PM-32: Purposing

PM-32: Purposing requires you to analyze the information resources that support mission-essential services or functions and confirm they are used only for their intended purpose, then keep evidence that the analysis happens and drives corrective action. Operationalize it by defining “intended purpose,” inventorying in-scope resources, testing actual use, documenting exceptions, and tracking remediation. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Key takeaways:

• Define and document intended purpose per system/data/service before you try to “analyze use.”
• Test real-world usage (access, data flows, integrations, user behavior) against purpose statements, not against vague policy language.
• Keep recurring evidence: analysis outputs, exceptions, approvals, and remediation tracking tied to mission-essential functions.

The pm-32: purposing requirement is easy to misunderstand because it looks like “policy hygiene,” but assessors treat it as a governance control with operational teeth. You are being asked to prove that the systems, data, and other information resources supporting mission-essential services are not quietly drifting into secondary uses that create security, privacy, legal, or mission risk.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to convert PM-32 into a repeatable analysis cycle: establish documented purpose statements, map them to mission-essential services/functions, verify actual use through technical and procedural checks, and document decisions when reality does not match intent. The control is less about writing a better policy and more about being able to answer, with evidence, “What is this resource for, who uses it, how is it actually used, and what did we do when we found a mismatch?”

If you support federal information systems or contractor systems handling federal data, PM-32 also becomes a practical discipline for preventing scope creep in data use, shadow integrations, and “temporary” access that becomes permanent. (NIST SP 800-53 Rev. 5)

Regulatory text

NIST PM-32 (Purposing): “Analyze {{ insert: param, pm-32_odp }} supporting mission essential services or functions to ensure that the information resources are being used consistent with their intended purpose.” (NIST SP 800-53 Rev. 5 OSCAL JSON)

What the operator must do:
You must perform an analysis (recurring, not one-time) of the information resources that support mission-essential services/functions, compare how those resources are actually used to how they are intended to be used, and address misalignment. The measurable outcome is evidence that you (1) defined intended purpose, (2) checked real usage, and (3) corrected or formally accepted exceptions with accountability.

Plain-English interpretation (what PM-32 is really asking)

PM-32 expects you to control “purpose drift.” Over time, systems and data get reused: a reporting database becomes a test bed, a collaboration tool becomes a records repository, a logging platform becomes a user analytics engine, a contractor account becomes a shared admin pathway. PM-32 requires a structured way to detect and manage that drift for resources tied to mission-essential work.

Think of it as purpose-based governance for information resources:

• Intended purpose is what leadership/owners approved the resource to do.
• Actual use is what users, admins, developers, and third parties are doing in production.
• Purposing analysis is the gap assessment plus the decision and action trail.

Who it applies to (entity and operational context)

Entities:

• Federal information systems
• Contractor systems handling federal data (NIST SP 800-53 Rev. 5 OSCAL JSON)

Operational scope (what to include):

• Systems and platforms that directly support mission-essential services/functions (business services, operational services, regulated services, critical internal services).
• Information resources beyond “systems,” such as data sets, repositories, analytics environments, identity stores, logging/monitoring platforms, and shared services, when they materially support the mission-essential function.
• Third-party hosted environments and SaaS where the federal mission-essential process runs or where federal data is processed/stored.

Practical scoping tip: Start with your mission-essential service map (or critical service inventory), then identify the top supporting applications, data stores, and integrations. PM-32 is not credible if it only covers a policy binder and ignores the production stack.

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

1) Assign ownership and define “information resources”

Deliverable: PM-32 control owner + RACI.

• Name a control owner in GRC (often security governance) and system/data owners accountable for purpose statements.
• Define the categories you will treat as “information resources” for your program (systems, datasets, environments, identity, logs, integrations, third-party services).

Why it matters: If you cannot say who approves “intended purpose,” you cannot prove resources are consistent with it.

2) Document intended purpose for in-scope resources

Deliverable: Purpose statements tied to mission-essential services/functions.
For each in-scope resource, capture:

• Mission-essential service/function supported
• Intended users and allowed roles (human and service accounts)
• Intended data types and permitted processing (store, transmit, transform, analyze)
• Allowed integrations and data sharing boundaries (including third parties)
• Explicitly prohibited uses (common: ad hoc analytics, training AI models, non-production testing with production data, personal storage)

Keep it short. One page per system is enough if it is unambiguous and approved by the owner.

3) Baseline “actual use” using technical and operational signals

Deliverable: Purposing analysis worksheet/report.
Test actual use against the purpose statement using evidence such as:

• Access review signals: who has privileged access, external identities, dormant accounts.
• Data flow mapping: where data exports go, API integrations, file transfers, BI connectors.
• Environment checks: production data in non-production, shared admin accounts, unmanaged endpoints with access.
• Logging and monitoring: categories of queries/jobs run, unusual usage patterns, bulk extraction events (qualitative, not statistical).
• Third-party use: what contracted service is actually processing, sub-processors, offshoring arrangements, support access.

You do not need perfect observability to start. You need a defensible method and documented follow-ups.

4) Identify mismatches and classify them

Deliverable: Exceptions register with severity and decision trail.
Common mismatch types:

• Access exceeds purpose: users/roles have capabilities unrelated to the approved function.
• Processing exceeds purpose: analytics, replication, or enrichment not in scope.
• Retention exceeds purpose: data kept “just in case” without purpose tie-back.
• Sharing exceeds purpose: exports to tools/third parties outside approved boundaries.
• Environment misuse: production data copied into dev/test without justification.

Classify each mismatch as:

• Remediate (preferred)
• Re-purpose (update intended purpose with formal approval, then adjust controls)
• Accept risk (time-bound exception with compensating controls and an owner)

5) Remediate and prevent recurrence

Deliverable: Remediation tickets + control updates.
Typical fixes:

• Tighten RBAC/ABAC, remove broad groups, enforce JIT/JEA for admin access
• Block unsanctioned exports/integrations; formalize approved connectors
• Tokenize/mask data for non-production; block production data movement where possible
• Update retention schedules; enforce deletion or archival
• Update SOPs for onboarding/offboarding, change management, and third-party access approvals

Prevent recurrence by adding “purpose check” gates:

• Architecture review: new integration must map to intended purpose
• Change management: major change requires purpose statement impact check
• Procurement/third-party due diligence: confirm service purpose and permitted processing

6) Make it recurring and assessment-ready

Deliverable: A recurring cadence and evidence plan.
PM-32 is weak if it is a one-off spreadsheet. Set a recurring review trigger, for example:

• When a mission-essential service changes
• When you onboard a new third party/integration
• When a system has a major change
• On a regular governance cadence defined by your program

Daydream (as a GRC operating layer) is a practical place to map PM-32 to an owner, document the implementation procedure, and generate a recurring evidence checklist so you can produce artifacts on demand without rebuilding context every cycle.

Required evidence and artifacts to retain

Keep artifacts that show definition, analysis, decision, and action:

1. Inventory & scope

• Mission-essential services/functions list and mapping to systems/resources
• In-scope information resources inventory (including key third parties)

2. Purpose definition

• Approved purpose statements (system/data purpose, allowed users, allowed processing, allowed sharing)
• Architecture diagrams or data flow diagrams that reflect intended use

3. Analysis outputs

• Purposing analysis report/worksheet per resource or per service
• Evidence inputs (access review exports, integration lists, change tickets, selected logs/screenshots)

4. Exception handling

• Exceptions register with business owner approval and expiration/conditions
• Risk acceptance memo(s) where applicable

5. Remediation tracking

• Tickets/epics with closure evidence
• Updated configurations/policies/SOPs post-remediation

Common exam/audit questions and hangups

Expect assessors to probe these points:

• “Show me the definition of intended purpose for this system and who approved it.”
• “How do you know the system is used that way in practice? What evidence did you check?”
• “Which mission-essential function does this resource support?”
• “Where do you record mismatches and how do you track them to closure?”
• “How do you handle new integrations or third-party access against intended purpose?”
• “How often do you re-perform this analysis, and what triggers an out-of-cycle review?”

Hangup: teams present a high-level acceptable use policy. PM-32 wants resource-level purpose and a concrete analysis of use.

Frequent implementation mistakes (and how to avoid them)

1. Purpose statements are generic (“business operations”).
   Fix: force a “purpose sentence” that a technical person can test (who, what data, what processing, what sharing).

2. No mapping to mission-essential services/functions.
   Fix: maintain a simple service-to-system mapping table; update it through change management.

3. Analysis is purely narrative with no evidence inputs.
   Fix: define a minimum evidence set (access list + integrations list + recent changes + data flow).

4. Exceptions exist but are scattered in email.
   Fix: centralize exceptions with owner, rationale, and expiration; require closure evidence or renewal.

5. Third parties are ignored.
   Fix: include major SaaS, hosting, MSPs, and data processors in the same purpose-based analysis if they support mission-essential functions.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat PM-32 primarily as an assessment and governance expectation under NIST SP 800-53 rather than a control with a specific cited enforcement pattern in this data set. (NIST SP 800-53 Rev. 5)

Risk-wise, PM-32 failures tend to surface as:

• Unauthorized processing or disclosure pathways (often via exports and integrations)
• Privilege sprawl and unbounded admin behavior
• Data retention and secondary use that create downstream compliance issues
• Broken scoping assumptions during incident response and reporting

Practical 30/60/90-day execution plan

Day 0–30: Stand up the minimum viable PM-32 program

• Name PM-32 control owner and system owner responsibilities.
• Define “information resources” categories for your org and scope the mission-essential services/functions.
• Select a pilot set of resources tied to a mission-essential function.
• Create a one-page purpose template and get approvals for pilot resources.
• Build an evidence checklist for the analysis (what you will pull and where it lives).

Day 31–60: Execute analysis and close the first gaps

• Perform the purposing analysis for the pilot set using your checklist.
• Stand up an exceptions register and remediation tracking workflow.
• Fix the obvious issues first (or document why you cannot yet): stale privileged access, shadow integrations, non-production data handling.
• Add a “purpose impact check” to change management for pilot systems.

Day 61–90: Scale and operationalize

• Expand scope to the rest of the mission-essential service map.
• Standardize reporting: per-service purposing analysis summary, exceptions status, remediation progress.
• Train system owners and app teams on writing testable purpose statements.
• In Daydream, map PM-32 to the control owner, store the procedure, and schedule recurring evidence collection so audits do not turn into last-minute evidence hunts.

Frequently Asked Questions

What counts as an “information resource” under PM-32?

Treat it broadly: systems, datasets, environments, identity services, logs, and third-party services that support mission-essential functions. Define your categories once, then apply them consistently. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Do I need to prove “no misuse,” or just that I analyze and respond?

PM-32 is framed as an analysis requirement with an outcome: resources are used consistent with intended purpose. Assessors will look for the analysis method plus evidence of corrective action or approved exceptions. (NIST SP 800-53 Rev. 5 OSCAL JSON)

How detailed should an intended purpose statement be?

Detailed enough that you can test it: who can use it, what data it holds, what processing is allowed, and where data can be shared. If the statement cannot drive an access or data flow decision, it is too vague.

How do we handle a system that legitimately has multiple purposes?

Document each purpose explicitly and tie each to a mission-essential service/function, then validate controls for each use case. If the new purpose changes risk, treat it as re-purposing with formal approval and control updates.

Does PM-32 apply to third-party SaaS and cloud providers?

Yes, if that third party service supports your mission-essential functions or processes federal data as part of the service. Include those services in scope and analyze actual use against contracted and approved purpose.

What evidence is most persuasive in an audit?

A clear mapping of mission-essential services to resources, approved purpose statements, an analysis report with specific evidence inputs (access, integrations, changes), and a tracked remediation/exception trail.