PM-24: Data Integrity Board

PM-24 requires you to establish a Data Integrity Board (DIB) with defined authority, membership, and operating procedures to oversee and adjudicate data integrity issues across your system environment. To operationalize it quickly, charter the board, define what “data integrity” decisions it owns (and what it doesn’t), run it on a fixed cadence, and retain meeting outputs as auditable evidence. ¹

Key takeaways:

• Stand up a formal governance body (charter, scope, membership, authority) focused on data integrity decisions. ¹
• Translate “data integrity” into a decision workflow: intake, triage, adjudication, corrective actions, and closure evidence.
• Auditors will look for proof the board operates, not just that it exists: agendas, minutes, decisions, and follow-through artifacts.

The pm-24: data integrity board requirement is a governance control, not a technical safeguard. NIST is asking you to create a standing forum that can make binding decisions about data integrity risks, conflicts, exceptions, and remediation priorities across the organization’s systems and data flows. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat the Data Integrity Board like any other enterprise governance body: publish a charter, name members with decision rights, define inputs/outputs, and integrate it with existing change management, incident response, data governance, and risk acceptance. The board becomes the place where “integrity-impacting” issues get escalated when teams disagree, when risk is ambiguous, or when integrity tradeoffs need a senior decision.

The common failure mode is creating a board “on paper” with no operating rhythm and no durable records. A well-run DIB produces a clean evidence trail: why a decision was made, what controls were selected, who owns corrective actions, and when integrity risk was reduced or accepted. If you already have a data governance council or security steering committee, PM-24 can often be met by formalizing a DIB function within that body, as long as integrity decisions are explicit and documented.

Regulatory text

Excerpt: “Establish a Data Integrity Board to:” ¹

Operator interpretation: NIST’s requirement is outcome-oriented: you must create a formal board (a governance mechanism) that is responsible for data integrity oversight and decision-making. The excerpt provided is incomplete in the source pack, but it is unambiguous about the minimum expectation: the organization must establish a Data Integrity Board (not an ad hoc working group) and make it real through authority, process, and records. ¹

Where teams get tripped up is treating this as a purely “data quality” initiative. PM-24 lives in the Program Management family, which signals governance and accountability across the security and risk program, not just engineering hygiene. ²

Plain-English meaning (what PM-24 is really asking for)

You need a named group that:

• Owns a defined scope of data integrity risks (accuracy, completeness, consistency, authorized modification, and protection from improper alteration in the systems context).
• Has authority to adjudicate disputes and accept residual integrity risk (or route acceptance to the right executive).
• Tracks integrity-impacting issues to closure with clear records.

Think “Change Advisory Board,” but for integrity-impacting decisions across data pipelines, system interfaces, privileged access patterns, and integrity-related incidents.

Who it applies to

PM-24 applies when you are implementing NIST SP 800-53 controls for:

• Federal information systems
• Contractor systems handling federal data ¹

Operationally, you should scope it to the environments where integrity failures matter to mission, compliance, or contractual obligations, including:

• Systems that store or process federal data
• Shared services (identity, logging, CI/CD) that can introduce integrity risk
• High-impact interfaces (ETL, APIs, file transfers) where data can be transformed or overwritten

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

1) Name the control owner and board sponsor

Assign a control owner in GRC (often the CISO org, security governance, or enterprise risk) and a board sponsor with decision authority (often a senior security or data executive). Your owner runs the process; your sponsor resolves escalations.

Practical tip: If you can’t get a true executive sponsor, define a documented escalation path to the risk acceptance authority used in your system authorization process.

2) Draft and approve a Data Integrity Board charter

Minimum charter elements auditors expect to see:

• Purpose and scope (systems/data in scope; integrity definition used internally)
• Decision rights (what the DIB can approve, reject, or require)
• Membership and quorum rules (who must attend for a valid decision)
• Meeting cadence and ad hoc triggers (incidents, major releases, exceptions)
• Inputs (tickets, incidents, assessments, monitoring findings)
• Outputs (decisions, corrective actions, risk acceptances, exceptions)
• Recordkeeping rules and retention location

Tie the charter to your NIST control mapping for “pm-24: data integrity board requirement” and reference your system boundary documentation where relevant. ¹

3) Define the board’s decision backlog (what gets escalated)

Create a one-page DIB intake standard that defines “integrity-impacting” events. Examples:

• Requests for exceptions to integrity controls (e.g., bypassing validation, disabling checks)
• Conflicting data definitions across systems that affect reporting or downstream decisions
• Privileged access patterns that allow unlogged modification of critical datasets
• Findings from assessments tied to integrity controls (tamper resistance, auditability)
• Integrity-related incidents (unauthorized changes, corruption, pipeline errors)

4) Build a repeatable workflow (intake → triage → adjudicate → track)

Use a ticketing tool or GRC workflow to enforce consistency:

1. Intake: submitter provides system, data set, impact, proposed action, timeline.
2. Triage: owner checks completeness; routes to SMEs for pre-read.
3. Adjudication: board decides (approve, reject, defer, accept risk with conditions).
4. Action tracking: create tasks with owners and due dates (your dates are internal targets, not regulatory claims).
5. Closure: verify evidence, document residual risk, update registers.

This workflow becomes your operational proof that the board exists in practice, not just on an org chart.

5) Integrate with existing governance to avoid duplicate committees

Most organizations already run:

• Change management / CAB
• Incident response reviews
• Data governance council
• Security risk acceptance

Decide where the DIB sits:

• Option A (common): DIB is a subcommittee of security governance with a defined integrity agenda line item and decision log.
• Option B: DIB is embedded into an existing data governance council but adopts security-style recordkeeping, escalation, and risk acceptance mechanics.

Pick one, document it, and show consistency in outputs.

6) Operationalize evidence capture from day one

Audits rarely fail you for imperfect meeting cadence. They fail you for missing artifacts. Require:

• Agenda template
• Decision log template
• Action item tracker
• Meeting minutes notes standard (what was decided and why)
• Repository and access controls for records

If you use Daydream, map PM-24 to a control owner, a written procedure, and recurring evidence artifacts so you can produce an audit-ready packet on demand. ¹

Required evidence and artifacts to retain

Use this as your “PM-24 audit folder” checklist:

Artifact	What it proves	Owner
DIB charter (approved)	Board exists with authority and scope	GRC / Sponsor
Membership roster + roles	Quorum and SMEs are defined	GRC
Meeting schedule / cadence record	Board operates	Board secretary
Agendas and minutes	Topics reviewed and decisions made	Board secretary
Decision log	Traceable approvals/denials/conditions	Control owner
Action tracker	Follow-through and accountability	PMO / GRC
Linked tickets (exceptions/incidents/findings)	Intake and workflow execution	Process owner
Evidence of closure	Integrity risk reduced or accepted with rationale	Control owner

Common exam/audit questions and hangups

Auditors and assessors tend to focus on:

• “Show me the charter and who can approve integrity exceptions.”
• “How do you decide what issues go to the board versus normal change management?”
• “Provide three recent examples: issue intake, board decision, and closure evidence.”
• “Where are records stored and who can edit them?”
• “How do you ensure actions are completed and verified?”

Hangup to anticipate: if you claim the DIB exists but can’t show decisions tied to real events (changes, incidents, exceptions), assessors will treat PM-24 as not implemented.

Frequent implementation mistakes (and how to avoid them)

1. Charter with no decision rights.
   Fix: write explicit authority boundaries (approve/deny/require compensating controls/escalate).

2. Board membership that can’t decide.
   Fix: include at least one role that can commit engineering time, plus risk acceptance representation.

3. No intake criteria; everything becomes a meeting topic.
   Fix: define triggers and thresholds so the board handles the hard cases, not routine QA.

4. Minutes that say “discussed” but not “decided.”
   Fix: require a decision statement, owner, and closure criteria for every agenda item.

5. Evidence scattered across email.
   Fix: a single system of record (GRC tool, ticketing system, controlled repository) and a decision log.

Enforcement context and risk implications

No public enforcement cases were provided in the source pack for PM-24, so you should treat this as an assessment readiness and governance credibility requirement rather than a “fine-driven” control. ¹ The risk is practical: integrity failures create downstream operational, reporting, and security impacts, and the absence of a decision forum causes inconsistent exception handling and undocumented risk acceptance.

Practical 30/60/90-day execution plan

First 30 days (stand up governance)

• Assign control owner and executive sponsor.
• Draft and approve the DIB charter.
• Identify in-scope systems and data flows that routinely raise integrity questions.
• Create templates: agenda, minutes, decision log, action tracker.
• Run a pilot meeting with one real backlog item.

Next 60 days (make it operational)

• Define and publish intake criteria and a submission workflow in your ticketing/GRC system.
• Integrate with change management and incident management: add an escalation path to the DIB.
• Train engineering, data, and security leads on what to escalate and what “good submissions” look like.
• Produce your first evidence packet: charter + two cycles of meeting records + linked tickets.

By 90 days (prove consistency and close loops)

• Review decision quality: are decisions repeatable, documented, and tied to closure criteria?
• Sample prior integrity-related incidents/defects; confirm the DIB either reviewed them or documented why not.
• Tune membership or quorum rules if decisions stall.
• Prepare for assessment: map PM-24 to owners, procedure, and recurring evidence so the audit request can be satisfied quickly, including through Daydream evidence collections. ¹

Frequently Asked Questions

Can our existing data governance council serve as the Data Integrity Board?

Yes, if you formally charter the council (or a subcommittee) with explicit integrity decision rights and keep decision records. Assessors will look for a clear PM-24 mapping to operating evidence. ¹

What counts as “data integrity” for PM-24 in practice?

Treat it as integrity-impacting risks and decisions: unauthorized modification, untraceable changes, conflicting transformations, and exception requests that weaken integrity controls. Document your internal definition in the charter so triage is consistent.

How often does the board need to meet?

NIST’s excerpt in the provided source does not specify a cadence. Set a regular rhythm that matches your change volume, and add ad hoc sessions for integrity incidents or high-risk releases. ¹

What evidence will an assessor ask for first?

The charter, membership list, and a decision log tied to real tickets or events usually come first. Minutes without outcomes are weaker than a decision log plus closure evidence.

Do we need to include third parties in the DIB process?

Include third party-related integrity topics in scope when their systems, tools, or access can change or corrupt your data. You usually do not need third parties “on the board,” but you do need an escalation and accountability path for them.

We have a security steering committee. Do we still need a separate DIB?

Not necessarily. You can meet PM-24 by adding a formal “Data Integrity Board” function within an existing committee, as long as integrity decisions are explicit, repeatable, and evidenced. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5