SA-10(7): Security and Privacy Representatives

SA-10(7) requires you to include security and privacy representatives in your system development life cycle activities, so security and privacy are built into requirements, design, implementation, and acceptance decisions, not added after delivery. Operationalize it by formally assigning named roles, embedding them into SDLC stage gates, and retaining proof of their review and approval. ¹

Key takeaways:

• Assign specific security and privacy representatives, with authority to review and block releases when needed.
• Add mandatory touchpoints (requirements, design, testing, release) where those representatives must participate and sign off.
• Keep evidence that shows involvement: meeting notes, tickets, approvals, and architecture/security review artifacts.

The sa-10(7): security and privacy representatives requirement is a build-process control: it pushes security and privacy expertise into the engineering workflow so system changes are reviewed by the right people at the right time. For a Compliance Officer, CCO, or GRC lead, the practical challenge is rarely “do we have security staff?” It’s whether those staff are explicitly included in the SDLC, consistently engaged on real work, and documented well enough that an assessor can trace security/privacy participation from requirements through release.

This requirement is easiest to pass when you treat it like a workflow design problem. You define who qualifies as a “security representative” and “privacy representative,” specify where they must be involved (for example, architecture review and pre-release risk acceptance), and implement enforceable gates in your tooling (ticketing, CI/CD, change management). Then you retain objective evidence from those tools. NIST’s text for this enhancement is short, but the audit expectations are operational: named roles, repeatable steps, and artifacts that demonstrate involvement. ²

Regulatory text

Excerpt (as provided): “Require {{ insert: param, sa-10.7_prm_1 }} to be included in the {{ insert: param, sa-10.7_prm_2 }}.” ¹

Operator translation: The control expects you to require security and privacy representatives to be included in the SDLC. The parameters in the catalog are placeholders, but the intent is clear: security and privacy representation must be built into how you develop, acquire, integrate, and change systems, not treated as optional consultation. ¹

What “included in the SDLC” means in practice

• They participate early (requirements and design), not only at the end (penetration test before launch).
• They have defined responsibilities and decision rights (review, approve, require remediation, or escalate risk).
• Their involvement is evidenced in work artifacts (tickets, reviews, approvals) that map to actual releases.

Plain-English interpretation

You must name qualified security and privacy representatives and embed them into the SDLC so they routinely review and influence system changes. Your program should make it difficult to ship material changes without their participation, and easy to prove their participation after the fact.

This is a governance control wrapped around engineering. It reduces two common failure modes:

1. Security and privacy requirements are never translated into build requirements, so teams “discover” gaps late.
2. Review happens, but it is informal (Slack chats, hallway conversations) and leaves no audit trail.

Who it applies to

Entity scope (typical):

• Federal information systems and programs implementing NIST SP 800-53 controls. ²
• Contractors and third parties handling federal data where NIST SP 800-53 controls are flowed down via contract, SSP requirements, or agency overlays. ²

Operational scope (where you enforce it):

• Product/application development teams shipping code or configuration changes.
• Infrastructure/platform teams managing IaC, network/security tooling, identity, and cloud resources.
• Acquisition and integration teams bringing in third-party software or managed services that alter system behavior.
• Major change events: new systems, new features, significant architecture changes, data flow changes, or changes that affect personally identifiable information processing.

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

1) Define the roles, qualifications, and authority

Create a short RACI-style definition for:

• Security Representative (SDLC): security engineering or security architecture role accountable for security requirements, threat modeling, security design review, and release risk acceptance.
• Privacy Representative (SDLC): privacy officer, privacy engineer, or counsel-supported privacy lead accountable for privacy requirements, data minimization checks, notice/consent alignment, retention and sharing constraints, and privacy risk acceptance.

Minimum decisions to make:

• Who can act in the role (title, team, or named individuals).
• When they must be engaged (which SDLC events).
• What they can approve vs. what requires escalation.

2) Put the requirement into your SDLC policy and procedures

Update your SDLC procedure so security and privacy representation is not optional. Make the language testable:

• “Security representative approval is required for release of: high-risk changes, new external endpoints, authZ changes, crypto changes, logging/monitoring changes…”
• “Privacy representative review is required for changes that introduce or modify personal data collection, sharing, profiling, retention, or cross-border transfer.”

Keep the triggers specific enough that engineers can self-classify, but backed by a forced triage step (next section).

3) Implement workflow gates in the tools engineers already use

Policy alone won’t hold. Add gates in:

• Ticketing (Jira/ADO/ServiceNow): required fields for “Security review required?” and “Privacy review required?” with routing to queues owned by the representatives.
• Pull request templates: required checkboxes/links to threat model, security design review, and privacy impact notes when triggers apply.
• Change management: explicit approval step for security and privacy reps for defined change categories.

Practical pattern: introduce a “Security/Privacy Triage” step at intake for epics and major changes. That triage assigns required artifacts (threat model, data flow diagram updates, DPIA/PIA where applicable) and sets the required approvers.

4) Define standard review artifacts (so reviews are consistent)

Give representatives a consistent package to review:

• Security: architecture diagram, data flows, threat model, authentication/authorization approach, logging/monitoring plan, dependency and SBOM notes if relevant, test plan.
• Privacy: data inventory impact (what data, purpose, retention), sharing/recipients, user notices/consent impacts, access controls, deletion/DSR support impacts, cross-system propagation.

Avoid creating paperwork for minor changes. Use a tiered approach (low/medium/high) with templates that scale.

5) Train engineering and product on when to pull security and privacy in

Run targeted enablement:

• What triggers a security review.
• What triggers a privacy review.
• What “done” looks like (required artifacts and approvals).
• How to document decisions and exceptions.

Keep it short and practical. Most failures are classification failures.

6) Establish an exception path with risk acceptance

You will have emergency changes. Define:

• Who can grant time-bound exceptions.
• What minimum review still occurs (for example, security rep consult within the change window, privacy rep consult if personal data impacted).
• How you record risk acceptance and follow-up remediation work.

7) Make it auditable: map to control ownership and recurring evidence

Assign a control owner (often AppSec lead or SDLC governance owner) and define recurring evidence pulls. If you use Daydream, map SA-10(7) to the owner, the exact workflow gates, and a standing evidence list so audits do not become a scavenger hunt.

Required evidence and artifacts to retain

Keep evidence that is (a) objective, (b) tied to real work, and (c) easy to sample.

Role and governance artifacts

• Named assignment of security and privacy representatives (org chart extract, responsibility memo, or role roster).
• SDLC procedure showing required inclusion and approval points.

Operational artifacts (best for audits)

• Sampled tickets showing security/privacy triage, comments, and approval.
• Pull requests with security/privacy checklist completion and reviewer approvals.
• Architecture/security review records (meeting notes, decision logs, design review templates).
• Privacy review records for personal-data changes (PIA/DPIA outputs where your program requires them, or internal privacy review checklists).
• Exception/risk acceptance records tied to releases.

Reporting artifacts

• A periodic report or dashboard extract showing coverage (which releases required review, which received it, open exceptions).

Common exam/audit questions and hangups

Expect assessors to test traceability and authority:

1. “Who are the security and privacy representatives for this system?”
   Have named roles and alternates, not just a team name.

2. “Show me where they are included in the SDLC.”
   Point to stage gates in documented process and the tooling configuration.

3. “Prove it happened for these releases.”
   Bring a sample set: epics, PRs, change tickets, and approvals.

4. “What happens when engineering disagrees?”
   Show escalation and risk acceptance paths, including who can approve exceptions.

5. “How do you know privacy review isn’t skipped?”
   Show triggers and routing logic, plus sampling results.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Assigning “Security” and “Privacy” as generic shared inboxes	No accountability; approvals become ambiguous	Name primary and alternate representatives per system or portfolio
Reviews occur only at the end of the cycle	Late discovery leads to exceptions and weak evidence	Add intake triage + design review gates
Privacy is treated as legal-only	Engineers change data flows without privacy control points	Add privacy triggers tied to data flow changes and product requirements
Evidence lives in chats	Hard to sample and retain	Require tickets/PR links for decisions and approvals
No exception process	Teams bypass controls in emergencies	Create documented risk acceptance with follow-up work items

Enforcement context and risk implications

No public enforcement cases were provided in the supplied source set for SA-10(7). Your risk exposure is still practical: if you cannot prove security and privacy representatives were included in the SDLC, assessors commonly record it as a process gap and may question whether security/privacy requirements are actually implemented as designed. ²

Practical 30/60/90-day execution plan

First 30 days (Immediate)

• Assign named security and privacy representatives for the in-scope systems/teams.
• Update SDLC procedure to require their involvement at defined gates.
• Implement a minimum viable triage step in the ticketing system with routing to the right reviewers.
• Define the evidence bundle you will retain for each reviewed change (ticket + PR + approval + review template).

By 60 days (Near-term)

• Add standardized review templates (security design review, privacy change review).
• Implement PR and change-management approvals so reviews cannot be silently skipped.
• Train engineering/product on triggers and the “definition of ready” for review.
• Start sampling: pick recent changes and verify you can reconstruct the review trail.

By 90 days (Operationalize and stabilize)

• Refine triggers (reduce noise, catch misses).
• Stand up a simple dashboard or recurring report for review coverage and exceptions.
• Run a tabletop: simulate an urgent change and test the exception path and documentation.
• In Daydream, link SA-10(7) to the control owner, the procedure, and the recurring evidence list so ongoing audits use the same package every time.

Frequently Asked Questions

Do I need separate people for “security” and “privacy” representatives?

Not always, but you need clear accountability for both functions. If one person covers both, document how they meet privacy responsibilities and how conflicts or gaps escalate.

What counts as “included in the SDLC” for SA-10(7)?

Inclusion means required participation at defined SDLC points, plus documented evidence of review and approval tied to real changes. Optional consultation without traceable artifacts usually fails sampling.

How do we trigger privacy review without reviewing every minor change?

Use data-impact triggers: new data elements, new purposes, new sharing, retention changes, or new integrations that move personal data. Route only those changes to the privacy representative.

We ship multiple times a day. How can representatives keep up?

Gate on risk, not on volume. Require representative review for high-risk change categories and for architectural or data-flow changes, and use templates to keep reviews fast and consistent.

Can a third party act as a security representative?

Yes if your governance model allows it and the person is formally assigned, qualified, and available for the required gates. You still need internal accountability for final risk acceptance.

What evidence is strongest in an audit?

Tool-generated records tied to releases: tickets showing triage, PR approvals by named reps, and stored review templates or decision logs. Chat transcripts and informal emails are weaker unless captured into the system of record.

Footnotes

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

2. NIST SP 800-53 Rev. 5