PM-5(1): Inventory of Personally Identifiable Information

PM-5(1) requires you to maintain a living inventory of every system, application, and project that processes personally identifiable information (PII), and to keep it current as your environment changes. To operationalize it fast, define what counts as PII for your organization, identify all PII processing locations (including third parties), assign owners, and run a recurring update workflow tied to change management and procurement.

Key takeaways:

• Your “PII inventory” must cover systems, applications, and projects, not just databases or data stores.
• “Maintain and update” is the operational trap: you need a repeatable mechanism tied to onboarding, changes, and decommissioning.
• Audit readiness depends on evidence: ownership, update logs, data flow references, and change triggers mapped to the inventory.

The pm-5(1): inventory of personally identifiable information requirement is an accountability control. It forces you to answer a basic question on demand: “Where do we process PII today?” If you cannot answer quickly and defensibly, you will struggle with incident response scoping, privacy impact assessments, retention and deletion, third-party due diligence, and system authorization activities.

PM-5(1) is frequently misunderstood as a one-time spreadsheet exercise. Assessors and internal audit teams usually look for operational hooks: how new SaaS tools get captured, how engineering projects get captured before launch, how M&A inherits systems into the inventory, and how decommissioned apps leave the inventory. The “inventory” is also expected to be complete across the lifecycle (planned, in development, production, and end-of-life), not just what’s currently in production.

This page gives requirement-level implementation guidance you can put into motion immediately: scope, roles, step-by-step build, recurring governance, and the evidence set you should retain. It is written for a Compliance Officer, CCO, or GRC lead driving execution across IT, security, privacy, engineering, and procurement.

Regulatory text

Requirement (PM-5(1)): “Establish, maintain, and update … an inventory of all systems, applications, and projects that process personally identifiable information.” ¹

Operator interpretation: you must (1) create the inventory, (2) keep it current through defined triggers and ownership, and (3) ensure it covers all PII-processing work, including internal tools, SaaS, custom apps, batch jobs, analytics pipelines, and in-flight projects. The control is part of NIST SP 800-53 Rev. 5 ².

Plain-English interpretation (what the requirement really demands)

You need a single, authoritative register that lists every place PII is processed, plus enough descriptive detail that a reviewer can validate completeness and you can use it during real operations (incidents, audits, privacy reviews, vendor intake). “Process” should be read broadly: collection, creation, access, transformation, transmission, storage, sharing, and deletion workflows.

A defensible PM-5(1) inventory has three properties:

1. Coverage: all systems, applications, and projects that touch PII.
2. Currency: a defined update mechanism that tracks change.
3. Accountability: named owners responsible for accuracy.

Who it applies to (entity and operational context)

PM-5(1) is relevant anywhere you implement NIST SP 800-53 Rev. 5, including:

• Federal information systems and agencies aligning to NIST SP 800-53 ².
• Contractors handling federal data (for example, supporting federal programs or operating systems subject to NIST-aligned controls) ².

Operationally, this lands with teams that introduce or change PII processing:

• Security/GRC (control ownership, audit readiness)
• Privacy office (PII definitions, impact analysis alignment)
• Enterprise architecture / IT ops (system registry)
• Engineering / product (projects, SDLC gates)
• Procurement / third-party risk (SaaS and service providers)
• Data/analytics (pipelines, warehouses, BI tools)

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

1) Set scope rules you can enforce

Define and publish:

• PII definition used internally (align to your privacy program and contracts).
• “System, application, project” boundary rules (examples: a “project” includes a new feature that adds PII fields; a “system” includes a managed SaaS platform; a “pipeline” counts if it transforms or transmits PII).
• Authoritative inventory location (GRC tool, CMDB with privacy attributes, or a dedicated inventory register). Pick one system of record and point everything to it.

Practical decision: if you already run a CMDB, add PII attributes there and treat the CMDB as the system of record. If your CMDB is incomplete, put the inventory in your GRC system and reconcile to the CMDB over time.

2) Design the minimum required inventory schema

Keep it tight, but operationally useful. Recommended fields:

• Asset identifier (system/app/project name + unique ID)
• Environment/status (planned, in development, production, decommissioning)
• Business owner and technical owner
• PII categories processed (free text plus tags)
• Processing purpose (why the PII is used)
• Data subjects (employees, customers, citizens, etc.)
• Data sources and sinks (upstream/downstream integrations)
• Third parties involved (processors/sub-processors, hosting, support access)
• Data residency/hosting model (on-prem, cloud, SaaS)
• Link to system documentation (architecture diagram, data flow, DPIA/PIA if applicable)
• Last reviewed date + review owner
• Change trigger reference (ticket/PR/procurement request)

This schema supports “establish” and “maintain” without turning into an unworkable catalog.

3) Build the initial inventory (fast, then refine)

Use multiple discovery inputs; no single source is complete:

• Procurement/AP: list SaaS and service providers; flag those that store or access PII.
• SSO/IdP directory: identify apps with broad access and likely PII exposure.
• Cloud account inventory: enumerate managed databases, storage buckets, analytics services, and key apps.
• Code repos and CI/CD: search for services that handle user profiles, identity, HR data, or logs containing identifiers.
• Data warehouse and BI: list datasets with PII columns; map them back to producing systems.
• Privacy intake artifacts: existing PIAs/DPIAs and records of processing, if you have them.

Operational tip: start by inventorying “systems and apps,” then add “projects” by embedding a capture step in your SDLC intake (next step).

4) Assign accountable owners and an update workflow

PM-5(1) fails most often on “update.” Fix that by defining:

• Control owner: typically GRC or privacy engineering.
• Record owners: business owner for accuracy of purpose and category; technical owner for integrations and hosting.
• Update triggers: procurement of a new third party, creation of a new system, change in data schema, new integration, production go-live, and decommissioning.

Make updates unavoidable:

• Add an inventory check to the change management template: “Does this change introduce or modify PII processing? If yes, update the PII inventory record.”
• Add an inventory record requirement to procurement: no purchase order or contract signature without confirming whether the third party processes PII and linking the inventory entry.
• Add a release gate in SDLC: a project cannot ship if it processes PII and has no inventory entry.

5) Operationalize “maintain and update” with recurring review

Run a recurring attestation:

• Record owners confirm whether their entry is still accurate.
• GRC/privacy reconciles discrepancies found through procurement and system inventories.
• Decommissioned assets are archived with end dates (do not delete the record; keep lifecycle history for audits and incident forensics).

If you use Daydream to manage control mappings and evidence, map PM-5(1) to an owner, a procedure, and recurring evidence artifacts so the update cycle produces assessor-ready proof without rebuilding the story each audit.

Required evidence and artifacts to retain

Auditors usually want evidence of both design and operation. Retain:

• PII inventory export (current snapshot) showing all systems/apps/projects in scope.
• Inventory procedure describing scope rules, required fields, owners, and update triggers.
• RACI or ownership list for inventory records.
• Change management samples showing inventory updates tied to tickets/approvals.
• Procurement/TPRM samples showing intake questions and resulting inventory updates for third parties that process PII.
• Review/attestation logs showing records were periodically confirmed and corrected.
• Exception records for legacy systems where data mapping is incomplete, with a remediation plan.

Common exam/audit questions and hangups

Expect these:

• “Show me how you know this inventory is complete.” (They want your discovery sources and reconciliation method.)
• “How do new SaaS tools get added?” (They want a procurement trigger, not an annual survey.)
• “Where are projects captured before launch?” (They want SDLC intake tied to the inventory.)
• “Who is accountable for accuracy?” (They want named owners, not a shared mailbox.)
• “How do you track PII flowing to third parties?” (They want explicit entries, not implied contract language.)

Frequent implementation mistakes (and how to avoid them)

• Mistake: inventorying only databases. Fix: inventory systems/apps/projects, then link to data stores as supporting detail.
• Mistake: treating the inventory as a privacy-only artifact. Fix: connect it to IT change, procurement, and engineering gates.
• Mistake: no lifecycle states. Fix: include planned/in-dev/production/decommissioning; auditors look for “projects,” not only production tools.
• Mistake: no evidence of updates. Fix: preserve change tickets, attestations, and revision history. A static spreadsheet with no history reads as non-operational.
• Mistake: ignoring third parties. Fix: add “third parties involved” as a required field and enforce it at intake.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this control, so this page does not cite specific actions. Practically, a weak PM-5(1) position increases operational risk: incident scope takes longer, notification decisions become guesswork, and third-party exposure is harder to bound. For federal and federal-adjacent environments, assessors commonly treat inventory gaps as program-level control failures because they undermine multiple downstream controls ².

Practical 30/60/90-day execution plan

First 30 days: stand up the register and get to “usable”

• Name a control owner and approve the inventory schema.
• Pick the system of record and implement basic access controls.
• Build an initial population from procurement + SSO + CMDB/cloud inventory.
• Define the update triggers and add them to change management and procurement intake.

Days 31–60: make it hard to bypass

• Add an SDLC intake question and release gate for PII-processing projects.
• Require third-party identification and linkage for any PII-processing system.
• Run a working session with engineering, IT, and privacy to close obvious gaps (shadow IT, analytics tooling, support platforms).

Days 61–90: prove it operates and produce audit-ready evidence

• Run an owner attestation cycle and capture the logs.
• Sample recent changes and verify the inventory updated correctly.
• Document exceptions and create a remediation backlog.
• Map PM-5(1) in Daydream (or your GRC system) to the owner, procedure, and recurring evidence outputs so audits become evidence retrieval, not archaeology.

Frequently Asked Questions

What counts as a “project” under PM-5(1)?

Treat any initiative that introduces or materially changes PII processing as a project, even if it ships inside an existing app. The safe test is: if it adds PII fields, new PII flows, or a new purpose, it needs an entry or an update.

Do we need to inventory logs and telemetry that include identifiers?

Yes if the logs contain PII and your systems process them for support, security monitoring, or analytics. Capture the logging/monitoring platform as a PII-processing system and describe what identifiers it receives.

Can we satisfy PM-5(1) with a CMDB alone?

Yes if the CMDB actually covers your full application portfolio and you add PII-processing attributes, owners, and update history. If the CMDB is incomplete, use a GRC-managed inventory and reconcile to the CMDB over time.

How do we handle third parties that access PII for support but don’t “store” it?

Include them. “Process” includes access, transmission, and troubleshooting workflows; add the third party to the system’s record and note the access path (support portal, remote access, ticket attachments).

How detailed does the inventory need to be to pass an audit?

Detailed enough to demonstrate completeness and currency: clear system boundaries, named owners, PII categories, and proof of updates tied to change/procurement. If you can’t use it to scope an incident quickly, it’s usually not detailed enough.

Who should own PM-5(1): privacy or security?

Put control ownership in GRC/security for audit accountability, and assign record-level accountability to business and technical owners. Privacy should define PII categories and review high-risk processing, but you still need operational hooks in IT and engineering.

Footnotes

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

2. NIST SP 800-53 Rev. 5