Overview
  1. 03.01: Access Control
  2. 03.02: Awareness and Training
  3. 03.03: Audit and Accountability
  4. 03.04: Configuration Management
  5. 03.05: Identification and Authentication
  6. 03.06: Incident Response
  7. 03.07: Maintenance
  8. 03.08: Media Protection
  9. 03.09: Personnel Security
  10. 03.10: Physical Protection
  11. 03.11: Risk Assessment
  12. 03.12: Security Assessment
  13. 03.13: System and Communications Protection
  14. 03.14: System and Information Integrity

Security Requirements for 03.03.02 User Accountability

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).

Assessment GuidanceExamine 0/12

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

Discussion

Capturing 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.

Examples

  1. Example 1

    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].

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 audit and accountability responsibilities
  • 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 system audit logging

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]?

Key References

NIST SP 800-171 Rev. 2 3.3.2

Evidence

  1. 03.03.02.a

    The content of the audit records needed to support the ability to uniquely trace users to their actions is defined

  1. 03.03.02.b

    Audit records, once created, contain the defined content