Overview

Security Requirements for 03.01.04 Separation of Duties

Separation of duties addresses the potential for abuse of authorized privileges and helps to reduce the risk of malevolent activity without collusion. Separation of duties includes dividing mission functions and system support functions among different individuals or roles; conducting system support functions with different individuals (e.g., configuration management, quality assurance and testing, system management, programming, and network security); and ensuring that security personnel administering access control functions do not also administer audit functions. Because separation of duty violations can span systems and application domains, organizations consider the entirety of organizational systems and system components when developing policy on separation of duties.

Assessment GuidanceExamine 0/8

How an assessor determines this requirement is met. Source: CMMC Assessment Guide – Level 2, Version 2.13 (NIST SP 800-171 Rev. 2).

Discussion

No one person should be in charge of an entire critical task from beginning to end. Documenting and dividing elements of important duties and tasks between employees reduces intentional or unintentional execution of malicious activities.

Examples

  1. Example 1

    You are responsible for the management of several key systems within your organization including some that process CUI. You assign the task of reviewing the system logs to two different people. This way, no one person is solely responsible for the execution of this critical security function [c].

  2. Example 2

    You are a system administrator. Human Resources notifies you of a new hire, and you create an account with general privileges, but you are not allowed to grant access to systems that contain CUI [a, b]. The program manager contacts the team in your organization that has system administration authority over the CUI systems and informs them which CUI the new hire will need to access. Subsequently, a second system administrator grants access privileges to the new hire [c].

Assessment Methods

Examine
The process of reviewing, inspecting, observing, studying, or analyzing assessment objects (e.g., policies, procedures, plans, system designs, mechanisms) to facilitate understanding, achieve clarification, or obtain evidence.Example: An assessor reads the access control policy and inspects system configuration settings to confirm they match.

Not all of the evidence listed is required to meet this requirement — check the items your organization has collected.

Interview
The process of holding discussions with individuals or groups within an organization to facilitate understanding, achieve clarification, or identify the location of evidence.Example: An assessor asks a system administrator to describe how user accounts are approved, reviewed, and disabled.
  • Personnel with responsibilities for defining divisions of responsibility and separation of duties
  • Personnel with information security responsibilities
  • System or network administrators
Test
The process of exercising assessment objects (e.g., activities, mechanisms) under specified conditions to compare actual behavior with expected behavior.Example: An assessor attempts to sign in with a disabled account to confirm that access is denied.
  • Mechanisms implementing separation of duties policy

Potential Assessment Considerations

  • Does system documentation identify the system functions or processes that require separation of duties (e.g., function combinations that represent a conflict of interest or an over-allocation of security privilege for one individual) [a]?

Key References

NIST SP 800-171 Rev. 2 3.1.4

Evidence

  1. 03.01.04.a

    The duties of individuals requiring separation are defined

  1. 03.01.04.b

    Responsibilities for duties that require separation are assigned to separate individuals

  1. 03.01.04.c

    Access privileges that enable individuals to exercise the duties that require separation are granted to separate individuals