NIST Special Publication 800-171 Revision 2
Date Published: January 28th, 2021
Withdrawn on May 14, 2024. Superseded by SP 800-171 Rev. 3
Author(s): Ron Ross (NIST), Victoria Pillitteri (NIST), Kelley Dempsey (NIST), Mark Riddle (NARA), Gary Guissanie (IDA)
Note: A Class Deviation is in effect as of May 2, 2024 (DEVIATION 2024O0013). The deviation clause requires contractors, who are subject to 252.204-7012, to comply with National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 Revision 2, instead of the version of NIST SP 800-171 in effect at the time the solicitation is issued or as authorized by the contracting officer. Click Here
3.3.2 Ensure that the actions of individual system users can be uniquely traced to those users, so they can be held accountable for their actions.
Control Family: Audit and Accountability
Control Type: Basic
SPRS Value: 3
SPRS Supplemental Guidance: N/A
CMMC Level(s): AU.L2-3.3.2
Top Ten Failed Requirement: No
Referenced in:
DFARS 252.204-7012
Derived From: NIST SP 800-53r4
AU-2
AU-3
AU-3(1)
AU-6
AU-11
AU-12
NIST Supplemental Guidance:
N/A
Discussion:
This requirement ensures that the contents of the audit record include the information needed to link the audit event to the actions of an individual to the extent feasible. Organizations consider logging for traceability including results from monitoring of account usage, remote access, wireless connectivity, mobile device connection, communications at system boundaries, configuration settings, physical access, nonlocal maintenance, use of maintenance tools, temperature and humidity, equipment delivery and removal, system component inventory, use of mobile code, and use of Voice over Internet Protocol (VoIP).
Upon assessment, assessors must determine if-
3.3.2[a] the content of the audit records needed to support the ability to uniquely trace
users to their actions is defined.
3.3.2[b] audit records, once created, contain the defined content.
Assessors are instructed to-
Examine: [SELECT FROM: Audit and accountability policy; procedures addressing audit records and event types; system security plan; system design documentation; system configuration settings and associated documentation; procedures addressing audit record generation; procedures addressing audit review, analysis, and reporting; reports of audit findings; system audit logs and records; system events; system incident reports; other relevant documents or records].
Interview: [SELECT FROM: Personnel with audit and accountability responsibilities; personnel with information security responsibilities; system or network administrators].
Test: [SELECT FROM: Mechanisms implementing system audit logging].
FURTHER DISCUSSION
NCapturing the necessary information in audit logs ensures that you can trace actions to a specific user. This may include capturing user IDs, source and destination addresses, and time stamps. Logging from networks, servers, clients, and applications should be considered in ensuring accountability. This requirement, AU.L2-3.3.2, which ensures logging and traceability of user actions, supports the control of non-privileged users required by AC.L2-3.1.7 as well as many other auditing, configuration management, incident response, and situation awareness requirements.
Example
You manage systems for a company that stores, processes, and transmits CUI. You want to ensure that you can trace all remote access sessions to a specific user. You configure the VPN device to capture the following information for all remote access connections: source and destination IP address, user ID, machine name, time stamp, and user actions during the remote session [b].
Potential Assessment Considerations
Are users uniquely traced and held responsible for unauthorized actions [a]?
Does the system protect against an individual denying having performed an action (nonrepudiation) [b]?