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PRI-13: Product or Service Delivery Restrictions

PRI 7 — High Identify

Mechanisms exist to prevent discrimination against a data subject for exercising their legal rights pertaining to modifying or revoking consent, including prohibiting: (1) Refusing products and/or services; (2) Charging different rates for goods and/or services; and (3) Providing different levels of quality.

Renumbered: Formerly PRI-03.5 in SCF 2025.4.

Code reused: In SCF 2025.4 and earlier, PRI-13 was Data Management Board. That control is now DCH-33.1.

Control Question: Does the organization prevent discrimination against a data subject for exercising their legal rights pertaining to modifying or revoking consent, including prohibiting: (1) Refusing products and/or services; (2) Charging different rates for goods and/or services; and (3) Providing different levels of quality?

General (2)
Framework Mapping Values
AICPA Privacy Management Framework (PMF) C3.1-POF2 C3.1-POF3
SCF DPMP 2026 2.4
US (8)
Framework Mapping Values
USA Federal HIPAA Administrative Simplification 2013 § 164.508(c)(2)(ii)(A) § 164.508(c)(2)(ii)(B) § 164.514(f)(2)(iii)
USA California CCPA 2025 7080(a) 7080(b) 7221(l)
USA Colorado Colorado Privacy Act 2021 6-1-1308(1)(c)(I) 6-1-1308(1)(c)(II)
USA Montana CDPA 2025 30-14-2812(2)(e)
USA Nevada Privacy Law 2023 603A.535.2
USA Oregon CPA 2023 Section 5(2)(d)
USA Texas CDPA 2025 541.101(b)(3) 541.101(c)
USA Virginia CDPA 2023 59.1-577.1.E 59.1-578.A.4
EMEA (3)
Framework Mapping Values
EMEA Germany FDPA 2017 3.3.59(3)
EMEA Kenya DPA 2019 IV.32(4)
EMEA Saudi Arabia PDPL Article 7
APAC (2)
Framework Mapping Values
APAC China Privacy Law 2021 Article 16
APAC South Korea PIPA 2011 III.1.16(2) III.1.22(4)

Capability Maturity Model

Level 0 — Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 — Performed Informally

SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

Level 2 — Planned & Tracked

SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 — Well Defined

Privacy (PRI) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with PRI domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with PRI domain capabilities are well-documented and kept current by process owners. ▪ A data privacy team, or similar function, is appropriately staffed and supported to implement and maintain PRI domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data privacy operations (e.g., privacy notice management software and customer management solution). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with PRI domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to prevent discrimination against a data subject for exercising their legal rights pertaining to modifying or revoking consent, including prohibiting: (1) Refusing products and/or services; (2) Charging different rates for goods and/or services; and (3) Providing different levels of quality.

Level 4 — Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Level 5 — Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

Assessment Objectives

  1. PRI-13_A01 processes exist to prevent the refusal of products and/or services on the grounds that a data subject does not agree to the processing of Personal Data (PD) or withdraws consent.

Technology Recommendations

Micro/Small

  • Data classification program
  • Data privacy program
  • Data Protection Impact Assessment (DPIA)
  • Product / project management

Small

  • Data classification program
  • Data privacy program
  • Data Protection Impact Assessment (DPIA)
  • Product / project management

Medium

  • Data classification program
  • Data privacy program
  • Data Protection Impact Assessment (DPIA)
  • Product / project management

Large

  • Data classification program
  • Data privacy program
  • Data Protection Impact Assessment (DPIA)
  • Product / project management

Enterprise

  • Data classification program
  • Data privacy program
  • Data Protection Impact Assessment (DPIA)
  • Product / project management

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