PM 27 Privacy Reporting

---
name: "PM-27_privacy-reporting"
description: "Develop [organization-defined] and disseminate to: [organization-defined] to demonstrate accountability with statutory, regulatory, and policy privacy"
category: "configuration"
version: "5.2.0"
author: "cyberstrike-official"
tags:
  - nist
  - sp800-53
  - rev5
  - pm-27
  - pm
tech_stack:
  - any
cwe_ids: []
chains_with:
  - IR-9
  - PM-19
prerequisites: []
severity_boost:
  IR-9: "Chain with IR-9 for comprehensive security coverage"
  PM-19: "Chain with PM-19 for comprehensive security coverage"
---

# 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

| Tool          | Purpose                           | Usage |
| ------------- | --------------------------------- | ----- |
| Manual Review | Documentation and interview-based | N/A   |

## 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

| Finding                                 | Severity | Impact                        |
| --------------------------------------- | -------- | ----------------------------- |
| PM-27 Privacy Reporting not implemented | Medium   | Program Management            |
| PM-27 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-27](https://csrc.nist.gov/projects/cprt/catalog#/cprt/framework/version/SP_800_53_5_1_1/home?element=pm-27)
- [NIST SP 800-53A Rev 5 (Assessment Procedures)](https://csrc.nist.gov/pubs/sp/800/53/a/r5/final)
- [NIST SP 800-53 Rev 5 Full Catalog](https://csrc.nist.gov/pubs/sp/800/53/r5/upd1/final)

## Checklist

- [ ] Control documented in SSP
- [ ] Implementation evidence collected
- [ ] Operating effectiveness validated
- [ ] Continuous monitoring in place
- [ ] Related controls (IR-9, PM-19) reviewed