Overview

Security Requirements for 03.03.09 Audit Management

Individuals with privileged access to a system and who are also the subject of an audit by that system, may affect the reliability of audit information by inhibiting audit logging activities or modifying audit records. This requirement specifies that privileged access be further defined between audit-related privileges and other privileges, thus limiting the users with audit-related privileges.

Assessment GuidanceExamine 0/11

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

Discussion

Companies should restrict access to audit logging functions to a limited number of privileged users who can modify audit logs and audit settings. General users should not be granted permissions to perform audit management. All audit managers should be privileged users, but only a small subset of privileged users will be given audit management responsibilities. Functions performed by privileged users must be distinctly separate from the functions performed by users who have audit-related responsibilities to reduce the potential of fraudulent activities by privileged users not being detected or reported. When possible, individuals who manage audit logs should not have access to other privileged functions.

Examples

  1. Example 1

    You are responsible for the administration of select company infrastructure that contains CUI, but you are not responsible for managing audit information. You are not permitted to review audit logs, delete audit logs, or modify audit log settings [b]. Full control of audit logging functions has been given to senior system administrators [a, b]. This separation of system administration duties from audit logging management is necessary to prevent possible log file tampering.

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
  • System developers
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 managing access to audit logging functionality

Potential Assessment Considerations

  • Are audit records of nonlocal accesses to privileged accounts and the execution of privileged functions protected [b]?

Key References

NIST SP 800-171 Rev. 2 3.3.9

Evidence

  1. 03.03.09.a

    A subset of privileged users granted access to manage audit logging functionality is defined

  1. 03.03.09.b

    Management of audit logging functionality is limited to the defined subset of privileged users