PM-20: Dissemination of Privacy Program Information

PM-20 requires you to maintain a single, central privacy-program webpage on your organization’s primary public website and keep it accurate, current, and easy to find. To operationalize it, assign an owner, define required content, connect updates to your privacy governance workflow, and retain evidence that the page exists, is maintained, and reflects your actual privacy program. ¹

Key takeaways:

• Create one authoritative, public “privacy program” hub page and treat it as a controlled compliance artifact. ¹
• Tie page updates to real governance triggers (policy changes, PIAs, system changes, incident learnings) so content stays aligned with operations. ²
• Preserve screenshots, change logs, approvals, and a content inventory to pass assessments without scrambling. ¹

PM-20: dissemination of privacy program information requirement is an “easy to overlook, hard to defend” control because it looks like a marketing-web task but gets assessed like governance. Assessors typically want proof that the public can find a central source of truth about your privacy program, and that the content reflects how you actually manage privacy risk across systems, data, and third parties.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat the webpage as a formal compliance deliverable: define what “privacy program information” means for your organization, publish it as a central resource on the principal public site, and run it through a lightweight content-control process (ownership, review cadence, and change approvals). The operational trap is misalignment: posting generic privacy statements while your internal program has different policies, contacts, or processes.

This page gives you requirement-level implementation guidance you can execute quickly: applicability, step-by-step actions, evidence to retain, common audit questions, and a practical execution plan you can run with a small team. Primary source: NIST SP 800-53 Rev. 5. ²

Requirement summary (plain English)

PM-20 requires a single central resource webpage on your organization’s main public website that serves as the central source of information about your privacy program. In practice, you must publish a “privacy program hub” page (not just a privacy policy) and keep it accurate over time through defined ownership and change control. ¹

This is not a purely technical control. It is governance plus content operations: the page must exist, be reachable by the public, and reflect your real privacy program structure and points of contact. ²

Regulatory text

Control requirement (excerpt): “Maintain a central resource webpage on the organization’s principal public website that serves as a central source of information about the organization’s privacy program and that:” ¹

Operator interpretation: you need one public page that is the authoritative index for privacy program information. Build it as a hub that links out to supporting pages (privacy policy, notices, rights request instructions, governance artifacts you choose to publish), then maintain it as a controlled compliance asset with clear ownership and an update workflow. ¹

Who it applies to (entity and operational context)

PM-20 is most directly relevant when you operate:

• Federal information systems, including agencies publishing public-facing web content about their privacy program. ¹
• Contractor systems handling federal data, where public-facing privacy posture and program transparency can be part of trust and oversight expectations (even if your contract scopes what must be public). ¹

Operationally, it applies wherever your organization has:

• A principal public website (corporate site, agency site, program site).
• A defined privacy program (policies, governance roles, incident response tie-ins, third-party controls).
• Any external audience that needs a reliable “start here” page for privacy questions, notices, and escalation paths. ²

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

Step 1: Name the control owner and stakeholders

Assign a single accountable owner (often the Privacy Officer, CPO, or GRC privacy lead) and define who must review changes: Legal, Security, Communications/Web, and the intake team for privacy requests. Record this in your control register and RACI. ²

Operational tip: if Web/Comms “owns publishing,” keep compliance ownership in Privacy/GRC and treat Web/Comms as an implementing party with SLAs for updates.

Step 2: Define the minimum content inventory for the hub page

Write a one-page content standard for what the “central resource webpage” must include. Keep it tight and auditable. Common inclusions:

• Privacy program overview (scope, governance structure at a high level).
• How to contact the privacy office (email, form, mailing address as applicable).
• Links to key public privacy documents (privacy policy, notices, cookie notice if applicable).
• How individuals can raise privacy questions/complaints or request assistance.
• Links to security or incident-related disclosures only if your program publishes them.
• Date of last review and how updates are governed. ²

You are not required to publish sensitive internal procedures. Publish enough to demonstrate program existence, accessibility, and a stable entry point. ¹

Step 3: Build the page on the principal public website with durable navigation

Implement the hub page under a stable URL path and link it from high-visibility areas (site footer, “Privacy,” “Policies,” or “About”). Ensure the hub reads as the central index, not a one-off blog post. ¹

Operational tip: avoid burying the page behind region selectors, login walls, or dynamic routes that change frequently. Assessors will test accessibility like a member of the public would.

Step 4: Connect updates to governance triggers (change control)

Define triggers that force review and potential update of the page:

• Privacy policy or notice updates.
• Changes in privacy office contact channels.
• Material updates to privacy governance (new officer, new oversight body).
• Major changes to data processing that alter public-facing disclosures.
• Post-incident corrective actions that affect public guidance (for example, new reporting channels). ²

Implement a lightweight workflow: draft → privacy review → legal review (as needed) → publish → archive evidence. This can run in a ticketing system, a GRC tool, or a documented email approval chain. ²

Step 5: Set a recurring review cadence and document it

Pick a review frequency that fits your change rate, then document it in the procedure. The requirement is “maintain,” so you must show ongoing attention, not a one-time publish. ¹

What auditors look for: proof the page is periodically reviewed even when nothing changes.

Step 6: Monitor availability and integrity of the public page

Add simple monitoring: uptime checks, periodic link checks, and verification that the footer link still points to the correct page after site redesigns. This can be owned by WebOps with reporting to the control owner. ²

Step 7: Map PM-20 to your control framework and evidence schedule

Document the control statement, procedure, owner, and recurring evidence artifacts in your control library. This is explicitly aligned with the recommended operational control: map PM-20 to owner, procedure, and recurring evidence artifacts. ¹

Where Daydream fits naturally: Daydream helps teams keep requirement-to-evidence mapping tight so PM-20 does not become a last-minute “go take a screenshot” scramble. You want a control record that tells your team exactly what to collect each cycle and where it lives.

Required evidence and artifacts to retain

Keep evidence that proves existence, accessibility, and maintenance. Recommended artifacts:

• Published URL of the privacy program hub page and a PDF export (or web archive capture).
• Dated screenshots showing the page content and site navigation path (footer link, menu placement).
• Content inventory standard (what the hub must contain) and the maintenance procedure (review cadence, approvals).
• Change log (CMS revision history, ticket history, or document version history) showing edits and approvals.
• Review attestations (tickets closed, meeting notes, or sign-off emails) even when no changes were needed.
• Link-check / uptime evidence (monitoring reports or periodic validation record).
• RACI / ownership record linking PM-20 to named roles. ¹

Common exam/audit questions and hangups

Expect these questions:

1. “Show me the central privacy program page on the principal public website.” ¹
2. “How do you ensure it stays current when policies or contacts change?” ²
3. “Who owns this control, and what is the review cadence?” ²
4. “Where is your evidence of periodic review and update approvals?” ¹
5. “After your last website redesign, how did you verify the page remained accessible?” ²

Hangups that slow audits:

• The “privacy policy” exists, but there is no program hub and no claim that it is the central resource. ¹
• Page exists but is not on the principal public site (hosted on a microsite or third-party platform without clear linkage). ¹
• No evidence of maintenance, only a current snapshot. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails PM-20	How to avoid it
Treating the privacy policy as the “central resource”	PM-20 expects a central source about the privacy program, not only legal notice text. 1	Create a hub page that links to the policy and adds program contact and navigation.
No named owner	Maintenance becomes ad hoc; updates lag after org changes. 2	Assign a control owner and backup; document in RACI and the procedure.
Page content diverges from operations	Public statements conflict with actual intake paths, timelines, or governance. 2	Tie updates to governance triggers and require privacy-team review before publishing.
Buried navigation	Assessors and the public cannot find it easily. 1	Put a persistent footer link and keep a stable URL.
No evidence trail	You cannot prove “maintain,” only “publish.” 1	Keep change logs, approvals, and periodic review attestations.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not list specific cases. ¹

Risk-wise, PM-20 gaps usually surface as:

• Assessment findings for missing or inaccessible public program information.
• Trust and oversight friction with federal customers if your public-facing privacy posture is unclear or inconsistent with contractual expectations.
• Operational failures when individuals or stakeholders cannot find correct privacy contacts or procedures, leading to missed deadlines, mishandled complaints, or inconsistent responses. ²

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

First 30 days (establish and publish)

• Assign control owner and backup; document RACI.
• Draft the hub page content standard (what must be included).
• Publish the central privacy program hub page on the principal public website.
• Capture baseline evidence: URL, PDF export, screenshots, and initial approval record. ¹

Days 31–60 (operationalize maintenance)

• Implement change-control workflow (ticket type, reviewers, approval steps).
• Add governance triggers to your privacy change management checklist.
• Set up link and availability checks; define who receives alerts.
• Store evidence in a single audit-ready folder or GRC record mapped to PM-20. ²

Days 61–90 (harden for assessments)

• Run a tabletop “audit pull”: have someone outside Privacy find the page from your homepage and collect evidence from scratch.
• Validate the hub page against your actual privacy program: contacts, escalation paths, and linked documents.
• Add a recurring review task and require a retained “no changes needed” attestation when applicable.
• If you use Daydream, configure the control record to auto-request recurring evidence and maintain a clean change history. ¹

Frequently Asked Questions

Does PM-20 require a public-facing privacy policy, or a separate page?

PM-20 requires a central resource webpage about your privacy program on your principal public website. A privacy policy can be linked from that hub, but the hub should function as the central index and contact point. ¹

What counts as the “principal public website” for a contractor with multiple product sites?

Use the primary corporate domain that represents the organization externally, then link from product sites back to the central hub. Keep the hub URL stable and easy to find from common navigation elements. ¹

How do we show “maintenance” if the page rarely changes?

Retain periodic review evidence even when no edits are needed, such as a closed ticket with reviewer sign-off and a dated screenshot or PDF export. Assessors want proof of ongoing governance. ¹

Can we host the page on a third-party platform (for example, a help center)?

PM-20 specifically calls for the central resource webpage on the organization’s principal public website. If you use a third-party platform, link to it from a central page on your principal site and treat that central page as the authoritative hub. ¹

Should we include privacy program org charts, PIAs, or internal procedures on the public page?

Publish only what you can support and keep current. The control is about providing a central source of information; you can keep sensitive operational detail internal while still providing clear contacts, notices, and program description. ²

What is the fastest way to make PM-20 audit-ready?

Publish the hub page, assign a named owner, and create a simple evidence pack: URL, screenshots, approval record, and a documented review cadence with a repeatable change log. Then map the control to recurring artifacts in your GRC workflow. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5