CM-13_data-action-mapping

CM-13 Data Action Mapping

High-Level Description

Family: Configuration Management (CM) Framework: NIST SP 800-53 Rev 5

Data actions are system operations that process personally identifiable information. The processing of such information encompasses the full information life cycle, which includes collection, generation, transformation, use, disclosure, retention, and disposal. A map of system data actions includes discrete data actions, elements of personally identifiable information being processed in the data actions, system components involved in the data actions, and the owners or operators of the system components. Understanding what personally identifiable information is being processed (e.g., the sensitivity of the personally identifiable information), how personally identifiable information is being processed (e.g., if the data action is visible to the individual or is processed in another part of the system), and by whom (e.g., individuals may have different privacy perceptions based on the entity that is processing the personally identifiable information) provides a number of contextual factors that are important to assessing the degree of privacy risk created by the system. Data maps can be illustrated in different ways, and the level of detail may vary based on the mission and business needs of the organization. The data map may be an overlay of any system design artifact that the organization is using. The development of this map may necessitate coordination between the privacy and security programs regarding the covered data actions and the components that are identified as part of the system.

What to Check

• Verify CM-13 Data Action Mapping is documented in SSP
• Confirm control is operating effectively
• Review evidence of continuous monitoring for CM-13

How to Test

Step 1: Review Documentation

Examine the System Security Plan (SSP) and related artifacts for CM-13 implementation details. Verify the organization has documented how this control is satisfied.

Step 2: Validate Implementation

# For cloud environments, use cloud-audit-mcp tools
# For on-premises, review system configurations directly

# Example: Check if account management policies exist
grep -r "account.management\|access.control" /etc/security/ 2>/dev/null

Step 3: Test Operating Effectiveness

Verify the control is actively functioning, not just documented. Check logs, configurations, and operational evidence.

Tools

Remediation Guide

Control Statement

Develop and document a map of system data actions.

Implementation Guidance

Data actions are system operations that process personally identifiable information. The processing of such information encompasses the full information life cycle, which includes collection, generation, transformation, use, disclosure, retention, and disposal. A map of system data actions includes discrete data actions, elements of personally identifiable information being processed in the data actions, system components involved in the data actions, and the owners or operators of the system components. Understanding what personally identifiable information is being processed (e.g., the sensitivity of the personally identifiable information), how personally identifiable information is being processed (e.g., if the data action is visible to the individual or is processed in another part of the system), and by whom (e.g., individuals may have different privacy perceptions based on the entity that is processing the personally identifiable information) provides a number of contextual factors that are important to assessing the degree of privacy risk created by the system. Data maps can be illustrated in different ways, and the level of detail may vary based on the mission and business needs of the organization. The data map may be an overlay of any system design artifact that the organization is using. The development of this map may necessitate coordination between the privacy and security programs regarding the covered data actions and the components that are identified as part of the system.

Risk Assessment

CWE Categories

References

• NIST SP 800-53 Rev 5 - CM-13
• NIST SP 800-53A Rev 5 (Assessment Procedures)
• NIST SP 800-53 Rev 5 Full Catalog

Checklist

• Control documented in SSP
• Implementation evidence collected
• Operating effectiveness validated
• Continuous monitoring in place
• Related controls (AC-3, CM-4, CM-12, PM-5, PM-27) reviewed