PM-3·high·Component: Program ManagementWhat this control requires
Include necessary resources for implementing information security and privacy programs in capital planning and investment requests, document any exceptions, and ensure the availability of planned resources for expenditure in accordance with applicable laws, regulations, and policies. This control supports the Capital Planning and Investment Resources capability within the Program Management family.
In plain English
Include necessary resources for implementing information security and privacy programs in capital planning and investment requests, document any exceptions, and ensure the availability of planned resources for expenditure in accordance with applicable laws, regulations, and policies. 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-3) 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.
- Security. 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, capability, regulations, investment requests, policy, resources.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policy or standard documents the safeguard. Focus: Information Security And Privacy Resources.
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.
- HIPAA (45 CFR Part 164) 164.316(b)(2)(ii) — Documentation- Availability
- ISO/IEC 27001:2022 A.5.1 — Policies for information security
- BSI C5:2020 SP-01 — Documentation, communication and provision of policies and instructions
- ISO/IEC 27701:2025 A.3.4 — Information security roles & responsibilities
- NIST SP 800-171 Rev. 3 3.1.9 — System Use Notification
Related controls in NIST SP 800-53 Rev. 5
- Control PM-4 — Plan Of Action And Milestones Process
- Control PM-22 — Personally Identifiable Information Quality Management
- Control PM-29 — Risk Management Program Leadership Roles
- Control PL-2(3) — Plan And Coordinate With Other Organizational Entities
- Control SA-2 — Allocation Of Resources
- Control PM-26 — Complaint Management
References
- NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
- Catalogue identifier:
Control PM-3
Topics: governance riskpolicy managementprivacy management