PM-20(1)·high·Component: Program ManagementWhat this control requires
Develop and post privacy policies on external-facing websites, mobile apps, and other digital services in plain language, ensuring they are easily understandable and navigable. The policies must inform the public about interaction practices and be updated whenever substantive changes are made. This control supports the Governance capability within the Program Management family.
In plain English
Develop and post privacy policies on external-facing websites, mobile apps, and other digital services in plain language, ensuring they are easily understandable and navigable. In practice, this means you can prove you policy management-level controls on a defined cadence.
Why it matters
SP 800-53 is the catalogue every U.S. federal authorisation (FedRAMP, FISMA, CMMC) and most regulated industries point at. A missing control surfaces as a Plan of Action & Milestones (POA&M) item that an Authorizing Official must approve before the Authority To Operate is granted or renewed.
This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.
What an auditor looks for
A 3PAO (FedRAMP) or Independent Assessor (NIST RMF) tests against NIST SP 800-53A assessment procedures. For each control they expect a documented implementation that addresses every assessment objective (Examine, Interview, Test) and an implementation summary in the System Security Plan.
Within Program Management, the assessor will trace your implementation back to the catalogue reference (Control PM-20(1)) and look for objective evidence on the latest two assessment cycles.
How to implement
Endpoint Protection
MDM. Make MDM enrollment a hard gate for device access (Intune compliance + Conditional Access, or Jamf + Okta device trust). Unmanaged devices simply don't get a session token.
EDR. Deploy CrowdStrike / SentinelOne / Defender for Endpoint to every server and laptop; alert on any host that stops sending telemetry for >24h.
Policy Management
Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.
Operational checklist
- Policy. Document the trigger, the owner and the cadence.
- Protection. Document the trigger, the owner and the cadence.
- Changes. Document the trigger, the owner and the cadence.
- Control. Document the trigger, the owner and the cadence.
- Public. Document the trigger, the owner and the cadence.
- Scope: management, privacy, protection, services, capability, applications, policy.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policy or standard documents the safeguard. Focus: Privacy Policies On Websites, Applications, And Digital Services.
Common pitfalls
- Pilot MDM rollouts that quietly exclude executives or engineers; carving out the highest-risk users is the most common audit failure.
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
How it maps to other frameworks
Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.
- SOC 2 (2017 TSC) P3.2 — Consent Management for Personal Information Collection
- HIPAA (45 CFR Part 164) 164.308(a)(5)(i) — Security Awareness and Training
- NIST SP 800-171 Rev. 3 3.13.15 — Session Authenticity
- BSI C5:2020 SP-01 — Documentation, communication and provision of policies and instructions
- ISO/IEC 27001:2022 A.5.21 — Managing information security in the ICT supply chain
Related controls in NIST SP 800-53 Rev. 5
- Control PL-2(3) — Plan And Coordinate With Other Organizational Entities
- Control PM-24 — Data Integrity Board
- Control PM-23 — Data Governance Body
- Control SA-2 — Allocation Of Resources
- Control PL-2(2) — Functional Architecture
- Control PM-4 — Plan Of Action And Milestones Process
References
- NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
- Catalogue identifier:
Control PM-20(1)
Topics: governance riskendpoint protectionpolicy managementprivacy management