PM-27: Privacy Reporting

PM-27: Privacy Reporting requires you to define a formal privacy reporting deliverable (what you report, to whom, how often, and in what format) and then consistently disseminate those reports to the right internal and external recipients. To operationalize it fast, assign an owner, standardize report content, set a distribution cadence, and retain evidence that reporting occurred. ¹

Key takeaways:

• You need a defined privacy reporting package, not ad hoc status updates, and it must be disseminated. ¹
• “Evidence of dissemination” is the exam hinge: distribution lists, timestamps, minutes, and report archives. ¹
• Map PM-27 to a control owner, a repeatable procedure, and recurring evidence artifacts so it survives staff turnover and audit sampling. ¹

Privacy reporting fails in predictable ways: teams do privacy work (PIAs, incident response, training, data mapping), but leadership and oversight bodies get inconsistent visibility. PM-27 fixes that by requiring a defined reporting deliverable and an explicit dissemination expectation. The practical outcome is simple: you can show what privacy topics were reported, who received the reporting, and that it happened on a reliable schedule.

For a Compliance Officer, CCO, or GRC lead, PM-27 is less about writing a policy and more about building a “privacy reporting operating rhythm.” Your job is to decide what belongs in the report, align recipients to their oversight responsibilities, and create auditable proof that the reporting was delivered. You also need to connect the reporting content to the privacy program’s real risk signals (complaints, incidents, assessments, third-party issues) so the report is defensible and useful.

This page translates the pm-27: privacy reporting requirement into a concrete operating procedure, an evidence checklist, and an execution plan you can put in motion immediately. ²

Regulatory text

Requirement excerpt (PM-27): “Develop {{ insert: param, pm-27_odp.01 }} and disseminate to:” ¹

Operator interpretation of the excerpt

• “Develop …” means you must define a tangible privacy reporting deliverable. In practice, that is a recurring report (or report set) with a defined scope, format, and ownership. ¹
• “Disseminate to …” means reporting does not “exist” until it is sent or presented to named recipients. Examiners look for proof of delivery, not just a saved document. ¹
• The excerpt in your source is parameterized (“{{ insert: param, pm-27_odp.01 }}”), so you must explicitly decide what that reporting package contains and document the decision as part of your implementation. ¹

Plain-English interpretation (what PM-27 is asking for)

You must (1) define what privacy reporting your organization produces, and (2) reliably deliver it to the right audiences. Think of PM-27 as the privacy-program analogue to security metrics reporting: it turns privacy operations into a repeatable, reviewable governance artifact. ¹

Who it applies to

PM-27 commonly applies where you operate under NIST SP 800-53 control expectations, including:

• Federal information systems with formal privacy program oversight. ¹
• Contractor systems handling federal data, where contract clauses and assessment regimes expect evidence of privacy governance practices aligned to NIST SP 800-53. ¹

Operationally, PM-27 touches:

• The Senior Agency Official for Privacy (or equivalent), privacy office, and governance bodies.
• Security and risk teams that need privacy risk surfaced alongside security risk.
• System owners / product teams whose PIAs, changes, and incidents drive report content.
• Third parties when your privacy posture depends on their processing activities, assessments, incidents, or contract terms (privacy reporting should include relevant third-party privacy risk where applicable).

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

1) Assign ownership and define the reporting “product”

• Name a PM-27 control owner (often Privacy Officer, CPO, or GRC lead) and a backup. ¹
• Define the reporting deliverable as a versioned artifact, such as:
  • “Privacy Program Quarterly Report” (deck + memo), and/or
  • “Monthly Privacy Operations Metrics” (dashboard export + narrative).
    Tie this definition to the parameterized placeholder in the excerpt so an assessor can see what you chose. ¹

2) Define recipients and dissemination methods

Create a dissemination matrix that lists:

• Recipients (roles or committees, not just names).
• Delivery method (email distribution list, governance meeting, ticketing system, portal).
• Trigger/cadence (recurring and event-driven).
  The goal is to remove ambiguity from “disseminate to.” ¹

Example dissemination matrix (starter):

Audience	What they need	Delivery method	When
Executive risk committee	Trends, top risks, exceptions	Slide deck + meeting minutes	Recurring cadence
System owners	Open actions, PIAs, changes	Tracker export + email	Recurring cadence
Security/GRC	Incidents, control gaps, POA&M alignment	Dashboard + ticket summary	Recurring cadence
Contract stakeholders (if required)	Contractual privacy reporting	Formal memo	As required

(Define the “when” based on your governance calendar; PM-27 requires reporting and dissemination, not a specific frequency in the excerpt.) ¹

3) Standardize report content so it survives audit sampling

Build a template with sections that map to how privacy programs are examined. Common sections:

• Material changes to processing, systems, or data inventory
• PIAs/threshold analyses completed and pending
• Privacy incidents or near misses (with status and learnings)
• Data subject requests volume/themes (if applicable)
• Third-party privacy risk highlights (new high-risk processors, issues)
• Training/awareness completion narrative (avoid unsupported percentages unless you can cite internally during audit)
• Open remediation items, owners, and due dates

Keep it stable across reporting cycles so auditors can compare periods and see trend discipline. ¹

4) Implement a repeatable dissemination workflow (not a one-off email)

Operationalize with a lightweight runbook:

• Draft report → internal review (privacy + GRC) → approval (privacy leader) → disseminate → archive evidence.
• Use consistent naming conventions and storage locations.
• If you present in a committee, treat the deck + minutes + attendee list as dissemination evidence.

If you run Daydream for compliance operations, this is where it fits naturally: map PM-27 to a single owner, link the procedure, and predefine the recurring evidence artifacts so each cycle is “fill template, distribute, attach proof,” not reinvent-the-wheel work. ¹

5) Retain evidence in an audit-ready package

Your evidence needs to answer two examiner questions:

1. Did you develop the report definition and content?
2. Did you disseminate it to the required audiences? ¹

Required evidence and artifacts to retain

Maintain an “PM-27 evidence folder” (or GRC control record) with:

• Reporting procedure/runbook (steps, roles, review/approval, dissemination). ¹
• Report template (version-controlled).
• Distribution lists (or recipient roster by role/committee).
• Completed reports for sampled periods (PDF/slide export + underlying metrics snapshot if feasible).
• Proof of dissemination, such as:
  • Email headers showing recipients and timestamps,
  • Meeting agenda/minutes showing the privacy report was delivered/presented,
  • Portal posting logs or ticket records.
• Approval evidence (sign-off email, workflow approval, or meeting minutes).
• Exception log (missed cycle, delayed dissemination, rationale, remediation).

Common exam/audit questions and hangups

Auditors tend to probe these areas:

• “Show me the defined privacy reporting deliverable for PM-27.” If you only have ad hoc emails, you will scramble. ¹
• “Who receives it, and why those recipients?” You need role-based reasoning tied to governance. ¹
• “How do you know dissemination happened?” Provide distribution proof, not screenshots without metadata. ¹
• “Is reporting consistent over time?” A stable template and archive answer this quickly.
• “What happens if reporting finds a material issue?” Have a handoff path to risk acceptance, POA&M, incident response, or corrective action tracking.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating PM-27 as a policy statement.
   Fix: Produce an actual reporting artifact and a dissemination record every cycle. ¹

2. Mistake: No clear recipients.
   Fix: Create a dissemination matrix with roles/committees and maintain it as governance changes. ¹

3. Mistake: Reporting content is a grab bag.
   Fix: Standardize headings and keep a defined “minimum content set” plus an “optional deep dive” section.

4. Mistake: Evidence is not auditable.
   Fix: Save emails with headers, minutes with attendance, and versioned reports. Avoid relying on chat messages as primary evidence unless your audit function accepts them.

5. Mistake: Privacy reporting isn’t connected to operational sources of truth.
   Fix: Feed the report from systems you already run: incident tracking, third-party due diligence, PIA tracker, ticketing, and change management.

Enforcement context and risk implications

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

Risk-wise, PM-27 gaps create predictable exposure: leadership cannot demonstrate privacy governance, and assessors may conclude the privacy program is not operating as designed due to missing evidence of reporting and dissemination. The control is “medium” severity in your requirement data, so treat it as a governance expectation that commonly appears in baseline assessments and maturity evaluations. ¹

Practical 30/60/90-day execution plan

First 30 days (stand up the operating mechanism)

• Assign PM-27 owner and backup; document responsibilities. ¹
• Draft the reporting template and the dissemination matrix (recipients by role/committee). ¹
• Decide where evidence will live and what counts as acceptable proof of dissemination.
• Pilot one reporting cycle with at least one governance audience and capture evidence end-to-end. ¹

By 60 days (make it repeatable and defensible)

• Finalize and publish the PM-27 runbook (draft → review → approval → disseminate → archive). ¹
• Tune report content: remove vanity metrics, add action tracking and decision points.
• Align the report to upstream inputs (PIA tracker, incidents, third-party risk register, change management), and document those feed sources.
• Run a second cycle and confirm dissemination evidence is consistently produced.

By 90 days (operate like it will be sampled)

• Run the report through a mock audit: pick a prior period and prove (a) the report existed, (b) it was approved, (c) it was disseminated to the defined recipients. ¹
• Add exception handling: missed cycle, alternate dissemination path, emergency reporting for incidents.
• If using Daydream, map PM-27 to your control library entry with owner, procedure link, and recurring evidence requests so reporting cycles generate audit-ready artifacts by default. ¹

Frequently Asked Questions

What exactly is the “privacy reporting” deliverable under PM-27?

PM-27 requires you to define a reporting package and then disseminate it to specified recipients. Your deliverable can be a recurring report, dashboard export, or governance deck, as long as it is defined and you retain evidence it was delivered. ¹

Do we need to report on a specific schedule (monthly, quarterly)?

The provided excerpt requires development and dissemination but does not specify a frequency. Set a cadence that matches your governance forums and risk appetite, then follow it consistently and document exceptions. ¹

Who should receive the PM-27 privacy report?

Define recipients by role and oversight responsibility, such as privacy leadership, risk committees, system owners, and security/GRC partners. The key is to document the “to whom” list and show dissemination evidence for those audiences. ¹

What counts as acceptable evidence that we “disseminated” the report?

Email distribution proof (with headers), meeting minutes showing presentation, portal posting logs, and workflow approvals are common, defensible artifacts. Save the report content alongside the dissemination proof for the same period. ¹

Can PM-27 be satisfied by a verbal update in a meeting?

A verbal update alone is hard to evidence. If you present in a meeting, retain the deck, agenda/minutes, and attendee list as proof of dissemination tied to the defined report content. ¹

How does PM-27 relate to third-party risk management?

If third parties process data or influence privacy risk, your privacy report should include relevant third-party privacy issues (assessments, incidents, contract gaps, remediation). That keeps privacy governance aligned to real operational exposure. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5