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

PM-21 Accounting of Disclosures

a. Develop and maintain an accurate accounting of disclosures of personally identifiable information, including: 1. Date, nature, and purpose of each disclosure; and 2. Name and address, or other contact information of the individual or organization to which the disclosure was made; b. Retain the accounting of disclosures for the length of the time the personally identifiable information is maintained or five years after the disclosure is made, whichever is longer; and c. Make the accounting of disclosures available to the individual to whom the personally identifiable information relates upon request.

Source: NIST SP 800-53 Rev 5, PM-21. 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.

8
artefacts
2
held by a system
2
at each review
moderate
to go live
SIEM / log platform
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

  • Audit logs · SIEM / log platform
  • Privacy Act exemption rules. · Data governance / DLP tooling

periodic reviewEvidence produced at each review

  • Records of disclosures · Document repository
  • Test of Organizational processes for disclosures; mechanisms supporting the accounting of disclosures, including commercial services that provide notifications and alerts. · SIEM / log platform

governing documentDocuments that govern the control

  • Privacy program plan · Policy repository / GRC workspace
  • Disclosure policies and procedures · Policy repository / GRC workspace
  • Privacy Act policies and procedures · Policy repository / GRC workspace
  • System of records notice · Policy repository / GRC workspace

First move

Start with the 2 of 8 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.

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(1) Dissemination of Privacy Program Information | Privacy Policies on Websites, Applications, and Digital… · PM-22 Personally Identifiable Information Quality Management