PM-15: Security and Privacy Groups and Associations

PM-15 requires you to formally establish, maintain, and prove ongoing contact with selected security and privacy groups or associations, so your program consistently receives timely threat, vulnerability, and privacy practice information. Operationalize it by naming an owner, selecting relevant groups, documenting engagement methods, and retaining evidence of participation and intake into your risk and control processes. ¹

Key takeaways:

• Assign a control owner and define which external security/privacy communities you will participate in, and why. ¹
• Turn “contact” into an operating rhythm: subscriptions, meetings, working groups, and a documented intake workflow into risk management. ¹
• Auditors look for evidence of institutionalization, not heroics; keep repeatable artifacts that show continuous engagement and action. ¹

The pm-15: security and privacy groups and associations requirement is a program management control from NIST SP 800-53 Rev. 5 that focuses on external engagement. It is easy to “do” informally (people read newsletters, attend a conference, join a Slack), but hard to pass in an assessment if you cannot show it is deliberate, sustained, and connected to your actual security and privacy operations.

For a Compliance Officer, CCO, or GRC lead, PM-15 is about institutional knowledge flow: you choose credible communities, establish formal contact paths, and prove that information from those sources reaches the right internal owners. This is not a PR exercise. It is a risk-reduction control that improves your ability to detect emerging issues, align with peer practices, and react to changes that affect your control environment.

If you need to operationalize PM-15 quickly, treat it like any other control: define scope, pick owners, document procedures, set an evidence cadence, and map outputs to downstream processes (risk register updates, vulnerability management, incident response, privacy reviews, or control updates). ²

Regulatory text

Control requirement (excerpt): “Establish and institutionalize contact with selected groups and associations within the security and privacy communities:” ¹

Operator interpretation of the text

• “Establish contact” means you have identified specific external groups and have a defined way to receive and exchange information (membership, mailing lists, ISAC participation, standards committees, professional associations, user groups, threat intel communities, or similar). ¹
• “Institutionalize” means it is not dependent on one person’s personal interest. You document ownership, cover absences/turnover, set expectations for participation, and retain evidence that the contact continues over time. ¹
• “Selected groups and associations” means you decide what is relevant to your mission, sector, and data types. Selection should be explainable in one sentence per group (e.g., “financial services threat sharing,” “cloud security benchmarks,” “privacy engineering practices”). ¹

Plain-English interpretation (what PM-15 is really asking)

You must be able to answer, with proof: “Which security and privacy communities do we stay connected to, how do we participate, and how do we bring what we learn back into our security and privacy program?” ¹

The assessment focus is usually not the prestige of the groups you join. It is whether:

• your engagement is intentional and repeatable,
• it covers both security and privacy (as applicable),
• and it produces actionable internal outcomes (tickets, risk entries, policy updates, training updates, control changes). ²

Who it applies to

PM-15 applies broadly where NIST SP 800-53 is used, including:

• Federal information systems, and
• contractor systems handling federal data (for example, environments where 800-53 controls are contractually flowed down). ¹

Operationally, PM-15 is most relevant when you:

• handle sensitive data that drives threat targeting or privacy obligations,
• rely on third parties (cloud, SaaS, MSPs) where ecosystem risk changes quickly,
• need early warning for vulnerabilities, sector threats, or privacy practice shifts,
• operate under ATO/FedRAMP-like expectations where evidence and repeatability matter. ²

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

Use this as a requirement-level implementation procedure.

1) Assign a control owner and define scope

• Control owner: typically Security Program, GRC, or Privacy Program leadership. Name a primary and a backup.
• Scope statement: list which parts of the organization the contact program covers (enterprise-wide vs. a specific system boundary).
  Artifact: “PM-15 Control Implementation Statement” with owner, scope, and review cadence. ¹

2) Select groups and associations with documented rationale

Create a short, reviewable register of chosen communities. Cover both:

• Security communities (threat sharing, vulnerability advisories, security engineering), and
• Privacy communities (privacy engineering, privacy governance, data protection practices), as applicable to your environment. ¹

Selection criteria you can defend in an exam:

• relevance to your sector/mission and technologies,
• quality and timeliness of information,
• ability to participate (not just read),
• legal/contract constraints on sharing information (handled via your legal review process).

Artifact: “External Communities Register” with: group name, purpose, membership type, participation method, internal owner, and expected outputs.

3) Define “contact methods” that are durable

A common audit failure is “we’re members” without defined mechanisms. Specify at least one method per group, such as:

• monitored mailing lists and advisories,
• attendance at recurring meetings,
• participation in working groups,
• formal liaison relationship (named contact at the association),
• shared portals where alerts and guidance are posted. ¹

Artifact: “PM-15 Contact Plan” that ties each group to a channel and monitoring responsibility.

4) Build an intake workflow from external info to internal action

Institutionalized contact must feed your program. Define:

• intake (who monitors; where items land),
• triage (who decides relevance),
• action routing (where it goes next: vulnerability management, risk register, privacy impact review, architecture review, policy update),
• closure (how you record what happened). ²

Practical pattern: a lightweight “External Advisory Intake” ticket type in your GRC, ITSM, or risk tool, with required fields: source, summary, affected assets, owner, disposition, linked evidence.

5) Set an operating rhythm and continuity plan

Auditors interpret “institutionalized” as repeatable operations:

• calendar recurring participation (meetings, calls, community briefings),
• define coverage for PTO and turnover,
• store credentials and subscription access in an enterprise-managed system (not personal email). ¹

6) Produce recurring evidence without creating busywork

Design evidence that is naturally produced:

• meeting notes or attendance records,
• copies of advisories received (or system logs showing receipt),
• internal communications summarizing key takeaways,
• tickets created from external items and their outcomes,
• periodic management review of the register and engagement outcomes. ¹

Where Daydream fits: Daydream can track the PM-15 control owner, implementation procedure, and recurring evidence artifacts in one place, so the requirement remains “institutionalized” even when staff rotates. ¹

Required evidence and artifacts to retain (assessment-ready list)

Keep artifacts that show design and operation:

Design evidence

• PM-15 Control Implementation Statement (owner, scope, roles)
• External Communities Register (selected groups + rationale)
• PM-15 Contact Plan (channels, monitoring responsibilities)
• External Advisory Intake procedure (workflow + routing)

Operational evidence

• membership confirmations or account records (where applicable)
• distribution list subscriptions and monitored inbox ownership
• meeting invites, attendance logs, or agendas
• notes/minutes showing material discussed
• intake tickets and dispositions tied to external sources
• risk register entries or control changes linked to external advisories ¹

Common exam/audit questions and hangups

Assessors commonly probe:

• “Which groups are you in, and why those?” Expect to justify relevance. ¹
• “Who owns PM-15 and how do you ensure continuity?” Personal memberships raise flags.
• “Show me the last few items you received and what you did with them.” They want a chain from external signal to internal action. ²
• “How do you cover privacy communities, not just security?” For many programs, privacy is the gap. ¹
• “How do you manage information-sharing constraints?” You need a rule of engagement, even if simple, aligned with your legal/privacy guardrails.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Relying on one security engineer’s personal network	Not institutionalized; no continuity	Make subscriptions and memberships enterprise-owned; document primary and backup owners. 1
Picking groups without rationale	Looks arbitrary; hard to defend in exams	Add a one-line “relevance” statement per group tied to your tech stack, sector, or data.
No intake workflow	You receive info but can’t prove impact	Create an intake ticket type and require disposition. 2
Security-only implementation	Misses privacy community engagement	Add at least one privacy-focused association and show outputs into privacy governance. 1
Evidence sprawl	Hard to produce during audits	Centralize evidence pointers (register + links) and standardize artifacts.

Risk implications (why operators care)

If you cannot demonstrate PM-15, the program risk is predictable:

• slower awareness of relevant vulnerabilities and exploit trends,
• missed peer learnings about effective controls and privacy practices,
• reduced ability to show “reasonable” program management maturity in assessments. ²

In practice, PM-15 also reduces operational friction. Teams stop debating “where did this guidance come from?” because you can point to the community source and the documented intake decision.

Practical execution plan (30/60/90-day)

Use this phased plan as a rollout playbook. Treat day counts as planning buckets, not guarantees.

First 30 days (stand up the control)

• Name owner and backup; write the PM-15 implementation statement. ¹
• Build the External Communities Register with an initial set of security and privacy groups.
• Decide contact methods (mailing lists, meetings, portals) and make access enterprise-managed.
• Define the intake workflow and where evidence will be stored.

Days 31–60 (start producing operational evidence)

• Begin monitoring and participation; capture meeting notes and advisories.
• Run intake-to-action on real items: create tickets, route owners, record disposition.
• Hold a short internal review with Security and Privacy leads to confirm the register matches current risks and systems. ²

Days 61–90 (institutionalize and audit-proof)

• Add continuity steps (coverage for absence, onboarding checklist for new owners).
• Standardize evidence capture (templates for notes, ticket fields, storage locations).
• Perform a mini “mock audit” walkthrough: show selection rationale, last items received, and resulting actions.
• If you use Daydream, map PM-15 to the control owner, procedure, and recurring evidence artifacts so the control stays operable and easy to evidence. ¹

Frequently Asked Questions

What counts as a “group or association” for PM-15?

PM-15 is flexible: it can be an industry association, threat-sharing community, professional society, standards working group, or other security/privacy community you can credibly engage with. Your job is to document selection and prove ongoing contact. ¹

Do we need both security and privacy groups?

The control text explicitly references “security and privacy communities,” so your register should address both where privacy is in scope for your system and organization. If privacy is not applicable to the system boundary, document that scoping decision. ¹

Is subscribing to newsletters enough?

Subscriptions can be part of “contact,” but auditors typically expect a stronger sign of institutionalization, such as assigned monitoring, recorded intake decisions, and evidence that information drove internal action. ²

How do we prove “institutionalized” without creating busywork?

Use artifacts you already produce: meeting invites, distribution list ownership, advisories received, and tickets created from external items. Standardize storage and keep a register that links to evidence rather than copying everything. ¹

What if Legal restricts information sharing with outside groups?

You can still meet PM-15 by receiving information and participating within constraints. Document rules of engagement, permitted sharing, and any approval steps so participation does not create privacy or confidentiality issues. ²

How should we handle third parties in PM-15?

Treat third-party ecosystems as a driver for selection. If critical third parties create concentrated risk (cloud, MSP, SaaS), include communities that publish relevant advisories and practice guidance for those technologies, then route intake items to third-party risk processes when appropriate. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5