PM-19: Privacy Program Leadership Role

PM-19 requires you to formally appoint a senior privacy leader with the authority, accountability, mission, and resources to run an organization-wide privacy program and manage privacy risk. To operationalize it fast, you need a documented designation, clear decision rights, defined program responsibilities, and recurring evidence that the role actively coordinates privacy requirements across the enterprise. ¹

Key takeaways:

• Name a senior privacy official and prove they have real authority and budget to act. ¹
• Define the role’s mission, accountability, and operating cadence across business units and systems. ¹
• Build an evidence set that shows ongoing leadership, not a one-time appointment memo. ¹
• Map PM-19 to a control owner, procedures, and recurring artifacts so audits don’t hinge on oral explanations. ¹

The pm-19: privacy program leadership role requirement is easy to “check the box” on and still fail in an assessment. Assessors look for proof that your privacy leader can make decisions, coordinate across functions, and drive execution through an organization-wide privacy program, not just hold a title.

PM-19 sits in NIST SP 800-53’s Program Management (PM) family and is commonly inherited across multiple systems because it operates at the organization level. That makes it high impact in practice: if the role is weak, every system’s privacy governance can look weak. If the role is strong and well-evidenced, you reduce friction across privacy controls because there is a clear escalation path, consistent standards, and a single accountable party.

This page translates the control into requirement-level implementation steps for a Compliance Officer, CCO, or GRC lead. The goal is fast operationalization: assign ownership, define decision rights, establish repeatable governance, and retain clean evidence so your next audit does not devolve into “who owns privacy?” interviews. ²

Regulatory text

Control requirement (PM-19): “Appoint a senior agency official for privacy with the authority, mission, accountability, and resources to coordinate, develop, and implement, applicable privacy requirements and manage privacy risks through the organization-wide privacy program.” ¹

Operator translation (what you must do):

1. Appoint a senior privacy leader (named person, named role).
2. Grant authority (decision rights, escalation path, ability to require action).
3. Define mission (scope of what the role is responsible for across the organization).
4. Set accountability (what outcomes the person is answerable for and how performance is evaluated).
5. Provide resources (budget, staffing, tooling access, time allocation) to run the privacy program.
6. Demonstrate the role actively coordinates, develops, and implements privacy requirements and manages privacy risk through an organization-wide program. ¹

Plain-English interpretation of the requirement

PM-19 is a governance control: you need a single senior leader who owns privacy program outcomes and can drive action across teams (security, legal, product, HR, procurement, engineering, and operations). A privacy program that relies on informal influence is fragile. PM-19 expects formal empowerment plus repeatable operating mechanisms (committees, reporting, approvals, and issue management) that connect privacy requirements to execution. ²

Who it applies to

Entities and environments

• Federal information systems and organizations implementing NIST SP 800-53 controls. ¹
• Contractor systems handling federal data where NIST SP 800-53 is flowed down through contracts, security requirements, or assessment regimes. ¹

Operational context

• Applies organization-wide, not just to one system. Your SSPs or control narratives may inherit it, but your evidence must show real enterprise governance.
• Applies whenever you process personal data that creates privacy obligations, privacy risk, or privacy engineering needs across business lines. The control’s language is framed for agencies, but contractors frequently implement the same pattern to satisfy customer and assessment expectations. ²

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

Step 1: Assign a control owner and name the senior privacy official

• Choose the senior privacy official (common patterns: Chief Privacy Officer, SAOP-equivalent, or a senior executive with privacy charter).
• Record the appointment in a formal instrument (executive memo, board/ELT resolution, or HR role designation).
• In your GRC system, map PM-19 to a control owner, an implementation procedure, and recurring evidence artifacts so operation is provable. This mapping is explicitly recommended as a best-practice control action. ¹

Practical decision point

• If legal “owns privacy,” confirm whether they have operational control to drive engineering and security work. If not, keep legal as a key stakeholder and appoint an operational privacy leader with formal decision rights.

Step 2: Define authority, mission, and accountability in writing

Create a one-page Privacy Program Leadership Charter that includes:

• Authority: what the leader can approve/deny (privacy risk acceptance, privacy requirements, go-live gates, third party privacy terms, exception approvals).
• Mission: what the program covers (policy, training, risk management, privacy engineering requirements, incident coordination, third party oversight).
• Accountability: what the leader must deliver (program reporting, risk register ownership, governance cadence, remediation tracking).
• Resources: named staff functions, budget line (if applicable), tool access, and ability to convene cross-functional teams. ¹

Step 3: Build the operating model (how coordination happens)

Implement mechanisms that show the role “coordinates, develops, and implements” privacy requirements:

• Privacy governance forum: standing meeting with Security, Legal, Procurement/TPRM, Product/Engineering, HR, and IT.
• Intake and triage: a single route for privacy reviews (projects, systems, data sharing, third parties).
• Decision records: documented outcomes for escalations (approvals, conditions, risk acceptance, required mitigations).
• Integration points: tie privacy leadership into change management, SDLC, third party onboarding, and incident response workflows. ²

Step 4: Establish privacy risk management ownership

PM-19 explicitly calls out manage privacy risks through the organization-wide program. Implement:

• A privacy risk register owned by the senior privacy official (or delegated with documented oversight).
• A risk acceptance process with named approvers and criteria.
• A tracking mechanism for remediation actions, due dates, and closure evidence. ¹

Step 5: Operationalize evidence generation (make audits boring)

Turn PM-19 into a repeatable control with recurring outputs:

• Meeting agendas and minutes for governance sessions
• Quarterly (or other recurring) privacy program status reports to leadership
• Logs of privacy reviews (projects, third parties, data sharing)
• Documented escalations and decisions
• Staffing plan and role descriptions that show resourcing ¹

Where Daydream fits naturally Most PM-19 failures are “we do this, but it’s scattered.” Daydream helps by mapping PM-19 to the correct owner, documenting the implementation procedure, and scheduling recurring evidence collection so you can answer audits with artifacts instead of interviews. ¹

Required evidence and artifacts to retain

Use this as your PM-19 evidence checklist:

Evidence artifact	What it proves	Owner
Appointment memo / role designation	A senior privacy official is formally appointed	CCO / HR
Privacy Program Leadership Charter	Authority, mission, accountability, resources are defined	Privacy lead
Org chart + role description	Position seniority and reporting line	HR
Governance forum roster + calendar	Cross-functional coordination exists	Privacy lead
Meeting minutes / decision log	The role drives decisions and follow-through	Privacy PMO
Privacy risk register + risk acceptance records	Ongoing privacy risk management	Privacy lead
Program status reporting	Executive oversight and accountability	Privacy lead
Evidence map for PM-19 (owner, procedure, artifacts)	Audit-ready operationalization	GRC lead

Common exam/audit questions and hangups

Expect assessors to probe these areas:

• “Who is the senior privacy official, and where is the appointment documented?” Provide the memo and org chart.
• “What authority do they have?” Show documented decision rights and examples of exercised authority (decision log).
• “How do they coordinate across the org?” Produce governance cadence and stakeholder participation records.
• “What resources back the program?” Show staffing assignments, time allocation, tool access, and budget ownership where applicable.
• “How are privacy risks tracked and accepted?” Provide risk register extracts and risk acceptance approvals. ¹

Frequent implementation mistakes and how to avoid them

1. Mistake: Title without power. A privacy lead exists, but cannot block launches or require remediation.
   Fix: document decision rights, escalation path, and risk acceptance authority. ¹

2. Mistake: Program lives in policy documents only.
   Fix: keep operational artifacts: minutes, decisions, risk register, and remediation tracking.

3. Mistake: Unclear scope between Security, Legal, and Privacy.
   Fix: publish a RACI for privacy activities (reviews, incidents, third party terms, training ownership) and align it to the charter.

4. Mistake: No resourcing proof.
   Fix: retain role descriptions, staffing plan, and evidence of assigned responsibilities.

5. Mistake: Evidence is ad hoc per audit.
   Fix: set up a recurring evidence calendar; store artifacts centrally; map PM-19 to owner, procedure, and recurring evidence (a recommended control action). ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not list enforcement examples.

Operationally, PM-19 failures create second-order risk: inconsistent privacy decisions across products and systems, delays during ATO or customer assessments, and weak accountability during privacy incidents. Assessors often treat weak governance as a program-level deficiency because it undermines many downstream privacy and security controls. ²

A practical 30/60/90-day execution plan

First 30 days (Immediate)

• Appoint the senior privacy official in writing and publish reporting line.
• Draft the Privacy Program Leadership Charter (authority, mission, accountability, resources).
• Create the PM-19 control record in your GRC system: control owner, implementation procedure, recurring evidence list. ¹

By 60 days (Near-term)

• Stand up the privacy governance forum; confirm cross-functional membership.
• Implement privacy intake and decision logging for projects and third parties.
• Start the privacy risk register and define risk acceptance/exception workflow. ¹

By 90 days (Stabilize operations)

• Produce the first privacy program status report for executive leadership.
• Run at least one full governance cycle: intake → review → decision → remediation tracking.
• Validate evidence quality by doing a mini “audit packet” for PM-19 (appointment, charter, meeting records, risk register extracts, decisions). ¹

Frequently Asked Questions

Can our CISO serve as the PM-19 senior privacy official?

Yes if the person has explicit privacy mission, accountability, and resources documented, and they actively coordinate privacy requirements across the organization. If privacy decisions routinely conflict with security priorities, separate roles with defined escalation can reduce bias. ¹

What’s the minimum documentation an auditor will accept for PM-19?

A formal appointment record plus a charter showing authority, mission, accountability, and resources. Add operational artifacts (meeting minutes, decision logs, risk register) to prove the role functions beyond a paper designation. ¹

How do we prove “resources” if we don’t have a dedicated privacy budget?

Show documented staff allocations, assigned responsibilities, and tool access (ticketing, GRC, reporting) that enable execution. Assessors generally want evidence the leader can get work done, not a specific budgeting model. ¹

Does PM-19 require a specific job title like “SAOP” or “Chief Privacy Officer”?

No specific title is stated. The requirement is the function: a senior official for privacy with authority, mission, accountability, and resources to run the organization-wide privacy program. ¹

Our privacy function is split across Legal and Security. How do we meet PM-19?

Keep the split if you appoint one senior privacy leader with clear decision rights and a defined operating model that coordinates the other stakeholders. Document the RACI and escalation path to avoid “shared ownership means no ownership.” ¹

What’s the fastest way to make PM-19 audit-ready?

Map PM-19 to a named owner, write a short charter, and start producing recurring evidence (governance meetings, decision logs, risk register updates) on a fixed cadence. Daydream can track the mapping and prompt evidence collection so your audit packet is always current. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5