PL-5: Privacy Impact Assessment

To meet the pl-5: privacy impact assessment requirement, you must run and document a Privacy Impact Assessment (PIA) for systems and projects that process personal data, then keep it current as the system, data, or uses change. Operationally, that means a repeatable trigger-based workflow, defined ownership, and retained evidence that privacy risks were identified, mitigations were selected, and approvals were captured ¹.

Key takeaways:

• Treat PL-5 as a gated intake: high-risk personal data use cases cannot ship without a completed PIA.
• Define triggers and scope rules so PIAs happen consistently (new systems, major changes, new data types, new sharing).
• Keep audit-ready artifacts: the PIA record, data flows, risk decisions, approvals, and follow-up remediation tracking ¹.

PL-5 sits in the Planning (PL) family in NIST SP 800-53 and is assessed like other “paper-to-practice” controls: assessors expect you to show a living process, not a one-time template. A workable PL-5 implementation connects privacy analysis to how work actually gets done, such as product launches, system changes, new integrations, third-party onboarding, and analytics initiatives.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to operationalize PL-5 as a set of decisions made at the right time: (1) determine whether a PIA is required, (2) identify privacy risks and impacts, (3) select controls and mitigations, (4) document approvals and residual risk acceptance, and (5) track actions to completion. This page gives you requirement-level guidance you can implement immediately: who owns it, what steps to run, what evidence to retain, and where audits tend to get stuck. It is written to support assessment readiness against NIST SP 800-53 Rev. 5 ².

Regulatory text

Regulatory excerpt: “NIST SP 800-53 control PL-5.” ²

Operator interpretation: PL-5 requires you to perform and document a Privacy Impact Assessment for relevant systems and/or projects and to use the output to drive privacy risk decisions. In practice, assessors look for: a defined PIA procedure, consistent triggering, documented results, and evidence that identified actions were completed or risk was accepted by an authorized owner ¹.

Plain-English interpretation (what PL-5 expects)

A PIA is your structured way to answer: What personal data is involved, how does it move, what could go wrong for individuals, what controls reduce that risk, and who approved the remaining risk? PL-5 is satisfied when you can show PIAs are:

• Performed when required (not optional or ad hoc).
• Complete enough to be decision-grade (data, purpose, sharing, retention, security/privacy controls).
• Connected to remediation (findings create tracked work).
• Kept current when material changes happen ¹.

Who it applies to

Entity scope

PL-5 is most directly applicable to:

• Federal information systems
• Contractor systems handling federal data ²

Operational scope (where PIAs must show up)

Apply the PL-5 PIA workflow to:

• New systems that collect, use, store, share, or delete personal data.
• Major changes to an existing system (new features, new analytics, new data sources, new user populations).
• New third parties that receive or process personal data on your behalf (tie-in to third-party due diligence and contract reviews).
• Changes in purpose (e.g., support data later used for marketing, ML training, fraud models).
• Data retention or deletion model changes (new archives, backups, legal holds).

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

Use this as a build sheet for operationalizing the pl-5: privacy impact assessment requirement.

1) Assign ownership and define decision rights

• Name a PIA process owner (often Privacy Officer, GRC, or Security Risk).
• Define required approvers: privacy, security, legal (as needed), and the business/system owner who can accept residual risk.
• Define escalation: what happens if a team disagrees with findings or wants an exception ¹.

Practical tip: If decision rights are unclear, PIAs become “documentation exercises” with no outcomes. Put the risk acceptance authority in writing.

2) Define PIA triggers and intake questions (make it hard to skip)

Create explicit triggers that route work into the PIA workflow:

• New or materially changed processing of personal data.
• New data sharing with third parties.
• New monitoring/telemetry that can identify or profile users.
• New uses of sensitive categories (even if permitted).

Implement a short intake form that asks:

• What personal data is processed?
• Purpose and lawful/business basis (as applicable to your governance model).
• Data sources, recipients, and transfers.
• Retention, deletion, and access model.
• High-level architecture / data flow diagram availability.

3) Standardize the PIA content (minimum required sections)

A “passable” PIA record should include:

• System/project description and owner.
• Data inventory at a usable level (data elements or categories).
• Data flows (collection → storage → use → sharing → deletion).
• Third parties and disclosures (who receives data and why).
• Risk analysis: likely privacy harms/impacts and misuse scenarios.
• Existing and planned controls (technical + process).
• Residual risk statement and acceptance/approval.
• Action items with owners and due dates ¹.

Keep it operator-grade: avoid long narrative. Use tables: dataset, purpose, access roles, retention, sharing, risk, control, owner.

4) Integrate PIA into delivery pipelines (so it runs on time)

Pick at least one “hard gate” integration point:

• Change management: “No production change approval for scoped changes without a PIA ID.”
• SDLC: privacy review checkpoint in design review.
• Third-party onboarding: PIA required before data is shared externally.
• Procurement/contracting: tie PIA outcomes to contract clauses, DPAs, security addenda.

5) Track mitigations to closure (control operation, not paperwork)

Convert PIA findings into trackable work:

• Security/privacy requirements in backlog (tickets).
• Contract actions for third parties (SLA, audit rights, subprocessor controls).
• Data minimization: remove fields, reduce collection frequency, restrict log content.
• Access controls: role-based access, break-glass, periodic reviews.
• Retention/deletion: retention schedule updates, deletion automation.

Maintain a simple status view: Open / In progress / Implemented / Risk accepted.

6) Set a refresh model (trigger-based plus periodic hygiene)

Auditors often ask: “How do you know PIAs remain accurate?” Your answer should be:

• Trigger-based refresh on material change (new data, new purpose, new third party, new integration).
• Periodic review on a defined schedule set by your risk appetite (this is your policy choice).

7) Make it assessable: map PL-5 to owner, procedure, and evidence

Document the PL-5 control implementation in your control library:

• Control statement (what you do).
• Control owner.
• Procedure/SOP link.
• Evidence list and frequency. This matches the recommended implementation approach in the provided backend guidance ².

Where Daydream fits naturally: Daydream can serve as the system of record for PL-5 by mapping the control to an owner, embedding the PIA workflow, and producing recurring evidence exports for assessors without rebuilding spreadsheets each cycle.

Required evidence and artifacts to retain

Keep evidence that proves design and operation:

Core artifacts

• PIA policy/standard and PIA procedure (SOP).
• PIA template (approved version) and completed PIAs.
• Data flow diagrams or architecture notes referenced by PIAs.
• Risk register entries created/updated from PIAs.
• Records of approvals and residual risk acceptance.
• Remediation tickets and closure evidence (screenshots, configs, PRs, contract addenda).
• Exception records (if PIA waived) with rationale and approval.

Evidence quality checks assessors use

• Traceability: PIA links to system ID, change request, third party record, and deployment artifact.
• Completeness: each required PIA section filled, not “TBD.”
• Timeliness: PIA dated before go-live for new high-risk processing.

Common exam/audit questions and hangups

Expect questions like:

• “Show me your last PIA for a system that processes personal data. How did you decide it was in scope?”
• “What are your PIA triggers? Where are they enforced in change management?”
• “How do you track PIA findings to completion?”
• “Who can accept privacy risk? Show the approval.”
• “How do PIAs cover third parties and onward sharing?” ¹

Hangups that slow audits:

• PIAs exist but are not connected to ticketing or change approvals.
• Data flows are missing or inconsistent with architecture diagrams.
• “One-and-done” PIAs with no refresh logic after major system changes.

Frequent implementation mistakes (and how to avoid them)

1. PIA template without triggers

• Fix: publish explicit triggers and embed them in intake forms and change workflows.

2. Risk statements that don’t drive action

• Fix: require each “high” finding to map to a mitigation plan or formal risk acceptance.

3. No third-party coverage

• Fix: add a dedicated PIA section for third parties: data shared, purpose, contract controls, subprocessing.

4. No evidence of operation

• Fix: keep a PIA log (system, date, trigger, approver) and export it for audits.

5. Over-scoping everything

• Fix: define a triage step. Not every minor UI change needs a full PIA, but privacy-significant changes do.

Risk implications (why PL-5 fails in practice)

PL-5 gaps usually show up as preventable surprises:

• A third party receives more data than expected.
• Logs contain personal data and get copied to analytics tools.
• A new feature changes purpose (support → marketing) without governance review.
• Retention expands quietly via backups or data lakes.

Even without a cited enforcement case in the provided sources, these are the kinds of breakdowns that create regulator and customer scrutiny because you cannot show prior assessment, decisioning, and mitigation evidence ¹.

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable PIA program)

• Assign PL-5 owner, approvers, and risk acceptance authority.
• Publish PIA triggers and a short intake form.
• Approve a PIA template with required sections and evidence expectations.
• Create a central PIA register (even a controlled spreadsheet is acceptable at first).
• Pilot PIAs on a small set of in-flight initiatives with personal data ¹.

Days 31–60 (connect PIAs to operational workflows)

• Integrate PIA gating into change management and/or SDLC design review.
• Add a third-party PIA checkpoint before external data sharing.
• Define how findings become tickets and how closure is validated.
• Train product, engineering, procurement, and security reviewers on “what good looks like.”

Days 61–90 (make it audit-ready and repeatable)

• Run a backlog cleanup: identify systems with personal data that never had a PIA, then schedule PIAs.
• Implement refresh rules for material changes and document them.
• Test the audit packet: pick one PIA and assemble the full evidence chain within a single folder/export.
• Move the workflow into a system of record (Daydream or your GRC tool) so evidence is consistent across cycles ².

Frequently Asked Questions

What counts as a “Privacy Impact Assessment” for PL-5?

A PIA is a documented assessment that identifies personal data processing, maps data flows, evaluates privacy risks to individuals, and records mitigations and approvals. For PL-5, it must be repeatable and tied to real decisions and follow-up actions ¹.

Do we need a PIA for every system change?

No. Define “material change” triggers so low-risk updates do not create noise. Require a PIA when the change introduces new personal data, new purposes, new sharing, or other privacy-significant shifts.

How should PIAs address third parties?

Include a dedicated section for third parties that receive or process personal data: what data, for what purpose, what contract controls apply, and whether subprocessing is allowed. Tie this back to your third-party due diligence and contracting workflow.

Who should approve a PIA?

The system or business owner should approve residual risk because they own the outcome, with privacy and security providing review and requirements. Document the approval in a way you can produce during an assessment ¹.

What evidence is most persuasive in an audit?

A completed PIA linked to a change request or project ticket, a data flow diagram, a list of findings with tracked remediation, and the final approval/risk acceptance record. Auditors want traceability from assessment to action ¹.

Can we implement PL-5 inside our GRC tool, or do we need a separate privacy tool?

Either works if you can prove consistent triggering, completion, approvals, and remediation tracking. Many teams centralize PL-5 in their GRC system of record (including Daydream) to simplify evidence collection and control mapping ².

Footnotes

1. NIST SP 800-53 Rev. 5

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