PE-19: Information Leakage

To meet the pe-19: information leakage requirement, you must identify where your systems could leak data through electromagnetic (EM) emanations and implement physical and technical safeguards appropriate to the sensitivity of the information and the environment. Operationalize it by scoping in-scope locations/assets, setting handling rules for sensitive processing areas, and retaining evidence that protections are designed, deployed, and checked. ¹

Key takeaways:

• PE-19 is about EM emanations (not network DLP) and is owned by security plus facilities for in-scope spaces.
• Most audit failures are scoping and evidence failures: no defined zones, no asset/location mapping, no inspection records.
• Start with a risk-based decision: where is EM leakage plausible and harmful, then document and enforce controls.

PE-19 sits in the Physical and Environmental Protection family for a reason: it addresses information exposure that can occur even when your cyber controls are strong. The requirement is narrow but operationally tricky because it often spans multiple teams (security engineering, facilities, IT operations, and sometimes program leadership for high-sensitivity work). It also tends to be “invisible” during day-to-day operations until an assessor asks, “Show me what you did to prevent EM emanation leakage in your sensitive processing areas.”

For most organizations, the fastest path to implementation is not buying specialized equipment. It is building a defensible scope and decision record: which systems and spaces are in scope, what sensitivity triggers additional protections, and what controls you selected for those zones. If you handle federal data or operate federal information systems, you need your PE-19 story to be consistent across your SSP/control narrative, facilities standards, and operational checks. ²

This page gives requirement-level guidance you can execute quickly: a plain-English interpretation, applicability, step-by-step implementation, evidence to keep, common audit hangups, and a practical 30/60/90 plan.

Regulatory text

Requirement (verbatim excerpt): “Protect the system from information leakage due to electromagnetic signals emanations.” ¹

What an operator must do:
You must prevent sensitive information from being inferred or captured from electromagnetic emissions produced by systems and components during processing, display, printing, or transmission. In practice, that means:

• Define the conditions where EM leakage matters (data type/sensitivity, threat model, proximity/exposure).
• Designate processing locations and assets where additional physical/technical measures apply.
• Implement and maintain safeguards (facility controls, equipment choices, separation, shielding where warranted).
• Prove it with evidence: decisions, diagrams, standards, and recurring checks.

Plain-English interpretation

PE-19 is about “side-channel” leakage through EM emanations. If someone can sit nearby (or in an adjacent room) and capture emissions from a workstation, monitor, cable, printer, or other equipment, they may reconstruct or infer sensitive information. PE-19 requires you to reduce that risk to an acceptable level for your system.

This is not the same as data loss prevention (DLP) for email or endpoints. It is a physical security + hardware + environment control, typically implemented through a mix of zoning, equipment standards, physical separation, and (when warranted) shielding or controlled spaces.

Who it applies to

Entity scope

• Federal information systems implementing NIST SP 800-53 controls. ²
• Contractor systems handling federal data where NIST SP 800-53 is flowed down contractually or used as the baseline. ¹

Operational contexts where PE-19 becomes real

• High-sensitivity programs, regulated data rooms, secure labs, and “closed areas.”
• Offices with shared walls, public-facing spaces, co-working environments, or colocated tenants.
• Remote/field operations where equipment is used in uncontrolled environments.
• Third-party operated spaces (managed facilities, outsourced call centers, contract labs) where you still own the risk.

What you actually need to do (step-by-step)

1) Assign ownership and write a one-page control intent

Set a primary owner in security (GRC or security engineering) and a co-owner in facilities/physical security. Document:

• In-scope systems and locations
• The definition of “sensitive processing” for your organization
• The baseline safeguards you will apply
• How exceptions are approved

This becomes your PE-19 control narrative and keeps the program from turning into ad hoc conversations.

2) Scope the “where” and “what”: locations, assets, and data sensitivity

Create a simple inventory that ties together:

• Spaces: rooms/suites/floors where sensitive processing occurs
• Assets: workstations, thin clients, monitors, printers, specialized devices
• Data types: what level triggers PE-19 protections (contract-defined categories, system categorization, or internal classifications)

Output artifact: a “Sensitive Processing Area (SPA) Register” with room IDs, responsible manager, allowed functions, and associated systems.

3) Perform an EM leakage exposure assessment (practical, not academic)

You are trying to answer two questions:

• Could emissions be captured? Consider adjacency (shared walls), uncontrolled visitors, exterior windows, and proximity to public areas.
• Would captured emissions matter? Tie back to confidentiality impact and the kinds of data displayed/processed.

Keep it simple: a short assessment per SPA with a risk rating and selected safeguards. If you need a more formal method, document the rationale and inputs, but keep the outcome actionable.

4) Select safeguards using a tiered approach

Most organizations implement PE-19 with escalating tiers. Your tiers should be defined internally and tied to sensitivity and exposure. Example safeguard categories:

• Administrative: rules for where sensitive processing may occur; restrictions on moving equipment; escort requirements; signage; clean desk/clear screen practices specific to SPAs.
• Physical: controlled access to SPAs; visitor management; window coverings where appropriate; controlled placement of screens/printers away from walls and public areas.
• Technical/equipment: approved hardware configurations for SPAs; cable management standards; restrictions on wireless peripherals in SPAs when justified by your assessment.

If shielding or specialized emanation-security equipment is warranted for your highest-risk areas, treat it as an engineering project with acceptance criteria and periodic verification.

5) Write enforceable standards and make them auditable

Turn the safeguards into two enforceable documents:

• SPA Standard (what the room must have, what is prohibited, how layout must be arranged)
• SPA Operating Procedure (how people use the room, how visitors are handled, how exceptions work)

A standard that can’t be checked will fail in an audit. Include objective checks (e.g., “room access is badge-controlled,” “visitor logs are retained,” “screen placement follows the approved layout”).

6) Implement, then verify with recurring checks

Implementation is not complete until you have:

• A before/after record that controls were deployed
• A verification step (walkthrough checklist, facilities inspection, or security validation)
• A recurring cadence for re-checking SPAs and revisiting scope when rooms move or systems change

7) Extend PE-19 to third parties where applicable

If a third party processes your sensitive federal data in their facility, put PE-19 into:

• Contract/security addendum language (obligation to prevent EM leakage for defined processing zones)
• Due diligence questionnaires (ask for their zoning/controls and evidence)
• Onsite assessment steps (verify access controls, layout, and operating procedures)

Daydream can help you operationalize this by mapping PE-19 to an owner, implementation procedure, and recurring evidence artifacts, so control operation stays consistent across internal teams and third parties. ¹

Required evidence and artifacts to retain

Keep evidence that shows scope, design decisions, implementation, and operation:

1. Control narrative / SSP excerpt describing how you protect against EM emanations. ¹
2. SPA Register (rooms, owners, systems, sensitivity triggers).
3. EM leakage exposure assessments per SPA (dated, approved).
4. SPA Standard and Operating Procedure (current version + change history).
5. Physical security artifacts: access control configuration evidence for SPAs, visitor procedure, and sample logs (redacted).
6. Implementation records: photos of room layout, as-built diagrams, work orders for modifications, approved equipment lists for SPAs.
7. Recurring inspection results and remediation tracking.
8. Exception records: approvals, compensating controls, expiration dates.

Common exam/audit questions and hangups

Assessors commonly press on:

• “Show me what’s in scope.” If you can’t name the rooms/systems, you will look unprepared.
• “Why are these safeguards sufficient?” Tie your choices to the exposure assessment and data sensitivity, not preferences.
• “How do you keep it from drifting?” Expect questions about revalidation when people move, office layouts change, or new devices appear.
• “What about remote work?” If sensitive processing occurs remotely, you need defined rules (or a prohibition) and an exception process.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Treating PE-19 as endpoint DLP	Wrong control family and wrong threat	Write the control narrative around EM emanations and physical exposure. 1
No defined sensitive processing areas	You can’t prove consistent protection	Create an SPA Register and make it the source of truth.
Relying on “we’re low risk” without documentation	Audits require rationale	Document the exposure assessment and approval.
Implementing expensive measures without acceptance checks	You can’t show control operation	Define verification steps and keep inspection records.
Ignoring third-party facilities	Risk transfers but accountability doesn’t	Add PE-19 obligations to third-party requirements and validate evidence.

Enforcement context and risk implications

No public enforcement cases were provided in the available source catalog for this requirement, so this page does not cite enforcement outcomes.

Risk-wise, PE-19 gaps tend to show up as:

• Confidentiality exposure for high-sensitivity processing in poorly controlled spaces
• Assessment findings for missing scope, missing rationale, or lack of operating evidence
• Contractual noncompliance where NIST SP 800-53 controls are required for the system boundary ²

A practical 30/60/90-day execution plan

Next 30 days (stabilize scope and ownership)

• Assign control owner and facilities co-owner; define RACI for SPAs.
• Draft PE-19 control narrative aligned to your system boundary. ¹
• Build the initial SPA Register from facilities lists + system inventory.
• Run exposure assessments for the highest-sensitivity rooms first.
• Freeze “sensitive processing in non-approved spaces” via interim guidance and an exception path.

Next 60 days (implement controls and make them auditable)

• Publish SPA Standard and Operating Procedure; train SPA owners.
• Implement quick-win physical changes: access controls, signage, layout fixes, visitor process.
• Establish approved equipment rules for SPAs and a procurement/IT intake check.
• Start a recurring inspection checklist and remediation tracking.

Next 90 days (operate, evidence, and extend to third parties)

• Complete assessments and safeguards for all SPAs in scope.
• Run a mock audit: sample two SPAs and produce the full evidence package in one folder.
• Integrate PE-19 into third-party due diligence for any outsourced sensitive processing.
• Use Daydream to map PE-19 to your control owner, procedure, and recurring evidence artifacts so the control stays current as rooms and systems change. ¹

Frequently Asked Questions

Does PE-19 require TEMPEST-certified equipment or shielded rooms?

PE-19 requires protection from information leakage due to EM emanations, but it does not prescribe a single method in the excerpted text. Use a documented exposure assessment to justify whether administrative/physical measures are sufficient or whether higher-assurance engineering controls are warranted. ¹

How do we scope PE-19 if we have a hybrid workforce?

Decide whether sensitive processing is permitted outside designated areas. If you allow it, define what locations qualify and what compensating controls apply, then retain exceptions and approvals as evidence.

What evidence is most persuasive to an assessor?

A named list of sensitive processing areas, written standards for those areas, and dated inspection results that show the standards are enforced. Pair that with a clear control narrative mapped to the system boundary. ¹

Who should own PE-19: security or facilities?

Security should own the control outcome and assessment readiness, while facilities/physical security typically owns implementation for rooms and access controls. Document the shared responsibility so issues do not stall during audits.

How do we handle third parties that process our federal data onsite in their facilities?

Treat their processing areas as in-scope and require equivalent protections contractually. Request their standards, inspection evidence, and exception process, then validate during due diligence or an onsite review.

What’s the fastest way to get PE-19 audit-ready without over-engineering?

Focus on scoping, written SPA rules, and recurring checks. Daydream helps by keeping the owner, procedure, and evidence artifacts mapped in one place, so you can answer assessor requests quickly and consistently. ¹

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5