PM-18_privacy-program-plan

PM-18 Privacy Program Plan

High-Level Description

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

A privacy program plan is a formal document that provides an overview of an organization’s privacy program, including a description of the structure of the privacy program, the resources dedicated to the privacy program, the role of the senior agency official for privacy and other privacy officials and staff, the strategic goals and objectives of the privacy program, and the program management controls and common controls in place or planned for meeting applicable privacy requirements and managing privacy risks. Privacy program plans can be represented in single documents or compilations of documents.

The senior agency official for privacy is responsible for designating which privacy controls the organization will treat as program management, common, system-specific, and hybrid controls. Privacy program plans provide sufficient information about the privacy program management and common controls (including the specification of parameters and assignment and selection operations explicitly or by reference) to enable control implementations that are unambiguously compliant with the intent of the plans and a determination of the risk incurred if the plans are implemented as intended.

Program management controls are generally implemented at the organization level and are essential for managing the organization’s privacy program. Program management controls are distinct from common, system-specific, and hybrid controls because program management controls are independent of any particular information system. Together, the privacy plans for individual systems and the organization-wide privacy program plan provide complete coverage for the privacy controls employed within the organization.

Common controls are documented in an appendix to the organization’s privacy program plan unless the controls are included in a separate privacy plan for a system. The organization-wide privacy program plan indicates which separate privacy plans contain descriptions of privacy controls.

What to Check

• Verify PM-18 Privacy Program Plan is documented in SSP
• Validate all 7 control requirements are implemented
• Confirm control is operating effectively
• Review evidence of continuous monitoring for PM-18

How to Test

Step 1: Review Documentation

Examine the System Security Plan (SSP) and related artifacts for PM-18 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 disseminate an organization-wide privacy program plan that provides an overview of the agency’s privacy program, and: Includes a description of the structure of the privacy program and the resources dedicated to the privacy program; Provides an overview of the requirements for the privacy program and a description of the privacy program management controls and common controls in place or planned for meeting those requirements; Includes the role of the senior agency official for privacy and the identification and assignment of roles of other privacy officials and staff and their responsibilities; Describes management commitment, compliance, and the strategic goals and objectives of the privacy program; Reflects coordination among organizational entities responsible for the different aspects of privacy; and Is approved by a senior official with responsibility and accountability for the privacy risk being incurred to organizational operations (including mission, functions, image, and reputation), organizational assets, individuals, other organizations, and the Nation; and Update the plan [organization-defined] and to address changes in federal privacy laws and policy and organizational changes and problems identified during plan implementation or privacy control assessments.

Implementation Guidance

A privacy program plan is a formal document that provides an overview of an organization’s privacy program, including a description of the structure of the privacy program, the resources dedicated to the privacy program, the role of the senior agency official for privacy and other privacy officials and staff, the strategic goals and objectives of the privacy program, and the program management controls and common controls in place or planned for meeting applicable privacy requirements and managing privacy risks. Privacy program plans can be represented in single documents or compilations of documents.

The senior agency official for privacy is responsible for designating which privacy controls the organization will treat as program management, common, system-specific, and hybrid controls. Privacy program plans provide sufficient information about the privacy program management and common controls (including the specification of parameters and assignment and selection operations explicitly or by reference) to enable control implementations that are unambiguously compliant with the intent of the plans and a determination of the risk incurred if the plans are implemented as intended.

Program management controls are generally implemented at the organization level and are essential for managing the organization’s privacy program. Program management controls are distinct from common, system-specific, and hybrid controls because program management controls are independent of any particular information system. Together, the privacy plans for individual systems and the organization-wide privacy program plan provide complete coverage for the privacy controls employed within the organization.

Common controls are documented in an appendix to the organization’s privacy program plan unless the controls are included in a separate privacy plan for a system. The organization-wide privacy program plan indicates which separate privacy plans contain descriptions of privacy controls.

Risk Assessment

CWE Categories

References

• NIST SP 800-53 Rev 5 - PM-18
• 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-8, PM-9, PM-19) reviewed