NIST SP 800-53 Rev. 5·Control SI-18(2)·high·Component: System and Information Integrity

What this control requires

Use data tags to automate the correction or deletion of personally identifiable information (PII) across its lifecycle. Tags can include details such as processing permissions, authority, de-identification status, impact level, and retention dates, supporting automated tools for data management. This control supports the Data Governance, Privacy Policy capability within the System and Information Integrity family.
— NIST SP 800-53 Rev. 5, Control SI-18(2)

In plain English

Use data tags to automate the correction or deletion of personally identifiable information (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 System and Information Integrity, the assessor will trace your implementation back to the catalogue reference (Control SI-18(2)) 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.
  • Data. Document the trigger, the owner and the cadence.
  • Protection. Document the trigger, the owner and the cadence.
  • System. Document the trigger, the owner and the cadence.
  • Scope: management, information, privacy, system, personally identifiable information, protection, retention, capability.

Evidence to collect

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

Signed policy or standard documents the safeguard. Focus: Data Tags.

Common pitfalls

  • Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

Related controls in NIST SP 800-53 Rev. 5

References

Topics: governance riskdata protectionlogging retentionpolicy managementprivacy management