PE-8(3): Limit Personally Identifiable Information Elements

PE-8(3) requires you to limit the personally identifiable information (PII) stored in visitor access records to only the specific data elements your privacy risk assessment says are necessary. Operationally, you must define the allowed PII fields, configure visitor systems and logs to collect only those fields, and keep evidence that the limit is implemented and periodically validated. ¹

Key takeaways:

• Your privacy risk assessment is the “source of truth” for which PII elements are permitted in visitor records. ¹
• The control fails most often due to “extra” fields in badge systems, sign-in apps, spreadsheets, and exported reports.
• Evidence needs to show both design (approved allowed elements) and operation (system configurations and periodic sampling).

Visitor management is a quiet PII factory. Front desks, security teams, and facility managers often collect more data than they need because the form template, badge system defaults, or a “just in case” mindset drives the workflow. PE-8(3) tightens that sprawl by forcing a single decision: exactly which PII elements belong in visitor access records, and where is that decision documented.

This requirement is narrow but operationally tricky because visitor records live in multiple places: physical logbooks, lobby kiosks, SaaS visitor management tools, access control/badge platforms, security ticketing systems, and ad hoc spreadsheets used for events. You can have a strong privacy program and still fail this control if one intake path captures extra PII, or if exports include fields that were supposed to be disabled.

Treat PE-8(3) as a data minimization implementation task tied to your privacy risk assessment. Your goal is to make “only collect what we approved” the default, not a training suggestion. The fastest path is to (1) define an allowlist of PII elements, (2) enforce it technically across all visitor intake and reporting paths, and (3) prove it with screenshots, configurations, and sampling results. ²

Regulatory text

“Limit personally identifiable information contained in visitor access records to the following elements identified in the privacy risk assessment: {{ insert: param, pe-08.03_odp }}.” ¹

Operator meaning: you must (a) perform or reference a privacy risk assessment that identifies which PII elements are necessary for visitor access records, and (b) ensure visitor access records contain only those elements. If your visitor log includes additional PII beyond what the assessment lists, you are out of compliance even if you “protect” that extra data well. ¹

Plain-English interpretation (what the control is really asking)

PE-8(3) is data minimization for visitor logging:

• Decide the minimum PII required to manage visitor access and safety for your environment.
• Document the allowed PII elements in your privacy risk assessment output.
• Configure every visitor logging method to collect and retain only those elements.
• Prevent drift: changes to forms, tools, or reporting must not reintroduce prohibited fields.

Common “PII elements” seen in visitor access records include: full name, organization, government ID number, driver’s license scan, photo, phone number, email, host name, purpose of visit, arrival/departure times, badge number, and signature. PE-8(3) does not tell you which of these are allowed; your privacy risk assessment does. ¹

Who it applies to (entity and operational context)

Applies to:

• Federal information systems and organizations implementing NIST SP 800-53 controls. ²
• Contractors handling federal data where NIST SP 800-53 is contractually required (including flow-down expectations in many federal programs). ²

Operationally, it applies anywhere you maintain visitor access records, including:

• Facilities with staffed reception/security
• Data centers and sensitive areas with badge readers
• R&D labs, controlled spaces, or regulated operations
• Temporary events hosted in controlled facilities
• Multi-tenant buildings where you still maintain a local visitor process

It also applies to third parties in your physical security chain if they run your visitor management tooling or guard services and generate records on your behalf. Your contracts and procedures must ensure their records meet your allowed-element limit.

What you actually need to do (step-by-step)

1) Name an owner and define the system boundary

• Assign a control owner (often Physical Security, Facilities, or Corporate Security) and a privacy partner (Privacy Office / Legal / GRC).
• Define which locations and systems are in scope: lobby app, badge system, paper logs, event sign-in, visitor photo capture, ID scanning devices, and any exports sent to security operations.

Deliverable: a short in-scope inventory list with system names and record repositories.

2) Extract the allowlist from the privacy risk assessment

PE-8(3) depends on “elements identified in the privacy risk assessment.” ¹

Operationalize that by producing a one-page “Visitor Record PII Allowlist” that includes:

• Allowed PII elements (field-level)
• Business purpose for each element (why it is necessary)
• Whether the element is optional/conditional (for example, only for after-hours access)
• Retention alignment (tie to your visitor log retention rule, if defined elsewhere)

Decision rule: if a field is not on the allowlist, it is prohibited in visitor access records.

3) Map each collection point to the allowlist (find “extra fields”)

Create a table and complete it by inspection and export tests:

Collection point	Where captured	Fields collected today	Allowed?	Action
Lobby kiosk	SaaS app form	(list fields)	compare to allowlist	remove/disable
Badge issuance	Access control	(list fields)	compare	restrict
Paper log	Clipboard	(list fields)	compare	redesign
Reporting export	CSV export	(list fields)	compare	limit export

This is where teams usually discover hidden PII: scanned IDs stored as attachments, “notes” fields used to record sensitive details, or default fields that can’t be removed without admin changes.

4) Enforce the limit technically (preferred) and procedurally (backstop)

Technical enforcement options:

• Form configuration: remove fields from visitor intake forms; disable “required” status for fields not on the allowlist.
• Disable ID scanning / image capture if those elements are not on the allowlist.
• Role-based access and field visibility: if the tool cannot remove a field, restrict who can view or export it and document compensating controls, but treat this as a risk exception because the requirement says “limit … contained in records,” not “limit access.” ¹
• Export controls: limit exported columns; disable scheduled exports that include extra PII.
• Paper controls: replace logbook templates; remove “ID number” and free-text lines that invite oversharing.

Procedural backstops:

• Update receptionist/guard SOPs with “do not collect” instructions and examples of prohibited entries.
• Add a change-control check: any change to visitor forms or badge workflows requires privacy review against the allowlist.

5) Validate operation with sampling and drift checks

You need evidence the limit is real, not aspirational.

• Pull a recent sample of visitor records from each system and verify fields present match the allowlist.
• Check exports and emailed reports, not just the UI.
• Verify third-party guard services follow the same templates and don’t keep parallel logs.

6) Document exceptions formally

If you must collect an additional element temporarily (for example, a special event requiring extra identity assurance), treat it as an exception:

• Record justification, scope, time bound, and compensating controls.
• Update the privacy risk assessment output if the new element becomes standard.

Required evidence and artifacts to retain

Auditors typically want artifacts that show what’s allowed, where it’s enforced, and proof it’s working.

Keep:

• Visitor Record PII Allowlist derived from the privacy risk assessment (or the relevant excerpt) ¹
• Visitor system inventory and data flow notes (collection points and repositories)
• Configuration evidence: screenshots or admin setting exports showing disabled fields, disabled ID scans, limited exports
• Current paper log template (blank) and the retired template showing removal of prohibited fields
• SOPs/work instructions for reception/security and third parties
• Validation results: sampling worksheet, date performed, reviewer, findings, remediation tickets
• Exception register entries (if any) tied back to risk acceptance

Daydream can help by mapping PE-8(3) to a named control owner, a repeatable procedure, and a recurring evidence list so the control stays “audit-ready” rather than re-discovered at assessment time.

Common exam/audit questions and hangups

Expect questions like:

• “Show me the privacy risk assessment output that identifies the allowed PII elements for visitor access records.” ¹
• “Which visitor management tools are in scope, including any used by third parties?”
• “Demonstrate in the system that prohibited fields cannot be collected.”
• “Do exports, backups, or downstream systems contain additional PII fields?”
• “How do you prevent a facility from re-adding fields without review?”
• “Show evidence of periodic checks that the collected fields still match the allowlist.”

Hangups that slow audits:

• The privacy risk assessment exists but doesn’t clearly list field-level elements for visitor records.
• Facilities claims “we don’t collect that anymore” but old templates are still in use at one site.
• SaaS tools store historical data with old fields; teams confuse “we stopped collecting” with “the records no longer contain it.”

Frequent implementation mistakes and how to avoid them

1. Allowlist is vague (“contact info”)

• Fix: list discrete fields (phone, email) and state whether each is allowed.

2. Only the front desk app is fixed; exports still include extra PII

• Fix: test CSV/PDF exports and scheduled reports; lock down report templates.

3. Paper logs ignored

• Fix: treat paper as a system. Replace templates, train staff, and spot-check.

4. Free-text “notes” becomes a privacy sink

• Fix: remove notes field or constrain it with predefined options and SOP language.

5. Third party guard services keep parallel logs

• Fix: contractually require the same allowlist and request sample evidence.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific actions.

Risk implications are still concrete:

• Extra PII in visitor logs increases breach impact and notification exposure.
• Visitor records are frequently shared internally during incidents; unnecessary PII spreads quickly.
• Identity document scans and photos raise sensitivity and complicate retention and access control.

Treat PE-8(3) as a risk-reduction control with a measurable outcome: fewer PII fields collected, fewer places that PII resides, and fewer people who can access it.

Practical 30/60/90-day execution plan

First 30 days (stabilize and define)

• Assign owner, privacy partner, and facilities points-of-contact.
• Inventory all visitor record collection points, including paper and third parties.
• Produce the Visitor Record PII Allowlist from the privacy risk assessment output and get formal approval. ¹
• Freeze form changes until the allowlist is enforced.

By 60 days (implement controls)

• Reconfigure visitor apps, badge workflows, and exports to match the allowlist.
• Replace paper templates and remove free-text fields where feasible.
• Update SOPs and train reception/security and third-party guards.
• Stand up an exception workflow for non-standard visits/events.

By 90 days (prove operation and prevent drift)

• Complete sampling across each site/system and document results.
• Close remediation tickets for any discovered extra fields.
• Add a change-management gate: visitor record field changes require privacy/GRC review against the allowlist.
• Schedule recurring evidence collection in your GRC tracker; Daydream can automate reminders and evidence requests so you can show continuous operation without last-minute scrambles.

Frequently Asked Questions

Does PE-8(3) mean we can’t collect government ID numbers from visitors?

PE-8(3) means you can only collect the PII elements your privacy risk assessment explicitly allows for visitor access records. If ID numbers are not on that list, remove them from forms and stop storing them in records. ¹

Our visitor SaaS tool has fields we can’t delete, only hide. Is that compliant?

Hiding a field may reduce collection, but you need to confirm the data is not still stored in the visitor access record. If the tool stores the field anyway, document an exception and pursue a configuration or vendor change so the record itself is limited. ¹

Do sign-in time and host name count as PII?

They can, depending on context and how they identify a person in your environment. Treat them as candidate PII elements and only include them in visitor records if your privacy risk assessment allowlist includes them. ¹

We stopped collecting extra fields, but old records still contain them. Are we failing?

PE-8(3) is about what visitor access records contain, so legacy records matter. Create a remediation plan: restrict access, consider redaction where feasible, and align retention/disposal so older records with prohibited elements are addressed. ¹

How do we handle special events where we want more visitor details?

Use an exception process with written justification and time bounds, then keep event records separated where possible. If the extra elements become routine, update the privacy risk assessment output and re-approve the allowlist. ¹

What’s the minimum evidence an assessor will accept for PE-8(3)?

Keep the approved allowlist from the privacy risk assessment and configuration proof that collection is limited across each intake path, plus a small sampling record showing the stored fields match the allowlist. ¹

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5