PM-18: Privacy Program Plan

PM-18 requires you to create and share an organization-wide privacy program plan that explains how your privacy program works in practice, who runs it, and how it connects to your systems, processes, and governance. Operationalize it by publishing a plan with clear ownership, scope, interfaces to security and risk functions, and a repeatable evidence trail for assessors. ¹

Key takeaways:

• A PM-18 plan is a program blueprint, not a policy; it should show governance, roles, processes, and program outputs.
• Assessors look for “developed and disseminated” plus proof the plan is current and used, not a stale document.
• The fastest path is mapping PM-18 to an owner, procedure, and recurring evidence artifacts, then running the plan through your governance cadence.

The pm-18: privacy program plan requirement is frequently underestimated because teams confuse it with a privacy policy or a notice. PM-18 is broader: it asks for an organization-wide plan that explains the privacy program’s structure and operation. That means a single, assessor-friendly document that ties together governance, roles, processes, and key privacy program activities across business units and systems. ¹

For a Compliance Officer, CCO, or GRC lead, PM-18 is less about writing prose and more about making the privacy program “auditable.” You need to show who owns the program, how decisions get made, what core processes exist (risk assessment, training, incident response interfaces, third-party privacy due diligence, monitoring), and how the organization communicates the plan to the right audiences.

Done well, the plan becomes your operational backbone for privacy: it anchors control ownership, reduces ad hoc decision-making, and gives internal audit and external assessors a reliable map of how privacy obligations are managed. Done poorly, PM-18 turns into a generic PDF that no one follows and you cannot evidence. ²

Regulatory text

Requirement (excerpt): “Develop and disseminate an organization-wide privacy program plan that provides an overview of the agency’s privacy program, and:” ¹

What the operator must do

1. Develop: Produce a written privacy program plan that is specific to your organization (or system boundary, if your governance is scoped that way) and describes how the privacy program operates. ¹
2. Disseminate: Share the plan with the audiences who need it to execute or oversee privacy work (not just file it in a repository). ¹
3. Make it organization-wide: The plan must cover the full privacy program, including cross-functional touchpoints (legal, security, product, HR, procurement, engineering, and internal audit). ¹

NIST’s text is short, but the assessment expectation is not: your plan should make it easy to trace from “privacy governance intent” to “repeatable operational processes” to “retained evidence.”

Plain-English interpretation (what PM-18 really expects)

PM-18 expects a single source of truth for “how we run privacy here.” A policy states rules. A program plan states:

• Who runs privacy (roles, committees, escalation paths)
• What the program covers (scope, systems, data types, third parties, geographies)
• How privacy work happens (processes, cadence, artifacts)
• How you prove it (evidence and reporting)

If you cannot point an assessor to a plan that connects these elements, you will struggle to defend consistency, accountability, and oversight even if teams do privacy work informally.

Who it applies to

PM-18 is commonly applied in:

• Federal information systems and agencies implementing NIST SP 800-53. ²
• Contractor systems handling federal data, where NIST-based requirements flow down through contracts or authorization frameworks. ¹

Operationally, you should treat PM-18 as applicable when:

• You operate a defined system boundary that must meet NIST controls.
• You process personal data in a way that creates privacy risk and requires formal governance.
• You rely on third parties that process personal data and need consistent program oversight.

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

Step 1: Assign an accountable owner and governance forum

• Name a control owner (often the Privacy Officer, CPO, or GRC owner for privacy controls).
• Name an approving authority (privacy steering committee, risk committee, or equivalent).
• Define RACI for core privacy processes.

Output: “PM-18 control owner + governance” section in the plan, plus a governance charter reference if one exists.

Step 2: Define scope in a way that matches how you are assessed

Write scope that matches your audit boundary:

• Organization-wide versus a specific system/program
• In-scope business units
• In-scope data types and processing contexts
• In-scope third parties (processors, sub-processors, service providers)

Operator tip: If your org has multiple systems, write one enterprise plan and add system annexes that list system-specific interfaces, owners, and artifacts.

Step 3: Document the privacy program operating model

Minimum sections that reduce audit friction:

• Program objectives and principles (brief, actionable)
• Roles and responsibilities (privacy, security, legal, engineering, procurement, HR)
• Decision workflow (who approves high-risk processing, new tools, new third parties)
• Escalation paths (incidents, complaints, regulator inquiries, exceptions)

Step 4: List your core privacy processes and their artifacts

Build a table that an auditor can test. Example structure:

Process area	What happens	Owner	Frequency/cadence	Evidence artifacts
Privacy risk assessment	Identify and track privacy risks for systems and projects	Privacy/GRC	On change + periodic review	Risk register entries, approvals
Third-party privacy due diligence	Validate third party privacy posture before onboarding	Procurement + Privacy	Per onboarding + renewals	DPIA/assessment, DPA review notes
Training and awareness	Role-based privacy training	HR + Privacy	Onboarding + refresh	LMS reports, training content
Incident interfaces	Privacy input into security incident response	Security + Privacy	Per incident	Incident tickets, post-incident review
Data handling rules	Retention, minimization, access	Data owners + Privacy	Ongoing	Standards, exceptions, access reviews

Keep it honest. If you cannot run a process yet, mark it as “planned” with a target milestone and interim controls, then track it through governance.

Step 5: Define dissemination and adoption mechanics

“Disseminate” means you can show the plan reached the people who must execute it. Practical approaches:

• Publish in your GRC or policy portal with access controls.
• Announce through a governance memo or internal comms channel.
• Train required stakeholders on “how to use the plan.”

Evidence matters more than elegance: capture screenshots, distribution lists, and acknowledgments.

Step 6: Map PM-18 to control operation and recurring evidence

The fastest way to keep PM-18 evergreen is to convert it into a control-operating rhythm:

• Control owner maintains the plan.
• Governance body reviews changes.
• Evidence is collected on a schedule tied to your audit calendar.

A clean approach is to map PM-18 to control owner, implementation procedure, and recurring evidence artifacts so you can prove ongoing operation without scrambling. ¹

If you run Daydream for third-party risk and GRC workflows, treat the PM-18 plan as the “parent” artifact that links to your third-party inventory, due diligence workflows, DPIA/PIA records, and exception handling logs. That turns PM-18 from a document into a navigable program map during assessments.

Required evidence and artifacts to retain

Retain artifacts that prove development, approval, dissemination, and ongoing use:

Core artifacts (expected in most audits)

• Privacy Program Plan (current version) with version control and effective date
• Approval record (meeting minutes, sign-off, ticket approval)
• Distribution evidence (announcement, portal publication record, required read acknowledgments)
• Ownership/RACI documentation (in the plan or referenced)
• Change log showing updates tied to organizational or system changes

Supporting artifacts (make testing easy)

• Privacy governance meeting agenda/minutes that reference plan review
• Crosswalk showing where key processes live (training, incident response, third-party due diligence)
• Evidence collection schedule or audit/test plan for privacy controls

Common exam/audit questions and hangups

Assessors tend to probe the same weak spots:

1. “Show me the plan, and show me who approved it.”
   Hangup: no formal approval trail, or approval by someone with no authority.

2. “Who received it, and how do you know they read it?”
   Hangup: “it’s in SharePoint” with no dissemination record.

3. “How does this plan connect to real workflows?”
   Hangup: the plan lists concepts but no operational procedures, owners, or artifacts.

4. “How do you keep it current?”
   Hangup: no review trigger (org change, new system, new third party type, incident lessons learned).

Frequent implementation mistakes (and how to avoid them)

Mistake 1: Writing a policy and calling it a program plan

Avoid it: Include operating model elements: governance, processes, cadence, evidence, and interfaces.

Mistake 2: Over-scoping without an implementable boundary

Avoid it: Define scope that matches your assessment boundary and operational reality. Use annexes for system-specific details.

Mistake 3: No dissemination proof

Avoid it: Treat dissemination like a control: track publication, notifications, acknowledgments, and training.

Mistake 4: No mapping to evidence

Avoid it: Maintain an evidence register for PM-18 and link it to each process area in the plan.

Risk implications (why auditors care)

PM-18 gaps create repeatable failure modes:

• Teams make inconsistent decisions about personal data because governance is unclear.
• Third-party onboarding skips privacy steps because responsibilities are not documented.
• During incidents, privacy notification and assessment steps lag because interfaces are not defined.
• Audits become “document hunts” because no evidence model exists.

PM-18 is also a forcing function: if your plan cannot name owners and outputs, your program likely relies on informal knowledge held by a few people.

Practical 30/60/90-day execution plan

First 30 days (stabilize and publish a usable v1)

• Assign control owner and approver.
• Draft plan outline with scope, governance, and a process/evidence table.
• Collect existing artifacts (policies, DPIAs/PIAs, training, incident procedures) and link them in the plan.
• Publish v1 and capture dissemination evidence.

Days 31–60 (operationalize and connect workflows)

• Build or refine RACI for each process area.
• Define review triggers and a change-log process.
• Align third-party privacy due diligence steps with procurement intake and contract review.
• Add an evidence register and assign evidence owners.

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

• Run a tabletop “assessment” against the plan: pick one project, one third party, and one incident scenario; trace required artifacts.
• Close gaps with concrete procedures (tickets, checklists, templates).
• Schedule governance reviews and document outcomes.
• Store final artifacts in a controlled repository and ensure read access matches roles.

Frequently Asked Questions

What should the PM-18 plan include that our privacy policy does not?

Your policy states rules and expectations. The PM-18 plan explains how the privacy program runs: governance, roles, processes, cadence, and what evidence you retain to prove operation. ¹

Does “disseminate” mean everyone in the company must acknowledge the plan?

Not necessarily. Disseminate means the right stakeholders can access it and you can prove distribution to roles that execute or oversee privacy work. Capture publication and notification evidence. ¹

We are a contractor handling federal data. Do we need an “agency-style” plan?

You need an organization-wide plan appropriate to your environment and contractual obligations, written so an assessor can understand how privacy governance and processes work for the system(s) in scope. ²

How do we keep the PM-18 plan current without creating bureaucracy?

Tie updates to real triggers: new systems, major product changes, new third-party processing patterns, incident lessons learned, and governance cadence. Maintain a lightweight change log and approvals.

What evidence will an auditor ask for first?

Expect requests for the current plan, approval records, dissemination proof, and a mapping from plan sections to operational artifacts (risk assessments, training records, third-party due diligence outputs). ¹

Can Daydream help with PM-18 even though it’s “just a plan”?

Yes, if you treat the plan as a hub. Daydream can track control ownership, link the plan to recurring evidence (including third-party due diligence artifacts), and keep an audit-ready record of updates and approvals.

Footnotes

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

2. NIST SP 800-53 Rev. 5