Inventory of Personally Identifiable Information
LOW MODERATE HIGHRequirements NIST SOURCE
Establish, maintain, and update [frequency] an inventory of all systems, applications, and projects that process personally identifiable information.
Discussion (NIST Supplemental Guidance)
An inventory of systems, applications, and projects that process personally identifiable information supports the mapping of data actions, providing individuals with privacy notices, maintaining accurate personally identifiable information, and limiting the processing of personally identifiable information when such information is not needed for operational purposes. Organizations may use this inventory to ensure that systems only process the personally identifiable information for authorized purposes and that this processing is still relevant and necessary for the purpose specified therein.
Implementation Guidance
Original engineering commentary written for this explorer — not NIST source text and not authoritative guidance.
No engineering interpretation has been authored for PM-5(1) yet. This section is architected to receive it — see the Requirements and Assessment sections above for the authoritative NIST source content in the meantime.
Assessment
Assessment Objectives
- the frequency at which to update the inventory of systems, applications, and projects that process personally identifiable information is defined;
- an inventory of all systems, applications, and projects that process personally identifiable information is established;
- an inventory of all systems, applications, and projects that process personally identifiable information is maintained;
- an inventory of all systems, applications, and projects that process personally identifiable information is updated <PM-05(01)_ODP frequency>.
Examine
[SELECT FROM: Procedures addressing system inventory development, maintenance, and updates; OMB FISMA reporting guidance; privacy program plan; information security program plan; personally identifiable information processing policy; system inventory; personally identifiable information inventory; data mapping documentation; other relevant documents or records].
Interview
[SELECT FROM: Organizational personnel with privacy program planning and plan implementation responsibilities; organizational personnel responsible for developing and maintaining the system inventory; organizational personnel with information security and privacy responsibilities].
Test
[SELECT FROM: Organizational processes for system inventory development, maintenance, and updates; mechanisms supporting the system inventory].
Overlays
STIGs & CCIs
No STIG checks or CCI mappings are currently loaded for PM-5(1). This section is architected to display, per product: STIG ID, Finding ID, Severity, Title, Description, Check, Fix, CCI, and NIST control mapping — but nothing is populated here until a real DISA STIG/CCI dataset is ingested.
Learn more about STIG/CCI integration →Evidence
Categorized from the SP 800-53A "Examine"/"Test" artifact list above by keyword — not an authoritative NIST evidence list.
Policy
- privacy program plan
- information security program plan
- personally identifiable information processing policy
Configuration
- Procedures addressing system inventory development, maintenance, and updates
- system inventory
- personally identifiable information inventory
Testing
- Organizational processes for system inventory development, maintenance, and updates
- mechanisms supporting the system inventory
Other Records
- OMB FISMA reporting guidance
- data mapping documentation
- other relevant documents or records