PM-20(1)_privacy-policies-on-websites-applications-and-digital-servic

PM-20(1) Privacy Policies on Websites, Applications, and Digital Services

Enhancement of: PM-20

High-Level Description

Family: Program Management (PM) Framework: NIST SP 800-53 Rev 5

Organizations post privacy policies on all external-facing websites, mobile applications, and other digital services. Organizations post a link to the relevant privacy policy on any known, major entry points to the website, application, or digital service. In addition, organizations provide a link to the privacy policy on any webpage that collects personally identifiable information. Organizations may be subject to applicable laws, executive orders, directives, regulations, or policies that require the provision of specific information to the public. Organizational personnel consult with the senior agency official for privacy and legal counsel regarding such requirements.

What to Check

• Verify PM-20(1) Privacy Policies on Websites, Applications, and Digital Services is documented in SSP
• Validate all 3 control requirements are implemented
• Confirm control is operating effectively
• Review evidence of continuous monitoring for PM-20(1)
• Verify enhancement builds upon base control PM-20

How to Test

Step 1: Review Documentation

Examine the System Security Plan (SSP) and related artifacts for PM-20(1) 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 post privacy policies on all external-facing websites, mobile applications, and other digital services, that: Are written in plain language and organized in a way that is easy to understand and navigate; Provide information needed by the public to make an informed decision about whether and how to interact with the organization; and 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.

Implementation Guidance

Organizations post privacy policies on all external-facing websites, mobile applications, and other digital services. Organizations post a link to the relevant privacy policy on any known, major entry points to the website, application, or digital service. In addition, organizations provide a link to the privacy policy on any webpage that collects personally identifiable information. Organizations may be subject to applicable laws, executive orders, directives, regulations, or policies that require the provision of specific information to the public. Organizational personnel consult with the senior agency official for privacy and legal counsel regarding such requirements.

Risk Assessment

CWE Categories

References

• NIST SP 800-53 Rev 5 - PM-20(1)
• 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 (none) reviewed