NIST SP 800-53 Rev. 5 PM-22 — Personally Identifiable Information Quality Management

What this control requires

Develop and document policies for reviewing, correcting, or deleting inaccurate or outdated PII across its lifecycle. Ensure the accuracy, relevance, and completeness of PII and disseminate notices of corrections or deletions. Provide an appeals process for adverse decisions regarding requests for correction or deletion of PII. This control supports the Governance capability within the Program Management family.

In plain English

Develop and document policies for reviewing, correcting, or deleting inaccurate or outdated PII across its lifecycle. 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-22) and look for objective evidence on the latest two assessment cycles.

How to implement

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.
• Information. Document the trigger, the owner and the cadence.
• Process. Document the trigger, the owner and the cadence.
• Control. Document the trigger, the owner and the cadence.
• Document. Document the trigger, the owner and the cadence.
• Scope: management, information, privacy, decisions, personally identifiable information, capability, policy, identifiable information quality management.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policy or standard documents the safeguard. Focus: Personally Identifiable Information Quality Management.

Common pitfalls

• 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.

• India DPDP Act 2023 LB-001 — Consent Quality & Management
• ISO/IEC 27001:2022 A.5.13 — Labelling of information
• 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
• GDPR Article 8 — Conditions applicable to child's consent in relation to information society services

Related controls in NIST SP 800-53 Rev. 5

• Control PM-25 — Minimization Of Personally Identifiable Information Used In Testing, Training, And Research
• Control SI-18 — Personally Identifiable Information Quality Operations
• Control PT-3(1) — Data Tagging
• Control PT-3(2) — Automation
• Control AT-3(5) — Processing Personally Identifiable Information
• Control PM-3 — Information Security And Privacy Resources

References

• NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
• Catalogue identifier: Control PM-22

Topics: governance riskpolicy managementprivacy management