EvidenceSheet

PM-19 Privacy Program Leadership Role

Appoint a senior agency official for privacy with the authority, mission, accountability, and resources to coordinate, develop, and implement, applicable privacy requirements and manage privacy risks through the organization-wide privacy program.

Source: NIST SP 800-53 Rev 5, PM-19. 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.

9
artefacts
0
held by a system
2
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

  • Privacy impact assessments · Data governance / DLP tooling
  • Privacy risk assessments · Data governance / DLP tooling

governing documentDocuments that govern the control

  • Privacy program documents, including policies, procedures, plans, and reports · Policy repository / GRC workspace
  • Public privacy notices, including Federal Register notices · Policy repository / GRC workspace
  • Privacy Act statements · Policy repository / GRC workspace
  • System of records notices · Document repository
  • Computer matching agreements and notices · Vendor register / contract repository
  • Contracts, information sharing agreements, and memoranda of understanding · Vendor register / contract repository
  • Governing requirements, including laws, executive orders, regulations, standards, and guidance · 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

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

PM-18 Privacy Program Plan · PM-20 Dissemination of Privacy Program Information