OMB Circular A-130, “Managing Information as a Strategic Resource”

CIRCULAR NO. A-130
TO THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES
SUBJECT: Managing Information as a Strategic Resource
1.
2.
3.
4.
5.

Introduction
Purpose
Applicability
Basic Considerations
Policy
a. Planning and Budgeting
b. Governance
c. Leadership and Workforce
d. IT Investment Management
e. Information Management and Access
f. Privacy and Information Security
g. Electronic Signatures
h. Records Management
i. Leveraging the Evolving Internet
6. Government-wide Responsibilities
7. Effectiveness
8. Oversight
9. Authority
10. Definitions
11. Inquiries
Appendix I: Responsibilities for Protecting and Managing Federal Information Resources
1. Introduction
2. Purpose
3. General Requirements
4. Specific Requirements
5. Government-wide Responsibilities
6. Discussion of the Major Provisions in the Appendix
7. Other Requirements
8. References

Appendix II: Responsibilities for Managing Personally Identifiable Information
1. Purpose
2. Introduction
3. Fair Information Practice Principles
4. Senior Agency Official for Privacy
5. Agency Privacy Program
6. Managing PII Collected for Statistical Purposes Under a Pledge of Confidentiality

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1. Introduction
Information and information technology (IT) resources are critical to the U.S. social, political,
and economic well-being. They enable the Federal Government to provide quality services to
citizens, generate and disseminate knowledge, and facilitate greater productivity and
advancement as a Nation. It is important for the Federal Government to maximize the quality
and security of Federal information systems, and to develop and implement uniform and
consistent information resources management policies in order to inform the public and improve
the productivity, efficiency, and effectiveness of agency programs. Additionally, as technology
evolves, it is important that agencies manage information systems in a way that addresses and
mitigates security and privacy risks associated with new information technologies and new
information processing capabilities.
These new information technologies and information processing capabilities also provide
significant opportunities for agencies. The deeply embedded nature of IT in all Federal agency
missions and business processes, and the emergence of the digital economy, combined with the
increasing interconnection of technology and public services, has changed the way we share
information, changed the way we use and view technology, and has forever changed Americans’
expectations. To meet expectations of the American people and facilitate innovation, the Federal
Government must continue to transform itself to embrace and respond to the digital revolution by
developing and maintaining a top-notch workforce and delivering secure, world-class digital
services that serve the public. With IT at the core of nearly everything the Federal Government
does, agencies must continually identify ways to apply new and emerging technologies that can
fundamentally improve the way Government works and delivers services to the American people
in the most cost-effective way possible. Delivering world-class digital services requires the
Federal Government to change its approach to buying, building, and delivering IT and
information. This Circular is designed to help drive the transformation of the Federal
Government and the way it builds, buys, and delivers technology by institutionalizing more agile
approaches intended to facilitate the rapid adoption of changing technologies, in a way that
enhances information security, privacy, and management of information resources across all
Federal programs and services.
2. Purpose
This Circular 1 establishes general policy for the planning, budgeting, governance, acquisition,
and management of Federal information, personnel, equipment, funds, IT resources and
supporting infrastructure and services. The appendices to this Circular also include
responsibilities for protecting Federal information resources and managing personally
identifiable information (PII). While it is the responsibility of all agency leadership, program
managers, and staff to implement the requirements of this Circular, agency heads have ultimate

1

Although this Circular touches on many specific information resources management issues such as privacy,
confidentiality, information quality, dissemination, and statistical policy, those topics are covered more fully in other
Office of Management and Budget (OMB) policies, which are available on the OMB website. Agencies shall
implement the policies in this Circular and those in other OMB policy guidance in a mutually consistent fashion.

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responsibility for ensuring that the requirements of this Circular are implemented for their
agency.
3. Applicability
The requirements of this Circular apply to the information resources management activities of all
agencies 2 of the Executive Branch of the Federal Government. The requirements of this Circular
apply to management activities concerning all information resources in any medium (unless
otherwise noted), including paper and electronic information. When an agency acts as a service
provider, the ultimate responsibility for compliance with applicable requirements of this Circular
is not shifted (to the service provider). Agencies shall describe the responsibilities of service
providers in relevant agreements with the service providers. Agencies are not required to apply
this Circular to national security systems (defined in 44 U.S.C. § 3552), but are encouraged to do
so where appropriate. For national security systems, agencies shall follow applicable statutes,
executive orders, directives, and internal agency policies.
4. Basic Considerations
Federal information is both a strategic asset and a valuable national resource. It enables the
Government to carry out its mission and programs effectively. It provides the public with
knowledge of the Government, society, economy, and environment – past, present, and future.
Federal information is also a means to ensure the accountability of Government, to manage the
Government’s operations, and to maintain and enhance the performance of the economy, the
public health, and welfare. Appropriate access to Federal information significantly enhances the
value of the information and the return on the Nation’s investment in its creation. The following
considerations reflect these principles:
a. The free flow of information between the Government and the public is essential to a
democratic society. Therefore, the management of Federal information resources shall
protect the public’s right of access to Federal information;
b. Government agencies shall be open, transparent, and accountable to the public. Promoting
openness and interoperability, subject to applicable legal and policy requirements, increases
operational efficiencies, reduces costs, improves services, supports mission needs, and
increases public access to valuable Federal information;
c. Making Federal information discoverable, accessible, and usable can fuel entrepreneurship,
innovation, and scientific discovery that improves the lives of Americans, and contributes
significantly to national stability and prosperity, and fosters public participation in
Government;
d. The Federal Government shall provide members of the public with access to public
information on Government websites. This responsibility includes taking affirmative steps to
ensure and maximize the quality, objectivity, utility, and integrity of Federal information
prior to public dissemination, and maintaining processes for addressing requests for
correction of information disseminated publicly;
2

‘Agency’ means any executive agency or department, military department, Federal Government corporation,
Federal Government-controlled corporation, or other establishment in the Executive Branch of the Federal
Government, or any independent regulatory agency.

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e. The open and efficient exchange of scientific and technical Federal information, subject to
applicable security and privacy controls and the proprietary rights of others, fosters
excellence in scientific research and effective use of Federal research and development
resources;
f. Federal information is a strategic asset subject to risks that must be managed to minimize
harm;
g. Protecting an individual’s privacy is of utmost importance. The Federal Government shall
consider and protect an individual’s privacy throughout the information life cycle;
h. While security and privacy are independent and separate disciplines, they are closely related,
and it is essential for agencies to take a coordinated approach to identifying and managing
security and privacy risks and complying with applicable requirements;
i. The design of information collections shall be consistent with the intended use of the
information, and the need for new information shall be balanced against the burden imposed
on the public, the cost of the collection, and any privacy risks;
j. It is essential that the Federal Government minimize the Federal information collection
burden on the public, minimize the costs of its information activities, and maximize the
usefulness of Government information; and
k. Attention to the management of Federal Government records from creation to disposition is
an essential component of sound information resources management that promotes public
accountability. Together with records preservation, it helps protect the Federal
Government’s historical record and safeguards the legal and financial rights of the Federal
Government and the public.
5. Policy
Agencies shall establish a comprehensive approach to improve the acquisition and management
of their information resources by: performing information resources management activities in an
efficient, effective, economical, secure, and privacy-enhancing manner; focusing information
resources planning to support their missions; implementing an IT investment management
process that links to and supports budget formulation and execution; and rethinking and
restructuring the way work is performed before investing in new information systems.
a. Planning and Budgeting
Agencies shall establish agency-wide planning and budgeting processes in accordance with
OMB guidance. As discussed below, important components of planning and budgeting
consist of developing and maintaining a strategy for managing and maintaining their
information resources, referred to as the Information Resource Management (IRM) Strategic
Plan, as well as ensuring effective collaboration between agency leadership on budget
activities.
1) Strategic Planning
In support of agency missions and business needs, and as part of the agency’s overall
strategic and performance planning processes, agencies shall develop and maintain an
IRM Strategic Plan that describes the agency’s technology and information resources
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goals, including but not limited to, the processes described in this Circular. The IRM
Strategic Plan must support the goals of the Agency Strategic Plan required by the
Government Performance and Results Modernization Act of 2010 (GPRA
Modernization Act). The IRM Strategic Plan shall demonstrate how the technology and
information resources goals map to the agency’s mission and organizational priorities.
These goals shall be specific, verifiable, and measurable, so that progress against these
goals can be tracked. The agency shall review its IRM Strategic Plan annually alongside
the Annual Performance Plan reviews, required by the GPRA Modernization Act, to
determine if there are any performance gaps or changes to mission needs, priorities, or
goals. As part of the planning and maintenance of an effective information strategy,
agencies shall meet the following requirements, in addition to all other requirements in
this Circular:
a) Inventories
Agencies shall:
i.

Maintain an inventory3 of the agency’s major information systems, 4 information
holdings, and dissemination products, at the level of detail that OMB and the
agency determine is most appropriate for overseeing and managing the
information resources; and

ii. Maintain an inventory of the agency’s information systems that create, collect,
use, process, store, maintain, disseminate, disclose, or dispose of PII to allow the
agency to regularly review its PII and ensure, to the extent reasonably
practicable, that such PII is accurate, relevant, timely, and complete; and to
allow the agency to reduce its PII to the minimum necessary for the proper
performance of authorized agency functions. 5
b) Information Management
Agencies shall:
i.

Continually facilitate adoption of new and emerging technologies, and regularly
assess the following throughout the life of each information system: the
inventory of the physical and software assets associated with the system 6; the
maintainability and sustainability of the information resources and infrastructure
supporting the system; and actively determine when significant upgrades,

3

The inventory of agency information resources shall include an enterprise-wide data inventory that accounts for
data used in the agency’s information systems.

4

The inventory of major information systems is required in accordance with 44 U.S.C. § 3505(c). All information
systems are subject to the requirements of the Federal Information Security Modernization Act (44 U.S.C. Chapter
35) whether or not they are designated as a major information system.
5

This inventory may be combined with the agency’s inventory of information systems, as described above.

6

Agencies shall ensure that physical devices, software applications, hardware platforms, and systems within the
organization are inventoried initially when obtained and updated on an ongoing basis.

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replacements, or disposition is required to effectively support agency missions
or business functions and adequately protect agency assets; 7 and
ii. Ensure the terms and conditions of contracts and other agreements involving the
processing, storage, access to, transmission, and disposition of Federal
information are linked to the IRM strategic plan goals, and are sufficient to
enable agencies to meet their policy and legal requirements.
c) Risk Management
Agencies shall:
i.

Consider information security, privacy, records management, public
transparency, and supply chain security issues for all resource planning and
management activities throughout the system development life cycle so that
risks are appropriately managed;

ii. Develop plan, in consultation with Chief Information Officers (CIOs), Senior
Agency Officials for Records Management (SAORMs), and Senior Agency
Officials for Privacy (SAOPs), for information systems and components that
cannot be appropriately protected or secured and ensure that such systems are
given a high priority for upgrade, replacement, or retirement; 8
iii. Regularly review and address risk regarding processes, people, and technology;
and
iv. Consult National Institute of Standards and Technology (NIST) Federal
Information Processing Standards (FIPS) and NIST Special Publications (SPs)
(e.g., 500, 800, and 1800 series guidelines).
2) Enterprise Architecture
Agencies shall develop an enterprise architecture (EA) that describes the baseline
architecture, target architecture, and a transition plan to get to the target architecture.
The agency’s EA shall align to their IRM Strategic Plan. The EA should incorporate
agency plans for significant upgrades, replacements, and disposition of information
systems when the systems can no longer effectively support missions or business
functions. The EA should align business and technology resources to achieve strategic
outcomes. The process of describing the current and future state of the agency, and
laying out a plan for transitioning from the current state to the desired future state, helps
agencies to eliminate waste and duplication, increase shared services, close performance
gaps, and promote engagement among Government, industry, and citizens.

7

The assessment process is described in NIST SP 800-53A, Guide for Assessing the Security Controls in Federal
Information Systems and Organizations.

8

Includes hardware, software, or firmware components no longer supported by developers, vendors, or
manufacturers through the availability of software patches, firmware updates, replacement parts, and maintenance
contracts. NIST SP 800-53, Security and Privacy Controls for Federal Information Systems and Organizations,
provides additional guidance on unsupported software components.

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3) Planning, Programming, and Budgeting
Agencies shall, in accordance with the Federal Information Technology Acquisition
Reform Act (FITARA) and related OMB policy: 9
a) Ensure that IT resources are distinctly identified and separated from non-IT
resources during the planning, programming, and budgeting processes in a manner
that affords agency CIOs appropriate visibility and specificity to provide effective
management and oversight of IT resources;
b) Ensure that the agency-wide budget development process includes the CFO, CAO,
and CIO in the planning, programming, and budgeting stages for programs that
include IT resources (not just programs that are primarily information- and
technology-oriented);
c) The agency head, in consultation with the CFO, CAO, CIO, and program leadership,
shall define the processes by which program leadership works with the CIO to plan
an overall portfolio of IT resources that achieve program and business objectives
efficiently and effectively by:
i.

Weighing potential and ongoing IT investments and their underlying capabilities
against other proposed and ongoing IT investments in the portfolio; and

ii. Identifying gaps between planned and actual cost, schedule, and performance
goals for IT investments and developing a corrective action plan to close such
gaps;
d) Ensure that the CIO approves the IT components of any plans, through a process
defined by the agency head that balances IT investments with other uses of agency
funding. Agencies shall also ensure that the CIO is included in the internal planning
processes for how the agency uses information resources to achieve its objectives at
all points in their life cycle, including operations and disposition or migration;
e) Ensure that agency budget justification materials, in their initial budget submission
to OMB, include a statement that affirms:
i.

The CIO has reviewed and approves the IT investments portion of the budget
request;

ii. The SAOP has reviewed the IT investments portion of the budget request to
ensure that privacy requirements, as well as any associated costs, are explicitly
identified and included with respect to any IT resources that will be used to
create, collect, use, process, store, maintain, disseminate, disclose, or dispose of
PII;

9

OMB policy documents can be located at https://www.whitehouse.gov/omb/circulars_default and
https://www.whitehouse.gov/omb/memoranda_default. The Department of Defense (DoD), the Intelligence
Community, and portions of other agencies that operate systems related to national security are subject to only
certain portions of Federal Information Technology Acquisition Reform (FITARA) (Pub. L. 113-291), as provided
for in the statute.

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iii. The CFO and CIO jointly affirm that the CIO had a significant role in reviewing
planned IT support for major program objectives and significant increases and
decreases in IT resources; and
iv. The IT Portfolio includes appropriate estimates of all IT resources included in
the budget request;
f) Ensure that the CFO, CAO, and CIO define agency-wide policy for the level of
detail of planned expenditure reporting for all transactions that include IT resources.
4) Business Continuity Planning
Agencies shall develop a Business Continuity Plan. 10 A Business Continuity Plan to
continue agency operations during times of service disruption is essential. Therefore,
agencies shall develop continuity strategies in order to ensure services and access can be
restored in time to meet the mission needs. Manual workarounds shall be part of the
plan so business can continue while information systems are being restored.
b. Governance
In support of agency missions and business needs, and in coordination with program
managers, agencies shall:
1) Define, implement, and maintain processes, standards, and policies applied to all
information resources at the agency, in accordance with OMB guidance;
2) Require that the CIO, in coordination with appropriate governance boards, defines
processes and policies in sufficient detail to address information resources appropriately.
At a minimum, these processes and policies shall require that:
a) Investments and projects in development are evaluated to determine the applicability
of agile development; 11
b) Open data standards are used to the maximum extent possible when implementing IT
systems;
c) Appropriate measurements are used to evaluate the cost, schedule, and overall
performance variances 12 of IT projects across the portfolio leveraging processes such

10

The Federal Information Security Modernization Act of 2014 (FISMA) (44 U.S.C. Chapter 35) requires each
agency to develop, document, and implement an agency-wide information security program that includes plans and
procedures to ensure continuity of operations for information systems that support the operations and assets of the
agency. For additional information related to continuity planning and contingency planning, see Appendix I.
11

This evaluation shall be conducted as part of the acquisition planning process and involve staff from the CIO of
the department, the implementing program managers, the appropriate contracting office representatives, and other
applicable agency officials;
12

Standard definitions from budget or performance management practices, such as earned value management, shall
be used for cost variance and schedule variance to measure progress.

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as IT investment management, enterprise architecture, and other agency IT or
performance management processes; 13
d) There are agency-wide policies and procedures for conducting IT investment
reviews, operational analyses, or other applicable performance reviews to evaluate
IT resources, including projects in development and ongoing activities;
e) Data and information needs are met through agency-wide data governance policies
that clearly establish the roles, responsibilities, and processes by which agency
personnel manage information as an asset and the relationships among technology,
data, agency programs, strategies, legal and regulatory requirements, and business
objectives; 14 and
f) Unsupported information systems and system components 15 are phased out as
rapidly as possible, and planning and budgeting activities for all IT systems and
services incorporate migration planning and resourcing to accomplish this
requirement;
3) Ensure that the CIO is a member of governance boards that inform decisions regarding
IT resources to provide for early matching of appropriate information resources with
program objectives. The CIO may designate, in consultation with other senior agency
officials, other agency officials to act as their representative to fulfill aspects of this
responsibility so long as the CIO retains accountability;
4) Require that information security and privacy be fully integrated into the system
development process;
5) Conduct TechStat reviews, led by the CIO, or use other applicable performance
measurements to evaluate the use of agency information resources. The CIO may
recommend to the agency head the modification, pause, or termination of any
acquisition, investment, or activity that includes a significant IT component based on the
CIO’s evaluation, within the terms of the relevant contracts and applicable regulations;
6) Establish and maintain a process for the CIO to regularly engage with program managers
to evaluate IT resources supporting each agency strategic objective. It shall be the CIO
and program managers’ shared responsibility to ensure that legacy and ongoing IT
investments are appropriately delivering customer value and meeting the business
objectives of the agency and the programs that support the agency; and
7) Measure performance in accordance with the GPRA Modernization Act and OMB
Circular A-11, Preparation, Submission, and Execution of the Budget.

13

The Federal Acquisition Streamlining Act of 1994 (Pub. L. 103-355) requires agencies to achieve, on average,
ninety percent of the cost and schedule goals established for major and non-major acquisition programs of the
agency without reducing the performance or capabilities of the items being acquired.
14

In accordance with the information management responsibilities outlined in 44 U.S.C. § 3506(b).

15

Includes hardware, software, or firmware components no longer supported by developers, vendors, manufacturers,
or communities through the availability of software patches, firmware updates, replacement parts, and maintenance
contracts. NIST SP 800-53, Security and Privacy Controls for Federal Information Systems and Organizations,
provides additional guidance on unsupported software components.

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c. Leadership and Workforce
Agencies shall:
1) Require that the Chief Human Capital Officer (CHCO), CIO, CAO, and SAOP develop
a set of competency requirements for information resources staff, including program
managers, information security, privacy, and IT leadership positions, and develop and
maintain a current workforce planning process to ensure that the agency can:
a) Anticipate and respond to changing mission requirements;
b) Maintain workforce skills in a rapidly developing IT environment; and
c) Recruit and retain the IT talent needed to accomplish the mission;
2) Ensure that the workforce, which supports the acquisition, management, maintenance,
and use of information resources, has the appropriate knowledge and skills to facilitate
the achievement of the portfolio’s performance goals and, further, evaluate the extent to
which the agency’s executive-level workforce has appropriate information and
technology-related knowledge and skills;
3) Implement innovative approaches and track performance of workforce development
training, including cross-functional training, rotational development and assignments,
and effective training and education used by the private sector, to maintain and enhance
skills or obtain additional skills;
4) Ensure that the CHCO and CIO jointly establish an agency-wide critical element (or
elements) to be included in all component or bureau CIOs’ performance evaluations. In
addition, the CIO shall identify key component or bureau CIOs and provide input to the
rating official for these component or bureau CIOs at the time of the initial summary
rating and for any required progress reviews. The rating official will consider the input
from the CIO when determining the initial summary rating and discuss it with the
component or bureau CIO during progress reviews;
5) Ensure that the CIO is involved in the recruitment, approves the selection, and provides
input for the performance review of any component or bureau CIO, which includes any
component or bureau leader who holds CIO duties but not necessarily the “CIO” title.
The title and responsibilities of current component or bureau CIOs should be designated
or transferred to other agency personnel by the agency head or their designee as
appropriate, and such decisions should take into consideration recommendations from
the agency CIO;
6) Ensure that the SAOP is involved in assessing and addressing the hiring, training, and
professional development needs of the agency with respect to privacy; and
7) Ensure that the CIO, CHCO, SAOP, and other hiring managers take advantage of
flexible hiring authorities for specialized positions, as established by the Office of
Personnel Management (OPM).
d. IT Investment Management
1) Acquisition of Information Technology and Services
Agencies shall:
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a) Make use of adequate competition, analyze risks (including supply chain risks)
associated with potential contractors and the products and services they provide, and
allocate risk responsibility between Government and contractor when acquiring IT;
b) Conduct definitive technical, cost, and risk analyses of alternative design
implementations, including consideration of the full life cycle costs of IT products
and services, including but not limited to, planning, analysis, design,
implementation, sustainment, maintenance, re-competition, and retraining costs,
scaled to the size and complexity of individual requirements; 16
c) Consider existing Federal contract solutions or shared services when developing
planned information systems, available within the same agency, from other agencies,
or from the private sector to meet agency needs to avoid duplicative IT investments;
d) Acquire IT products and services in accordance with Government-wide
requirements; 17
e) Ensure that decisions to improve existing information systems with customdeveloped solutions or develop new information systems are initiated only when no
existing alternative private sector or governmental source can efficiently meet the
need, taking into account long-term sustainment and maintenance;
f) Structure acquisitions for major IT investments into useful segments, with a narrow
scope and brief duration, in order to reduce risk, promote flexibility and
interoperability, increase accountability, and better match mission need with current
technology and market conditions;
g) To the extent practicable, modular contracts for IT, including orders for increments
or useful segments of work, should be awarded within 180 days after the solicitation
is issued. If award cannot be made within 180 days, agencies shall consider
cancelling the solicitation. The IT acquired should be delivered within 18 months
after the solicitation resulting in award of the contract was issued; 18
h) Align IT procurement requirements with larger agency strategic goals;
i) Promote innovation in IT procurements, including conducting market research in
order to maximize utilization of innovative ideas; and
j) Include security, privacy, accessibility, records management, and other relevant
requirements in solicitations.
2) Agency Approval
Agencies shall ensure that all acquisition strategies, plans, and requirements (as
described in FAR Part 7), or interagency agreements (such as those used to support
16
Other acquisition planning provisions are set forth in the Federal Acquisition Regulation (FAR) Subpart 7.1,
Acquisition Plans, and Part 10, Market Research.
17

For information regarding Government-wide requirements, refer to OMB policy and the Federal Acquisition
Regulation. For the acquisition of Personal Identity Verification (PIV) and public key infrastructure (PKI) products
and services, also refer to the FIPS 201 Evaluation Program at https://www.idmanagement.gov.
18

Pursuant to Public Contracts statute (41 U.S.C. § 2308).

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purchases through another agency) that include IT are reviewed and approved by the
purchasing agency’s CIO. These approvals shall consider the following factors:
a) Alignment with mission and program objectives in coordination with program
leadership;
b) Appropriateness with respect to the mission and business objectives supported by the
IRM Strategic Plan;
c) Inclusion of innovative solutions;
d) Appropriateness of contract type for IT-related resources;
e) Appropriateness of IT-related portions of statement of needs or statement of work;
f) Ability to deliver functionality in short increments;
g) Inclusion of Government-wide IT requirements, such as information security; and
h) Opportunities to migrate from end-of-life software and systems, and to retire those
systems.
3) Investment Planning and Control
Agencies are responsible for establishing a decision-making process that shall cover the
life of each information system and include explicit criteria for analyzing the projected
and actual costs, benefits, and risks, including information security and privacy risks,
associated with the IT investments. Agencies shall designate IT investments according
to relevant statutes, regulations, and guidance in OMB Circular A-11, and execute
processes commensurate with the size, scope, duration, and delivery risk of the
investment. The IT investment processes shall encompass planning, budgeting,
procurement, management, and assessment. For further guidance related to investment
planning, refer to OMB Circular A-11, including the Capital Programming Guide. At a
minimum, agencies shall ensure that:
a) All IT resources (see “Information Technology Resources” definition) are included
in IT investment planning documents or artifacts;
b) Decisions related to major IT investments are supported by business cases with
appropriate evidence;
c) IT investments implement an agile development approach, as appropriate; 19
d) IT investments support and enable core mission and operational functions and
processes related to the agency’s missions and business requirements;
e) IT capital investment plans and budgetary requests are reviewed to ensure that
Government-wide requirements, as well as any associated costs, are explicitly
identified and included, with respect to any IT resources. This includes IT resources
that will be used to create, collect, use, process, store, maintain, disseminate,
disclose, or dispose of PII; and

19

For additional information, refer to OMB memoranda at https://www.whitehouse.gov/omb/memoranda_default.

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f) Decisions to improve, enhance, or modernize existing IT investments or to develop
new IT investments are made only after conducting an alternatives analysis that
includes both government-provided (internal, interagency, and intra-agency where
applicable) and commercially available options, and the option representing the best
value to the Government has been selected.
4) Selection Criteria and Requirements
Agencies shall consider the following factors when analyzing IT investments:
a) Qualitative and quantitative research methods are used to determine the goals, needs,
and behaviors of current and prospective managers and users of the service to
strengthen the understanding of requirements;
b) All decisions concerning the selection of information system technologies and
services – including decisions to acquire or develop custom or duplicative solutions
– shall be merit-based and consider factors such as, but not limited to, ability to meet
operational or mission requirements, total life cycle cost of ownership, performance,
security, interoperability, privacy, accessibility, ability to share or reuse, resources
required to switch vendors, and availability of quality support. Consistent with the
FAR, contracts for custom software development are to include contractual
provisions that reaffirm the right to reuse the software throughout the Federal
Government;
c) Agencies shall consider use of suitable existing Federal information technology
resources and commercially-available solutions in order to ensure effective
management of Federal resources. Consistent with law and regulation, agencies
should consider and evaluate the suitability of existing Federal information
technologies and related services, including software, Federal shared services, and
commercially-available solutions before embarking upon new developments of
software and information technologies; and
d) Information systems security levels are commensurate with the impact that may
result from unauthorized access, use, disclosure, disruption, modification, or
destruction of such information consistent with NIST standards and guidelines.
5) IT Investment Design and Management
Agencies shall implement the following requirements:
a) Information systems and processes must support and maximize interoperability and
access to information, where appropriate, by using documented, scalable, and
continuously available application programming interfaces and open machinereadable formats;
b) IT investments must facilitate interoperability, application portability, and scalability
across networks of heterogeneous hardware, software, and communications
platforms;
c) Information systems, technologies, and processes shall facilitate accessibility under
the Rehabilitation Act of 1973, as amended; in particular, see specific electronic and

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IT accessibility requirements commonly known as “section 508” requirements (29
U.S.C. § 794d);
d) Records management functions and retention and disposition requirements must be
fully incorporated into information life cycle processes and stages, including the
design, development, implementation, and decommissioning of information systems,
particularly Internet resources to include storage solutions and cloud-based services
such as software as a service, platform as a service, and infrastructure as a service;
and
e) IT investments use an Earned Value Management System (EVMS) and Integrated

Baseline Review, when appropriate, as required by FAR Subpart 34.2. When an
EVMS is required, agencies must have a documented process for accepting a
contractor’s EVMS. Agencies are encouraged to share information about their
acceptance process with other agencies and to consider recognizing each other’s
acceptance of an EVMS so that a contractor is not required to complete a duplicative
process. When an EVMS is not required, implement a baseline validation process as
part of an overall investment risk management strategy consistent with OMB
guidance.
e. Information Management and Access
1) Agencies shall incorporate the following steps, as appropriate, in planning, budgeting,
governance, and other policies:
a) Federal information is properly managed throughout its life cycle, including all
stages through which the information passes, such as: creation, collection, use,
processing, storage, maintenance, dissemination, disclosure, and disposition;
b) Federal information is managed by making information accessible, discoverable, and
usable by the public to the extent permitted by law and subject to privacy, security
(which includes confidentiality), or other valid restrictions pertaining to access, use,
dissemination, and disclosure;
c) Federal information is managed consistent with applicable records retention and
disposition requirements;
d) Federal information and information systems are managed in a manner that identifies
and mitigates privacy and security risks; and
e) Federal information is managed with clearly designated roles and responsibilities to
promote effective and efficient design and operation of information resources
management processes within their agency.
2) Agencies have a responsibility to provide information to the public consistent with their
missions and subject to Federal law and policy. Agencies will discharge this
responsibility by:
a) Publishing public information online in a manner that promotes analysis and reuse
for the widest possible range of purposes, meaning that the information is publicly
accessible, machine-readable, appropriately described, complete, and timely. This

14

includes providing such public information in a format(s) accessible to employees
and members of the public with disabilities; 20
b) Avoiding establishing, or permitting others to establish on their behalf, exclusive,
restricted, or other distribution arrangements that interfere with the agency’s ability
to disseminate its public information on a timely and equitable basis;
c) Avoiding charging fees or royalties for public information or establishing
unnecessary restrictions on the resale or re-dissemination of public information by
the public. Agencies shall not, unless specifically authorized by statute, establish
fees that exceed the cost of dissemination to the public, restrict or regulate the use,
resale, or re-dissemination of public information by the public; or establish any
mechanism that interferes with the timely and equitable availability of public
information to the public; 21
d) As appropriate, making Government publications available to depository libraries
through the Government Publishing Office regardless of format; 22
e) Taking advantage of all dissemination channels, including Federal, State, local,
tribal, and territorial governments, libraries and educational institutions, for-profit
and nonprofit organizations, and private sector entities, in discharging agency
information dissemination responsibilities; and
f) Considering the impact of providing agency information and services over the
Internet for individuals who do not own computers or lack Internet access and, to the
extent practicable, pursuing additional or alternative modes of delivery to ensure that
such information and services are accessible to, and their availability is not
diminished for, such individuals.
3) Agencies shall establish policies, procedures, and standards that enable data governance
so that information is managed and maintained according to relevant statute, regulations,
and guidance.
4) Agencies shall collect or create information in a way that supports downstream
interoperability among information systems and streamlines dissemination to the public,
where appropriate, by creating or collecting all new information electronically by
default, in machine-readable open formats, using relevant data standards, that upon
creation includes standard extensible metadata in accordance with OMB guidance.
5) Agencies shall include appropriate provisions in contracts, and other agreements, to
encourage recipients of Federal funding to maximize access to data developed under an
award and to prepare data management plans that describe data to be created in funded
programs and approaches for long-term preservation and access to created data.

20

Pursuant to Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794d).

21

Pursuant to the Paperwork Reduction Act (PRA) of 1980, as amended by the Paperwork Reduction Act of 1995
(44 U.S.C. Chapter 35).
22

Pursuant to the Depository Library Act of 1962 (44 U.S.C. Chapter 19).

15

6) Agencies shall ensure that there is a mechanism for the public to provide feedback about
public information.
7) Agencies shall manage information in accordance with the following principles as
appropriate:
a) Providing notice of Federal agency practices for the creation, collection, use,
processing, preservation, storage, maintenance, disclosure, dissemination, and
disposal of information, as appropriate;
b) Providing adequate notice when initiating, substantially modifying, or terminating
dissemination of significant information that the public may be using;
c) Identifying the source of the information disseminated to the public, if from outside
the agency, where practicable;
d) Considering target audiences of Federal information when determining format,
frequency of update, and other information management decisions;
e) Considering the impact of decisions and actions in each stage of the information life
cycle on other stages;
f) Considering the effects of information management actions on members of the
public and State, local, tribal and territorial governments and their access to Federal
information and ensure consultation with the public and those governments as
appropriate;
g) Seeking to satisfy new information needs through interagency or intergovernmental
sharing of information, or through nongovernmental sources, where lawful and
appropriate, before creating or collecting new information; and
h) Complying with all applicable statutes and policies governing the disclosure or
dissemination of information, including those related to the quality, privacy, security,
accessibility, and other valid access, use, and dissemination restrictions.
f. Privacy and Information Security 23
1) Privacy
Agencies shall:
a) Establish and maintain a comprehensive privacy program that ensures compliance
with applicable privacy requirements, develops and evaluates privacy policy, and
manages privacy risks; 24
b) Designate an SAOP who has agency-wide responsibility and accountability for
developing, implementing, and maintaining an agency-wide privacy program to
23

Although this section includes requirements for protecting Federal information resources, this area is covered
more fully in the Appendices to this Circular.
24

When considering privacy risks, privacy programs shall consider the risks to an individual or individuals
associated with the agency’s creation, collection, use, processing, storage, maintenance, dissemination, disclosure,
or disposal of their PII.

16

ensure compliance with all applicable statutes, regulations, and policies regarding the
creation, collection, use, processing, storage, maintenance, dissemination, disclosure,
and disposal of PII by programs and information systems, developing and evaluating
privacy policy, and managing privacy risks at the agency; 25
c) Monitor Federal law, regulation, and policy for changes that affect privacy;
d) Limit the creation, collection, use, processing, storage, maintenance, dissemination,
and disclosure of PII to that which is legally authorized, relevant, and reasonably
deemed necessary for the proper performance of agency functions;
e) To the extent reasonably practicable, ensure that PII is accurate, relevant, timely, and
complete, and reduce all PII to the minimum necessary for the proper performance of
authorized agency functions;
f) Take steps to eliminate unnecessary collection, maintenance, and use of Social
Security numbers, and explore alternatives to the use of Social Security numbers as a
personal identifier;
g) Comply with all applicable privacy-related laws, including the requirements of the
Privacy Act, 26 and ensure that the Privacy Act system of records notices are
published, revised, and rescinded, as required;
h) Maintain all records with PII in accordance with applicable records retention or
disposition schedules approved by the National Archives and Records
Administration (NARA);
i) Conduct privacy impact assessments when developing, procuring, or using IT, in
accordance with the E-Government Act, 27 and make the privacy impact assessments
available to the public in accordance with OMB policy;
j) Maintain and post privacy policies on all agency websites, mobile applications, and
other digital services, in accordance with the E-Government Act and OMB policy;
and
k) Ensure that the SAOP and the agency’s privacy personnel closely coordinate with
the agency CIO, senior agency information security officer, and other agency offices
and officials, as appropriate.

25

The SAOP shall be designated by the head of the agency, pursuant to Executive Order 13719, Establishment of
the Federal Privacy Council (2016), and OMB guidance.

26

Agencies should also consult OMB policies on privacy, and OMB Circular A-108, Federal Agency
Responsibilities for Review, Reporting, and Publication under the Privacy Act.
27

Section 208(b) of the E-Government Act requires agencies, absent an applicable exception under that section, to
conduct a PIA before: (i) developing or procuring IT that collects, maintains, or disseminates information that is in
an identifiable form; or (ii) initiating a new collection of information that – (I) will be collected, maintained, or
disseminated using IT; and (II) includes any information in an identifiable form permitting the physical or online
contacting of a specific individual, if identical questions have been posed to, or identical reporting requirements
imposed on, 10 or more persons, other than agencies, instrumentalities, or employees of the Federal Government.

17

2) Information Security
To provide proper safeguards, agencies shall:
a) Ensure that the CIO designates a senior agency information security officer to
develop and maintain an agency-wide information security program in accordance
with the Federal Information Security Modernization Act of 2014 (FISMA);
b) Protect information in a manner commensurate with the risk that would result from
unauthorized access, use, disclosure, disruption, modification, or destruction of such
information; and
c) Implement security policies issued by OMB, as well as requirements issued by the
Department of Commerce, the Department of Homeland Security (DHS), the
General Services Administration (GSA), and the Office of Personnel Management
(OPM). This includes applying the standards and guidelines contained in the NIST
FIPS, NIST SPs (e.g., 800 series guidelines), and where appropriate and directed by
OMB, NIST Interagency or Internal Reports (NISTIRs). 28
g. Electronic Signatures 29
To support the transition to electronic government, agencies shall:
1) Allow individuals or entities that deal with the agencies the option to submit information
or transact with the agency electronically, when practicable, and for agencies to maintain
records electronically, when practicable. Electronic records and their related electronic
signatures are not to be denied legal effect, validity, or enforceability merely because
they are in electronic form; 30
2) Promote the use of electronic contract formation, signatures, and recordkeeping in private
commerce by establishing legal equivalence between: contracts written on paper and
contracts in electronic form; pen-and-ink signatures and electronic signatures; and other
legally required written documents (termed “records”) and the same information in
electronic form; and 31

28

NISTIRs describe research of a technical nature of interest to a specialized audience.

29

In support of Government Paperwork Elimination Act (GPEA) and Electronic Signatures in Global and National
Commerce Act (E-Sign), the Federal Chief Information Officers Council maintains guidance on use of Electronic
Signatures (E-Signatures) in Federal organization transactions. The Federal Chief Information Officers Council
guidance, Use of Electronic Signatures in Federal Organization Transactions, can be located at
https://www.idmanagement.gov. This guidance expands upon OMB guidance.
30

Pursuant to the Government Paperwork Elimination Act of 1998 (44 U.S.C. § 3504).

31

Pursuant to E-Sign (15 U.S.C. Chapter 96). E-Sign applies broadly to commercial, consumer, and business
transactions affecting interstate or foreign commerce, and to transactions regulated by both Federal and State
Government.

18

3) Develop and implement processes to support use of digital signatures, a form of
electronic signature, for employees and contractors. 32
h. Records Management
Agencies shall:
1) Designate a senior agency official for records management (SAORM) who has overall
agency-wide responsibility for records management;
2) Institute records management programs that provide documentation of agency
activities; 33
3) Manage electronic records in accordance with Government-wide requirements. This
includes:
a) Managing all permanent electronic records electronically to the fullest extent
possible for eventual transfer and accessioning by NARA in an electronic format;
and
b) Managing all email records electronically and retaining them in an appropriate
electronic system that supports records management and litigation requirements,
including the capability to identify, retrieve, and retain the records for as long as they
are needed;
4) Ensure the ability to access, retrieve, and manage records throughout their life cycle
regardless of form or medium;
5) Ensure agency records managed by the SAORM are treated as information resources and
follow the requirements in this Circular;
6) Establish and obtain the approval of the Archivist of the United States for retention
schedules for Federal records in a timely fashion;
7) Ensure the proper and timely disposition of Federal records in accordance with a
retention schedule approved by the Archivist of the United States; and
8) Provide training and guidance, as appropriate, to all agency employees and contractors
regarding their Federal records management responsibilities.
i. Leveraging the Evolving Internet
In a global and connected economy, it is essential for the United States and the Federal
Government to strive to ensure that Internet-based technologies remain competitive. The
Federal Government needs to continue to lead in innovation, contribute to the free flow of
information, participate in an open and available market, and do this in a way that is scalable
and secure. Networking demands, escalating with the continued emergence of connecting
technologies, has grown well beyond initial capabilities. The use of the newest Internet
Protocol (currently, Internet Protocol Version 6 [IPv6]) is an essential part of accomplishing
32

Digital signatures can help agencies streamline mission or business processes and transition manual processes to
more automated processes to include, for example, online transactions.
33

Additional information regarding adequate and proper documentation is available in 36 C.F.R. § 1222.22.

19

these goals and ensuring that the network infrastructure can meet our needs for growing
capacity, security, and privacy, and keep the United States competitive in the ever-escalating
global electronic economy. Therefore, agencies shall:
1) Implement agency-wide processes requiring that all IT acquisitions using Internet
Protocol conform to the FAR; and 34
2) Ensure that all public-facing Internet services and enterprise networks fully support the
newest version of Internet Protocol as required by OMB policy.
6. Government-wide Responsibilities
a. Department of Commerce
The Secretary of Commerce shall:
1) Develop and issue standards and guidelines for the security and privacy of information
in Federal information systems and systems which create, collect, process, store,
transmit, disseminate, or dispose of information on behalf of the Federal Government; 35
2) Provide OMB and the agencies with scientific and technical advisory services relating to
the development and use of IT; 36
3) Conduct studies and evaluations concerning telecommunications technology, and the
improvement, expansion, testing, operation, and use of Federal telecommunications
systems, and advise the Director of OMB and appropriate agencies of the
recommendations that result from such studies; 37
4) Develop, in consultation with the Secretary of State and the Director of OMB, plans,
policies, and programs relating to international telecommunications issues affecting
Federal information activities; 38
5) Identify needs for standardization of telecommunications and information processing
technology, and develop standards, in consultation with the Secretary of Defense and the
Administrator of General Services, to ensure efficient application of such technology; 39

34

When acquiring information technology using Internet Protocol, agencies must include the appropriate Internet
Protocol compliance requirements in accordance with § 11.002(g) of the FAR. For
additional information, refer to https://www.acquisition.gov/.
35

National Institute of Standards and Technologies (NIST) Act, 15 U.S.C. § 278g-3.

36

Pursuant to the NIST Act (15 U.S.C. § 278g-3).

37
Pursuant to the National Telecommunications and Information Administration (NTIA) Organization Act, as
amended (47 U.S.C. § 902(b)(2)(F)).
38

Pursuant to the NTIA Organization Act, as amended (47 U.S.C. §902(b)(2)(G)).

39

Pursuant to the NIST Act, 15 U.S.C. §§ 272(b), 278g-3, and OMB A-119, Federal Participation in the
Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities.

20

6) Ensure that the Federal Government is represented in the development of national and
international (in consultation with the Secretary of State) IT standards, and advise the
Director of OMB on such activities; 40
7) Evaluate new information technologies to assess their security vulnerabilities, with
technical assistance from the Department of Defense (DOD) and DHS;
8) Solicit and consider the recommendations of the Information Security and Privacy
Advisory Board regarding such standards and guidelines; 41 and
9) Lead the development of a Cybersecurity Framework to reduce cyber risks to critical
infrastructure pursuant to Executive Order 13636, Improving Critical Infrastructure
Cybersecurity.
b. Department of Homeland Security
The Secretary of Homeland Security shall: 42
1) Perform its responsibilities under FISMA, including assisting OMB in carrying out its
statutory authorities and functions of information security oversight and policy
responsibilities; 43
2) Develop and oversee the implementation of binding operational directives pursuant to
FISMA; 44
3) Monitor agency implementation of information security policies and practices;
4) Convene meetings with senior agency officials to help ensure effective implementation
of information security policies and procedures;
5) Coordinate Government-wide efforts on information security policies and practices,
including consultation with the Federal Chief Information Officers Council, and the
Director of NIST;
6) Provide operational and technical assistance to agencies in implementing policies,
principles, standards, and guidelines on information security, including implementation
of standards promulgated under 40 U.S.C. § 11331, including by:
a) Operating the Federal information security incident center established under 44
U.S.C. § 3556;
b) Upon request by an agency, deploying technology to assist the agency to
continuously diagnose and mitigate cyber threats and vulnerabilities, with or without
reimbursement;

40

Pursuant to NIST Act, 15 U.S.C. §§ 272(b), 273, 278g–3 and OMB A-119, Federal Participation in the
Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities.

41

Pursuant to the National Institute of Standards and Technology Act (15 U.S.C. §278g–4).

42

Pursuant to FISMA (44 U.S.C. § 3553).

43

FISMA, 44 U.S.C. § 3553(b)(1).

44

FISMA, 44 U.S.C. § 3553(b)(2).

21

c) Compiling and analyzing data on agency information security; and
d) Developing and conducting targeted operational evaluations, including threat and
vulnerability assessments, on the information systems;
7) Consult with the Director of NIST regarding any binding operational directives that
implements the standards and guidelines developed by NIST;
8) Coordinate the development of binding operational directives and the oversight of the
implementation of such directives with OMB to ensure consistency with OMB policies;
9) Ensure that binding operational directives do not conflict with the guidelines issued
under 40 U.S.C. § 11331;
10) Take other actions as the Director of OMB or the Secretary, in consultation with the
Director of OMB, may determine necessary to carry out the implementation of effective
agency information security policies and practices for information systems;
11) Manage Government-wide information security programs and provide and operate
Federal information security shared services, in coordination with OMB and in
accordance with OMB policies;
12) Provide, as appropriate, intelligence and other information about cyber threats,
vulnerabilities, and incidents to agencies to assist in risk assessments conducted under
FISMA; 45 and
13) Solicit and consider the recommendations of the Information Security Privacy Advisory
Board, established by the National Institute of Standards and Technology Act (NIST
Act). 46
c. Federal Chief Information Officers Council (Federal CIO Council)
Pursuant to the E-Government Act of 2002, the Federal CIO Council shall: 47
1) Develop recommendations for OMB on Government information resources management
policies and requirements;
2) Share experiences, ideas, best practices, and innovative approaches related to
information resources management;
3) Assist OMB in the identification, development, and coordination of multiagency projects
and other innovation initiatives to improve Federal Government performance through
use of IT;
4) Promote the development and use of common performance measures for agency
information resources management, as further described in statute;

45

44 U.S.C. § 3556(a)(4).

46

Pursuant to DHS current practices.

47

E-Government Act of 2002 (44 U.S.C. § 3603).

22

5) Work as appropriate with NIST and OMB to develop recommendations on IT standards
developed under the NIST Act and promulgated under section 11331 of title 40, and
maximize the use of commercial standards, as further described in statute;
6) Work with OPM to assess and address the hiring, training, classification, and
professional development needs of the Federal Government related to information
resources management;
7) Work with the Archivist of the United States to assess how the Federal Records Act can
be addressed effectively by Federal information resources management activities; and
8) Solicit perspectives from the Chief Financial Officers Council, Federal Acquisition
Officers Council, Chief Human Capital Officers’ Council, Budget Officers Advisory
Council, and other key groups in the Federal Government, as well as industry, academia,
and other Federal, State, local, tribal and territorial governments, on matters of concern
to the Council as appropriate.
d. Federal Privacy Council
Pursuant to Executive Order 13719, the Federal Privacy Council shall: 48
1) Develop recommendations for OMB on Federal Government privacy policies and
requirements;
2) Coordinate and share ideas, best practices, and approaches for protecting privacy and
implementing appropriate privacy safeguards;
3) Assess and recommend how best to address the hiring, training, and professional
development needs of the Federal Government with respect to privacy matters;
4) Perform other privacy-related functions, consistent with law, as designated by the Chair
of the Federal Privacy Council; and
5) In performing its duties, engage in appropriate coordination as described in Executive
Order 13719. 49

48

Executive Order 13719, Establishment of the Federal Privacy Council (2016).

49

Executive Order 13719, Establishment of the Federal Privacy Council (2016 )at § 4(d), “Coordination”:
(i) The Chair and the Privacy Council shall coordinate with the Federal Chief Information Officers Council
(CIO Council) to promote consistency and efficiency across the executive branch when addressing privacy
and information security issues. In addition, the Chairs of the Privacy Council and the CIO Council shall
coordinate to ensure that the work of the two councils is complementary and not duplicative.
(ii) The Chair and the Privacy Council should coordinate, as appropriate, with such other interagency councils
and councils and offices within the Executive Office of the President, as appropriate, including the
President’s Management Council, the Chief Financial Officers Council, the President’s Council on Integrity
and Efficiency, the National Science and Technology Council, the National Economic Council, the Domestic
Policy Council, the National Security Council staff, the Office of Science and Technology Policy, the
Interagency Council on Statistical Policy, the Federal Acquisition Regulatory Council, and the Small Agency
Council.

23

e. General Services Administration
The Administrator of General Services shall:
1)

Provide a Government-wide network services contract that leverages shared solutions
for many agencies; 50

2) Ensure that contract vehicles and services made available to agencies are cost-effective
and provide for capabilities that are consistent with Government-wide requirements; 51
3) Assist OMB in setting strategic direction for electronic government and overseeing
Government-wide implementation, and recommend changes relating to Governmentwide strategies and priorities; 52
4) Promote innovative uses of IT by agencies, particularly initiatives involving multiagency
collaboration, through support of pilot projects, research, experimentation, and the use of
innovative technologies; 53
5) Maintain a Federal public key infrastructure (PKI) framework to allow efficient
interoperability among agencies when using digital certificates; 54 and
6) Ensure that effective controls are in place to protect the confidentiality, integrity, and
availability of the Federal PKI framework components managed and overseen by the
agency, to include performing information security continuous monitoring of the Federal
PKI.
f. National Archives and Records Administration
The Archivist of the United States shall:
1) Administer the Federal Records Act and NARA regulations (36 CFR Subchapter B—
Records Management); 55
2) Develop regulations relating to electronic records management; 56
3) Work with agencies to ensure the transfer of permanent Federal electronic records to the
National Archives of the United States in digital or electronic form to the greatest extent
possible; 57
50
Pursuant to the Clinger-Cohen Act (also known as the “Information Technology Management Reform Act of
1996”) (40 U.S.C. § 11314(b)).
51

Pursuant to the Clinger-Cohen Act (also known as the “Information Technology Management Reform Act of
1996”) (40 U.S.C. §§ 11302, 11314(a)).
52

Pursuant to the E-Government Act of 2002 (44 U.S.C. § 3602).

53

Pursuant to the E-Government Act of 2002 (44 U.S.C. § 3602).

54

Federal PKI provides the government with a common infrastructure to administer digital certificates and publicprivate key pairs, including the ability to issue, maintain, and revoke public key certificates.
55

Pursuant to the Federal Records Act of 1950, as amended, codified (44 U.S.C. Chapters 21, 29, 31, 33).

56

Pursuant to the Federal Records Act of 1950, as amended, codified (44 U.S.C. Chapters 31 and 33).

57

Pursuant to the Federal Records Act of 1950, as amended, codified (44 U.S.C. Chapters 21, 29, 31, 33).

24

4) Ensure agency compliance with records management requirements, provide records
management training, and facilitate public access to high-value Government records; 58
and
5) Serve as the Executive Agent for the Controlled Unclassified Information (CUI)
program. 59
g. Office of Personnel Management
The Administrator of the Office of Personnel Management shall: 60
1) Analyze, on an ongoing basis, the workforce needs of the Federal Government related to
IT and information resources management, in conjunction with relevant agencies;
2) Identify training needs of the Federal Government workforce related to IT and
information resources management;
3) Oversee the development of curricula, training methods, and training priorities that
correspond to the projected personnel needs related to IT and information resources
management; and
4) Assess the training of employees in IT disciplines to address information resources
management needs.
7. Effectiveness
This Circular is not intended to, and does not, create any right or benefit, substantive or
procedural, enforceable at law or in equity by any party against the United States, its
departments, agencies, or entities, its officers, employees, or agents, or any other person.
8. Oversight
The Director of OMB shall use IT planning reviews, fiscal budget reviews, information
collection reviews, management reviews, and such other measures as the Director deems
necessary to evaluate the adequacy and efficiency of each agency’s information resources
management and compliance with this Circular.
The Director of OMB may, consistent with statute and upon written request of an agency, grant a
waiver from particular requirements of this Circular. Requests for waivers must detail the
reasons why a particular waiver is sought, identify the duration of the waiver sought, and include
a plan for the prompt and orderly transition to full compliance with the requirements of this
Circular. Notice of each waiver request must be published promptly by the agency in the Federal
Register, with a copy of the waiver request made available to the public on request.

58

Pursuant to the Federal Records Act of 1950, as amended, codified (44 U.S.C. Chapters 21, 29, 31, 33).

59

Pursuant to Executive Order 13556, Controlled Unclassified Information.

60

Pursuant to the E-Government Act of 2002 (44 U.S.C. § 3501 note; Pub. L. 107–347, § 209(b)(1)).

25

9. Authority
OMB issues this Circular pursuant to the Clinger-Cohen Act (also known as the “Information
Technology Management Reform Act of 1996”) (40 U.S.C. § 11101-11704); E-Government Act
of 2002 (44 U.S.C. Chapters 35 and 36); Federal Information Security Modernization Act of
2014 (44 U.S.C. Chapter 35, Subchapter II); Federal Information Technology Acquisition
Reform Act (FITARA) (Pub. L. 113-291) 61; Paperwork Reduction Act (PRA) of 1980, as
amended by the Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35); Privacy Act of 1974,
as amended (5 U.S.C. § 552a); Digital Accountability and Transparency Act of 2014 (Pub. L.
113-101); Electronic Signatures in Global and National Commerce Act (E-Sign) (15 U.S.C.
Chapter 96); Government Paperwork Elimination Act of 1998 (44 U.S.C. § 3504); Government
Performance and Results Act (GPRA) of 1993, as amended by the Government Performance and
Results Modernization Act (GPRA Modernization Act) of 2010 (5 U.S.C. § 306 and 31 U.S.C.
§§ 1115 et seq.); Office of Federal Procurement Policy Act (41 U.S.C. Chapter 7); Budget and
Accounting Procedures Act of 1950, as amended (31 U.S.C. Chapter 11); Chief Financial
Officers Act (31 U.S.C. § 3512 et seq.); and Executive Order 13719, Establishment of the
Federal Privacy Council (2016).
10. Definitions
a. The following definitions are applicable within this policy:
1) ‘Accessibility’ means information technology products or services that are in full
compliance with the standards of section 508 of the Rehabilitation Act of 1973. 62
2) ‘Adequate security’ means security protections commensurate with the risk resulting
from the unauthorized access, use, disclosure, disruption, modification, or destruction of
information. This includes ensuring that information hosted on behalf of an agency and
information systems and applications used by the agency operate effectively and provide
appropriate confidentiality, integrity, and availability protections through the application
of cost-effective security controls.
3) ‘Agency’ means any executive agency or department, military department, Federal
Government corporation, Federal Government-controlled corporation, or other
establishment in the Executive Branch of the Federal Government, or any independent
regulatory agency.
4) ‘Agency Strategic Plan’ means a plan that provides general and long-term goals that the
agency aims to achieve, the actions the agency will take to realize those goals, the

61
Title VIII, Subtitle D of the National Defense Authorization Act (NDAA) for Fiscal Year 2015, Pub. L. 113-291.
Further references in the text that refer to “FITARA” refer to these sections.
62

The United States Architectural and Transportation Barriers Compliance Board’s (Access Board) Information and
Communication Technology Standards and Guidelines for information and communications technologies (ICT),
known as the Section 508 Standards. The 508 standards apply to ICT developed, procured, maintained, or used by
Federal agencies covered by section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794d), as amended.
Accessibility also refers to the guidelines for telecommunications equipment and customer premises equipment
covered by Section 255 of the Communications Act of 1934 (47 U.S.C. § 151 et seq.).

26

strategies planned, how the agency will deal with challenges and risks that may hinder
achieving results, and the approaches it will use to monitor its progress. 63
5) ‘Agile Development’ means a development methodology that uses an iterative approach
to deliver solutions incrementally through close collaboration and frequent reassessment.
6) ‘Authorization to Operate’ means the official management decision given by a senior
Federal official or officials to authorize operation of an information system and to
explicitly accept the risk to agency operations (including mission, functions, image, or
reputation), agency assets, individuals, other organizations, and the Nation based on the
implementation of an agreed-upon set of security and privacy controls. Authorization
also applies to common controls inherited by agency information systems.
7) ‘Authorization boundary’ means all components of an information system to be
authorized for operation by an authorizing official. This excludes separately authorized
systems to which the information system is connected. 64
8) ‘Authorization package’ means the essential information that an authorizing official uses
to determine whether to authorize the operation of an information system or the use of a
designated set of common controls. At a minimum, the authorization package includes
the information system security plan, privacy plan, security control assessment, privacy
control assessment, and any relevant plans of action and milestones.
9) ‘Authorizing official’ means a senior Federal official or executive with the authority to
authorize (i.e., assume responsibility for) the operation of an information system or the
use a designated set of common controls at an acceptable level of risk to agency
operations (including mission, functions, image, or reputation), agency assets,
individuals, other organizations, and the Nation.
10) ‘Binding Operational Directive’ means a compulsory direction from the Department of
Homeland Security to an agency that is for the purposes of safeguarding Federal
information and information systems from a known or reasonably suspected information
security threat, vulnerability, or risk; shall be in accordance with policies, principles,
standards, and guidelines issued by the Director of the Office of Management and
Budget; and may be revised or repealed by the Director if the direction issued on behalf
of the Director is not in accordance with policies and principles developed by the
Director (44 U.S.C. § 3552).
11) ‘Business Continuity Plan’ means a plan that focuses on sustaining an organization’s
mission or business processes during and after a disruption, and may be written for

63

For additional information, refer to the Government Performance and Results Act (GPRA) of 1993, as amended
by the Government Performance and Results Modernization Act (GPRA Modernization Act) of 2010 (5 U.S.C. §
306 and 31 U.S.C. § 1115 et seq.); and OMB Circular A-11, Preparation, Submission, and Execution of the Budget.
64

Agencies have significant flexibility in determining what constitutes an information system and its associated
boundary.

27

mission or business processes within a single business unit or may address the entire
organization’s processes. 65
12) ‘Chief Information Officer’ means the senior official that provides advice and other
assistance to the head of the agency and other senior management personnel of the
agency to ensure that IT is acquired and information resources are managed for the
agency in a manner that achieves the agency’s strategic goals and information resources
management goals; and is responsible for ensuring agency compliance with, and prompt,
efficient, and effective implementation of, the information policies and information
resources management responsibilities, including the reduction of information collection
burdens on the public.
13) ‘Chief Information Officers Council’ means the Council codified in the E-Government
Act of 2002 (44 U.S.C § 101).
14) ‘Common control’ means a security or privacy control that is inherited by multiple
information systems or programs. 66
15) ‘Controlled Unclassified Information’ means information that requires safeguarding or
dissemination controls pursuant to and consistent with law, regulations, and
Government-wide policies, excluding information classified under Executive Order
13526 of December 29, 2009, or the Atomic Energy Act, as amended.
16) ‘Critical infrastructure’ means systems and assets, whether physical or virtual, so vital to
the United States that the incapacity or destruction of such systems and assets would
have a debilitating impact on security, national economic security, national public health
safety, or any combination of those matters (42 U.S.C. § 5195c(e)).
17) ‘Cybersecurity’ means prevention of damage to, protection of, and restoration of
computers, electronic communications systems, electronic communications services,
wire communication, and electronic communication, including information contained
therein, to ensure its availability, integrity, authentication, confidentiality, and nonrepudiation.
18) ‘Dissemination’ means the government-initiated distribution of information to a
nongovernment entity, including the public. The term ‘dissemination,’ as used within
this Circular, does not include distribution limited to Federal Government employees,
intra- or interagency use or sharing of Federal information, and responses to requests for
agency records under the Freedom of Information Act (5 U.S.C. § 552) or the Privacy
Act (5 U.S.C. § 552a).
19) ‘Enterprise architecture’ (a) means – (i) a strategic information asset base, which defines
the mission; (ii) the information necessary to perform the mission; (iii) the technologies
necessary to perform the mission; and (iv) the transitional processes for implementing
65

The Federal Information Security Modernization Act (44 U.S.C. § 3554(b))) requires each agency to develop,
document, and implement an agency-wide information security program that includes plans and procedures to
ensure continuity of operations for information systems that support the operations and assets of the agency.

66

A control is inherited by an information system when the control is selected for the system but the control is
developed, implemented, assessed, authorized, and monitored by entities other than those responsible for the system.

28

new technologies in response to changing mission needs; and (b) includes – (i) a
baseline architecture; (ii) a target architecture; and (iii) a sequencing plan (44 U.S.C. §
3601).
20) ‘Environment of operation’ means the physical surroundings in which an information
system processes, stores, and transmits information.
21) ‘Executive agency’ has the meaning defined in Title 41, Public Contracts section 133
(41 U.S.C. § 133).
22) ‘Federal information’ means information created, collected, processed, maintained,
disseminated, disclosed, or disposed of by or for the Federal Government, in any
medium or form.
23) ‘Federal information system’ means an information system used or operated by an
agency or by a contractor of an agency or by another organization on behalf of an
agency.
24) ‘Federal Privacy Council’ means the Council established by Executive Order 13719. 67
25) ‘Government publication’ means information that is published as an individual
document at Government expense, or as required by law, in any medium or form (44
U.S.C. § 1901).
26) ‘Hybrid control’ means a security or privacy control that is implemented for an
information system in part as a common control and in part as a system-specific control.
27) ‘Incident’ means an occurrence that actually or imminently jeopardizes, without lawful
authority, the confidentiality, integrity, or availability of information or an information
system; or constitutes a violation or imminent threat of violation of law, security
policies, security procedures, or acceptable use policies (44 U.S.C. § 3552).
28) ‘Information’ means any communication or representation of knowledge such as facts,
data, or opinions in any medium or form, including textual, numerical, graphic,
cartographic, narrative, electronic, or audiovisual forms.
29) ‘Information dissemination product’ means any recorded information, regardless of
physical form or characteristics, disseminated by an agency, or contractor thereof, to the
public.
30) ‘Information life cycle’ means the stages through which information passes, typically
characterized as creation or collection, processing, dissemination, use, storage, and
disposition, to include destruction and deletion.
31) ‘Information management’ means the planning, budgeting, manipulating, and controlling
of information throughout its life cycle. The term encompasses both information itself
and the related resources, such as personnel, equipment, funds, and information
technology.
32) ‘Information resources’ means information and related resources, such as personnel,
equipment, funds, and information technology (44 U.S.C. § 3502).
67

Executive Order 13719, Establishment of the Federal Privacy Council (2016).

29

33) ‘Information resources management’ means the process of managing information
resources to accomplish agency missions. The term encompasses an agency’s
information and the related resources, such as personnel, equipment, funds, and
information technology (44 U.S.C. § 3502).
34) ‘Information Resource Management Strategy’ means a strategy that demonstrates how
information resources management decisions are integrated with organizational
planning, budget, procurement, financial management, human resources management,
and program decisions (44 U.S.C. 3506 (b)(2)).
35) ‘Information security’ means the protection of information and information systems
from unauthorized access, use, disclosure, disruption, modification, or destruction in
order to provide:
a) Integrity, which means guarding against improper information modification or
destruction, and includes ensuring information non-repudiation and authenticity;
b) Confidentiality, which means preserving authorized restrictions on access and
disclosure, including means for protecting personal privacy and proprietary
information; and
c) Availability, which means ensuring timely and reliable access to and use of
information (44 U.S.C. § 3552).
36) ‘Information security architecture’ means an embedded, integral part of the enterprise
architecture that describes the structure and behavior of the enterprise security processes,
information security systems, personnel, and organizational subunits, showing their
alignment with the enterprise’s mission and strategic plans.
37) ‘Information security continuous monitoring’ means maintaining ongoing awareness of
information security, vulnerabilities, threats, and incidents to support agency risk
management decisions. 68
38) ‘Information security continuous monitoring program’ means the compendium of
methods, tools, and techniques necessary to implement the agency information
continuous monitoring strategy in a way that is sufficient to inform risk-based decisions
and maintain operations within established risk tolerances. The program includes
determining monitoring metrics, establishing monitoring frequencies, and developing a
monitoring architecture.
39) ‘Information security continuous monitoring strategy’ means a comprehensive plan to
address monitoring requirements and activities at each organizational tier (organization,
mission or business process, and information system).
40) ‘Information system security plan’ means a formal document that provides an overview
of the security requirements for an information system and describes the security
controls in place or planned for meeting those requirements. 69
68

The terms continuous and ongoing in this context mean that security controls and agency risks are assessed and
analyzed at a frequency sufficient to support risk-based security decisions to adequately protect agency information.

69

The information system security plan and the privacy plan may be integrated into one consolidated document.

30

41) ‘Information security program plan’ means a formal document that provides an overview
of the security requirements for an organization-wide information security program and
describes the program management controls and common controls in place or planned
for meeting those requirements.
42) ‘Information system’ means a discrete set of information resources organized for the
collection, processing, maintenance, use, sharing, dissemination, or disposition of
information (44 U.S.C. § 3502).
43) ‘Information system life cycle’ means all phases in the useful life of an information
system, including planning, acquiring, operating, maintaining, and disposing. (See also
OMB A-11 Part 7, Capital Programming Guide and OMB Circular A-131, Value
Engineering for more information regarding the costs and management of assets through
their complete life cycle.)
44) ‘Information system resilience’ means the ability of an information system to operate
under adverse conditions or stress, even if in a degraded or debilitated state, while
maintaining essential operational capabilities, and to recover to an effective operational
posture in a time frame consistent with mission needs.
45) ‘Information technology’ means any services or equipment, or interconnected system(s)
or subsystem(s) of equipment, that are used in the automatic acquisition, storage,
analysis, evaluation, manipulation, management, movement, control, display, switching,
interchange, transmission, or reception of data or information by the agency. For
purposes of this definition, such services or equipment if used by the agency directly or
is used by a contractor under a contract with the agency that requires its use; or to a
significant extent, its use in the performance of a service or the furnishing of a product.
The term “information technology” includes computers, ancillary equipment (including
imaging peripherals, input, output, and storage devices necessary for security and
surveillance), peripheral equipment designed to be controlled by the central processing
unit of a computer, software, firmware and similar procedures, services (including cloud
computing and help-desk services or other professional services which support any point
of the life cycle of the equipment or service), and related resources. The term
“information technology” does not include any equipment that is acquired by a
contractor incidental to a contract which does not require its use (40 U.S.C. § 11101).
46) ‘Information technology investment’ means an expenditure of information technology
resources to address mission delivery and management support. This may include a
project or projects for the development, modernization, enhancement, or maintenance of
a single information technology asset or group of information technology assets with
related functionality, and the subsequent operation of those assets in a production
environment. These investments shall have a defined life cycle with start and end dates,
with the end date representing the end of the currently estimated useful life of the
investment, consistent with the investment’s most current alternatives analysis if
applicable.
47) ‘Information Technology Investment Management’ means a decision-making process
that, in support of agency missions and business needs, provides for analyzing, tracking,
and evaluating the risks, including information security and privacy risks, and results of
31

all major investments made by an agency for information systems. The process shall
cover the life of each system and shall include explicit criteria for analyzing the
projected and actual costs, benefits, and risks, including information security and privacy
risks, associated with the investments. 70
48) ‘Information technology resources’ means all agency budgetary resources, personnel,
equipment, facilities, or services that are primarily used in the management, operation,
acquisition, or other activity related to the life cycle of information technology;
acquisitions or interagency agreements that include information technology and the
services or equipment provided by such acquisitions or interagency agreements; but does
not include grants that establish or support information technology not operated directly
by the Federal Government.
49) ‘Initial authorization’ means the initial risk determination and risk acceptance decision
based on a zero-base review 71 of the information system conducted prior to its entering
the operations or maintenance phase of the system development life cycle. The zerobase review includes an assessment of all security and privacy controls (i.e., systemspecific, hybrid, and common controls) contained in an information system security plan
or in a privacy plan and implemented within an information system or the environment
in which the system operates.
50) ‘Interagency agreement’ means, for the purposes of this document, a written agreement
entered into between two or more Federal agencies that specifies the goods to be
furnished or tasks to be accomplished by one agency (the servicing agency) in support of
the other(s) (the requesting agency), including assisted acquisitions as described in OMB
Memorandum: Improving the Management and Use of Interagency Acquisitions and
other cases described in FAR Part 17.
51) ‘Major information system’ means a system that is part of an investment that requires
special management attention as defined in OMB guidance 72 and agency policies, a
“major automated information system” as defined in 10 U.S.C. § 2445, or a system that
is part of a major acquisition as defined in the OMB Circular A-11, Capital
Programming Guide, consisting of information resources. 73
52) ‘Major information technology investment’ means an investment that requires special
management attention as defined in OMB guidance and agency policies, a “major
automated information system” as defined in 10 U.S.C. § 2445, or a major acquisition as

70

See the Clinger Cohen Act of 1996 (40 U.S.C. § 11302) for statutory requirements.

71

A zero-base review of an information system is the first complete security assessment performed in order to
provide the authorizing official with a comprehensive set of security-related information to facilitate making an
appropriate risk determination.
72
For example, an information system requires special management attention because of its importance to an agency
mission; its high development, operating, or maintenance costs; or its significant role in the administration of agency
programs, finances, property, or other resources.
73
All information systems are subject to the requirements of the Federal Information Security Modernization Act
(44 U.S.C. Chapter 35) whether or not they are designated as a major information system.

32

defined in the OMB Circular A-11, Capital Programming Guide, consisting of
information resources.
53) ‘National security system’ means any information system (including any
telecommunications system) used or operated by an agency or by a contractor of an
agency, or other organization on behalf of an agency, the function, operation, or use of
which involves intelligence activities; involves cryptologic activities related to national
security; involves command and control of military forces; involves equipment that is an
integral part of a weapon or weapons system; or is critical to the direct fulfillment of
military or intelligence missions (excluding a system that is to be used for routine
administrative and business applications, for example, payroll, finance, logistics, and
personnel management applications); or is protected at all times by procedures
established for information that have been specifically authorized under criteria
established by an executive order or an Act of Congress to be kept classified in the
interest of national defense or foreign policy (44 U.S.C. § 3552).
54) ‘Ongoing authorization’ means the risk determinations and risk acceptance decisions
subsequent to the initial authorization, taken at agreed-upon and documented frequencies
in accordance with the agency’s mission or business requirements and agency risk
tolerance. Ongoing authorization is a time-driven or event-driven authorization process
whereby the authorizing official is provided with the necessary and sufficient
information regarding the security and privacy state of the information system to
determine whether the mission or business risk of continued system operation is
acceptable.
55) ‘Open data’ means publicly available data that are made available consistent with
relevant privacy, confidentiality, security, and other valid access, use, and dissemination
restrictions, and are structured in a way that enables the data to be fully discoverable and
usable by end users. Generally, open data are consistent with principles, explained in
OMB guidance, of such data being public, accessible, machine-readable, described,
reusable, complete, timely, and managed post-release.
56) ‘Overlay’ means a specification of security or privacy controls, control enhancements,
supplemental guidance, and other supporting information employed during the tailoring
process, that is intended to complement (and further refine) security control baselines.
The overlay specification may be more stringent or less stringent than the original
security control baseline specification and can be applied to multiple information
systems. (See “tailoring” definition.)
57) ‘Personally identifiable information’ means information that can be used to distinguish
or trace an individual’s identity, either alone or when combined with other information
that is linked or linkable to a specific individual.
58) ‘Privacy continuous monitoring’ means maintaining ongoing awareness of privacy risks
and assessing privacy controls at a frequency sufficient to ensure compliance with
applicable privacy requirements and to manage privacy risks.
59) ‘Privacy continuous monitoring program’ means an agency-wide program that
implements the agency’s privacy continuous monitoring strategy and maintains ongoing
awareness of threats and vulnerabilities that may pose privacy risks; monitors changes to
33

information systems and environments of operation that create, collect, use, process,
store, maintain, disseminate, disclose, or dispose of PII; and conducts privacy control
assessments to verify the continued effectiveness of all privacy controls selected and
implemented at an agency across the agency risk management tiers to ensure continued
compliance with applicable privacy requirements and manage privacy risks.
60) ‘Privacy continuous monitoring strategy’ means a formal document that catalogs the
available privacy controls implemented at an agency across the agency risk management
tiers and ensures that the controls are effectively monitored on an ongoing basis by
assigning an agency-defined assessment frequency to each control that is sufficient to
ensure compliance with applicable privacy requirements and to manage privacy risks.
61) ‘Privacy control’ means the administrative, technical, and physical safeguards employed
within an agency to ensure compliance with applicable privacy requirements and
manage privacy risks.
62) ‘Privacy control assessment’ means the assessment of privacy controls to determine
whether the controls are implemented correctly, operating as intended, and sufficient to
ensure compliance with applicable privacy requirements and manage privacy risks. A
privacy control assessment is both an assessment and a formal document detailing the
process and the outcome of the assessment.
63) ‘Privacy impact assessment’ means an analysis of how information is handled to ensure
handling conforms to applicable legal, regulatory, and policy requirements regarding
privacy; to determine the risks and effects of creating, collecting, using, processing,
storing, maintaining, disseminating, disclosing, and disposing of information in
identifiable form in an electronic information system; and to examine and evaluate
protections and alternate processes for handling information to mitigate potential privacy
concerns. A privacy impact assessment is both an analysis and a formal document
detailing the process and the outcome of the analysis.
64) ‘Privacy program plan’ means a formal document that provides an overview of an
agency’s privacy program, including a description of the structure of the privacy
program, the resources dedicated to the privacy program, the role of the Senior Agency
Official for Privacy and other privacy officials and staff, the strategic goals and
objectives of the privacy program, and the program management controls and common
controls in place or planned for meeting applicable privacy requirements and managing
privacy risks.
65) ‘Privacy plan’ means a formal document that details the privacy controls selected for an
information system or environment of operation that are in place or planned for meeting
applicable privacy requirements and managing privacy risks, details how the controls
have been implemented, and describes the methodologies and metrics that will be used
to assess the controls. 74
66) ‘Program management control’ means, in the context of information security and
privacy, a control that is generally implemented at the agency level, independent of any

74

The privacy plan and the information system security plan may be integrated into one consolidated document.

34

particular information system, and essential for managing information security or
privacy programs.
67) ‘Provisioned IT Service’ means an information technology service that is owned,
operated, and provided by an outside vendor or external government organization, and
consumed by the agency.
68) ‘Public information’ means any information, regardless of form or format, that an
agency discloses, disseminates, or makes available to the public (44 U.S.C. Chapter 35).
69) ‘Reauthorization’ means the risk determination and risk acceptance decision that occurs
after an initial authorization. In general, reauthorization actions may be time-driven or
event-driven; however, under ongoing authorization, reauthorization is typically an
event-driven action initiated by the authorizing official or directed by the Risk Executive
(function) in response to an event that drives risk above the previously agreed-upon
agency risk tolerance.
70) ‘Records’ means all recorded information, regardless of form or characteristics, made or
received by a Federal agency under Federal law or in connection with the transaction of
public business and preserved or appropriate for preservation by that agency or its
legitimate successor as evidence of the organization, functions, policies, decisions,
procedures, operations, or other activities of the United States Government or because of
the informational value of data in them (44 U.S.C. § 3301).
71) ‘Records management’ means the planning, controlling, directing, organizing, training,
promoting, and other managerial activities involved with respect to records creation,
records maintenance and use, and records disposition in order to achieve adequate and
proper documentation of the policies and transactions of the Federal Government and
effective and economical management of agency operations (44 U.S.C. § 2901(2)).
72) ‘Resilience’ means the ability to prepare for and adapt to changing conditions and
withstand and recover rapidly from disruption. Resilience includes the ability to
withstand and recover from deliberate attacks, accidents, or naturally occurring threats or
incidents.
73) ‘Risk’ means a measure of the extent to which an entity is threatened by a potential
circumstance or event, and typically is a function of: (i) the adverse impact, or
magnitude of harm, that would arise if the circumstance or event occurs; and (ii) the
likelihood of occurrence. 75
74) ‘Risk management’ means the program and supporting processes to manage risk to
agency operations (including mission, functions, image, reputation), agency assets,
individuals, other organizations, and the Nation, and includes: establishing the context
for risk-related activities; assessing risk; responding to risk once determined; and
monitoring risk over time.
75) ‘Risk management strategy’ means the description of how an agency intends to assess
risk, respond to risk, and monitor risk, making explicit and transparent the risk

75

Risk can include both information security and privacy risks.

35

perceptions that organizations routinely use in making both investment and operational
decisions.
76) ‘Risk response’ means accepting, avoiding, mitigating, sharing, or transferring risk to
agency operations, agency assets, individuals, other organizations, or the Nation.
77) ‘Security category’ means the characterization of information or an information system
based on an assessment of the potential impact that a loss of confidentiality, integrity, or
availability of such information or information system would have on agency operations,
agency assets, individuals, other organizations, and the Nation.
78) ‘Security control’ means the safeguards or countermeasures prescribed for an
information system or an organization to protect the confidentiality, integrity, and
availability of the system and its information.
79) ‘Security control assessment’ means the testing or evaluation of security controls to
determine the extent to which the controls are implemented correctly, operating as
intended, and producing the desired outcome with respect to meeting the security
requirements for an information system or organization.
80) ‘Security control baseline’ means the set of minimum security controls defined for a
low-impact, moderate-impact, or high-impact information system.
81) ‘Senior Agency Official for Privacy’ means the senior official, designated by the head of
each agency, who has agency-wide responsibility for privacy, including implementation
of privacy protections; compliance with Federal laws, regulations, and policies relating
to privacy; management of privacy risks at the agency; and a central policy-making role
in the agency’s development and evaluation of legislative, regulatory, and other policy
proposals.
82) ‘Senior Agency Official for Records Management’ means the senior official who has
direct responsibility for ensuring that the agency efficiently and appropriately complies
with all applicable records management statutes, regulations, NARA policy and OMB
policy.
83) ‘Supply chain’ means a linked set of resources and processes between multiple tiers of
developers that begins with the sourcing of products and services and extends through
the design, development, manufacturing, processing, handling, and delivery of products
and services to the acquirer.
84) ‘Supply chain risk’ means risks that arise from the loss of confidentiality, integrity, or
availability of information or information systems and reflect the potential adverse
impacts to organizational operations (including mission, functions, image, or reputation),
organizational assets, individuals, other organizations, and the Nation.
85) ‘Supply chain risk management’ means the process of identifying, assessing, and
mitigating the risks associated with the global and distributed nature of information and
communications technology product and service supply chains.
86) ‘System-specific control’ means a security or privacy control for an information system
that is implemented at the system level and is not inherited by any other information
system.
36

87) ‘Systems security engineering’ means a specialty engineering discipline of systems
engineering. It applies scientific, mathematical, engineering, and measurement
concepts, principles, and methods to deliver, consistent with defined constraints and
necessary trade-offs, a trustworthy asset protection capability that satisfies stakeholder
requirements; is seamlessly integrated into the delivered system; and presents residual
risk that is deemed acceptable and manageable to stakeholders.
88) ‘Tailoring’ means the process by which security control baselines are modified by
identifying and designating common controls; applying scoping considerations; selecting
compensating controls; assigning specific values to agency-defined control parameters;
supplementing baselines with additional controls or control enhancements; and
providing additional specification information for control implementation. The tailoring
process may also be applied to privacy controls. (See “overlay” definition.)
89) ‘TechStat’ means a face-to-face, evidence-based accountability review of an IT
investment that enables the Federal Government to intervene to turn around, halt, or
terminate IT projects that are failing or are not producing results for the American
people.
90) ‘Trustworthy information system’ means an information system that is believed to be
capable of operating within defined levels of risk despite the environmental disruptions,
human errors, structural failures, and purposeful attacks that are expected to occur in its
environment of operation.
b. Terms that are not specifically defined in this section are assumed to have standard dictionary
meanings, or are defined in other OMB policy.
11. Inquiries
All questions or inquiries should be addressed to the Office of Management and Budget,
Washington, D.C. 20503. Telephone: (202) 395-0379 or (202) 395-3785 or Email:
A130@omb.eop.gov.

37

Appendix I to OMB Circular A-130
Responsibilities for Protecting and Managing Federal Information Resources
1. Introduction
Agencies of the Federal Government depend on the secure acquisition, processing, storage,
transmission, and disposition of information to carry out their core missions and business
functions. This allows diverse information resources ranging from large enterprise information
systems (or systems of systems) to small mobile computing devices to collect, process, store,
maintain, transmit, and disseminate this information. The information relied upon is subject to a
range of threats that could potentially harm or adversely affect organizational operations (e.g.,
mission, functions, image, or reputation), organizational assets, individuals, other organizations,
or the Nation. These threats include environmental disruptions, purposeful attacks, structural
failures, human errors, and other threats that can compromise Federal information resources.
Personnel at all levels of the Federal Government must understand how to manage information
security and protect privacy.
Federal agencies must implement information security programs and privacy programs with the
flexibility to meet current and future information management needs and the sufficiency to
comply with Federal requirements and manage risks. Emerging technologies and services may
continue to shift the ways in which agencies acquire, develop, manage, and use information and
technology. As technologies and services continue to change, so will the threat environment.
Agency programs must have the capability to identify, respond to, and recover from current
threats while protecting their information resources and the privacy of the individuals whose
information they maintain. The programs must also have the capability to address new and
emerging threats. To be effective, information security and privacy considerations must be part
of the day-to-day operations of agencies. This can best be accomplished by planning for the
requisite security and privacy capabilities as an integral part of the agency strategic planning and
risk management processes, not as a separate activity. This includes, but is not limited to, the
integration of Federal information security and privacy requirements (and security and privacy
controls) into the enterprise architecture, system development life cycle activities, systems
engineering processes, and acquisition processes.
To ensure that Federal agencies can successfully carry out their assigned missions and business
operations in an environment of sophisticated and complex threats, they must deploy systems
that are both trustworthy and resilient. To increase the level of trustworthiness and resilience of
Federal information systems, the systems should employ technologies that can significantly
increase the built-in protection capability of those systems and make them inherently less
vulnerable. This can require a significant investment in appropriate architectures and the
application of systems engineering concepts and principles in the design of Federal information
systems.
As Federal agencies take advantage of emerging information technologies and services to obtain
more effective mission and operational capabilities, achieve greater efficiencies, and reduce
costs, they must also apply the principles and practices of risk management, information security,
and privacy to the acquisition and use of those technologies and services. While there are certain
security and privacy requirements and associated controls that are mandatory, agencies are
Appendix I - 1

required to employ risk-based approaches and decision making to ensure that security and
privacy capabilities are sufficient to protect agency assets, operations, and individuals. Such
risk-based approaches involve framing, assessing, responding to, and monitoring security and
privacy risks on an ongoing basis. Risk-based approaches can also support potential
performance improvements and cost savings when agencies make decisions about maintaining,
modernizing, or replacing existing information technologies and services or implementing new
technologies and services that leverage internal, other government, or private sector innovative
and market-driven solutions. These responsibilities extend to the creation, collection, use,
processing, storage, maintenance, dissemination, disclosure, and disposal of Federal information
when such information is hosted by non-Federal entities on behalf of the Federal Government.
Ultimately, agency heads remain responsible and accountable for ensuring that information
management practices comply with all Federal requirements, that information security and
privacy programs are appropriately managed, and that Federal information is adequately
protected commensurate with the risk resulting from the unauthorized access, use, disclosure,
disruption, modification, or destruction of such information.
2. Purpose
This Appendix establishes minimum requirements for Federal information security programs,
assigns Federal agency responsibilities for the security of information and information systems,
and links agency information security programs and agency management control systems
established in accordance with OMB Circular A-123, Management’s Responsibility for
Enterprise Risk Management and Internal Controls. This Appendix also establishes
requirements for Federal agency privacy programs, assigns responsibilities for privacy program
management, and describes how agencies should take a coordinated approach to implementing
information security and privacy controls. Additionally, this Appendix incorporates
requirements of statute, such as FISMA (44 U.S.C. Chapter 35), the E-Government Act of 2002
(44 U.S.C. Chapters 35 and 36), the Paperwork Reduction Act (44 U.S.C. Chapter 35), and the
Privacy Act of 1974, and responsibilities assigned in executive orders and Presidential directives.
3. General Requirements
a. Agencies shall implement an agency-wide risk management process that frames, assesses,
responds to, and monitors information security and privacy risk on an ongoing basis across
the three organizational tiers (i.e., organization level, mission or business process level, and
information system level). 76
b. Agencies shall develop, implement, document, maintain, and oversee agency-wide
information security and privacy programs including people, processes, and technologies to:
1) Provide for agency information security and privacy policies, planning, budgeting,
management, implementation, and oversight;

76
NIST SP 800-39, Managing Information Security Risk: Organization, Mission, and Information System View,
provides additional information on risk management processes and strategies. See also Section 5.b of this Appendix.

Appendix I - 2

2) Protect information and information systems from unauthorized access, use, disclosure,
disruption, modification, or destruction in order to provide for their confidentiality,
integrity, and availability;
3) Provide adequate security for all information created, collected, processed, stored,
transmitted, disseminated, or disposed of by or on behalf of the agency, to include
Federal information residing in contractor information systems and networks;
4) Cost-effectively manage information security and privacy risks, which includes reducing
such risks to an acceptable level;
5) Implement a risk management framework to guide and inform the categorization of
Federal information and information systems; the selection, implementation, and
assessment of security and privacy controls; the authorization of information systems and
common controls; and the continuous monitoring of information systems;
6) Implement security and privacy controls, and verify that they are operating as intended,
and continuously monitored and assessed; put procedures in place so that security and
privacy controls remain effective over time, and that steps are taken to maintain risk at an
acceptable level within organizational risk tolerance;
7) Employ systems security engineering principles, concepts, and techniques during the life
cycle of information systems to facilitate the development, deployment, operation, and
sustainment of trustworthy and adequately secure systems;
8) Implement supply chain risk management principles to protect against the insertion of
counterfeits, unauthorized production, tampering, theft, insertion of malicious software,
as well as poor manufacturing and development practices throughout the system
development life cycle;
9) Implement policies and procedures to ensure that all personnel are held accountable for
complying with agency-wide information security and privacy requirements and
policies;
10) Ensure that, in a timely manner, agency CIOs and SAOPs are made aware of
information systems and components that cannot be appropriately protected or secured
and that such systems are given a high priority for upgrade, replacement, or retirement; 77
and
11) Ensure ongoing collaboration between the senior agency information security officer and
the SAOP to ensure coordination of security and privacy activities.
c. Agencies that share PII shall require, as appropriate, other agencies and entities with which
they share PII to maintain the PII in an information system with a particular NIST FIPS
Publication 199 confidentiality impact level, as determined by the agency sharing the PII.
d. Agencies that share PII with other agencies or entities shall impose, where appropriate,
conditions (including the selection and implementation of particular security and privacy
controls) that govern the creation, collection, use, processing, storage, maintenance,
77
Until such information systems or components are appropriately dispositioned, agencies are expected to
immediately implement interim remediation measures such as limiting access or connectivity.

Appendix I - 3

dissemination, disclosure, and disposal of the PII through written agreements, including
contracts, data use agreements, information exchange agreements, and memoranda of
understanding.
e. Agencies shall protect Controlled Unclassified Information (CUI) and shall apply NIST FIPS
and NIST (800-series) SPs, as appropriate. This includes limiting the disclosure of
proprietary information to that which is legally authorized, and impose appropriate
conditions on use where a continuing obligation to ensure the confidentiality of the
information exists.
f. Agencies shall ensure compliance with all applicable statutory, regulatory, and policy
requirements and develop and maintain effective information security and privacy programs.
This includes using privacy impact assessments and other tools to manage privacy risks.
g. Agencies shall implement policies issued by OMB, as well as requirements issued by the
Department of Commerce, DHS, GSA, and OPM. This includes applying the standards and
guidelines contained in NIST FIPS, NIST (800-series) SPs, and, where appropriate and
directed by OMB, NISTIRs.
4. Specific Requirements 78
a. Security Categorization
Agencies shall:
1) Identify authorization boundaries for information systems in accordance with NIST SPs
800-18 and 800-37; and
2) Categorize information and information systems, in accordance with FIPS Publication
199 and NIST SP 800-60, considering potential adverse security and privacy impacts to
organizational operations and assets, individuals, other organizations, and the Nation.
b. Planning, Budgeting, and Enterprise Architecture
Agencies shall:
1) Identify and plan for the resources needed to implement information security and
privacy programs;
2) Ensure that information security and privacy are addressed throughout the life cycle of
each agency information system, and that security and privacy activities and costs are
identified and included in IT investment capital plans and budgetary requests;
3) Plan and budget to upgrade, replace, or retire any information systems for which security
and privacy protections commensurate with risk cannot be effectively implemented;

78

The requirements in this section represent those areas deemed to be of fundamental importance to the achievement
of effective agency information security programs and those areas deemed to require specific emphasis by OMB.
The security programs developed and executed by agencies need not be limited to the aforementioned areas but can
employ a comprehensive set of safeguards and countermeasures based on the principles, concepts, and
methodologies defined NIST standards and guidelines.

Appendix I - 4

4) Ensure that investment plans submitted to OMB as part of the budget process meet the
information security and privacy requirements appropriate for the life cycle stage of the
investment; and
5) Incorporate Federal information security and privacy requirements into the agency’s
enterprise architecture to ensure that risk is addressed and information systems achieve
the necessary levels of trustworthiness, protection, and resilience.
c. Plans, Controls, and Assessments
Agencies shall:
1) Develop and maintain an information security program plan that provides an overview
of the organization-wide information security requirements and documents the program
management controls and common controls in place or planned for meeting those
requirements;
2) Develop and maintain a privacy program plan that provides an overview of the agency’s
privacy program, including a description of the structure of the privacy program, the
resources dedicated to the privacy program, the role of the Senior Agency Official for
Privacy and other privacy officials and staff, the strategic goals and objectives of the
privacy program, the program management controls and common controls in place or
planned for meeting applicable privacy requirements and managing privacy risks, and
any other information determined necessary by the agency’s privacy program;
3) Employ a system life cycle process that incorporates the principles, concepts, methods,
and techniques of systems security engineering to ensure the development of trustworthy
and resilient information systems;
4) Develop supply chain risk management plans as described in NIST SP 800-161 to ensure
the integrity, security, resilience, and quality of information systems;
5) Employ a process to select and implement security controls for information systems and
the environments in which those systems operate 79 that satisfies the minimum
information security requirements in FIPS Publication 200 and security control baselines
in NIST SP 800-53, tailored as appropriate; 80
6) Employ a process to select and implement privacy controls for information systems and
programs that satisfies applicable privacy requirements in OMB guidance, including, but
not limited to, Appendix I to this Circular and OMB Circular A-108, Federal Agency
Responsibilities for Review, Reporting, and Publication under the Privacy Act;
7) Implement information system security using sound systems security engineering
principles, concepts, methods, practices, and techniques;
8) Develop and maintain security plans for information systems to document which
security controls have been selected and how those controls have been implemented;
79

The environment of operation includes the physical surroundings in which an information system processes,
stores, and transmits information. Agencies should take the environment into account when selecting,
implementing, documenting, and assessing security controls.
80

Agencies must conduct tailoring activities in accordance with OMB policy.

Appendix I - 5

9) Develop and maintain a privacy plan that details the privacy controls selected for an
information system that are in place or planned for meeting applicable privacy
requirements and managing privacy risks, details how the controls have been
implemented, and describes the methodologies and metrics that will be used to assess the
controls;
10) Deploy effective security controls to provide Federal employees and contractors with
multifactor authentication, digital signature, and encryption capabilities that provide
assurance of identity and are interoperable Government-wide and accepted across all
Executive Branch agencies;
11) Adhere to Government-wide requirements in the deployment and use of identity
credentials used by employees and contractors accessing Federal facilities; 81
12) Designate common controls in order to provide cost-effective security and privacy
capabilities that can be inherited by multiple agency information systems or programs; 82
13) Conduct and document assessments of all selected and implemented security and privacy
controls to determine whether security and privacy controls are implemented correctly,
operating as intended, and sufficient to ensure compliance with applicable requirements
and to manage security and privacy risks;
14) Conduct and document security and privacy control assessments prior to the operation of
an information system, and periodically thereafter, consistent with the frequency defined
in the agency information security continuous monitoring (ISCM) and privacy
continuous monitoring (PCM) strategies and the agency risk tolerance;
15) Use agency plans of action and milestones (POA&Ms), and make available or provide
access to OMB, DHS, inspectors general, and the U.S. Government Accountability
Office, upon request, to record and manage the mitigation and remediation of identified
weaknesses and deficiencies, not associated with accepted risks, in agency information
systems; and
16) Obtain approval from the authorizing official for connections from the information
system, as defined by its authorization boundary, to other information systems based on
the risk to the agency’s operations and assets, individuals, other organizations, and the
Nation.

81

NIST SP 800-116, A Recommendation for the Use of PIV Credentials in Physical Access Control Systems
(PACS), provides additional information on the use of PIV Credentials, the Government-wide standard identity
credential, in physical access control systems. Physical access controls systems, which include, for example,
servers, databases, workstations and network appliances in either shared or isolated networks, are considered
information systems.
82

When common controls protect multiple agency information systems of differing impact levels, the controls shall
be implemented at the highest impact level among the systems. If such controls cannot be implemented at the
highest impact level of the information systems, agencies shall factor this situation into their assessments of risk and
take appropriate risk mitigation actions (e.g., adding security controls, changing assigned values of security control
parameters, implementing compensating controls, changing certain aspects of mission or business processes, or
separating the higher impact system into its own domain where it can be afforded appropriate levels of protection).

Appendix I - 6

d. Authorization to Operate and Continuous Monitoring
Agencies shall:
1) Designate senior Federal officials to formally authorize an information system to operate
and authorize agency-designated common controls for use; 83
2) Complete an initial authorization to operate for each information system and all agencydesignated common controls based on a determination of, and explicit acceptance of, the
risk to agency operations and assets, individuals, other organizations, and the Nation,
and prior to operational status;
3) Transition information systems and common controls to an ongoing authorization
process when eligible for such a process and with the formal approval of the respective
authorizing officials;
4) Reauthorize information systems and common controls as needed, on a time- or eventdriven basis in accordance with agency risk tolerance;
5) Develop and maintain an ISCM strategy to address information security risks and
requirements across the organizational risk management tiers; 84
6) Implement and update, in accordance with organization-defined frequency, the ISCM
strategy to reflect the effectiveness of deployed controls; significant changes to
information systems; and adherence to Federal statutes, policies, directives, instructions,
regulations, standards, and guidelines;
7) Ensure that all selected and implemented controls are addressed in the ISCM strategy
and are effectively monitored on an ongoing basis, as determined by the agency’s ISCM
program; 85
8) Establish and maintain an ISCM program that:
a) Provides an understanding of agency risk tolerance and helps officials set priorities
and manage information security risk consistently throughout the agency;
b) Includes metrics that provide meaningful indications of security status and trend
analysis at all risk management tiers;
c) Ensures the continued effectiveness of all security controls selected and implemented
by monitoring controls with the frequencies specified in the ISCM strategy;
d) Verifies compliance with information security requirements derived from
organizational missions or business functions, Federal statutes, directives,
instructions, regulations, policies, standards and guidelines;
83

Common controls are authorized for operation in the same manner as system-specific controls.

84
NIST SP 800-39, Managing Information Security Risk, defines three risk management tiers for managing
information security risk within organizations. These include an organization or governance tier, mission or business
process tier, and information system tier.
85

For greater efficiency, the ISCM and PCM strategies may be consolidated into a single unified continuous
monitoring strategy. Similarly, the ISCM and PCM programs may also be consolidated into a single unified
continuous monitoring program.

Appendix I - 7

e) Is informed by all applicable agency IT assets to help maintain visibility into the
security of those assets and the protection of PII associated with those assets;
f) Ensures knowledge and control of changes to information systems that have potential
to affect security;
g) Maintains awareness of threats and vulnerabilities that have the potential to affect
security, including the mitigation of those threats and vulnerabilities;
9) Develop and maintain a PCM strategy, a formal document that:
a) Catalogs the available privacy controls implemented at the agency across the agency
risk management tiers; and
b) Ensures that the privacy controls are effectively monitored on an ongoing basis by
assigning an agency-defined assessment frequency to each control that is sufficient
to ensure compliance with applicable privacy requirements and to manage privacy
risks;
10) Establish and maintain an agency-wide PCM program that implements the agency’s
PCM strategy and:
a) Conducts privacy control assessments to verify the continued effectiveness of all
privacy controls selected and implemented at the agency across the agency risk
management tiers to ensure continued compliance with applicable privacy
requirements and manage privacy risks;
b) Identifies assessment methodologies and metrics to determine whether privacy
controls are implemented correctly, operating as intended, and sufficient to ensure
compliance with applicable privacy requirements and manage privacy risks;
c) Maintains ongoing awareness of threats and vulnerabilities that may pose privacy
risks; and
d) Monitors changes to information systems and environments of operation that create,
collect, use, process, store, maintain, disseminate, disclose, or dispose of PII;
11) Ensure that a robust ISCM program and PCM program are in place before agency
information systems are eligible for ongoing authorization; and
12) Leverage available Federal shared services, where practicable and appropriate.
e. Privacy Controls for Federal Information Systems and Programs
The SAOP has agency-wide responsibility and accountability for developing, implementing,
and maintaining an agency-wide privacy program to manage privacy risks, develop and
evaluate privacy policy, and ensure compliance with all applicable statutes, regulations, and
policies regarding the creation, collection, use, processing, storage, maintenance,
dissemination, disclosure, and disposal of PII by programs and information systems. The
SAOP shall:
1) Develop and maintain a privacy program plan that provides an overview of an agency’s
privacy program, including a description of the structure of the privacy program, the
resources dedicated to the privacy program, the role of the SAOP and other privacy
officials and staff, the strategic goals and objectives of the privacy program, and the
Appendix I - 8

program management controls and common controls in place or planned for meeting
applicable privacy requirements and managing privacy risks;
2) Develop and maintain a PCM strategy and PCM program to maintain ongoing awareness
of privacy risks and assess privacy controls at a frequency sufficient to ensure
compliance with applicable privacy requirements and manage privacy risks;
3) Conduct and document the results of privacy control assessments to verify the continued
effectiveness of all privacy controls selected and implemented at the agency across all
agency risk management tiers to ensure continued compliance with applicable privacy
requirements and manage privacy risks;
4) Identify assessment methodologies and metrics to determine whether privacy controls
are implemented correctly, operating as intended, and sufficient to ensure compliance
with applicable privacy requirements and manage privacy risks;
5) Designate which privacy controls will be treated as program management, common,
information system-specific, and hybrid privacy controls at the agency;
6) Review IT capital investment plans and budgetary requests to ensure that privacy
requirements (and associated privacy controls), as well as any associated costs, are
explicitly identified and included, with respect to any IT resources that will be used to
create, collect, use, process, store, maintain, disseminate, disclose, or dispose of PII;
7) Review and approve, in accordance with NIST FIPS Publication 199 and NIST SP 80060, the categorization of information systems that create, collect, use, process, store,
maintain, disseminate, disclose, or dispose of PII; 86
8) Review and approve the privacy plans for agency information systems prior to
authorization, reauthorization, or ongoing authorization;
9) Review authorization packages for information systems that create, collect, use, process,
store, maintain, disseminate, disclose, or dispose of PII to ensure compliance with
applicable privacy requirements and manage privacy risks, prior to authorizing officials
making risk determination and acceptance decisions; and
10) Coordinate with the CIO, the senior agency information security officer, and other
agency officials in implementation of these requirements.
f. Incident Detection, Response, and Recovery
It is essential that agencies react appropriately to incidents after employing a risk-based
approach to selecting and implementing their security and privacy controls for their
information and information systems.

86

The categorization of information systems that create, collect, use, process, store, maintain, disseminate, disclose,
or dispose of PII will depend on the sensitivity level of the PII, the privacy risks, and the associated risk to agency
operations, agency assets, individuals, other organizations, and the Nation. Agencies should generally categorize
information systems that create, collect, use, process, store, maintain, disseminate, disclose, or dispose of PII at the
moderate or high confidentiality impact level. See Appendix II for additional information regarding the sensitivity
level of PII.

Appendix I - 9

Agencies shall: 87
1) Develop and implement incident management policies and procedures, in accordance
with OMB policies and NIST guidelines that address incident detection, response, and
recovery. This includes developing and implementing appropriate activities to identify
the occurrence of an incident; developing and implementing appropriate activities to take
action regarding a detected incident; and developing and implementing the appropriate
activities to maintain plans for resilience and to restore any capabilities or services that
were impaired due to an incident;
2) Designate sensitive positions and execute commensurate security clearance levels for
appropriate agency personnel;
3) Establish clear roles and responsibilities to ensure the oversight and coordination of
incident response activities and that incidents are documented, reported, investigated,
and handled;
4) Periodically test incident response procedures to ensure effectiveness of such
procedures;
5) Document lessons learned for incident response and update procedures annually or as
required by OMB or DHS;
6) Ensure that processes are in place to verify corrective actions;
7) Maintain formal incident response capabilities and mechanisms to include notification to
affected individuals and adequate training and awareness for employees and contractors
on how to report and respond to incidents;
8) Implement formal incident management policies to include definitions, detection and
analysis, containment, internal and external notification and reporting requirements,
incident reporting methods, post-incident procedures, roles and responsibilities, and
guidance on how to mitigate impacts to the agency and its respondents following an
incident;
9) Report incidents to OMB, DHS, the CIO, the SAOP, their respective inspectors general
and general counsel, law enforcement, and Congress in accordance with procedures
issued by OMB; and
10) Provide reports on incidents as required by FISMA, OMB policy, DHS binding
operational directives, Federal information security incident center guidelines, NIST
guidelines, and agency procedures.

87

Pursuant to FISMA (44 U.S.C. Chapter 35).

Appendix I - 10

g. Contingency Planning 88
Agencies shall:
1) Develop and test contingency plans 89 for information systems that:
a) Identify essential missions and business functions and associated contingency
requirements;
b) Provide recovery objectives, restoration priorities, and metrics;
c) Address contingency roles and responsibilities; and
d) Address maintaining essential missions, functions, and services despite a disruption,
compromise, or failure of information systems.
2) Provide for the recovery and reconstitution of information systems to a known state after
a disruption, compromise, or failure.
h. Awareness and Training
Agencies shall:
1) Develop, maintain, and implement mandatory agency-wide information security and
privacy awareness and training programs for all employees and contractors;
2) Ensure that the security and privacy awareness and training programs are consistent with
applicable policies, standards, and guidelines issued by OMB, NIST, and OPM;
3) Apprise agency employees about available security and privacy resources, such as
products, techniques, or expertise;
4) Provide foundational as well as more advanced levels of security and privacy training to
information system users (including managers, senior executives, and contractors) and
ensure that measures are in place to test the knowledge level of information system
users;
5) Provide role-based security and privacy training to employees and contractors with
assigned security and privacy roles and responsibilities, including managers, before
authorizing access to Federal information or information systems or performing assigned
duties;
88

The Federal Information Security Modernization Act of 2014 (44 U.S.C. Chapter 35) requires each agency to
develop, document, and implement an agency-wide information security program that includes plans and procedures
to ensure continuity of operations for information systems that support the operations and assets of the agency.
Plans related to contingency plans for organizational information systems include, for example, Business Continuity
Plans, Disaster Recovery Plans, Continuity of Operations Plans, Crisis Communications Plans, Critical
Infrastructure Plans, Cyber Incident Response Plans, Insider Threat Implementation Plan, and Occupant Emergency
Plans.

89
Testing of contingency plans must be consistent with the assessment procedures in NIST SP 800-53A, Guide for
Assessing the Security Controls in Federal Information Systems and Organizations. In addition, Homeland Security
Presidential Directive 20, National Continuity Directive, requires the establishment and maintenance of an effective
national continuity capability. Federal Continuity Directive 1, Federal Executive Branch National Continuity
Program and Requirements, provides direction for the further development of continuity plans and programs.

Appendix I - 11

6) Establish rules of behavior, including consequences for violating rules of behavior, for
employees and contractors that have access to Federal information or information
systems, including those that create, collect, use, process, store, maintain, disseminate,
disclose, or dispose of PII; and
7) Ensure that employees and contractors have read and agreed to abide by the rules of
behavior for the Federal information and information systems for which they require
access prior to being granted access.
i. Specific Safeguarding Measures to Reinforce the Protection of Federal Information and
Information Systems 90
Agencies shall:
1) Implement a policy of least functionality by only permitting the use of networks,
systems, applications, and data, as well as programs, functions, ports, protocols, or
services that are necessary in meeting mission or business needs;
2) Implement policies of least privilege at multiple layers – network, system, application,
and data so that users have role-based access to only the information and resources that
are necessary for a legitimate purpose;
3) Implement a policy of separation of duties to address the potential for abuse of
authorized privileges and help to reduce the risk of malicious activity without collusion;
4) Isolate sensitive or critical information resources (e.g., information systems, system
components, applications, databases, and information) into separate security domains
with appropriate levels of protection based on the sensitivity or criticality of those
resources;
5) Implement access control policies for information resources that ensure individuals have
appropriate authorization and need, and that the appropriate level of identity proofing or
background investigation is conducted prior to granting access;
6) Protect administrator, user, and system documentation related to the design,
development, testing, operation, maintenance, and security of the hardware, firmware,
and software components of information systems;
7) Continuously monitor, log, and audit the execution of information system functions by
privileged users (that ordinary users are not authorized to perform) to detect misuse and
to help reduce the risk from insider threats;
8) Prohibit the use of unsupported information systems and system components, and ensure
that systems and components that cannot be appropriately protected or secured are given
a high priority for upgrade or replacement; 91
90

NIST SP 800-53, Security and Privacy Controls for Federal Information Systems and Organizations, provides
information on additional security safeguarding measures.
91

Includes hardware, software, or firmware components no longer supported by developers, vendors, or
manufacturers through the availability of software patches, firmware updates, replacement parts, and maintenance
contracts. NIST SP 800-53, Security and Privacy Controls for Federal Information Systems and Organizations,
provides additional guidance on unsupported software components.

Appendix I - 12

9) Implement and maintain current updates and patches for all software and firmware
components of information systems; 92
10) For systems that promote public access, ensure that identity proofing, registration, and
authentication processes provide assurance of identity consistent with security and
privacy requirements, in accordance with Executive Order 13681, 93 OMB policy, and
NIST standards and guidelines;
11) Require use of multifactor authentication for employees and contractors in accordance
with Government-wide identity management standards; 94
12) Develop and implement processes to support use of digital signatures for employees and
contractors;
13) Ensure that all public key infrastructure (PKI) certificates used by an agency and issued
in accordance with Federal PKI policy validate to the Federal PKI trust anchor when
being used for user signing, encrypting purposes, authentication and authorization; 95
14) Encrypt all FIPS 199 moderate-impact and high-impact information at rest and in transit,
unless encrypting such information is technically infeasible or would demonstrably
affect the ability of agencies to carry out their respective missions, functions, or
operations; and the risk of not encrypting is accepted by the authorizing official and
approved by the agency CIO, in consultation with the SAOP (as appropriate); 96
15) Implement the current encryption algorithms and validated cryptographic modules in
accordance with NIST standards and guidelines;
16) Ensure that only individuals or processes acting on behalf of individuals with legitimate
need for access have the ability to decrypt sensitive information;
17) Implement data-level protection and access controls to ensure the security of and access
to Federal information; and
92

Security-relevant software and firmware updates include, for example, patches, service packs, hot fixes, device
drivers, basic input output system (BIOS), and antivirus signatures.
93

Executive Order 13681, Improving the Security of Consumer Financial Transactions, October 2014.

94

Pursuant to Homeland Security Presidential Directive 12, Policy for a Common Identification Standard for
Federal Employees and Contractors, NIST FIPS 201 describes the initial Government-wide identity management
standard for employees and contractors as a smartcard form factor (the PIV card). With the emergence of a newer
generation of computing devices and in particular with mobile devices, the use of PIV cards has evolved technically
to include other form factors that can be deployed directly with mobile devices as specified in NIST SP 800-157.
The PIV credential associated with this alternative is called a Derived PIV Credential. Derived PIV Credentials are
based on the general concept of derived credentials in NIST SP 800-63. Issuing a Derived PIV credential to PIV
card holders does not require repeating identity proofing and vetting processes. The user simply proves possession
and control of a valid PIV Card to receive a Derived PIV Credential.
95

The trust anchor refers to the Federal PKI root certificate operated by the Federal PKI Management Authority.
This root certificate is the trusted source of all Federal PKI certificates. For additional information, refer to
https://www.idmanagement.gov and Federal PKI policy.
96

The encryption of organizational information when in transit over a network and when at rest in storage devices
ensures that such information is persistently protected and promotes a defense-in-depth security strategy.

Appendix I - 13

18) Ensure that all Federal systems and services identified in the Domain Name System are
protected with Domain Name System Security (DNSSEC) and that all systems are
capable of validating DNSSEC protected information. 97
j. Non-Federal Entities
Agencies shall:
1) Ensure that terms and conditions in contracts and other agreements involving the
creation, collection, use, processing, storage, maintenance, dissemination, disclosure,
and disposal of Federal information, incorporate security and privacy requirements and
are sufficient to enable agencies to meet Federal and agency-specific requirements
pertaining to the protection of Federal information; 98
2) Provide oversight of information systems used or operated by contractors or other
entities on behalf of the Federal Government or that collect or maintain Federal
information on behalf of the Federal Government, to include:
a) Documenting and implementing policies and procedures for information security and
privacy oversight, to include ensuring appropriate vetting and access control
processes for contractors and others with access to information systems containing
Federal information;
b) Ensuring that security and privacy controls of such information systems and services
are effectively implemented and comply with NIST standards and guidelines and
agency requirements;
c) Ensuring that these information systems are included in the agency’s inventory of
information systems;
d) Ensuring that the interface characteristics, security requirements, and the nature of
the information communicated is documented for each interface between these
systems and agency-owned or operated information systems;
e) Ensuring that procedures are in place for incident response for these information
systems including timelines for notification of affected individuals and reporting to
OMB, DHS, and other entities as required in OMB guidance;
f) Requiring agreements (e.g., memoranda of understanding, interconnection security
agreements, contracts) for interfaces between these information systems and agencyowned or operated information systems; and
3) Consistent with the agency’s authority, ensure that the requirements of the Privacy Act
apply to a Privacy Act system of records when a contractor operates the system of
records on behalf of the agency to accomplish an agency function;
4) Collaborate with non-Federal entities and other agencies as appropriate to ensure that
security and privacy requirements pertaining to these non-Federal entities, such as State,
97

DNSSEC is a critical component of the Internet infrastructure. DNSSEC enables clients to cryptographically
verify that each such translation is provided by a server with the authority to do so, and that the translation response
from the server was not modified before reaching the client.
98

For additional information and associated requirements pertaining to IT acquisitions, refer to the FAR.

Appendix I - 14

local, tribal, and territorial governments, are consistent to the greatest extent possible;
and
5) Ensure that terms and conditions of contracts and other agreements include sufficient
provisions for Federal Government notification and access, as well as cooperation with
agency personnel and Inspectors General.
k. Mitigation of Deficiencies and Issuance of Status Reports
Agencies shall correct deficiencies that are identified through information security and
privacy assessments, ISCM and PCM programs, or internal or external audits and reviews, to
include OMB reviews. OMB Circular A-123, Management’s Responsibility for Internal
Controls, provides guidance to determine whether a deficiency in controls is material when
so judged by the agency head against other agency deficiencies. Material deficiencies must
be included in the annual Federal Managers Financial Integrity Act (FMFIA) report, and
remediation tracked and managed through the agency’s POA&M process. Less significant
deficiencies need not be included in the FMFIA report, but must be tracked and managed
through the agency’s POA&M process.
l. Reporting
Agencies shall provide performance metrics information and FISMA reports in accordance
with processes established by OMB and DHS pursuant to FISMA.
m. Independent Evaluations
Pursuant to FISMA, agencies shall: 99
1) Perform an independent evaluation of the information security programs and practices to
determine the effectiveness of such programs and practices, as further described in
statute. 100 The evaluation may include an evaluation of their privacy program and
practices, as appropriate. Each evaluation shall include:
a) Testing of the effectiveness of information security policies, procedures, and
practices of a representative subset of the agency’s Federal information systems; 101
b) An assessment of the effectiveness of the information security policies, procedures,
and practices of the agency; and
c) Separate presentations, as appropriate, regarding information security relating to
national security systems.

99

FISMA (44 U.S.C. § 3555).

100

FISMA (44 U.S.C. § 3555).

101

Agencies have flexibility in implementing the baseline controls in SP 800-53; however, agencies are required to
justify, in their security plans or overlays, any tailoring actions.

Appendix I - 15

5. Discussion of the Major Provisions in the Appendix
This section provides additional information regarding the requirements in this appendix.
a. NIST Standards and Guidelines
NIST standards and guidelines associate each information system with an impact level. The
standards and guidelines also provide a corresponding starting set of baseline security
controls and tailoring guidance 102 to ensure that the set of security controls in the information
system security plan (approved by the authorizing official) and privacy controls in the
privacy plan (approved by the SAOP) satisfy the information security, privacy, and mission
or business protection needs of the agency.
For non-national security programs and information systems, agencies must apply NIST
guidelines unless otherwise stated by OMB. FIPS are mandatory. 103 There is flexibility
within NIST's guidelines (specifically in the 800-series) in how agencies apply those
guidelines. Unless specified by additional implementing policy by OMB, the concepts and
principles described in NIST guidelines must be applied. However, NIST guidelines
generally allow agencies latitude in their application. Consequently, the application of NIST
guidelines by agencies can result in different solutions that are equally acceptable and
compliant with the guidelines.
For legacy information systems, agencies are expected to meet the requirements of, and be in
compliance with, NIST standards and guidelines within one year of their respective
publication dates unless otherwise directed by OMB. The one-year compliance date for
revisions to NIST publications applies only to new or updated material in the publications.
For information systems under development or for legacy systems undergoing significant
changes, agencies are expected to meet the requirements of, and be in compliance with, NIST
standards and guidelines immediately upon deployment of the systems.
b. Risk Management Strategy
Managing risk is a complex, multifaceted activity that requires the involvement of the entire
agency—from senior leaders and executives providing the strategic vision and top-level
goals and objectives for the agency; to mid-level leaders planning, executing, and managing
projects; to individuals on the front lines operating the information systems supporting the
agency’s missions or business functions. Risk management is a comprehensive process that
requires agencies to establish the context in which risk-based decisions are made; assess risk;
respond to risk once determined; and monitor risk on an ongoing basis using effective
organizational communications and a feedback loop for continuous improvement in the riskrelated activities of agencies. Risk management is conducted as an agency-wide activity to
ensure that risk-based decision-making is integrated into every aspect of the agency’s
planning and operations.

102

Agencies must conduct tailoring activities in accordance with OMB policy.

103

Pursuant to FISMA (44 U.S.C. Chapter 35).

Appendix I - 16

A key aspect of the risk management process is the development of the risk management
strategy. The risk management strategy describes how an agency intends to assess risk,
respond to risk, and monitor risk—making explicit and transparent the risk perceptions that
agencies routinely use in making both investment and operational decisions. Establishing a
realistic and credible risk management strategy requires that agencies identify their risk
assumptions, risk constraints, risk tolerance, and priorities and trade-offs. The risk
management strategy also includes any strategic-level decisions by senior leaders and
executives regarding the management of risk to agency operations and assets, individuals,
other organizations, and the Nation. The risk management strategy guides and informs the
use and application of the Risk Management Framework.
c. Risk Management Framework
The Risk Management Framework, as described in NIST SP 800-37, provides a disciplined
and structured process that integrates information security and risk management activities
into the system development life cycle. The Risk Management Framework requires agencies
to categorize each information system and the information processed, stored, and transmitted
by each system based on a mission or business impact analysis. Agencies select an initial set
of baseline security controls for the information system based on the security categorization
and then tailor the security control baseline as needed, based on an organizational assessment
of risk and local conditions, as described in NIST SP 800-53. After implementing the
security controls, agencies assess the controls using appropriate assessment methods as
described in NIST SP 800-53A to determine whether the controls are implemented correctly,
operating as intended, and producing the desired outcome with respect to meeting the
security requirements for the system.
The authorization to operate the system is based on a determination of the risk to agency
operations and assets, individuals, other organizations, and the Nation resulting from the
operation and use of the system and the decision by the authorizing official that this risk is
acceptable. Subsequent to the authorization decision and as part of an information security
continuous monitoring strategy and program, agencies monitor the security controls in the
system on an ongoing basis, as described in NIST SP 800-137. Monitoring includes, but is
not limited to, assessing control effectiveness, documenting changes to the system or its
environment of operation, conducting security impact analyses of the associated changes, and
reporting the security state of the system to designated agency officials on an ongoing basis.
An effective implementation of the Risk Management Framework ensures that managing
information system-related risks is consistent with the agency’s mission or business
objectives and overall risk management strategy, and risk tolerance established by the senior
leadership through the risk executive function 104 as discussed in NIST SP 800-39. It also
ensures that the requisite security and privacy requirements and controls are integrated into
104
The risk executive function is an individual or group within an agency that helps to ensure that: (i) risk-related
considerations for individual information systems, to include the authorization to operate decisions, are viewed from
an agency-wide perspective with regard to the overall strategic goals and objectives of the agency in carrying out its
missions and business functions; and (ii) managing information system-related risks is consistent across the agency,
reflects the agency’s risk tolerance, and is considered along with other agency risks affecting its missions or
business functions.

Appendix I - 17

the agency’s enterprise architecture and system development life cycle processes. Finally,
the Risk Management Framework supports consistent, well-informed, and ongoing
authorization decisions, transparency of risk management information, reciprocity, and
information sharing.
d. Security Control Baselines
It is important to achieve adequate security for Federal information and information systems
and a consistent level of protection for such information and systems Government-wide. To
meet this objective, agencies must select an appropriate set of security controls for their
information systems that satisfies the minimum security requirements set forth in FIPS
Publication 200. The security controls must include one of the three security control
baselines from NIST SP 800-53 that are associated with the designated categorization
(impact levels) of their information systems. The security control baselines define the set of
minimum security controls for a low-impact, moderate-impact, or high-impact information
system and provide a starting point for the tailoring process. Agencies are required to tailor
the security control baselines to customize their safeguarding measures for specific missions,
business lines, and operational environments—and to do so in a cost-effective, risk-based
manner. Tailoring allows agencies to designate common controls; apply scoping
considerations; select compensating controls; assign specific values to agency-defined
control parameters; supplement baselines with additional controls when necessary; and
provide additional specification information for control implementation. Agencies must
include a justification, in their information system security plans or overlays, for any
tailoring actions that result in changes to the initial security control baselines. Agencies are
not permitted to make changes to security control baselines when such changes result in
control selections that are inconsistent with security requirements set forth in Federal
statutes, executive orders, regulations, directives, or policies.
Agencies may also develop overlays for specific types of information or communities of
interest (e.g., all web-based applications, all health care-related systems) as part of the
security control selection process. Overlays provide a specification of security or privacy
controls, control enhancements, supplemental guidance, and other supporting information as
part of the tailoring process, that is intended to complement (and further refine) security
control baselines. The overlay may be more stringent or less stringent than the original
security control baseline and can be applied to multiple information systems.
All selected security controls must be documented in an information system security plan and
implemented. Agencies can use the priority code designations associated with each security
control in NIST SP 800-53 to assist in making sequencing decisions for control
implementation. This prioritization helps to ensure that the foundational security controls
upon which other controls depend are implemented first, thus enabling agencies to deploy
controls in a more structured and timely manner in accordance with available resources.
Independent evaluations, when conducted, shall focus on the effectiveness of the security
controls selected and implemented (as documented in agency information system security
plans after all tailoring actions have been completed on the security control baselines) and the
justification for any decisions to change the control baselines.

Appendix I - 18

e. Security and Privacy Assessments
Agencies must ensure that periodic testing and evaluation of the effectiveness of information
security and privacy policies, procedures, and practices are performed with a frequency
depending on risk, but at least annually. However, this general requirement to test and
evaluate the effectiveness of information security and privacy policies, procedures, and
practices does not imply that agencies must assess every selected and implemented security
and privacy control at least annually. Rather, agencies must continuously monitor all
implemented security and privacy controls (i.e., system-specific, hybrid, and common
controls) with a frequency determined by the agency in accordance with the ISCM and PCM
strategies. These strategies will define the specific security and privacy controls selected for
assessment during any one-year period (i.e., the annual assessment window) with the
understanding that all controls may not be formally assessed every year. Rotational
assessment of security and privacy controls is consistent with the transition to ongoing
authorization and assumes the information system has completed an initial authorization
where all controls were formally assessed for effectiveness. As the transition to ongoing
authorization progresses and agency ISCM programs mature, agencies must ensure that
assessment frequencies are determined in accordance with NIST SP 800-137.
Security and privacy control assessments shall ensure that security and privacy controls
selected by agencies are implemented correctly, operating as intended, and effective in
satisfying security and privacy requirements. The risk may change over time based on
changes in the threat, agency missions or business functions, personnel, technology, or
environments of operation. Consequently, maintaining a capability for real-time or near realtime analysis of the threat environment and situational awareness following an incident is
paramount. The type, rigor, and frequency of control assessments, which is established by
the agency’s risk tolerance and risk management strategy, shall be commensurate with the
level of awareness necessary for effectively determining information security and privacy
risk. Technical security tools such as malicious code scanners, vulnerability assessment
products (which look for known security weaknesses, configuration errors, and the
installation of the latest patches), and penetration testing can assist in the ongoing assessment
of information systems.
f. Authorizing Official
The authorizing official is a senior agency official or executive with the authority to formally
assume responsibility for operating an information system at an acceptable level of risk to
agency operations and assets, individuals, other organizations, and the Nation. Authorizing
officials have budgetary oversight for an information system or be responsible for the
mission or business operations supported by the system. Through the authorization process,
authorizing officials are responsible and accountable for the risks associated with information
system operations. Because information security is closely related to the privacy protections
required for PII, authorizing officials are also responsible and accountable for the privacy
risks that arise from the operation of an information system. Accordingly, authorizing
officials must be in management positions with a level of authority commensurate with
understanding and accepting such information system-related security and privacy risks.
Appendix I - 19

Since the SAOP is the senior official, designated by the head of each agency, who has overall
agency-wide responsibility for privacy, agencies must consider input and recommendations
submitted by the SAOP in the authorization decision. Additionally, the SAOP has
responsibility for reviewing the authorization package for information systems that create,
collect, use, process, store, maintain, disseminate, disclose, or dispose of PII, to ensure that
privacy risks are managed prior to system authorization. In situations where the authorizing
official and SAOP cannot reach a final resolution regarding the appropriate protection for the
agency information and information system, the head of the agency must review the
associated risks and requirements and make a final determination regarding the issuance of
the authorization to operate. 105
Agencies can choose from several different approaches when planning for and conducting
authorizations. These include an authorization with a single authorizing official, an
authorization with multiple authorizing officials, or leveraging an existing authorization (see
Section 6j, Joint and Leveraged Authorizations). Agencies can, at their discretion, include
the CIO or the SAOP as a co-authorizing official with a senior agency official who has
budgetary oversight for an information system or is responsible for the mission or line of
business supported by the system being authorized for operation. Regardless of the approach
used, only Federal Government personnel may serve as an authorizing official.
g. Authorization to Operate
The authorization to operate an information system and the authorization of agencydesignated common controls granted by senior Federal officials provide an important quality
control for agencies. The decision to authorize an information system to operate shall be
based on a review of the authorization package and includes an assessment of compliance
with applicable requirements and risk to agency operations and assets, individuals, other
organizations, and the Nation. As stated above, the decision to authorize a system, or
agency-defined common controls, shall be made by the appropriate authorizing official.
Since the information system security plan and privacy plan establish the security and
privacy controls selected for implementation, those plans are a critical part of the
authorization package and shall form the basis for the authorization, supplemented by more
specific information as needed.
In the event that there is a change in authorizing officials, the new authorizing official
reviews the current authorization decision document, authorization package, and any updated
documents created as a result of the continuous monitoring activities. If the new authorizing
official is willing to accept the currently documented risk, then the official signs a new
authorization decision document, thus formally transferring responsibility and accountability
for the information system or the common controls and explicitly accepting the risk. If the
new authorizing official is not willing to accept the previous authorization results (including
the identified risk), a reauthorization action may need to be initiated or the new authorizing

105
The head of the agency is the highest-level senior official or executive within an agency with the overall
responsibility to provide information security protections commensurate with the risk and magnitude of harm (i.e.,
impact) to organizational operations and assets, individuals, other organizations, and the Nation.

Appendix I - 20

official may instead establish new terms and conditions for continuing the original
authorization, but not extend the original authorization termination date.
h. Ongoing Authorization
Ongoing authorization 106 is a process whereby the authorizing official makes risk
determination and risk acceptance decisions subsequent to the initial authorization, taken at
agreed-upon and documented frequencies in accordance with the agency’s risk tolerance and
mission or business requirements. In order to implement an ongoing authorization process,
and move from a static, point-in-time authorization process to a dynamic, near real-time
ongoing authorization process for information systems and controls, two conditions must be
met by agencies. First, the information system or common controls must have been granted
an initial authorization to operate by the designated authorizing official. Second, ISCM and
PCM programs must be in place to monitor all implemented security and privacy controls
with the appropriate degree of rigor 107 and at the appropriate frequencies in accordance with
applicable ISCM and PCM strategies, OMB guidance, and NIST guidelines. Ongoing
authorization can either be a time-driven or event-driven process whereby the authorizing
official is provided with the necessary and sufficient information regarding the near real-time
state of the information system and inherited common controls to determine whether all
applicable security and privacy requirements have been satisfied and the mission or business
risk is acceptable. Effective ongoing authorization requires robust ISCM and PCM strategies
and effective operational ISCM and PCM programs.
Agencies must define and implement a process to designate information systems or common
controls that have satisfied the two conditions noted in the previous paragraph and are to be
transitioned to ongoing authorization. The process includes the means for the authorizing
official to formally acknowledge that the information system or common controls are being
managed under an ongoing authorization process and accept the responsibility for ensuring
that all necessary activities associated with the ongoing authorization process are performed.
Until a formal approval is obtained from the authorizing official to transition to ongoing
authorization, information systems (and common controls) remain under a static
authorization process with specific authorization termination dates enforced by the agency.
i. Reauthorization
Reauthorization consists of a review of the information system similar to the review carried
out during the initial authorization but conducted during the operations or maintenance phase
of the system development life cycle rather than prior to that phase. In general,
reauthorization actions may be time-driven or event-driven. However, under ongoing
authorization, reauthorization is typically an event-driven action initiated by the authorizing
official or directed by the Risk Executive (function) in response to an event or significant
106

For additional information on Ongoing Authorization and its relationship to initial authorization and
reauthorization, refer to NIST Supplemental Guidance on Ongoing Authorization: Transitioning to Near Real-Time
Risk Management, http://csrc.nist.gov/publications.
107

The term rigor is used in conjunction with security control assessments and monitoring. It is typically associated
with the application of assessment methods described in NIST SP 800-53A, and in particular, the attribute of depth
which addresses the formality and comprehensiveness of the assessment or monitoring activity.

Appendix I - 21

change that increases information security or privacy risk above the previously agreed-upon
agency risk tolerance. A significant change is defined as a change that is likely to affect the
security or privacy state of an information system.
The reauthorization process differs from the initial authorization inasmuch as the authorizing
official can initiate a complete zero-base review of the information system or common
controls, or a targeted review based on the type of event or significant change that triggered
the reauthorization, the assessment of risk related to the event, the risk response of the
agency, and the agency risk tolerance. Reauthorization is a separate activity from the
ongoing authorization process, though security- and privacy-related information from the
agency’s ISCM and PCM programs may still be leveraged to support reauthorization. Note
also that reauthorization actions may necessitate a review of and changes to the ISCM or
PCM strategy, which may in turn affect ongoing authorization.
j. Joint and Leveraged Authorizations
Agencies are encouraged to use joint and leveraged authorizations whenever
practicable. 108 Joint authorizations can be used when multiple agency officials either from
the same agency or different agencies, have a shared interest in authorizing an information
system or common controls. The participating officials are collectively responsible and
accountable for the system and the common controls and jointly accept the risks that may
adversely impact agency operations and assets, individuals, other organizations, and the
Nation. Agencies choosing a joint authorization approach should work together on the
planning and the execution of the Risk Management Framework tasks described in NIST SP
800-37 and document their agreement and progress in implementing the tasks. The specific
terms and conditions of the joint authorization are established by the participating parties in
the joint authorization including, for example, the process for ongoing determination and
acceptance of risk. The joint authorization remains in effect only as long as there is mutual
agreement among authorizing officials and the authorization meets the requirements
established by Federal or agency policies.
Leveraged authorizations can be used when an agency chooses to accept some or all of the
information in an existing authorization package generated by another agency based on the
need to use the same information resources (e.g., information system or services provided by
the system). 109 The leveraging agency reviews the owning agency’s authorization package
as the basis for determining risk to the leveraging agency. The leveraging agency considers
risk factors such as the time elapsed since the authorization results were produced,
differences in environments of operation (if applicable), the impact of the information to be
processed, stored, or transmitted, and the overall risk tolerance of the leveraging agency. The
leveraging agency may determine that additional security measures are needed and negotiate
with the owning agency to provide such measures. To the extent that a leveraged
authorization includes an information system that creates, collects, uses, processes, stores,
108

NIST SP 800-37, Guide for Applying the Risk Management Framework to Federal Information Systems, provides
guidance on joint and leveraged security authorizations.
109

Agencies using leveraged authorization information from other (owning) agencies shall ensure that such
information is included as part of their own Risk Management Framework to provide the appropriate context for
managing risk within the leveraging organizations.

Appendix I - 22

maintains, disseminates, discloses, or disposes of PII, leveraging agencies must consult their
SAOP. The SAOP may determine that additional measures are required to manage privacy
risks prior to leveraging the authorization.
k. Continuous Monitoring
Agencies must develop ISCM and PCM strategies and implement ISCM and PCM activities
in accordance with applicable statutes, directives, policies, instructions, regulations,
standards, and guidelines. Agencies have the flexibility to develop an overarching ISCM and
PCM strategy (e.g., at the agency, bureau, or component level) that addresses all information
systems, or continuous monitoring strategies that address each agency information system
individually. The ISCM and PCM strategies must document all available security and
privacy controls selected and implemented by agencies, including the frequency of and
degree of rigor associated with the monitoring process. ISCM and PCM strategies, which
must be approved by the appropriate agency authorizing official and SAOP, respectively,
must also include all common controls inherited by agency information systems.
l. Critical Infrastructure
Agencies that operate information systems that are part of the critical infrastructure must
conduct a risk assessment to ensure that security controls for those systems are appropriately
tailored (including the deployment of additional controls, when necessary), thus providing
the required level of protection for critical Federal missions and business operations. In
addition, agencies must ensure that the privacy controls assigned to critical infrastructure
meet applicable privacy requirements and manage privacy risks. This includes the
continuous monitoring of deployed security and privacy controls in information systems
designated as critical infrastructure to determine the ongoing effectiveness of those controls
against current threats; improving the effectiveness of those controls, when necessary;
managing associated changes to the systems and environments of operation; and satisfying
specific protection and compliance requirements in statutes, executive orders, directives, and
policies required for critical infrastructure protection.
m. Encryption
When the assessed risk indicates the need, agencies must encrypt Federal information at rest
and in transit unless otherwise protected by alternative physical and logical safeguards
implemented at multiple layers, including networks, systems, applications, and data.
Encrypting information at rest and in transit helps to protect the confidentiality and integrity
of such information by making it less susceptible to unauthorized disclosure or modification.
Agencies must apply encryption requirements to Federal information categorized as either
moderate or high impact in accordance with FIPS Publication 199 unless encrypting such
information is technically unfeasible or would demonstrably affect their ability to carry out
their respective mission, functions, or operations. In situations where the use of encryption is
technically infeasible, for example, due to an aging legacy system, agencies must initiate the
appropriate system or system component upgrade or replacement actions at the earliest
opportunity to be able to accommodate such safeguarding technologies. Authorizing
officials who choose to operate information systems without the use of required encryption
technologies must carefully assess the risk in doing so, and they must receive written
Appendix I - 23

approval for the exception from the agency CIO, in consultation with the SAOP (as
appropriate). Only FIPS-validated cryptography is approved for use in Federal information
systems covered by this policy.
n. Digital Signatures
Digital signatures can mitigate a variety of security vulnerabilities by providing
authentication and non-repudiation capabilities, and ensuring the integrity of Federal
information whether such information is used in day-to-day operations or archived for future
use. Additionally, digital signatures can help agencies streamline mission or business
processes and transition manual processes to more automated processes to include, for
example, online transactions. Because of the advantages provided by this technology, OMB
expects agencies to implement digital signature capabilities in accordance with Federal PKI
policy, and NIST standards and guidelines. For employees and contractors, agencies must
require the use of the digital signature capability of Personal Identity Verification (PIV)
credentials. For individuals that fall outside the scope of PIV applicability, agencies should
leverage approved Federal PKI credentials when using digital signatures.
o. Identity Assurance
Identity assurance is an essential element of an effective information security program. To
streamline the process of citizens, businesses, and other partners 110 securely accessing
Government services online requires a risk-appropriate demand of identity assurance.
Identity assurance, in an online context, is the ability of an agency to determine that a claim
to a particular identity made by an individual can be trusted to actually be the individual’s
true identity. 111 Citizens, businesses, and other partners that interact with the Federal
Government need to have and be able to present electronic identity credentials to identify and
authenticate themselves remotely and securely when accessing Federal information
resources. An agency needs to be able to know, to a degree of certainty commensurate with
the risk determination, that the presented electronic identity credential truly represents the
individual presenting the credential before a transaction is authorized. 112 To transform
processes for citizens, businesses, and other partners accessing Federal services online, OMB
expects agencies to use a standards-based federated identity management approach that
enables security, privacy, ease-of-use, and interoperability among electronic authentication
systems. 113

110

“Other partners” may include contractors not subject to the NIST FIPS 201 identity standard.

111

Pursuant to Executive Order 13681, Improving the Security of Consumer Financial Transactions, agencies
making personal data accessible to citizens through digital applications shall require the use of multiple factors of
authentication and an effective identity proofing process, as appropriate.
112

NIST SP 800-63, Electronic Authentication Guidance, provides additional guidance on identity assurance.

113

The requirements in this paragraph focus on citizens, businesses, and other partners that interact with the Federal
Government. For Federal employees and contractors, with long-term access to Federal facilities and information
systems, agencies are required to follow Personal Identity Verification requirements in accordance with OMB policy
and NIST standards and guidelines.

Appendix I - 24

p. Unsupported Information System Components
Unsupported information system components (e.g., when developers or vendors are no
longer providing critical software patches) provide a substantial opportunity for adversaries
to exploit weaknesses discovered in the currently installed components. Prohibit the use of
unsupported information systems and system components, and ensure that systems and
components that cannot be appropriately protected or secured are given a high priority for
upgrade or replacement. Exceptions to replacing unsupported system components may
include, for example, systems that provide critical mission or business capability where
newer technologies are not available or where the systems are so isolated that installing
replacement components is not an option. For such systems, agencies can establish in-house
support, for example, by developing customized patches for critical software components or
securing the services of external providers who through contractual relationships, provide
ongoing support for the designated unsupported components. Such contractual relationships
can include, for example, open source software value-added vendors.
q. Cybersecurity Framework
The Cybersecurity Framework was developed by NIST in response to Executive Order
13636, Improving Critical Infrastructure Cybersecurity. The Framework describes five core
cybersecurity functions (i.e., Identify, Protect, Detect, Respond, and Recover) that may be
helpful in raising awareness and facilitating communication among agency stakeholders,
including executive leadership. The Cybersecurity Framework may also be helpful in
improving communications across organizations, allowing cybersecurity expectations to be
shared with business partners, suppliers, and among sectors. The Framework is not intended
to duplicate the current information security and risk management practices in place within
the Federal Government. However, in the course of managing information security risk
using the established NIST Risk Management Framework and associated security standards
and guidelines required by FISMA, agencies can leverage the Cybersecurity Framework to
complement their current information security programs. NIST is responsible for providing
guidance on how agencies can use the Cybersecurity Framework and in particular, how the
two frameworks can work together to help agencies develop, implement, and continuously
improve their information security programs.
r. FISMA Applicability to Non-Federal Entities
FISMA describes Federal agency security responsibilities as including “information
collected or maintained by or on behalf of an agency” and “information systems used or
operated by an agency or by a contractor of an agency or other organization on behalf of
an agency.” FISMA requires each agency to provide information security for the
information and “information systems that support the operations and assets of the agency,
including those provided or managed by another agency, contractor, or other source.” This
includes services that are either fully or partially provided, including agency-hosted,
outsourced, and cloud-based solutions.
Additionally, because FISMA applies to Federal information and information systems, in
certain circumstances, its requirements also apply to a specific class of IT that the ClingerCohen Act of 1996 (40 U.S.C. § 11101(6)) did not include, i.e., “equipment that is acquired
Appendix I - 25

by a Federal contractor incidental to a Federal contract.” Therefore, when Federal
information is used within incidentally acquired equipment, the agency continues to be
responsible and accountable for ensuring that FISMA requirements are met for such
information.
s. Controlled Unclassified Information
The Controlled Unclassified Information program, established by Executive Order 13556, is
a system that standardizes and simplifies the way the agencies handle unclassified
information that requires safeguarding or dissemination controls, pursuant to and consistent
with applicable law, regulations, and Government-wide policies. The program emphasizes
the openness and uniformity of Government-wide practices. Its purpose is to address
inefficient and confusing processes that have historically led to inconsistent marking and
safeguarding as well as restrictive dissemination policies.
6. Other Requirements
Agencies must adhere to all other applicable information requirements such as privacy
requirements in accordance with the Privacy Act of 1974, and its implementing OMB guidance;
confidentiality protection requirements in accordance with the Confidentiality Information
Protection and Statistical Efficiency Act of 2002 (CIPSEA) and its implementing OMB
guidance; applicable requirements of statutes, and regulations pertaining to management of
Federal records; and other relevant statutes, executive orders, Presidential directives, and
policies.
7. References 114
a. The following references are used within this policy:
1) Executive Order 13556, Controlled Unclassified Information, November 2010.
2) Executive Order 13636, Improving Critical Infrastructure Cybersecurity, February 2013.
3) Executive Order 13681, Improving the Security of Consumer Financial Transactions,
October 2014.
4) Homeland Security Presidential Directive 12, Policy for a Common Identification
Standard for Federal Employees and Contractors, August 2004.
5) Homeland Security Presidential Directive 20 (National Security Presidential Directive
51), National Continuity Policy, May 2007.
6) Federal Continuity Directive 1 (FCD 1), Federal Executive Branch National Continuity
Program and Requirements, February 2008.
7) National Communications System (NCS) Directive 3-10, Minimum Requirements for
Continuity Communications Capabilities, July 2007.

114
Statutes, executive orders, and Presidential directives relevant to this appendix are listed in the Authorities
section of the main body. Additionally, OMB policy documents can be located at
https://www.whitehouse.gov/omb/circulars_default and https://www.whitehouse.gov/omb/memoranda_default.

Appendix I - 26

8) National Institute of Standards and Technology Federal Information Processing
Standards Publication 199, Standards for Security Categorization of Federal
Information and Information Systems.
9) National Institute of Standards and Technology Federal Information Processing
Standards Publication 200, Minimum Security Requirements for Federal Information
and Information Systems.
10) National Institute of Standards and Technology Federal Information Processing
Standards Publication 201, Personal Identity Verification of Federal Employees and
Contractors.
11) National Institute of Standards and Technology Special Publication 800-18, Guide for
Developing Security Plans for Federal Information Systems.
12) National Institute of Standards and Technology Special Publication 800-30, Guide for
Conducting Risk Assessments.
13) National Institute of Standards and Technology Special Publication 800-37, Guide for
Applying the Risk Management Framework to Federal Information Systems: A Security
Life Cycle Approach.
14) National Institute of Standards and Technology Special Publication 800-39, Managing
Information Security Risk: Organization, Mission, and Information System View.
15) National Institute of Standards and Technology Special Publication 800-47, Security
Guide for Interconnecting Information Technology Systems.
16) National Institute of Standards and Technology Special Publication 800-53, Security and
Privacy Controls for Federal Information Systems and Organizations.
17) National Institute of Standards and Technology Special Publication 800-53A, Guide for
Assessing the Security Controls in Federal Information Systems and Organizations:
Building Effective Security Assessment Plans.
18) National Institute of Standards and Technology Special Publication 800-59, Guideline
for Identifying an Information System as a National Security System.
19) National Institute of Standards and Technology Special Publication 800-60, Guide for
Mapping Types of Information and Information Systems to Security Categories.
20) National Institute of Standards and Technology Special Publication 800-63, Electronic
Authentication Guideline.
21) National Institute of Standards and Technology Special Publication 800-73, Interfaces
for Personal Identity Verification.
22) National Institute of Standards and Technology Special Publication 800-76, Biometric
Specifications for Personal Identity Verification.
23) National Institute of Standards and Technology Special Publication 800-78,
Cryptographic Algorithms and Key Sizes for Personal Identity Verification.

Appendix I - 27

24) National Institute of Standards and Technology Special Publication 800-79, Guidelines
for the Authorization of Personal Identity Verification Card Issuers (PCI) and Derived
PIV Credential Issuers (DPCI).
25) National Institute of Standards and Technology Special Publication 800-116, Guidelines
for the Use of PIV Credentials in Physical Access Control Systems (PACS).
26) National Institute of Standards and Technology Special Publication 800-122, Guide to
Protecting the Confidentiality of Personally Identifiable Information (PII).
27) National Institute of Standards and Technology Special Publication 800-137,
Information Security Continuous Monitoring for Federal Information Systems and
Organizations.
28) National Institute of Standards and Technology Special Publication 800-157, Guidelines
for Derived Personal Identity Verification Credentials.
29) National Institute of Standards and Technology Special Publication 800-161, Supply
Chain Risk Management Practices for Federal Information Systems and Organizations.
30) National Institute of Standards and Technology Special Publication 800-162, Guide to
Attribute Based Access Control (ABAC) Definition and Considerations.
31) National Institute of Standards and Technology Special Publication 800-171, Protecting
Controlled Unclassified Information in Nonfederal Information Systems and
Organizations.
32) National Institute of Standards and Technology Framework for Improving Critical
Infrastructure Cybersecurity.
33) National Institute of Standards and Technology Supplemental Guidance on Ongoing
Authorization: Transitioning to Near Real-Time Risk Management.
b. References in this section without specific publication dates or revision numbers refer to the
most recent updates to those publications.

Appendix I - 28

Appendix II to OMB Circular A-130
Responsibilities for Managing Personally Identifiable Information
1. Purpose
This Appendix outlines some of the general responsibilities for Federal agencies managing
information resources that involve personally identifiable information (PII) and summarizes the
key privacy requirements included in other sections of this Circular. The requirements included
in this Appendix apply to PII in any form or medium, including paper and electronic media.
Although all of the requirements referenced in this Appendix concern the management of PII,
some of the requirements are not solely the responsibility of agencies’ privacy programs. The
inclusion of shared requirements in this Appendix is not intended to suggest that agencies’
privacy programs are solely or primarily responsible for meeting such requirements; however,
agencies’ privacy programs shall play a key role in meeting requirements that involve PII. This
Appendix does not provide a comprehensive account of all the statutory and policy requirements
associated with managing PII and protecting privacy. Agencies shall consult law, regulation, and
policy, including OMB guidance, to understand all applicable requirements.
The main body of this Circular establishes general policies for Federal agencies managing
information resources. Appendix I to this Circular establishes requirements for information
security and privacy programs and provides guidance on how agencies should take a coordinated
approach when managing Federal information resources. This Appendix and Appendix I are
companion documents; it is important to review the appendices together in order to understand
the coordination between privacy and security. As noted in the citations, all of the requirements
summarized in the tables in this Appendix come from the main body or Appendix I to this
Circular.
Previous versions of Circular A-130 included information about the reporting and publication
requirements of the Privacy Act of 1974 (“Privacy Act”) and additional OMB guidance. This
information is being revised and will be reissued in OMB Circular A-108. 115 This Appendix
does not extend or interpret the Privacy Act, including agency requirements under the Privacy
Act.
2. Introduction
The Federal Government necessarily creates, collects, uses, processes, stores, maintains,
disseminates, discloses, and disposes of PII to carry out missions mandated by Federal statute.
The term PII, as defined in this Circular, refers to information that can be used to distinguish or
trace an individual’s identity, either alone or when combined with other information that is
linked or linkable to a specific individual. Because there are many different types of information
that can be used to distinguish or trace an individual’s identity, the term PII is necessarily broad.
To determine whether information is PII, the agency shall perform an assessment of the specific
risk that an individual can be identified using the information with other information that is
linked or linkable to the individual. In performing this assessment, it is important to recognize
115

Agencies shall continue to apply the requirements in Appendix I of the 2000 version of Circular A-130 regarding
review, reporting, and publication pertaining to the Privacy Act until OMB issues a revised version of those
requirements in OMB Circular A-108.

Appendix II - 1

that information that is not PII can become PII whenever additional information becomes
available – in any medium and from any source – that would make it possible to identify an
individual.
Once the agency determines that an information system contains PII, the agency shall then
consider the privacy risks and the associated risk to agency operations, agency assets,
individuals, other organizations, and the Nation. When considering privacy risks, the agency
shall consider the risks to an individual or individuals associated with the agency’s creation,
collection, use, processing, storage, maintenance, dissemination, disclosure, and disposal of their
PII. In particular, the agency shall evaluate the sensitivity of each individual data element that is
PII, as well as all of the data elements together. The sensitivity level of the PII will depend on
the context, including the purpose for which the PII is created, collected, used, processed, stored,
maintained, disseminated, disclosed, or disposed. For example, the sensitivity level of a list of
individuals’ names may depend on the source of the information, the other information
associated with the list, the intended use of the information, the ways in which the information
will be processed and shared, and the ability to access the information. In addition, when
determining the privacy and associated risks, the agency shall also consider the volume of PII. A
higher volume of PII about a single individual or multiple individuals may pose increased
privacy or associated risks.
3. Fair Information Practice Principles
The Fair Information Practice Principles (FIPPs) are a collection of widely accepted principles
that agencies should use when evaluating information systems, processes, programs, and
activities that affect individual privacy. The FIPPs are not OMB requirements; rather, they are
principles that should be applied by each agency according to the agency’s particular mission
and privacy program requirements.
Rooted in a 1973 Federal Government report from the Department of Health, Education, and
Welfare Advisory Committee, “Records, Computers and the Rights of Citizens,” the FIPPs have
informed Federal statute and the laws of many U.S. states and foreign nations, and have been
incorporated in the policies of many organizations around the world. The precise expression of
the FIPPs has varied over time and in different contexts. However, the FIPPs retain a consistent
set of core principles that are broadly relevant to agencies’ information management practices.
For purposes of this Circular, the FIPPs are as follows:
a. Access and Amendment. Agencies should provide individuals with appropriate access to PII
and appropriate opportunity to correct or amend PII. 116
b. Accountability. Agencies should be accountable for complying with these principles and
applicable privacy requirements, and should appropriately monitor, audit, and document
compliance. Agencies should also clearly define the roles and responsibilities with respect to
116
The Access and Amendment principle is included as part of the “Individual Participation” privacy control family
in NIST SP 800-53, Security and Privacy Controls for Federal Information Systems. OMB is including Access and
Amendment as a stand-alone principle in this Circular to emphasize the importance of allowing individuals to access
and amend their information when appropriate.

Appendix II - 2

PII for all employees and contractors, and should provide appropriate training to all
employees and contractors who have access to PII.
c. Authority. Agencies should only create, collect, use, process, store, maintain, disseminate, or
disclose PII if they have authority to do so, and should identify this authority in the
appropriate notice. 117
d. Minimization. Agencies should only create, collect, use, process, store, maintain,
disseminate, or disclose PII that is directly relevant and necessary to accomplish a legally
authorized purpose, and should only maintain PII for as long as is necessary to accomplish
the purpose. 118
e. Quality and Integrity. Agencies should create, collect, use, process, store, maintain,
disseminate, or disclose PII with such accuracy, relevance, timeliness, and completeness as is
reasonably necessary to ensure fairness to the individual.
f. Individual Participation. Agencies should involve the individual in the process of using PII
and, to the extent practicable, seek individual consent for the creation, collection, use,
processing, storage, maintenance, dissemination, or disclosure of PII. Agencies should also
establish procedures to receive and address individuals’ privacy-related complaints and
inquiries.
g. Purpose Specification and Use Limitation. Agencies should provide notice of the specific
purpose for which PII is collected and should only use, process, store, maintain, disseminate,
or disclose PII for a purpose that is explained in the notice and is compatible with the
purpose for which the PII was collected, or that is otherwise legally authorized.
h. Security. Agencies should establish administrative, technical, and physical safeguards to
protect PII commensurate with the risk and magnitude of the harm that would result from its
unauthorized access, use, modification, loss, destruction, dissemination, or disclosure.
i. Transparency. Agencies should be transparent about information policies and practices with
respect to PII, and should provide clear and accessible notice regarding creation, collection,
use, processing, storage, maintenance, dissemination, and disclosure of PII. 119
4. Senior Agency Official for Privacy
Agencies are required to designate a Senior Agency Official for Privacy (SAOP) who has
agency-wide responsibility and accountability for ensuring compliance with applicable privacy
requirements and managing privacy risks. The SAOP shall have a central policy-making role
and shall ensure that the agency considers the privacy impact of all agency actions and policies
that involve PII. The SAOP’s review of privacy risks should begin at the earliest planning and
117

The Authority principle is included as part of the “Purpose Specification” privacy control family in NIST SP 80053, Security and Privacy Controls for Federal Information Systems. OMB is including Authority as a stand-alone
principle in this Circular to emphasize the importance of identifying a specific authority for creating, collecting,
using, processing, storing, maintaining, disseminating, or disclosing PII.
118

In some versions of the FIPPs, the “minimization” principle is referred to under a different name, such as
“collection limitation.”
119
In some versions of the FIPPs, the “transparency” principle is referred to under a different name, such as
“openness.”

Appendix II - 3

development stages of agency actions and policies that involve PII, and should continue
throughout the life cycle of the information.
The SAOP shall ensure that the agency complies with applicable privacy requirements in statute,
regulation, and policy.
5. Agency Privacy Program
In order to manage Federal information resources that involve PII, agencies shall develop,
implement, document, maintain, and oversee agency-wide privacy programs that include people,
processes, and technologies. Among other things, where PII is involved, agencies’ privacy
programs shall play a key role in information security, records management, strategic planning,
budget and acquisition, contractors and third parties, workforce, training, incident response, and
implementing the Risk Management Framework. This Appendix does not provide a
comprehensive account of all the statutory and policy requirements associated with managing PII
and protecting privacy. Agencies shall consult law, regulation, and policy, including OMB
guidance, to understand all applicable requirements.
Agencies’ privacy programs are led by the SAOP and are responsible for ensuring compliance
with applicable privacy requirements, developing and evaluating privacy policy, and managing
privacy risks. At the discretion of the SAOP and consistent with applicable law, other qualified
agency personnel may perform particular privacy functions that are assigned to the SAOP.
Many of the requirements summarized in this Appendix are shared requirements and are not
solely the responsibility of agencies’ privacy programs. The inclusion of shared requirements in
this Appendix is intended to convey that agencies’ privacy programs shall be responsible to the
extent that the requirements pertain to the management of PII.
a.

General Requirements

Agencies shall have comprehensive privacy programs that ensure compliance with applicable
privacy requirements, develop and evaluate privacy policy, and manage privacy risks. The
following table summarizes many of the general privacy requirements that are set forth in this
Circular. While some of the requirements summarized in the table are not exclusively privacy
requirements, they may still require the involvement of agencies’ privacy programs.
Responsibility

Description

Establish and maintain a
comprehensive privacy
program.

Agencies shall establish and maintain a comprehensive
privacy program that ensures compliance with
applicable privacy requirements, develops and
evaluates privacy policy, and manages privacy risks.

Main Body § 5(f)(1)(a);
Appendix I §§ 3(b), 3(f),
4(e).

Ensure compliance with
privacy requirements
and manage privacy
risks.

Agencies shall ensure compliance with all applicable
statutory, regulatory, and policy requirements and use
privacy impact assessments and other tools to manage
privacy risks. Agencies shall cost-effectively manage
privacy risks and reduce such risks to an acceptable
level.

Main Body §§ 4(g),
5(e)(1)(d), 5(f)(1)(a);
Appendix I § 3(a), 3(b)(4),
3(f), 3(g).

Appendix II - 4

Citation

Responsibility

Description

Citation

Monitor Federal law,
regulation, and policy
for changes.

Agencies shall monitor Federal law, regulation, and
policy for changes that affect privacy.

Main Body § 5(f)(1)(c).

Develop and maintain a
privacy program plan.

Agencies shall develop and maintain a privacy program
plan that provides an overview of the agency’s privacy
program, including a description of the structure of the
privacy program, the resources dedicated to the privacy
program, the role of the SAOP and other privacy
officials and staff, the strategic goals and objectives of
the privacy program, the program management controls
and common controls in place or planned for meeting
applicable privacy requirements and managing privacy
risks, and any other information determined necessary
by the agency’s privacy program.

Appendix I § 4(c)(2),
4(e)(1).

Designate a Senior
Agency Official for
Privacy.

The head of each agency shall designate an SAOP who
has agency-wide responsibility and accountability for
developing, implementing, and maintaining an agencywide privacy program to ensure compliance with all
applicable statues, regulations, and policies regarding
the creation, collection, use, processing, storage,
maintenance, dissemination, disclosure, and disposal of
PII by programs and information systems, developing
and evaluating privacy policy, and managing privacy
risks at the agency.

Main Body § 5(f)(1)(b);
Appendix I § 4(e).

Ensure coordination
between privacy and
other programs.

Agencies shall ensure that the SAOP and the agency’s
privacy personnel closely coordinate with the agency
CIO, senior agency information security officer, and
other agency offices and officials, as appropriate.

Main Body §§ 4(h),
5(f)(1)(k); Appendix I §§
3(b)(11), 4(e)(10).

Ensure that privacy is
addressed throughout the
life cycle of each
information system.

Agencies shall ensure that privacy is addressed
throughout the life cycle of each agency information
system.

Main Body §§ 4(g),
5(a)(1)(c)(i), 5(b)(4);
Appendix I § 4(b)(2).

Incorporate privacy
requirements into
enterprise architecture.

Agencies shall incorporate Federal privacy
requirements into the agency’s enterprise architecture
to ensure that risk is addressed and information
systems achieve the necessary levels of
trustworthiness, protection, and resilience.

Appendix I § 4(b)(5).

Comply with the Privacy
Act.

Agencies shall comply with the requirements of the
Privacy Act and ensure that Privacy Act system of
records notices are published, revised, and rescinded,
as required.

Main Body § 5(f)(1)(g).

Conduct privacy impact
assessments.

Agencies shall conduct privacy impact assessments in
accordance with the E-Government Act and make the
privacy impact assessments available to the public in
accordance with OMB policy.

Main Body § 5(f)(1)(i).

Appendix II - 5

Responsibility

Description

Citation

Balance the need for
information collection
with the privacy risks.

Agencies shall ensure that the design of information
collections is consistent with the intended use of the
information, and the need for new information is
balanced against any privacy risks.

Main Body § 4(i).

Comply with
requirements for
disclosure and
dissemination.

Agencies shall comply with all applicable privacy
statutes and policies governing the disclosure or
dissemination of information and comply with any
other valid access, use, and dissemination restrictions.

Main Body § 5(e)(1)(b)(d), 5(e)(7)(h).

Maintain and post
privacy policies on
websites, mobile
applications, and other
digital services.

Agencies shall maintain and post privacy policies on
all agency websites, mobile applications, and other
digital services, in accordance with the E-Government
Act and OMB policy.

Main Body § 5(f)(1)(j).

Provide performance
metrics and reports.

Agencies shall provide performance metrics
information and reports in accordance with processes
established by OMB and DHS pursuant to FISMA.

Appendix I § 4(1).

b. Considerations for Managing PII
Agencies’ privacy programs shall maintain an inventory of PII, regularly review all PII
maintained by the agency, and comply with applicable requirements regarding the creation,
collection, use, processing, storage, maintenance, dissemination, disclosure, and disposal of PII.
In addition, agencies’ privacy programs shall impose, where appropriate, conditions on other
agencies and entities to which PII is being disclosed that govern the creation, collection, use,
processing, storage, maintenance, dissemination, disclosure, and disposal of the PII. The
following table summarizes the privacy requirements in this Circular that pertain to the general
management of PII. While some requirements summarized in the table are not exclusively
privacy requirements, they may still require the involvement of agencies’ privacy programs.
Responsibility

Description

Citation

Maintain an inventory of
agency information
systems that involve PII
and regularly review and
reduce PII to the
minimum necessary.

Agencies shall maintain an inventory of the agency’s
information systems that create, collect, use, process,
store, maintain, disseminate, disclose, or dispose of PII
to allow the agency to regularly review its PII and
ensure, to the extent reasonably practicable, that such
PII is accurate, relevant, timely, and complete; and to
allow the agency to reduce its PII to the minimum
necessary for the proper performance of authorized
agency functions.

Main Body § 5(a)(1)(a)(ii),
5(f)(1)(e).

Eliminate unnecessary
collection, maintenance,
and use of Social
Security numbers.

Agencies shall take steps to eliminate unnecessary
collection, maintenance, and use of Social Security
numbers, and explore alternatives to the use of Social
Security numbers as a personal identifier.

Main Body § 5(f)(1)(f).

Appendix II - 6

Responsibility

Description

Citation

Follow approved records
retention schedules for
records with PII.

Agencies shall ensure that all records with PII are
maintained in accordance with applicable records
retention or disposition schedules approved by NARA.

Main Body § 5(f)(1)(h).

Limit the creation,
collection, use,
processing, storage,
maintenance,
dissemination, and
disclosure of PII.

Agencies shall limit the creation, collection, use,
processing, storage, maintenance, dissemination, and
disclosure of PII to that which is legally authorized,
relevant, and reasonably deemed necessary for the
proper performance of agency functions.

Main Body § 5(f)(1)(d).

Require entities with
which PII is shared to
maintain the PII in an
information system with
a particular
categorization level.

Agencies that share PII shall require, as appropriate,
other agencies and entities with which they share PII to
maintain the PII in an information system with a
particular NIST FIPS Publication 199 confidentiality
impact level, as determined by the agency sharing the
PII.

Appendix I § 3(c).

Impose conditions on the
creation, collection, use,
processing, storage,
maintenance,
dissemination,
disclosure, and disposal
of shared PII through
agreements.

Agencies that share PII with other agencies or entities
shall impose, where appropriate, conditions (including
the selection and implementation of particular security
and privacy controls) that govern the creation,
collection, use, processing, storage, maintenance,
dissemination, disclosure, and disposal of the PII
through written agreements, including contracts, data
use agreements, information exchange agreements, and
memoranda of understanding.

Appendix I § 3(d).

c. Budget and Acquisition
Agencies’ privacy programs shall have the resources needed to manage Federal information
resources that involve PII. This will require privacy programs to play a key role in the
development of the agencies’ budget requests, as well as any decisions to acquire or develop
information system technologies and services. The following table summarizes the privacy
requirements in this Circular that pertain to budget and acquisition activities. While some of the
requirements summarized in the table are not exclusively privacy requirements, they may still
require the involvement of agencies’ privacy programs.
Responsibility

Description

Citation

Identify and plan for
resources needed for
privacy program.

Agencies shall identify and plan for the resources
needed to implement privacy programs.

Appendix I § 4(b)(1).

Include privacy
requirements in IT
solicitations.

Agencies shall include privacy requirements in
solicitations for IT and services.

Main body § 5(d)(1)(j).

Appendix II - 7

Responsibility

Description

Citation

Establish a process to
evaluate privacy risks
for IT investments.

Agencies shall consider privacy when analyzing IT
investments, and establish a decision-making process
that shall cover the life of each information system and
include explicit criteria for analyzing the projected and
actual costs, benefits, and risks, including privacy risks,
associated with the IT investments.

Main Body § 5(d)(3),
5(d)(4)(b).

Ensure that privacy risks
are addressed and costs
are included in IT capital
investment plans and
budgetary requests.

The SAOP shall review IT capital investment plans and
budgetary requests to ensure that privacy requirements
(and associated privacy controls), as well as any
associated costs, are explicitly identified and included,
with respect to any IT resources that will be used to
create, collect, use, process, store, maintain,
disseminate, disclose, or dispose of PII. Agencies shall
ensure that agency budget justification materials, in
their initial budget submission to OMB, include a
statement affirming that the SAOP has conducted the
necessary review.

Main Body § 5(a)(3)(e)(ii),
5(d)(3)(e); Appendix I §
4(b)(2), 4(e)(6).

Ensure that investment
plans meet the privacy
requirements appropriate
for the life cycle stage of
the investment.

Agencies shall ensure that investment plans submitted
to OMB as part of the budget process meet the privacy
requirements appropriate for the life cycle stage of the
investment.

Appendix I § 4(b)(4).

Upgrade, replace, or
retire unprotected
information systems.

Agencies shall plan and budget to upgrade, replace, or
retire any information systems for which protections
commensurate with risk cannot be effectively
implemented.

Appendix I § 4(b)(3).

Ensure that SAOPs are
made aware of
information systems and
components that cannot
be protected.

Agencies shall ensure that, in a timely manner, SAOPs
are made aware of information systems and
components that cannot be appropriately protected or
secured, and that such systems are given a high priority
for upgrade, replacement, or retirement.

Main Body § 5(a)(1)(c)(ii);
Appendix I § 3(b)(10).

d.

Contractors and Third Parties

Agencies’ privacy programs shall ensure that entities that create, collect, use, process, store,
maintain, disseminate, disclose, or dispose of information on behalf of a Federal agency or that
operate or use information systems on behalf of a Federal agency, comply with the privacy
requirements in law and OMB policies. The following table summarizes the privacy
requirements in this Circular that pertain to contractors and third parties. While some of the
requirements summarized in the table are not exclusively privacy requirements, they may still
require the involvement of agencies’ privacy programs.

Appendix II - 8

Responsibility

Description

Citation

Ensure that contracts and
other agreements
incorporate privacy
requirements.

Agencies shall ensure that terms and conditions in
contracts, and other agreements involving the creation,
collection, use, processing, storage, maintenance,
dissemination, disclosure, and disposal of Federal
information, incorporate privacy requirements and are
sufficient to enable agencies to meet Federal and
agency-specific requirements pertaining to the
protection of Federal information.

Main Body § 5(a)(1)(b)(ii);
Appendix I § 4(j)(1).

Maintain agency-wide
privacy training for all
employees and
contractors.

Agencies shall develop, maintain, and implement
mandatory agency-wide privacy awareness and training
programs for all employees and contractors.

Appendix I § 4(h)(1)-(2),
(4)-(7).

Ensure that the Privacy
Act applies to
contractors where
required.

Agencies shall, consistent with the agency’s authority,
ensure that the requirements of the Privacy Act apply
to a Privacy Act system of records when a contractor
operates the system of records on behalf of the agency
to accomplish an agency function.

Appendix I § 4(j)(3).

Oversee information
systems operated by
contractors.

Agencies shall provide oversight of information
systems used or operated by contractors or other
entities on behalf of the Federal Government or that
collect or maintain Federal information on behalf of the
Federal Government.

Appendix I § 4(j)(2).

Implement policies on
privacy oversight of
contractors.

Agencies shall document and implement policies and
procedures for privacy oversight of contractors and
other entities, to include ensuring appropriate vetting
and access control processes for contractors and others
with access to information systems containing Federal
information.

Appendix I § 4(j)(2)(a).

Ensure implementation
of privacy controls for
contractor information
systems.

Agencies shall ensure that privacy controls of
information systems and services used or operated by
contractors or other entities on behalf of the agency are
effectively implemented and comply with NIST
standards and guidelines and agency requirements.

Appendix I § 4(j)(2)(b).

Maintain an inventory of
contractor information
systems.

Agencies shall ensure that information systems used or
operated by contractors or other entities on behalf of
the agency are included in the agency’s inventory of
information systems.

Appendix I § 4(j)(2)(c).

Ensure that incident
response procedures are
in place for contractor
information systems.

Agencies shall ensure that procedures are in place for
incident response for information systems used or
operated by contractors or other entities on behalf of
the agency, including timelines for notification of
affected individuals and reporting to OMB, DHS, and
other entities as required in OMB guidance.

Appendix I § 4(j)(2)(e).

e. Privacy Impact Assessments
As a general matter, an agency shall conduct a privacy impact assessment (PIA) under section
208(b) of the E-Government Act of 2002, absent an applicable exception under that section,
Appendix II - 9

when the agency develops, procures, or uses information technology to create, collect, use,
process, store, maintain, disseminate, disclose, or dispose of PII. 120 A PIA is an analysis of how
PII is handled to ensure that handling conforms to applicable privacy requirements, determine
the privacy risks associated with an information system or activity, and evaluate ways to mitigate
privacy risks. A PIA is both an analysis and a formal document detailing the process and the
outcome of the analysis.
A PIA is one of the most valuable tools Federal agencies use to ensure compliance with
applicable privacy requirements and manage privacy risks. Agencies shall conduct and draft a
PIA with sufficient clarity and specificity to demonstrate that the agency fully considered
privacy and incorporated appropriate privacy protections from the earliest stages of the agency
activity and throughout the information life cycle. In order to conduct a meaningful PIA, the
agency’s SAOP shall work closely with the program managers, information system owners,
information technology experts, security officials, counsel, and other relevant agency officials.
Moreover, a PIA is not a time-restricted activity that is limited to a particular milestone or stage
of the information system or PII life cycles. Rather, the privacy analysis shall continue
throughout the information system and PII life cycles. Accordingly, a PIA shall be considered a
living document that agencies are required to update whenever changes to the information
technology, changes to the agency’s practices, or other factors alter the privacy risks associated
with the use of such information technology.
In addition to serving as an important analytical tool for agencies, a PIA also serves as notice to
the public regarding the agency’s practices with respect to privacy and information technology.
All PIAs shall be drafted in plain language and shall be posted on the agency’s website, unless
doing so would raise security concerns or reveal classified or sensitive information. Although
PIAs are generally required by law, such as by the E-Government Act of 2002, agencies may
also develop policies to require PIAs in circumstances where a PIA would not be required by
law.
f. Workforce Management
Agencies’ privacy programs shall play a key role in workforce management activities. The
SAOP shall be involved in assessing the hiring and professional development needs at the
agency with respect to privacy. The following table summarizes the privacy requirements in this
Circular that pertain to workforce management activities. While some of the requirements
summarized in the table are not exclusively privacy requirements, they may still require the
involvement of agencies’ privacy programs.

120

See 44 U.S.C. § 3501 note; Pub. L. 107–347, § 208(b). Section 208(b) of the E-Government Act requires
agencies, absent an applicable exception under this section, to conduct a PIA before: (i) developing or procuring IT
that collects, maintains, or disseminates information that is in an identifiable form; or (ii) initiating a new collection
of information that – (I) will be collected, maintained, or disseminated using IT; and (II) includes any information in
an identifiable form permitting the physical or online contacting of a specific individual, if identical questions have
been posed to, or identical reporting requirements imposed on, 10 or more persons, other than agencies,
instrumentalities, or employees of the Federal Government.

Appendix II - 10

Responsibility

Description

Citation

Ensure that the SAOP is
involved in assessing and
addressing privacy hiring,
training, and professional
development needs.

Agencies shall ensure that the SAOP is involved in
assessing and addressing the hiring, training, and
professional development needs of the agency with
respect to privacy.

Main Body § 5(c)(6).

Maintain a workforce
planning process.

Agencies shall ensure that the CHCO, CIO, CAO,
and SAOP develop and maintain a current workforce
planning process to ensure that the agency can
anticipate and respond to changing mission
requirements, maintain workforce skills in a rapidly
developing IT environment, and recruit and retain
the IT talent needed to accomplish the mission.

Main Body § 5(c)(1).

Develop a set of privacy
competency requirements.

Agencies shall ensure that the CHCO, CIO, CAO,
and SAOP develop a set of competency requirements
for information resources staff, including program
managers and information security, privacy, and IT
leadership positions.

Main Body § 5(c)(1).

Ensure that the workforce
has the appropriate
knowledge and skill.

Agencies shall ensure that the workforce, which
supports the acquisition, management, maintenance,
and use of information resources, has the appropriate
knowledge and skill.

Main Body § 5(c)(2).

Take advantage of flexible
hiring authorities for
specialized positions.

Agencies shall ensure that the CIO, CHCO, SAOP,
and other hiring managers take advantage of flexible
hiring authorities for specialized positions, as
established by OPM.

Main Body § 5(c)(7).

g. Training and Accountability
Agencies’ privacy programs shall develop, maintain, and provide agency-wide privacy
awareness and training programs for all employees and contractors. In addition, the privacy
program shall establish rules of behavior for employees and contractors with access to PII and
hold agency personnel accountable for complying with applicable privacy requirements and
managing privacy risks. The following table summarizes the privacy requirements in this
Circular that pertain to training and accountability activities. Some of the requirements
summarized in the table are not solely privacy requirements but may require the involvement of
agencies’ privacy programs.
Responsibility

Description

Maintain agency-wide
privacy training for all
employees and contractors.

Agencies shall develop, maintain, and implement
mandatory agency-wide privacy awareness and
training programs for all employees and contractors.

Appendix I § 4(h)(1).

Ensure that privacy
training is consistent with
applicable policies.

Agencies shall ensure that the privacy awareness and
training programs are consistent with applicable
policies, standards, and guidelines issued by OMB,
NIST, and OPM.

Appendix I § 4(h)(2).

Appendix II - 11

Citation

Responsibility

Description

Citation

Apprise agency employees
about available privacy
resources.

Agencies shall apprise agency employees about
available privacy resources, such as products,
techniques, or expertise.

Appendix I § 4(h)(3).

Provide foundational and
advanced privacy training.

Agencies shall provide foundational as well as more
advanced levels of privacy training to information
system users (including managers, senior executives,
and contractors) and ensure that measures are in
place to test the knowledge level of information
system users.

Appendix I § 4(h)(4).

Provide role-based privacy
training to appropriate
employees and contractors.

Agencies shall provide role-based privacy training to
employees and contractors with assigned privacy
roles and responsibilities, including managers, before
authorizing access to Federal information or
information systems or performing assigned duties.

Appendix I § 4(h)(5).

Hold personnel
accountable for complying
with privacy requirements
and policies.

Agencies shall implement policies and procedures to
ensure that all personnel are held accountable for
complying with agency-wide privacy requirements
and policies.

Appendix I § 3(b)(9).

Establish rules of behavior
for employees and
contractors with access to
PII and consequences for
violating the rules.

Agencies shall establish rules of behavior, including
consequences for violating rules of behavior, for
employees and contractors that have access to
Federal information or information systems,
including those that create, collect, use, process,
store, maintain, disseminate, disclose, or dispose of
PII.

Appendix I § 4(h)(6).

Ensure that employees and
contractors read and agree
to rules of behavior.

Agencies shall ensure that employees and contractors
have read and agreed to abide by the rules of
behavior for the Federal information and information
systems for which they require access prior to being
granted access.

Appendix I § 4(h)(7).

h. Incident Response
Agencies’ privacy programs shall develop and implement incident management and response
capabilities. The following table summarizes the privacy requirements in this Circular that
pertain to incident response. While some of the requirements summarized in the table are not
solely privacy requirements, they may still require the involvement of agencies’ privacy
programs.
Responsibility
Maintain formal incident
management and response
policies and capabilities.

Description
Agencies shall maintain formal incident response
capabilities and mechanisms, implement formal
incident management policies, and provide
adequate training and awareness for employees
and contractors on how to report and respond to
incidents.

Appendix II - 12

Citation
Appendix I § 4(f)(1), (7)(8).

Responsibility

Description

Citation

Establish roles and
responsibilities to ensure
oversight and coordination of
incident response.

Agencies shall establish clear roles and
responsibilities to ensure the oversight and
coordination of incident response activities and
that incidents are documented, reported,
investigated, and handled.

Appendix I § 4(f)(3).

Periodically test incident
response procedures.

Agencies shall periodically test incident response
procedures to ensure effectiveness of such
procedures.

Appendix I § 4(f)(4).

Document incident response
lessons learned and update
procedures.

Agencies shall document lessons learned for
incident response and update procedures annually
or as required by OMB or DHS.

Appendix I § 4(f)(5).

Ensure that processes are in
place to verify corrective
actions.

Agencies shall ensure that processes are in place to
verify corrective actions.

Appendix I § 4(f)(6).

Report incidents in
accordance with OMB
guidance.

Agencies shall report incidents to OMB, DHS, the
CIO, the SAOP, their respective inspectors general
and general counsel, law enforcement, and
Congress in accordance with procedures issued by
OMB.

Appendix I § 4(f)(9).

Provide reports on incidents
as required.

Agencies shall provide reports on incidents as
required by FISMA, OMB policy, DHS binding
operational directives, Federal information
security incident center guidelines, NIST
guidelines, and agency procedures.

Appendix I § 4(f)(10).

i. Risk Management Framework 121
Agencies’ privacy programs have responsibilities under the Risk Management Framework,
which is also covered in Appendix I to this Circular. The Risk Management Framework
provides a disciplined and structured process that integrates information security, privacy, and
risk management activities into the information system development life cycle. This Circular
requires agencies to use the Risk Management Framework to manage privacy risks beyond those
that are typically included under the “confidentiality” objective of the term “information
security.” 122 While many privacy risks relate to the unauthorized access or disclosure of PII,
121

Traditionally, the Risk Management Framework was a framework to help agencies address information security
and related risks in the authorization process for Federal information systems. As explained in this Appendix, this
Circular integrates agencies’ privacy programs into the Risk Management Framework process. NIST has published
a suite of standards and guidelines that describe how to implement an agency-wide risk management framework. As
of the date of this publication, many of the existing NIST standards and guidelines that detail how to implement an
agency-wide risk management framework do not fully address the role of privacy and agencies’ privacy programs.
In the future, NIST may revise or develop standards and guidelines to further clarify how privacy and agencies’
privacy programs are integrated into the Risk Management Framework.
122

The term “information security,” as defined in law and in this Circular, includes three objectives: integrity,
availability, and confidentiality. The term “confidentiality” means “preserving authorized restrictions on access and
disclosure, including means for protecting personal privacy and proprietary information.” See 44 U.S.C. § 3552.

Appendix II - 13

privacy risks may also result from other activities, including the creation, collection, use, and
retention of PII; the inadequate quality or integrity of PII; and the lack of appropriate notice,
transparency, or participation. 123
The Risk Management Framework has the following steps:
1) Categorize. Agencies shall categorize each information system and the information
processed, stored, and transmitted by that information system based on an assessment of
the potential impact that a loss of confidentiality, integrity, or availability of such
information or information system would have on agency operations, agency assets,
individuals, other organizations, and the Nation. 124 Each information system is
categorized at low, moderate, or high impact according to the criteria in NIST standards
and guidelines. The SAOP is responsible for reviewing and approving the categorization
of information systems that create, collect, use, process, store, maintain, disseminate,
disclose, or dispose of PII.
The categorization of information systems that create, collect, use, process, store,
maintain, disseminate, disclose, or dispose of PII will depend on the sensitivity of the
PII, the privacy risks, and the associated risk to agency operations, agency assets,
individuals, other organizations, and the Nation. Agencies should generally categorize
information systems that create, collect, use, process, store, maintain, disseminate,
disclose, or dispose of PII at the moderate or high confidentiality impact level.
2) Select. Agencies shall select security and privacy controls for each information system.
A security control is a safeguard or countermeasure prescribed for an information system
or an agency to protect the confidentiality, integrity, and availability of the system and
its information. Security controls primarily pertain to security but they can also enhance
privacy. Agencies shall select an initial set of baseline security controls for the
information system based on the security categorization and then tailor the security
control baseline, as needed, based on an assessment of security risk and local
conditions. 125
A privacy control is an administrative, technical, or physical safeguard employed within
an agency to ensure compliance with applicable privacy requirements and manage
privacy risks. 126 In order to help agencies satisfy privacy requirements and manage
privacy risks, NIST has developed a set of privacy controls, based on the FIPPs, in
Special Publication (SP) 800-53, Security and Privacy Controls for Federal Information
123

Refer to the Fair Information Practice Principles in section 3 of this Appendix.

124

See National Institute of Standards and Technology FIPS Publication 199, Standards for Security Categorization
of Federal Information and Information Systems (Feb. 2004), available at http://csrc.nist.gov/publications.

125

The use of a privacy overlay may assist agencies in effectively selecting and tailoring security controls for
information systems that create, collect, use, process, store, maintain, disseminate, disclose, or dispose of PII.
126

Privacy risks can include risks beyond those that are typically included under the “confidentiality” prong of the
term “information security.” Agencies shall use privacy controls to manage all privacy risks associated with PII or
an information system, regardless of whether those risks would be considered information security risks.

Appendix II - 14

Systems and Organizations. 127 Agencies are required to use the NIST privacy controls
and shall implement a privacy control selection process for information systems.
Agencies shall use NIST privacy controls in a manner that is consistent with the
agency’s authorities, missions, and operational needs.
For privacy controls, the SAOP is responsible for designating which controls the agency
will treat as program management, common, information system-specific, and hybrid
controls. Privacy program management controls are controls that are generally
implemented at the agency level and essential for managing the agency’s privacy
program. Program management controls are distinct from common, information systemspecific, and hybrid controls because program management controls are independent of
any particular information system. Agencies shall document program management
controls in their privacy program plan.
The other types of controls – common, information system-specific, and hybrid controls
– are necessarily implemented, at least in part, at the information system level. Common
controls are controls that are inherited by multiple information systems. When a control
is inherited by an information system, the control is selected for the information system
but the control is developed, implemented, assessed, authorized, and monitored by
programs or officials other than those responsible for the information system.
Information system-specific controls are controls that are implemented for a particular
information system or the portion of a hybrid control that is implemented for a particular
information system. Hybrid controls are controls that are implemented for an
information system in part as a common control and in part as an information systemspecific control.
The determination as to whether a privacy control is a common, hybrid, or information
system-specific control is based on context. By assigning privacy controls to an
information system as information system-specific, hybrid, or common controls, the
agency assigns responsibility and accountability to specific agency programs or officials
for the overall development, implementation, assessment, authorization, and monitoring
of those controls. Privacy controls designated by the agency as common controls are, in
most cases, managed by an agency program or official other than the information system
owner. Moreover, privacy controls designated as information system-specific controls
may be the primary responsibility of information system owners and their respective
authorizing officials. In all cases, the management of privacy controls shall be subject to
the coordination and oversight of the SAOP.
3) Implement. Agencies shall implement the security and privacy controls selected for an
information system and document how the controls are deployed. Agencies shall
develop and maintain security plans and privacy plans for an information system that
provide an overview of the security and privacy requirements for the information system
and describe the security and privacy controls in place or planned for meeting those
requirements. All privacy controls that are selected for an information system shall be
127
National Institute of Standards and Technology Special Publication 800-53, Security and Privacy Controls for
Federal Information Systems and Organizations (Apr. 2013), available at http://csrc.nist.gov/publications.

Appendix II - 15

documented in the privacy plan for the information system. The security plan and the
privacy plan may be separate or integrated into one consolidated document.
4) Assess. Agencies shall assess the security and privacy controls using appropriate
methods to determine the extent to which the controls are implemented correctly,
operating as intended, and producing the desired outcome with respect to meeting the
security and privacy requirements for the system and managing risks. The SAOP shall
conduct an initial assessment of the privacy controls selected for an information system
prior to operation, and shall assess the privacy controls periodically thereafter at a
frequency sufficient to ensure compliance with applicable privacy requirements and to
manage privacy risks. If a PIA is conducted for the information system, the agency may
incorporate the initial assessment of the privacy controls into the PIA process.
5) Authorize. Agencies shall authorize an information system prior to operation and
periodically thereafter. Authorization of an information system is an explicit acceptance
of the risk to agency operations (including mission, functions, image, or reputation),
agency assets, individuals, other organizations, and the Nation, based on the
implementation of the security and privacy controls. The determination to authorize an
information system shall be made by an agency’s authorizing official or officials (which
may include the SAOP) and shall be based on a review of the information system
authorization package, which includes the security plan, the privacy plan, documented
assessments of the security and privacy controls, and any relevant plans of action and
milestones.
Authorizing officials are responsible and accountable for the risks associated with an
information system. However, since the SAOP is the senior official, designated by the
head of each agency, who has agency-wide responsibility for privacy, agencies shall
consider recommendations submitted by the SAOP in the decision to authorize an
information system. In addition, the SAOP is responsible for reviewing the authorization
package for an information system that creates, collects, uses, processes, stores,
maintains, disseminates, discloses, or disposes of PII, to ensure compliance with
applicable privacy requirements and manage privacy risks prior to system authorization.
6) Monitor. Agencies shall monitor and assess security and privacy controls selected for an
information system and shall continue to monitor and assess those controls on an
ongoing basis. This includes assessing the effectiveness of the security and privacy
controls, documenting changes to the information system, analyzing the security and
privacy impact associated with the changes, and reporting the state of the system to
appropriate agency officials. The type, rigor, and frequency of control assessments shall
be sufficient to account for risks that change over time based on changes in the threat
environment, agency missions and business functions, personnel, technology, or
environments of operation.
The ongoing assessment of privacy risks and privacy controls is referred to as privacy
continuous monitoring (PCM). The SAOP shall develop and maintain a written PCM
strategy that catalogs the available privacy controls implemented at the agency across
the agency risk management tiers and ensures that the controls are effectively monitored
Appendix II - 16

on an ongoing basis by assigning an agency-defined assessment frequency to each
control that is sufficient to ensure compliance with applicable privacy requirements and
to manage privacy risks.
In addition, the SAOP shall establish and maintain a PCM program to implement the
PCM strategy. The PCM program is an agency-wide program that is responsible for:
maintaining ongoing awareness of threats and vulnerabilities that may pose privacy
risks; monitoring changes to information systems and environments of operation that
create, collect, use, process, store, maintain, disseminate, disclose, or dispose of PII; and
conducting privacy control assessments to verify the continued effectiveness of all
privacy controls selected and implemented at the agency across the agency risk
management tiers to ensure continued compliance with applicable privacy requirements
and management of privacy risks.
Although the term “privacy continuous monitoring” is new to this Circular, the concept
of conducting an ongoing assessment of privacy risks is not new. For many IT systems,
agencies are already required to conduct PIAs that involve an analysis of privacy risks
throughout the life cycle of the information system and the PII, and the drafting of a
living document that is updated whenever changes to the IT or the agency’s practices
alter the privacy risks associated with the use of the IT. 128 In fact, for IT systems for
which a PIA is conducted, agencies may use the PIA as the principal tool to satisfy the
requirement to assess the privacy controls for an information system.
The requirement for agencies to implement the Risk Management Framework is described in
more detail in Appendix I to this Circular. The following table summarizes the privacy
requirements in this Circular that pertain to the Risk Management Framework. While some of
the requirements summarized in the table are not exclusively privacy requirements, they may still
require the involvement of the agencies’ privacy programs.
Responsibility

Description

Citation

Implement a risk
management
framework.

Agencies shall implement a risk management
framework to guide and inform the categorization of
Federal information and information systems; the
selection, implementation, and assessment of privacy
controls; the authorization of information systems and
common controls; and the continuous monitoring of
information systems.

Appendix I § 3(a), 3(b)(5).

Review and approve
the categorization of
information systems
that involve PII.

The SAOP shall review and approve, in accordance with
NIST FIPS Publication 199 and NIST Special
Publication 800-60, the categorization of information
systems that create, collect, use, process, store, maintain,
disseminate, disclose, or dispose of PII.

Appendix I § 4(a)(2),
4(e)(7).

128

Refer to section 5.e of this Appendix for additional information about PIAs.

Appendix II - 17

Responsibility

Description

Designate program
management,
common, information
system-specific, and
hybrid privacy
controls.

The SAOP shall designate which privacy controls will
be treated as program management, common,
information system-specific, and hybrid privacy controls
at the agency. Agencies shall designate common
controls in order to provide cost-effective privacy
capabilities that can be inherited by multiple agency
information systems or programs.

Appendix I § 4(c)(12),
4(e)(5).

Implement a privacy
control selection
process.

Agencies shall employ a process to select and
implement privacy controls for information systems and
programs that satisfies applicable privacy requirements
in OMB guidance, including, but not limited to,
Appendix I to this Circular and OMB Circular A-108,
Federal Agency Responsibilities for Review, Reporting,
and Publication under the Privacy Act.

Appendix I § 4(c)(6).

Develop, approve, and
maintain privacy plans
for information
systems.

The SAOP shall review and approve the privacy plans
for agency information systems prior to authorization,
reauthorization, or ongoing authorization. Agencies
shall develop and maintain a privacy plan that details the
privacy controls selected for an information system that
are in place or planned for meeting applicable privacy
requirements and managing privacy risks, details how
the controls have been implemented, and describes the
methodologies and metrics that will be used to assess
the controls.

Appendix I § 4(c)(9),
4(e)(8).

Identify privacy
control assessment
methodologies and
metrics.

The SAOP shall identify assessment methodologies and
metrics to determine whether privacy controls are
implemented correctly, operating as intended, and
sufficient to ensure compliance with applicable privacy
requirements and manage privacy risks.

Appendix I § 4(e)(4).

Conduct assessments
of privacy controls.

The SAOP shall conduct and document the results of
privacy control assessments to verify the continued
effectiveness of all privacy controls selected and
implemented at the agency across all agency risk
management tiers to ensure continued compliance with
applicable privacy requirements and manage privacy
risks. Agencies shall conduct and document privacy
control assessments prior to the operation of an
information system, and periodically thereafter,
consistent with the frequency defined in the agency
privacy continuous monitoring strategy and the agency
risk tolerance.

Appendix I §§ 3(b)(6),
4(c)(13)-(14), 4(e)(3).

Correct deficiencies
that are identified in
information systems.

Agencies shall correct deficiencies that are identified
through privacy assessments, the privacy continuous
monitoring program, or internal or external audits and
reviews, to include OMB reviews. Agencies shall use
agency plans of action and milestones to record and
manage the mitigation and remediation of identified
weaknesses and deficiencies, not associated with
accepted risks, in agency information systems.

Appendix I § 4(c)(15), 4(k).

Appendix II - 18

Citation

Responsibility

Description

Citation

Develop and maintain
a privacy continuous
monitoring strategy.

The SAOP shall develop and maintain a privacy
continuous monitoring strategy, a formal document that
catalogs the available privacy controls implemented at
the agency across the agency risk management tiers and
ensures that the privacy controls are effectively
monitored on an ongoing basis by assigning an agencydefined assessment frequency to each control that is
sufficient to ensure compliance with applicable privacy
requirements and to manage privacy risks.

Appendix I § 4(d)(9),
4(e)(2).

Establish and maintain
a privacy continuous
monitoring program.

The SAOP shall establish and maintain an agency-wide
privacy continuous monitoring program that implements
the agency’s privacy continuous monitoring strategy and
maintains ongoing awareness of threats and
vulnerabilities that may pose privacy risks; monitors
changes to information systems and environments of
operation that create, collect, use, process, store,
maintain, disseminate, disclose, or dispose of PII; and
conducts privacy control assessments to verify the
continued effectiveness of all privacy controls selected
and implemented at the agency across the agency risk
management tiers to ensure continued compliance with
applicable privacy requirements and manage privacy
risks. Agencies shall ensure that a robust privacy
continuous monitoring program is in place before
agency information systems are eligible for ongoing
authorization.

Appendix I §§ 3(b)(6),
4(d)(10)-(11), 4(e)(2).

Review authorization
packages for
information systems
that involve PII.

The SAOP shall review authorization packages for
information systems that create, collect, use, process,
store, maintain, disseminate, disclose, or dispose of PII
to ensure compliance with applicable privacy
requirements and manage privacy risks, prior to
authorizing officials making risk determination and
acceptance decisions.

Appendix I § 4(e)(9).

Encrypt moderateimpact and highimpact information.

Agencies shall encrypt all NIST FIPS Publication 199
moderate-impact and high-impact information at rest
and in transit, unless encrypting such information is
technically infeasible or would demonstrably affect the
ability of agencies to carry out their respective missions,
functions, or operations; and the risk of not encrypting is
accepted by the authorizing official and approved by the
agency CIO, in consultation with the SAOP (as
appropriate).

Appendix I § 4(i)(14).

6. Managing PII Collected for Statistical Purposes Under a Pledge of Confidentiality
The Nation relies on the flow of credible statistics to support the decisions of individuals,
households, governments, businesses, and other organizations. Any loss of trust in the relevance,
accuracy, objectivity, or integrity of the Federal statistical system and its products can foster
uncertainty about the validity of measures our Nation uses to monitor and assess performance,
progress, and needs.
Appendix II - 19

Given the importance of robust and objective official Federal statistics, agencies and components
charged with the production of these statistics are assigned particular responsibility.
Specifically, information acquired by an agency or component under a pledge of
confidentiality129 and for exclusively statistical purposes shall be used by officers, employees, or
agents of the agency exclusively for statistical purposes. 130 As defined in the Confidential
Information Protection and Statistical Efficiency Act of 2002 (CIPSEA), statistical purpose
refers to the description, estimation, or analysis of the characteristics of groups, without
identifying the individuals or organizations that comprise such groups; it includes the
development, implementation, or maintenance of methods, technical or administrative
procedures, or information resources that support such purposes. 131 These agencies and
components shall protect the integrity and confidentiality of this information against
unauthorized access, use, disclosure, modification, or destruction throughout the life cycle of the
information. Further, these agencies and components shall adhere to legal requirements and
should follow best practices for protecting the confidentiality of data, including training their
employees and agents, and ensuring the physical and information system security of confidential
information.

129

The term “confidentiality” can have multiple meanings. For example, in the context of general information
security, the term means “preserving authorized restrictions on information access and disclosure, including means
for protecting personal privacy and proprietary information.” See 44 U.S.C. § 3552. However, for the purposes of
section 6 of Appendix II to this Circular, the term “confidentiality” refers to the requirement that “data or
information acquired by an agency under a pledge of confidentiality for exclusively statistical purposes shall not be
disclosed by an agency in identifiable form, for any use other than an exclusively statistical purpose, except with the
informed consent of the respondent.” See 44 U.S.C. § 3501 note; Pub. L. 107–347, § 512(b)(1).

130
44 U.S.C. § 3501 note; Pub. L. 107-347, § 512(a). There are some narrowly-delineated, authorized, nonstatistical
uses of information collected for statistical purposes that are noted in Section 504 of CIPSEA, including providing
information to a law enforcement agency for the prosecution of submissions to the collecting agency of false
statistical information under statutes that authorize criminal or civil penalties for the provision of false statistical
information, unless such disclosure or use would otherwise be prohibited under Federal law.
131

44 U.S.C. § 3501 note; Pub. L. 107-347, § 502(9)(A)).

Appendix II - 20