EvidenceSheet
NIST SP 800-53 Rev 5 · PM - Program Management

PM-20(1) Dissemination of Privacy Program Information | Privacy Policies on Websites, Applications, and Digital…

Develop and post privacy policies on all external-facing websites, mobile applications, and other digital services, that: (a) Are written in plain language and organized in a way that is easy to understand and navigate; (b) Provide information needed by the public to make an informed decision about whether and how to interact with the organization; and (c) Are updated whenever the organization makes a substantive change to the practices it describes and includes a time/date stamp to inform the public of the date of the most recent changes.

Source: NIST SP 800-53 Rev 5, PM-20(1). 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.

3
artefacts
0
held by a system
1
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 procedures and practices for authorizing, conducting, managing, and reviewing personally identifiable information processing; organizational procedures and practices for disseminating privacy program information; mechanisms supporting the dissemination of privacy program information · Data governance / DLP tooling

governing documentDocuments that govern the control

  • Privacy program plan · Policy repository / GRC workspace
  • Privacy policies on the agency website, mobile applications, and/or other digital services · 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.

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PM-20 Dissemination of Privacy Program Information · PM-21 Accounting of Disclosures