PM-21_accounting-of-disclosures

PM-21 Accounting of Disclosures

High-Level Description

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

The purpose of accounting of disclosures is to allow individuals to learn to whom their personally identifiable information has been disclosed, to provide a basis for subsequently advising recipients of any corrected or disputed personally identifiable information, and to provide an audit trail for subsequent reviews of organizational compliance with conditions for disclosures. For federal agencies, keeping an accounting of disclosures is required by the PRIVACT ; agencies should consult with their senior agency official for privacy and legal counsel on this requirement and be aware of the statutory exceptions and OMB guidance relating to the provision.

Organizations can use any system for keeping notations of disclosures, if it can construct from such a system, a document listing of all disclosures along with the required information. Automated mechanisms can be used by organizations to determine when personally identifiable information is disclosed, including commercial services that provide notifications and alerts. Accounting of disclosures may also be used to help organizations verify compliance with applicable privacy statutes and policies governing the disclosure or dissemination of information and dissemination restrictions.

What to Check

• Verify PM-21 Accounting of Disclosures is documented in SSP
• Validate all 4 control requirements are implemented
• Confirm control is operating effectively
• Review evidence of continuous monitoring for PM-21

How to Test

Step 1: Review Documentation

Examine the System Security Plan (SSP) and related artifacts for PM-21 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 maintain an accurate accounting of disclosures of personally identifiable information, including: Date, nature, and purpose of each disclosure; and Name and address, or other contact information of the individual or organization to which the disclosure was made; 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 Make the accounting of disclosures available to the individual to whom the personally identifiable information relates upon request.

Implementation Guidance

The purpose of accounting of disclosures is to allow individuals to learn to whom their personally identifiable information has been disclosed, to provide a basis for subsequently advising recipients of any corrected or disputed personally identifiable information, and to provide an audit trail for subsequent reviews of organizational compliance with conditions for disclosures. For federal agencies, keeping an accounting of disclosures is required by the PRIVACT ; agencies should consult with their senior agency official for privacy and legal counsel on this requirement and be aware of the statutory exceptions and OMB guidance relating to the provision.

Organizations can use any system for keeping notations of disclosures, if it can construct from such a system, a document listing of all disclosures along with the required information. Automated mechanisms can be used by organizations to determine when personally identifiable information is disclosed, including commercial services that provide notifications and alerts. Accounting of disclosures may also be used to help organizations verify compliance with applicable privacy statutes and policies governing the disclosure or dissemination of information and dissemination restrictions.

Risk Assessment

CWE Categories

References

• NIST SP 800-53 Rev 5 - PM-21
• 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, AU-2, PT-2) reviewed