PM-18 Privacy Program Plan
a. Develop and disseminate an organization-wide privacy program plan that provides an overview of the agency’s privacy program, and: 1. Includes a description of the structure of the privacy program and the resources dedicated to the privacy program; 2. Provides an overview of the requirements for the privacy program and a description of the privacy program management controls and common controls in place or planned for meeting those requirements; 3. Includes the role of the senior agency official for privacy and the identification and assignment of roles of other privacy officials and staff and their responsibilities; 4. Describes management commitment, compliance, and the strategic goals and objectives of the privacy program; 5. Reflects coordination among organizational entities responsible for the different aspects of privacy; and 6. Is approved by a senior official with responsibility and accountability for the privacy risk being incurred to organizational operations (including mission, functions, image, and reputation), organizational assets, individuals, other organizations, and the Nation; and b. Update the plan organization-defined frequency and to address changes in federal privacy laws and policy and organizational changes and problems identified during plan implementation or privacy control assessments.
Source: NIST SP 800-53 Rev 5, PM-18. 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.
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
- Procedures addressing program plan reviews, updates, and approvals · Policy repository / GRC workspace
- Records of program plan reviews, updates, and approvals · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Privacy program plan · Policy repository / GRC workspace
- Procedures addressing program plan development and implementation · Policy repository / GRC workspace
- Procedures addressing coordination of the program plan with relevant entities · Policy repository / GRC workspace
First move
Common gaps auditors find
- No organization-wide privacy program plan describes the program's structure and resources
- The privacy program plan is not approved by a senior official or updated as required
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 sheetPM-17 Protecting Controlled Unclassified Information on External Systems · PM-19 Privacy Program Leadership Role