What evidence do auditors commonly ask for on PL-9 Central Management?

Security and privacy planning policy; Procedures addressing security and privacy plan development and implementation; System security plan; Privacy plan; Test of Organizational processes for the central management of controls and related processes; mechanisms supporting and/or implementing central management of controls and related processes.

What is the most common gap auditors find on PL-9?

The controls and processes to be centrally managed were never defined

NIST SP 800-53 Rev 5 · PL - Planning

`PL-9` Central Management

Centrally manage organization-defined controls and related processes.

Source: NIST SP 800-53 Rev 5, PL-9. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open NIST SP 800-53 Rev 5 in the compliance library.

Base controls and their enhancements. Which apply follows the baseline you are assessed against (for example FedRAMP Moderate or High, or the low, moderate and high baselines of SP 800-53B). Text in square brackets is a parameter your organisation sets.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Test of Organizational processes for the central management of controls and related processes; mechanisms supporting and/or implementing central management of controls and related processes · Document repository

governing documentDocuments that govern the control

Security and privacy planning policy · Policy repository / GRC workspace
Procedures addressing security and privacy plan development and implementation · Policy repository / GRC workspace
System security plan · Policy repository / GRC workspace
Privacy plan · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

The controls and processes to be centrally managed were never defined
Centrally managed controls are implemented inconsistently across systems

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

PL-8(2) Security and Privacy Architectures | Supplier Diversity · PL-10 Baseline Selection