What is the most common gap auditors find on SI-18(5)?

Individuals are not notified when their PII has been corrected or deleted

NIST SP 800-53 Rev 5 · SI - System and Information Integrity

`SI-18(5)` Personally Identifiable Information Quality Operations | Notice of Correction or Deletion

Q: What evidence do auditors commonly ask for on SI-18(5) Personally Identifiable Information Quality Operations | Notice of Correction or Deletion?

System and information integrity policy; System and information integrity procedures; Personally identifiable information processing policy; System configuration; Individual requests for corrections or deletions; Notifications of correction or deletion action.

Notify organization-defined recipients of personally identifiable information and individuals that the personally identifiable information has been corrected or deleted.

Source: NIST SP 800-53 Rev 5, SI-18(5). 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

System configuration · Cloud console / configuration management

periodic reviewEvidence produced at each review

System audit records · Policy repository / GRC workspace
Test of Organizational processes for notifications of correction or deletion; automated mechanisms supporting and/or implementing notifications of correction or deletion · Document repository

governing documentDocuments that govern the control

System and information integrity policy · Policy repository / GRC workspace
System and information integrity procedures · Policy repository / GRC workspace
Personally identifiable information processing policy · Policy repository / GRC workspace
Individual requests for corrections or deletions · Document repository
Notifications of correction or deletion action · Document repository
System security plan · Policy repository / GRC workspace
Privacy plan · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Cloud console / configuration management on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

Individuals are not notified when their PII has been corrected or deleted
The defined recipients of PII are not notified of corrections or deletions

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

SI-18(4) Personally Identifiable Information Quality Operations | Individual Requests · SI-19 De-identification