cyberstrikeus PM-19 Privacy Program Leadership Role
High-Level Description
Family: Program Management (PM) Framework: NIST SP 800-53 Rev 5
The privacy officer is an organizational official. For federal agencies—as defined by applicable laws, executive orders, directives, regulations, policies, standards, and guidelines—this official is designated as the senior agency official for privacy. Organizations may also refer to this official as the chief privacy officer. The senior agency official for privacy also has roles on the data management board (see PM-23 ) and the data integrity board (see PM-24).
What to Check
- Verify PM-19 Privacy Program Leadership Role is documented in SSP
- Confirm control is operating effectively
- Review evidence of continuous monitoring for PM-19
How to Test
Step 1: Review Documentation
Examine the System Security Plan (SSP) and related artifacts for PM-19 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
| Tool | Purpose | Usage |
|---|---|---|
| Manual Review | Documentation and interview-based | N/A |
Remediation Guide
Control Statement
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.
Implementation Guidance
The privacy officer is an organizational official. For federal agencies—as defined by applicable laws, executive orders, directives, regulations, policies, standards, and guidelines—this official is designated as the senior agency official for privacy. Organizations may also refer to this official as the chief privacy officer. The senior agency official for privacy also has roles on the data management board (see PM-23 ) and the data integrity board (see PM-24).
Risk Assessment
| Finding | Severity | Impact |
|---|---|---|
| PM-19 Privacy Program Leadership Role not implemented | Medium | Program Management |
| PM-19 partially implemented | Low | Incomplete Program Management |
CWE Categories
| CWE ID | Title |
|---|---|
| N/A | No direct CWE mapping |
References
- NIST SP 800-53 Rev 5 - PM-19
- 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 (PM-18, PM-20, PM-23, PM-24, PM-27) reviewed