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3.3.1Keep logs, and keep them long enough

Logs exist, contain enough to reconstruct events, and are retained for a stated period.

The requirement, verbatim

NIST SP 800-171 Rev. 2 · 3.3.1

Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity.

Requirement 3.3.1, practice name in the CMMC assessment guide: System Auditing.

NIST's discussion

An event is any observable occurrence in a system, which includes unlawful or unauthorized system activity. Organizations identify event types for which a logging functionality is needed as those events which are significant and relevant to the security of systems and the environments in which those systems operate to meet specific and ongoing auditing needs. Event types can include password changes, failed logons or failed accesses related to systems, administrative privilege usage, or third-party credential usage. In determining event types that require logging, organizations consider the monitoring and auditing appropriate for each of the CUI security requirements. Monitoring and auditing requirements can be balanced with other system needs. For example, organizations may determine that systems must have the capability to log every file access both successful and unsuccessful, but not activate that capability except for specific circumstances due to the potential burden on system performance.

Audit records can be generated at various levels of abstraction, including at the packet level as information traverses the network. Selecting the appropriate level of abstraction is a critical aspect of an audit logging capability and can facilitate the identification of root causes to problems. Organizations consider in the definition of event types, the logging necessary to cover related events such as the steps in distributed, transaction-based processes (e.g., processes that are distributed across multiple organizations) and actions that occur in service-oriented or cloud-based architectures.

Audit record content that may be necessary to satisfy this requirement includes time stamps, source and destination addresses, user or process identifiers, event descriptions, success or failure indications, filenames involved, and access control or flow control rules invoked. Event outcomes can include indicators of event success or failure and event-specific results (e.g., the security state of the system after the event occurred).

Detailed information that organizations may consider in audit records includes full text recording of privileged commands or the individual identities of group account users. Organizations consider limiting the additional audit log information to only that information explicitly needed for specific audit requirements. This facilitates the use of audit trails and audit logs by not including information that could potentially be misleading or could make it more difficult to locate information of interest. Audit logs are reviewed and analyzed as often as needed to provide important information to organizations to facilitate risk-based decision making. NIST SP 800-92 provides guidance on security log management.

NIST SP 800-171 Rev. 2, discussion under 3.3.1. Whitespace normalised; wording unchanged.

Assessment objectives

An assessor decides each of these separately. The requirement is met only when every objective is.

  1. [a] event types to be logged are specified
  2. [b] event types to be logged are reviewed and updated
  3. [c] the content of audit records needed to support monitoring is defined
  4. [d] audit records are created (generated)
  5. [e] audit records, once created, contain the defined content
  6. [f] retention requirements for audit records are defined
  7. [g] audit records are retained as defined

NIST SP 800-171A, determination statements for 3.3.1.

For assessors: examine, interview, test

NIST SP 800-171A names what an assessor may examine, whom they may interview, and what they may test for this requirement. Assessors select from these lists; they are not a checklist of everything you must produce.

Examine
  • Audit and accountability policy
  • procedures addressing audit record generation
  • system security plan
  • system design documentation
  • system configuration settings and associated documentation
  • system audit logs and records
  • list of organization-defined auditable events
  • other relevant documents or records
Interview
  • Personnel with audit and accountability responsibilities
  • personnel with information security responsibilities
  • system or network administrators
Test
  • Mechanisms implementing system audit logging

NIST SP 800-171A, potential assessment methods and objects for 3.3.1.

Evidence

No evidence examples are published for this requirement yet. The objectives above are what an assessor checks; evidence is whatever shows each one is true in your environment, dated and kept with your system security plan.

Scoring weight

Worth 5 points. Not meeting this requirement subtracts 5 from your 110-point SPRS score. These are the requirements with the largest effect on your posture.

DoD NIST SP 800-171 Assessment Methodology v1.2.1 weighting, as carried in the Bedrock scoring table. The score starts at 110 and subtracts the weight of every requirement not met.

In Rev. 3

Rev. 2 is what your contract requires today. A standing DoD class deviation keeps Rev. 2 in force; NIST has published Rev. 3, but it is not adopted for contracts. In Rev. 3 this requirement is reworded: 03.03.01 Event Logging. It gains organization-defined parameters.

See the Rev. 2 and Rev. 3 wording word by word, or start with the status page.

Where this page's facts come from
Requirement text
bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.basicRequirement@rev2
Discussion
bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.discussion@rev2
Practice name
bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.title@rev2 (CMMC Assessment Guide practice name)
Objectives
bedrock-cmmc-api@89b8e8e:migrations/005_reference_objectives.sql#AssessmentObjective.description@rev2
Examine, interview, test
bedrock-cmmc-api@89b8e8e:migrations/005_reference_objectives.sql#AssessmentObjective.description@rev2 ({examineGuidance, interviewGuidance, testGuidance})
Level
bedrock-cmmc-api@89b8e8e:migrations/021_fix_level1_requirements.sql#Requirement.cmmcLevel@rev2
Weight
bedrock-cmmc-api@89b8e8e:internal/cmmc/requirement_values.go#requirementValues (DoD AM v1.2.1 / eMASS L2 template v3.8)
Rev. 3 mapping
bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/r2_r3_transition_map.json#r2_to_r3
Plain-language title and summary
editorial/CMMC Navigator.dc.html#RAW (Foxx Cyber editorial)