PT-6(1): Routine Uses

“Routine uses” are one of the most failure-prone parts of federal privacy operations because they sit between policy and real data sharing. If your organization operates a federal information system, or you are a contractor operating a system on behalf of an agency (or handling federal data inside a covered environment), PT-6(1) is the requirement that forces discipline: you cannot publish routine uses in a SORN and then forget them. You must review them for accuracy and confirm they remain compatible with why you collected the data in the first place. (NIST SP 800-53 Rev. 5 OSCAL JSON)

For a CCO, Compliance Officer, or GRC lead, the fastest path to operationalizing the pt-6(1): routine uses requirement is to turn it into a recurring control with three moving parts: (1) a complete list of routine uses per SORN, (2) a documented “compatibility assessment” decision for each routine use, and (3) a change workflow that updates the SORN (and related data-sharing practices) when reality drifts. Your goal is simple: if an auditor asks why a particular disclosure is allowed, you can point to the current SORN text and a dated review record showing it is still correct and purpose-compatible. (NIST SP 800-53 Rev. 5)

Regulatory text

Requirement (verbatim): “Review all routine uses published in the system of records notice at {{ insert: param, pt-06.01_odp }} to ensure continued accuracy, and to ensure that routine uses continue to be compatible with the purpose for which the information was collected.” (NIST SP 800-53 Rev. 5 OSCAL JSON)

What the operator must do: maintain a repeatable review process for each SORN’s routine uses, confirm each routine use description matches current practice (accuracy), and confirm each routine use still aligns with the original collection purpose (compatibility). Where a routine use no longer matches practice or purpose, you must route remediation: update practices to match the published routine use, update the routine use text through the SORN change path, or stop the disclosure. (NIST SP 800-53 Rev. 5)

Plain-English interpretation (what PT-6(1) really demands)

PT-6(1) is a “keep your public privacy promises true” control. Your SORN is the public statement of what system data you collect and how you disclose it under defined routine uses. The control expects you to:

• Re-check the text: does each routine use still describe who receives the data, what is shared, and why?
• Re-check the reality: are your actual disclosures consistent with what you published?
• Re-check the purpose: if the system collects data for Purpose A, are you disclosing it for a reason that remains compatible with Purpose A? (NIST SP 800-53 Rev. 5 OSCAL JSON)

A practical way to think about “compatibility” for operations: if you had to explain the disclosure to a privacy reviewer using only the collection purpose statement and the routine use text, would it make sense without hand-waving?

Who it applies to (entity and operational context)

PT-6(1) applies in practice to:

• Federal information systems that maintain a SORN-covered system of records (privacy program + system owners). (NIST SP 800-53 Rev. 5)
• Contractors and service providers operating systems for agencies or handling federal data in environments where the agency’s privacy requirements flow down (common in managed services, shared platforms, contact center operations, case management, benefits administration, and identity workflows). (NIST SP 800-53 Rev. 5)

Operationally, the requirement hits teams that control disclosures:

• Privacy Office / SAOP function (governance and SORN stewardship)
• System Owner and ISSO/ISSM (system boundary and documentation)
• Data Steward(s) (data element meaning and permitted uses)
• Legal/Privacy counsel (compatibility judgments and publication steps)
• Third-party management and procurement (sharing with external recipients) (NIST SP 800-53 Rev. 5)

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

Use this as a control procedure you can paste into your GRC tool.

1) Build the routine-use inventory ¹

1. Identify each system that has a SORN (or is within scope of an agency SORN).
2. Extract every routine use statement from the SORN into a structured register.
3. For each routine use, capture minimum fields:
   • SORN name/identifier and link to the published text
   • Routine use label/title (if used) and exact wording
   • Recipient category (e.g., other agencies, courts, contractors, researchers)
   • Data categories implicated (high level)
   • Business process that triggers the disclosure
   • System interfaces or export mechanisms used
   • Owner accountable for confirming accuracy (role + name) (NIST SP 800-53 Rev. 5 OSCAL JSON)

Operator tip: many programs fail because the SORN text lives in a PDF while the disclosures live in integrations, tickets, and contract SOWs. Put them side-by-side in the same register.

2) Define “accuracy” checks that match real operations

For each routine use, validate accuracy by testing:

• Is the described recipient category still correct?
• Are the disclosure channels still correct (API, batch file, portal access, reports)?
• Does the routine use still reflect actual data elements shared, at least at the category level?
• Are the named third parties still active and covered by contract terms that match the routine use?
• Do incident response, subpoenas, or program changes cause “shadow disclosures” outside the routine use scope? (NIST SP 800-53 Rev. 5)

Evidence-friendly method: pull a sample of disclosures (interface logs, data exchange inventories, or outgoing report listings) and map them to specific routine uses.

3) Run a compatibility assessment (the core of PT-6(1))

Create a short compatibility memo entry per routine use. Keep it structured:

• Collection purpose reference: quote or reference the system’s stated purpose for collecting the information (from the SORN/system documentation).
• Compatibility rationale: one paragraph explaining why the routine use disclosure remains aligned with that purpose.
• Change flags: what changed since last review (mission, program, recipients, data types), and whether that affects compatibility.
• Decision: Compatible / Compatible with updates required / Not compatible (requires remediation). (NIST SP 800-53 Rev. 5 OSCAL JSON)

This is where many reviews get too vague. “Still needed for operations” is not a compatibility rationale. Tie the disclosure back to the purpose.

4) Route changes through a defined workflow

If you find misalignment, choose one remediation path and document it:

• Update operations to match the routine use (stop the extra data elements, narrow recipients, adjust access controls).
• Update the routine use/SORN through the agency’s publication and approval process.
• Terminate the disclosure if no compatible basis remains under the routine use. (NIST SP 800-53 Rev. 5)

Track each as a corrective action with an owner, due date, and closure evidence.

5) Set a recurring review cadence and triggers

PT-6(1) requires “review,” but does not specify a frequency in the provided text. Implement both:

• Recurring review on a defined schedule you can defend internally.
• Event-based review triggers when material changes occur, such as new program purposes, new routine-use recipients, major interface changes, or new third-party sharing arrangements. (NIST SP 800-53 Rev. 5)

6) Make it assessable in your GRC system

To keep audits smooth, map PT-6(1) to:

• A named control owner
• A written procedure
• Recurring evidence artifacts (register exports, review logs, approvals)
• A control test step (what the assessor checks and what “pass” looks like) (NIST SP 800-53 Rev. 5 OSCAL JSON)

Daydream (as a workflow pattern, even if you implement it elsewhere) fits well here: control ownership, scheduled tasks, and evidence collection are the difference between “we do this” and “we can prove this.”

Required evidence and artifacts to retain

Keep artifacts that prove both the review happened and the decisions were reasoned:

• Routine use register (current version + prior versions)
• Copy of each applicable SORN text used for the review (or stable link and snapshot)
• Review schedule and assignment records (tickets, calendar invites, tasking memo)
• Compatibility assessment records per routine use (structured memo or form)
• Accuracy testing support (data exchange inventory extracts, interface listings, disclosure samples, third-party lists)
• Approvals and sign-offs (privacy officer/system owner as defined by your program)
• Change records: corrective actions, SORN update package status, implementation changes, closure notes (NIST SP 800-53 Rev. 5)

Common exam/audit questions and hangups

Expect these questions from assessors operating against NIST 800-53:

1. “Show me the last review of routine uses for this SORN.” They want dates, scope, and sign-off. (NIST SP 800-53 Rev. 5)
2. “How did you determine compatibility with the collection purpose?” They want a repeatable method, not opinions. (NIST SP 800-53 Rev. 5 OSCAL JSON)
3. “How do you know actual disclosures match the routine use text?” They want operational evidence: interfaces, exports, recipients. (NIST SP 800-53 Rev. 5)
4. “What triggers an out-of-cycle review?” They want defined triggers tied to change management. (NIST SP 800-53 Rev. 5)
5. “What changed since the last review?” They want a delta, even if the answer is “no change,” plus how you verified. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Hangup to avoid: producing a privacy policy excerpt instead of SORN routine-use review records. PT-6(1) is about reviewing the routine uses published in the SORN. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Treating the review as a checklist with no compatibility rationale	PT-6(1) explicitly requires compatibility with the collection purpose	Require a short written compatibility statement per routine use tied to the system purpose. (NIST SP 800-53 Rev. 5 OSCAL JSON)
Only reviewing SORN text, not disclosures	Accuracy includes whether routine uses reflect real sharing	Map each routine use to interfaces, reports, exports, and active third parties. (NIST SP 800-53 Rev. 5)
No defined triggers for interim review	Big changes happen between scheduled reviews	Add triggers tied to change management and third-party onboarding. (NIST SP 800-53 Rev. 5)
No version history	Auditors ask what changed over time	Keep versioned registers and decision logs with approvals. (NIST SP 800-53 Rev. 5)
“Contractor = routine use covered” assumption	A contract does not automatically make the disclosure compatible	Validate the disclosure purpose and scope still match collection purpose and SORN routine use language. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Enforcement context and risk implications

No public enforcement cases were provided for this specific requirement in the source data, so you should treat enforcement risk qualitatively and focus on operational consequences. The real risk pattern is mismatch: routine uses that are outdated or overly broad become a weak point during assessments, privacy incident response, or complaints because you cannot show that disclosures remain purpose-compatible and accurately described. (NIST SP 800-53 Rev. 5)

Practical 30/60/90-day execution plan

You asked for speed. Here is a plan you can run without waiting for a full program redesign.

First 30 days (stand up the control)

• Assign an accountable owner for PT-6(1) and confirm stakeholders (privacy, system owner, data steward, procurement).
• Inventory in-scope SORNs and extract routine uses into a register.
• Define the review procedure template: accuracy checks + compatibility memo fields + approval path.
• Pick your evidence system of record (GRC tool, ticketing system, or controlled repository) and define naming conventions. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Days 31–60 (run the first real review)

• Perform the routine use review for the highest-risk systems first (systems with frequent sharing, many interfaces, or many third parties).
• For each routine use, complete the compatibility assessment entry and document accuracy validation with at least one operational support artifact.
• Open corrective actions where routine uses and practice diverge; assign owners and track to closure. (NIST SP 800-53 Rev. 5)

Days 61–90 (stabilize and make it auditable)

• Expand reviews to remaining SORNs in scope.
• Integrate triggers into change management: new data exchanges, new third parties, purpose changes, or major releases prompt a routine-use review.
• Run an internal “mock audit” by sampling routine uses and tracing to evidence.
• Lock in recurring review tasks and evidence collection so next cycle is repeatable. (NIST SP 800-53 Rev. 5)

Frequently Asked Questions

What counts as a “routine use” for PT-6(1)?

For this requirement, routine uses are the disclosures listed in the System of Records Notice for the system of records. Your job is to review the routine uses that are published there for accuracy and compatibility with the collection purpose. (NIST SP 800-53 Rev. 5 OSCAL JSON)

How do I document “compatibility” without turning it into a legal memo?

Use a short structured rationale that references the collection purpose and explains why the disclosure supports or aligns with that purpose. Keep it consistent across routine uses so an assessor can compare decisions. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Do I need to review routine uses even if nothing changed?

Yes. PT-6(1) requires review to confirm continued accuracy and continued compatibility, which implies you must periodically re-validate and record the decision even if the outcome is “no change.” (NIST SP 800-53 Rev. 5 OSCAL JSON)

What evidence is most convincing to an auditor?

A versioned routine-use register, dated review records with approvals, and operational artifacts showing actual disclosures (interfaces, exchange inventories, recipient lists) mapped to each routine use. (NIST SP 800-53 Rev. 5)

We share data with a new third party. Is that automatically covered if the routine use mentions contractors?

Do not assume. Confirm the actual sharing scope matches the routine use description and that the disclosure purpose remains compatible with the collection purpose; if not, route a change to the SORN routine use or stop/narrow the sharing. (NIST SP 800-53 Rev. 5 OSCAL JSON)

How should a GRC team operationalize this without slowing delivery teams?

Embed triggers into existing change and third-party intake workflows, then require a short compatibility entry and a mapping to the relevant routine use before production data sharing starts. Keep the evidence capture lightweight but consistent. (NIST SP 800-53 Rev. 5)

Footnotes

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