PM-18 Privacy Program Plan
a. Develop and disseminate an organization-wide privacy program plan that provides an overview of the agency’s privacy program, and:
1. Includes a description of the structure of the privacy program and the resources dedicated to the privacy program;
2. Provides an overview of the requirements for the privacy program and a description of the privacy program management controls and common controls in place or planned for meeting those requirements;
3. Includes the role of the senior agency official for privacy and the identification and assignment of roles of other privacy officials and staff and their responsibilities;
4. Describes management commitment, compliance, and the strategic goals and objectives of the privacy program;
5. Reflects coordination among organizational entities responsible for the different aspects of privacy; and
6. Is approved by a senior official with responsibility and accountability for the privacy risk being incurred to organizational operations (including mission, functions, image, and reputation), organizational assets, individuals, other organizations, and the Nation; and
b. Update the plan pm-18_odp and to address changes in federal privacy laws and policy and organizational changes and problems identified during plan implementation or privacy control assessments.
A privacy program plan is a formal document that provides an overview of an organization’s privacy program, including a description of the structure of the privacy program, the resources dedicated to the privacy program, the role of the senior agency official for privacy and other privacy officials and staff, the strategic goals and objectives of the privacy program, and the program management controls and common controls in place or planned for meeting applicable privacy requirements and managing privacy risks. Privacy program plans can be represented in single documents or compilations of documents.
The senior agency official for privacy is responsible for designating which privacy controls the organization will treat as program management, common, system-specific, and hybrid controls. Privacy program plans provide sufficient information about the privacy program management and common controls (including the specification of parameters and assignment and selection operations explicitly or by reference) to enable control implementations that are unambiguously compliant with the intent of the plans and a determination of the risk incurred if the plans are implemented as intended.
Program management controls are generally implemented at the organization level and are essential for managing the organization’s privacy program. Program management controls are distinct from common, system-specific, and hybrid controls because program management controls are independent of any particular information system. Together, the privacy plans for individual systems and the organization-wide privacy program plan provide complete coverage for the privacy controls employed within the organization.
Common controls are documented in an appendix to the organization’s privacy program plan unless the controls are included in a separate privacy plan for a system. The organization-wide privacy program plan indicates which separate privacy plans contain descriptions of privacy controls.
- PRIVACT Privacy Act (P.L. 93-579), December 1974.
- OMB A-130 Office of Management and Budget Memorandum Circular A-130, *Managing Information as a Strategic Resource* , July 2016.
Related controls 3
- PM-08 Critical Infrastructure Plan L M H P
- PM-09 Risk Management Strategy L M H P
- PM-19 Privacy Program Leadership Role L M H P