PRI-28: Authorized Agent
Mechanisms exist to allow data subjects to authorize another person or entity (e.g., authorized agent and proxy), acting on the data subject's behalf, to make Personal Data (PD) processing decisions.
Renumbered: Formerly PRI-03.6 in SCF 2025.4.
Control Question: Does the organization allow data subjects to authorize another person or entity (e.g., authorized agent and proxy), acting on the data subject's behalf, to make Personal Data (PD) processing decisions?
General (1)
| Framework | Mapping Values |
|---|---|
| SCF DPMP 2026 | 2.6 |
US (11)
| Framework | Mapping Values |
|---|---|
| USA Federal Data Privacy Framework 2023 | II.2.b |
| USA Federal COPPA 2024 | Sec. 6502.(b)(1)(B) Sec. 6502.(b)(1)(B)(ii) |
| USA Federal HIPAA Administrative Simplification 2013 | § 164.502(g)(1) § 164.502(g)(2) § 164.502(g)(3)(i) § 164.502(g)(3)(i)(A) |
| USA California CCPA 2025 | 7026(j) 7027(j) 7063(a) 7063(a)(1) 7063(a)(2) 7063(b) 7063(c) 7063(d) 7221(j) |
| USA Colorado Colorado Privacy Act 2021 | 6-1-1306(1)(a)(II) |
| USA Montana CDPA 2025 | 30-14-2808(3)(a) 30-14-2808(3)(c) 30-14-2809(1) 30-14-2809(2) |
| USA Oregon CPA 2023 | Section 4(4) |
| USA Oregon 646A 2025 | 646A.576(3) 646A.576(4) |
| USA Tennessee TIPA 2025 | 47-18-3203(a)(1) |
| USA Texas CDPA 2025 | 541.055(e) 541.055(e)(1) 541.055(e)(2) 541.055(e)(3) 541.055(e)(4) |
| USA Virginia CDPA 2023 | 59.1-577.A 59.1-577.1.D 59.1-578.A.5 59.1-578.F.3 |
EMEA (4)
| Framework | Mapping Values |
|---|---|
| EMEA EU GDPR 2016 | Article 8.1 Article 8.2 |
| EMEA Hungary Act CXII 2011 | II.5.6(2) |
| EMEA Italy PDPC 2018 | Article 82(2)(a) |
| EMEA Kenya DPA 2019 | IV.27(a) IV.27(b) IV.27(c) IV.28(2)(d) |
APAC (4)
| Framework | Mapping Values |
|---|---|
| APAC China Privacy Law 2021 | Article 49 |
| APAC India DPDPA 2023 | 6(7) 9(1) 14(1) |
| APAC South Korea PIPA 2011 | V.38(1) V.38(2) |
| APAC Philippines DPA 2012 | IV.17 |
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 allow data subjects to authorize another person or entity (e.g., authorized agent and proxy), acting on the data subject's behalf, to make Personal Data (PD) processing decisions.
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
- PRI-28_A01 data subjects are empowered to authorize another person or entity, acting on the data subject's behalf, to make Personal Data (PD) processing decisions.
Evidence Requirements
- E-PRI-06 Data Subject Access
-
Documented evidence of how data subject access requests are handled that includes intake through remediation.
Privacy
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