cyberstrikeus PM-24 Data Integrity Board
High-Level Description
Family: Program Management (PM) Framework: NIST SP 800-53 Rev 5
A Data Integrity Board is the board of senior officials designated by the head of a federal agency and is responsible for, among other things, reviewing the agency’s proposals to conduct or participate in a matching program and conducting an annual review of all matching programs in which the agency has participated. As a general matter, a matching program is a computerized comparison of records from two or more automated PRIVACT systems of records or an automated system of records and automated records maintained by a non-federal agency (or agent thereof). A matching program either pertains to Federal benefit programs or Federal personnel or payroll records. At a minimum, the Data Integrity Board includes the Inspector General of the agency, if any, and the senior agency official for privacy.
What to Check
- Verify PM-24 Data Integrity Board is documented in SSP
- Validate all 2 control requirements are implemented
- Confirm control is operating effectively
- Review evidence of continuous monitoring for PM-24
How to Test
Step 1: Review Documentation
Examine the System Security Plan (SSP) and related artifacts for PM-24 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
Establish a Data Integrity Board to: Review proposals to conduct or participate in a matching program; and Conduct an annual review of all matching programs in which the agency has participated.
Implementation Guidance
A Data Integrity Board is the board of senior officials designated by the head of a federal agency and is responsible for, among other things, reviewing the agency’s proposals to conduct or participate in a matching program and conducting an annual review of all matching programs in which the agency has participated. As a general matter, a matching program is a computerized comparison of records from two or more automated PRIVACT systems of records or an automated system of records and automated records maintained by a non-federal agency (or agent thereof). A matching program either pertains to Federal benefit programs or Federal personnel or payroll records. At a minimum, the Data Integrity Board includes the Inspector General of the agency, if any, and the senior agency official for privacy.
Risk Assessment
| Finding | Severity | Impact |
|---|---|---|
| PM-24 Data Integrity Board not implemented | Medium | Program Management |
| PM-24 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-24
- 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-4, PM-19, PM-23, PT-2, PT-8) reviewed