Control statement
- a.Develop and maintain an accurate accounting of disclosures of personally identifiable information, including:
- 1.Date, nature, and purpose of each disclosure; and
- 2.Name and address, or other contact information of the individual or organization to which the disclosure was made;
- b.Retain the accounting of disclosures for the length of the time the personally identifiable information is maintained or five years after the disclosure is made, whichever is longer; and
- c.Make the accounting of disclosures available to the individual to whom the personally identifiable information relates upon request.
Discussion
The purpose of accounting of disclosures is to allow individuals to learn to whom their personally identifiable information has been disclosed, to provide a basis for subsequently advising recipients of any corrected or disputed personally identifiable information, and to provide an audit trail for subsequent reviews of organizational compliance with conditions for disclosures. For federal agencies, keeping an accounting of disclosures is required by the [PRIVACT](#18e71fec-c6fd-475a-925a-5d8495cf8455) ; agencies should consult with their senior agency official for privacy and legal counsel on this requirement and be aware of the statutory exceptions and OMB guidance relating to the provision. Organizations can use any system for keeping notations of disclosures, if it can construct from such a system, a document listing of all disclosures along with the required information. Automated mechanisms can be used by organizations to determine when personally identifiable information is disclosed, including commercial services that provide notifications and alerts. Accounting of disclosures may also be used to help organizations verify compliance with applicable privacy statutes and policies governing the disclosure or dissemination of information and dissemination restrictions.
From control text to operational evidence
Use Accounting of Disclosures as a testable risk decision. Translate the official statement into accountable people, repeatable processes, configured technology, and evidence that demonstrates the outcome over time. In this family, pay particular attention to enterprise program governance, accountability, resources, metrics, and organization-wide risk decisions.
Implementation workflow
- Define the control boundary, responsible owner, inherited portions, and systems or processes in scope.
- Resolve each organization-defined parameter before declaring the control implemented.
- Document how the implementation satisfies every clause of the official control statement.
- Collect evidence as a normal byproduct of operation rather than only before an assessment.
- Review exceptions, changes, and monitoring results on a risk-based cadence.
Evidence examples
- program charters and policies
- governance meeting records
- risk and performance metrics
- resource and responsibility assignments
Common failure patterns
- program metrics count activity instead of outcomes
- system-level risks never reach enterprise governance
- responsibilities assigned without authority or resources
- privacy and security managed in separate silos
Questions practitioners should ask
- What risk decision is this control intended to support in this system?
- Which parts are implemented locally, inherited, shared, or not applicable—and what evidence supports that decision?
- Do the documented narrative, deployed configuration, operating process, and collected evidence agree?
- What event or threshold requires the implementation to be reviewed or changed?
Assessment objectives and methods
Show the assessment objective
- PM-21a.an accurate accounting of disclosures of personally identifiable information is developed and maintained;
- PM-21a.01
- PM-21a.01[01]the accounting includes the date of each disclosure;
- PM-21a.01[02]the accounting includes the nature of each disclosure;
- PM-21a.01[03]the accounting includes the purpose of each disclosure;
- PM-21a.02
- PM-21a.02[01]the accounting includes the name of the individual or organization to whom the disclosure was made;
- PM-21a.02[02]the accounting includes the address or other contact information of the individual or organization to whom the disclosure was made;
- PM-21a.01
- PM-21b.the accounting of disclosures is retained for the length of time that the personally identifiable information is maintained or five years after the disclosure is made, whichever is longer;
- PM-21c.the accounting of disclosures is made available to the individual to whom the personally identifiable information relates upon request.
Examine
- Privacy program plan
- disclosure policies and procedures
- records of disclosures
- audit logs
- Privacy Act policies and procedures
- system of records notice
- Privacy Act exemption rules.
Interview
- Organizational personnel with privacy program responsibilities
- organizational personnel with privacy responsibilities.
Test
- Organizational processes for disclosures
- mechanisms supporting the accounting of disclosures, including commercial services that provide notifications and alerts.
Related controls
These relationships come from the official OSCAL catalog. They indicate useful dependencies or context, not automatic inheritance or equivalence.
Authoritative sources
Bare Metal Cyber is an independent educational publisher and is not affiliated with or endorsed by NIST. Official control requirements and interpretations remain with NIST and the responsible authorizing organization.