance, and privacy functions to confirm that transparency practices align with actual statutory and regulatory disclosure obligations.
Periodically review whether your communications continue to give individuals and the organization a reliable understanding of data processing and associated privacy risks, updating them as processing activities or applicable requirements change.