PM-26: Complaint Management

PM-26 requires you to run a defined, auditable process for receiving, tracking, triaging, and responding to complaints, concerns, or questions about your security and privacy practices. To operationalize it fast, stand up intake channels, a case workflow with SLAs and escalation, approved response content, and evidence that shows each complaint was logged, investigated, answered, and used to drive corrective actions. ¹

Key takeaways:

• Treat security/privacy complaints as governed “cases” with ownership, triage, escalation, and closure criteria. ¹
• Your primary audit risk is missing evidence: no case log, no response records, no trend reviews, no linkage to remediation. ¹
• Integrate complaint management with incident response, privacy requests, and third-party management so routing is consistent and repeatable. ²

PM-26: complaint management requirement is a program-management control in NIST SP 800-53 Rev. 5 that forces discipline around how your organization hears from people who are worried about security or privacy, and what you do next. In practice, that means you need a reliable way for individuals to submit complaints or questions, and you need a consistent operational workflow to respond, document outcomes, and fix root causes.

This control shows up in uncomfortable moments: a user reports suspected account takeover, a customer asks why you collect a data element, an employee reports a misdirected email with personal data, or a third party flags a security weakness in an integration. If you do not have a governed process, you will miss deadlines, provide inconsistent answers, fail to escalate issues that should become incidents, and lose the evidence trail auditors expect.

The good news: PM-26 is straightforward to implement if you treat it like case management. Define intake, classification, SLAs, escalation paths, response approvals, retention rules, and reporting. Then prove you run it by retaining artifacts for a sample of cases. ¹

Regulatory text

NIST SP 800-53 Rev. 5 PM-26 excerpt: “Implement a process for receiving and responding to complaints, concerns, or questions from individuals about the organizational security and privacy practices that includes:” ¹

What the operator must do: You must implement (not just document) a repeatable process that (1) accepts inbound complaints/concerns/questions about security and privacy practices, and (2) responds to them in a controlled, trackable way. Assessors will look for operational evidence that you receive these inputs, route them to the right owners, respond consistently, and use patterns to improve controls. ²

Plain-English interpretation (what PM-26 really expects)

PM-26 expects a “front door” for security/privacy concerns and a “back office” to handle them. The front door is your intake channels (web form, email alias, hotline, ticket portal, mail). The back office is a case workflow with: logging, triage, assignment, investigation, response, closure, and trend reporting.

A common misconception: “We have a security@ email, so we’re done.” That is partial. PM-26 is about managing the full lifecycle and being able to prove it happened. The minimum bar is: every inbound item becomes a record, every record has an owner and status, and every record has a documented response and closure rationale. ¹

Who it applies to (entity and operational context)

PM-26 is relevant wherever you implement NIST SP 800-53 Rev. 5 controls, including:

• Federal information systems that must align to NIST SP 800-53 baselines. ²
• Contractor systems handling federal data where NIST SP 800-53 is flowed down contractually or used as the governing control set. ¹

Operationally, it applies to any environment where individuals can reasonably raise concerns about your security/privacy practices:

• Customer-facing products and SaaS platforms
• Internal enterprise systems (employees raising privacy/security concerns)
• Third-party integrated environments (partners or customers flagging security issues)

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

Use this as a build sheet for a PM-26 operating procedure.

1) Name an accountable owner and backups

• Assign a process owner (often Privacy, Security GRC, or Trust/Compliance).
• Define triage owners (Security Operations, Privacy Office, Legal, Support).
• Document backup coverage and handoffs to avoid stalled cases.

Exam tip: Auditors ask “who owns this control?” before they ask “show me tickets.”

2) Define intake channels and publish them

Stand up and document at least one monitored intake method for each audience:

• External: security/privacy contact page, email alias, portal form
• Internal: helpdesk category, ethics hotline routing, internal form

Minimum requirements for each channel:

• Monitored mailbox/queue with access control
• Auto-acknowledgement (even a simple receipt)
• Ability to capture attachments and metadata

3) Create a classification and routing schema

Define categories that drive routing and urgency. Keep it simple and operational:

Category	Examples	Primary owner	Escalate to
Security vulnerability report	Bug report, misconfiguration	Security/AppSec	CISO delegate
Suspected incident	Account takeover claim	SecOps/IR	Incident Commander
Privacy practice question	Why collect X?	Privacy	Legal (as needed)
Data handling complaint	“You shared my data”	Privacy	Security + Legal
Third-party concern	Partner flags control weakness	TPRM/GRC	Security leadership

Add severity criteria that trigger escalation (for example, credible claim of unauthorized access, or complaint alleging improper disclosure of personal data). Keep the criteria tied to your incident response and privacy workflows so you do not run parallel systems. ²

4) Implement a case workflow with required fields

Run complaints as cases in your ticketing system (ITSM, GRC tool, or a secure workflow). Require fields that create audit-ready evidence:

• Unique case ID
• Intake channel and timestamp
• Complainant identity and contact (or anonymous flag)
• Category and severity
• System/product in scope
• Assigned owner and due date
• Investigation notes and attachments
• Response sent (text or template ID) and date
• Closure code (resolved, duplicate, not in scope, referred)
• Links to related items: incident record, problem record, risk, corrective action

Practical guardrail: If your workflow allows closure without a response artifact, you will fail evidence reviews.

5) Set response standards (SLAs, tone, approvals)

Define:

• Acknowledgement standard: confirm receipt and set expectations.
• Substantive response standard: answer the question, describe actions taken, or explain why you cannot disclose details.
• Approval rules: which responses require Privacy/Legal review (common for privacy practice questions and allegations).

Avoid overpromising. Your standard language should be truthful, consistent, and aligned with your public privacy/security statements. ²

6) Add escalation paths and “stop-the-line” triggers

Write explicit triggers that require same-day escalation to incident response or leadership, such as:

• Credible report of unauthorized access to data
• Vulnerability report with active exploitation claim
• Complaint asserting regulatory violation tied to privacy/security practices

Tie this to your incident response plan and breach/incident decision workflow so teams do not debate routing during pressure. ²

7) Close the loop with corrective actions and trend reporting

PM-26 is stronger when complaint data feeds improvement:

• Weekly or monthly review of open/overdue cases
• Quarterly trend analysis: top categories, repeat issues, systemic gaps
• Documented corrective actions: training updates, product fixes, policy clarifications
• Feedback into risk register when complaints reveal control weaknesses

If you use Daydream for third-party risk management and evidence collection, treat PM-26 like any other control: map a control owner, link the operating procedure, and schedule recurring evidence pulls (case log export, trend reports, and sample case packets). This reduces scramble during assessments. ¹

Required evidence and artifacts to retain

Keep artifacts that prove design and operation. Auditors usually sample cases, so store evidence in a consistent “case packet.”

Design evidence (static):

• Complaint Management SOP / workflow diagram
• RACI (process owner, triage, responders, approvers)
• Intake channel list and published contact points
• Classification and escalation criteria
• Response templates and approval rules
• Training/enablement materials for staff handling cases

Operational evidence (recurring):

• Case register (export) showing all complaints for a period
• Sampled case packets with: intake, triage, investigation notes, response sent, closure
• Metrics report: volumes, aging, overdue, categories
• Management review notes and action items
• Corrective action tickets linked back to complaint cases

Retention: Align retention with your broader recordkeeping policy; the key is consistency and access control for sensitive content. ²

Common exam/audit questions and hangups

Expect these questions and prepare crisp artifacts:

1. “Show me your documented process.”
   Have the SOP and workflow diagram ready, plus the tool screenshots.

2. “How do individuals submit complaints?”
   Provide the published channels and demonstrate monitoring (mailbox access list, queue settings).

3. “How do you ensure timely responses?”
   Show SLA fields, due dates, and overdue reporting.

4. “How do you route to Security vs Privacy vs Legal?”
   Show the classification matrix and escalation criteria.

5. “Give me 5 cases from the last period.”
   Have a pre-built case packet template and a clean export method.

6. “What happens when a complaint indicates an incident?”
   Show cross-links to incident records and your escalation trigger policy. ²

Frequent implementation mistakes (and how to avoid them)

• Mistake: Intake exists, but no logging discipline.
  Fix: Require every inbound message to become a case ID before work starts.

• Mistake: Complaints handled in Slack or email threads only.
  Fix: Allow discussion elsewhere, but the system of record must be the case tool with summarized decisions and response artifacts.

• Mistake: No closure criteria.
  Fix: Define closure codes and require a “response sent” field (or documented reason for no response, such as anonymous reporter with no contact).

• Mistake: Privacy requests mixed with complaints with no routing.
  Fix: Use separate categories and workflows where needed, but keep a single intake triage so nothing is dropped.

• Mistake: No trend review, so repeat issues persist.
  Fix: Add a recurring management review and track corrective actions to closure.

Risk implications (why operators care)

Weak complaint management creates two predictable failure modes:

• Operational risk: issues that should become incidents or root-cause fixes stay as untracked emails, delaying containment and remediation.
• Assurance risk: during an assessment, you cannot prove you respond to individuals about security/privacy practices, which drives findings even if teams “usually respond.” ¹

Practical 30/60/90-day execution plan

Use a phased rollout that prioritizes “working process + evidence” before refinements.

First 30 days (stand up the minimum viable process)

• Assign process owner and triage group; publish RACI.
• Confirm intake channels, monitoring, and access controls.
• Configure a case type in your ticketing system with required fields.
• Write the SOP (1–2 pages) and create initial response templates.
• Run a tabletop with sample complaints to validate routing and escalation.

Days 31–60 (make it auditable)

• Start weekly operational reviews of open/overdue cases.
• Build a standard “case packet” export/checklist for audits.
• Train frontline teams (Support, SecOps, Privacy) on logging and response rules.
• Add cross-linking rules to incident response and corrective action tracking.
• Test evidence retrieval: pick random cases and confirm you can reconstruct decisions.

Days 61–90 (optimize and integrate)

• Add trend reporting and management review notes.
• Identify recurring issues and open corrective actions with owners and due dates.
• Tune severity criteria, response approvals, and templates based on real cases.
• If you manage many third parties, align complaint routing for third-party-related concerns with your third-party risk process so ownership is clear and evidence is centralized. ²

Frequently Asked Questions

Do we need a dedicated “complaints” tool, or can we use our ITSM/helpdesk?

An ITSM/helpdesk system is fine if it can log cases, enforce required fields, track status/ownership, and store response artifacts. The audit test is evidence of consistent operation, not the brand of tool. ¹

Are anonymous complaints allowed under PM-26?

PM-26 does not prohibit anonymous submissions, and allowing them can reduce reporting friction. If you accept anonymous complaints, define how you document resolution when you cannot reply directly. ²

How do we separate privacy rights requests from privacy complaints?

Use a shared intake triage but distinct categories and workflows so deadlines, approvals, and evidence differ cleanly. Link related records so an assessor can follow the chain without mixing processes. ²

What should we do when a complaint alleges a security breach?

Route it through the complaint intake, then immediately escalate per your incident response triggers and open (or link to) an incident record. Keep the complaint case as the communications wrapper and the incident record as the operational system of record for containment. ²

How much detail should we provide in responses to vulnerability reporters?

Provide a clear acknowledgement, scope confirmation, and next steps; limit sensitive details based on your disclosure policy and Legal guidance. Preserve what you did and when, and store the final response text in the case file. ²

What evidence is most likely to be missing during an audit?

Teams usually have a mailbox and informal responses, but they cannot produce a complete case register with consistent fields, closure rationale, and linked remediation work. Build the case packet template early and require it for closure. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5