Control statement
Establish a Data Integrity Board to:
- a.Review proposals to conduct or participate in a matching program; and
- b.Conduct an annual review of all matching programs in which the agency has participated.
Discussion
A Data Integrity Board is the board of senior officials designated by the head of a federal agency and is responsible for, among other things, reviewing the agency’s proposals to conduct or participate in a matching program and conducting an annual review of all matching programs in which the agency has participated. As a general matter, a matching program is a computerized comparison of records from two or more automated [PRIVACT](#18e71fec-c6fd-475a-925a-5d8495cf8455) systems of records or an automated system of records and automated records maintained by a non-federal agency (or agent thereof). A matching program either pertains to Federal benefit programs or Federal personnel or payroll records. At a minimum, the Data Integrity Board includes the Inspector General of the agency, if any, and the senior agency official for privacy.
From control text to operational evidence
Use Data Integrity Board 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
a Data Integrity Board is established;
- PM-24a.the Data Integrity Board reviews proposals to conduct or participate in a matching program;
- PM-24b.the Data Integrity Board conducts an annual review of all matching programs in which the agency has participated.
Examine
- Privacy program plan
- privacy program documents relating to the Data Integrity Board, including documents establishing the board, its charter of operations, and any plans and reports
- computer matching agreements and notices
- information sharing agreements
- memoranda of understanding
- records documenting annual reviews
- governing requirements, including laws, executive orders, regulations, standards, and guidance
Interview
- members of the Data Integrity Board (e.g., the chief information officer, senior information security officer, senior agency official for privacy, and agency Inspector General)
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.