PM-27_privacy-reporting

PM-27 Privacy Reporting

High-Level Description

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

Through internal and external reporting, organizations promote accountability and transparency in organizational privacy operations. Reporting can also help organizations to determine progress in meeting privacy compliance requirements and privacy controls, compare performance across the federal government, discover vulnerabilities, identify gaps in policy and implementation, and identify models for success. For federal agencies, privacy reports include annual senior agency official for privacy reports to OMB, reports to Congress required by Implementing Regulations of the 9/11 Commission Act, and other public reports required by law, regulation, or policy, including internal policies of organizations. The senior agency official for privacy consults with legal counsel, where appropriate, to ensure that organizations meet all applicable privacy reporting requirements.

What to Check

• Verify PM-27 Privacy Reporting is documented in SSP
• Validate all 3 control requirements are implemented
• Confirm control is operating effectively
• Review evidence of continuous monitoring for PM-27

How to Test

Step 1: Review Documentation

Examine the System Security Plan (SSP) and related artifacts for PM-27 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 [organization-defined] and disseminate to: [organization-defined] to demonstrate accountability with statutory, regulatory, and policy privacy mandates; and [organization-defined] and other personnel with responsibility for monitoring privacy program compliance; and Review and update privacy reports [organization-defined].

Implementation Guidance

Through internal and external reporting, organizations promote accountability and transparency in organizational privacy operations. Reporting can also help organizations to determine progress in meeting privacy compliance requirements and privacy controls, compare performance across the federal government, discover vulnerabilities, identify gaps in policy and implementation, and identify models for success. For federal agencies, privacy reports include annual senior agency official for privacy reports to OMB, reports to Congress required by Implementing Regulations of the 9/11 Commission Act, and other public reports required by law, regulation, or policy, including internal policies of organizations. The senior agency official for privacy consults with legal counsel, where appropriate, to ensure that organizations meet all applicable privacy reporting requirements.

Risk Assessment

CWE Categories

References

• NIST SP 800-53 Rev 5 - PM-27
• 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 (IR-9, PM-19) reviewed