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3.9.2Close accounts when people move or leave

Access is revoked promptly on termination or transfer.

The requirement, verbatim

NIST SP 800-171 Rev. 2 · 3.9.2

Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.

Requirement 3.9.2, practice name in the CMMC assessment guide: Personnel Actions.

NIST's discussion

Protecting CUI during and after personnel actions may include returning system-related property and conducting exit interviews. System-related property includes hardware authentication tokens, identification cards, system administration technical manuals, keys, and building passes. Exit interviews ensure that individuals who have been terminated understand the security constraints imposed by being former employees and that proper accountability is achieved for system-related property. Security topics of interest at exit interviews can include reminding terminated individuals of nondisclosure agreements and potential limitations on future employment. Exit interviews may not be possible for some terminated individuals, for example, in cases related to job abandonment, illnesses, and non-availability of supervisors. For termination actions, timely execution is essential for individuals terminated for cause. In certain situations, organizations consider disabling the system accounts of individuals that are being terminated prior to the individuals being notified.

This requirement applies to reassignments or transfers of individuals when the personnel action is permanent or of such extended durations as to require protection. Organizations define the CUI protections appropriate for the types of reassignments or transfers, whether permanent or extended. Protections that may be required for transfers or reassignments to other positions within organizations include returning old and issuing new keys, identification cards, and building passes; changing system access authorizations (i.e., privileges); closing system accounts and establishing new accounts; and providing for access to official records to which individuals had access at previous work locations and in previous system accounts.

NIST SP 800-171 Rev. 2, discussion under 3.9.2. Whitespace normalised; wording unchanged.

Assessment objectives

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

  1. [a] a policy and/or process for terminating system access and any credentials coincident with personnel actions is established
  2. [b] system access and credentials are terminated consistent with personnel actions such as termination and transfer
  3. [c] the system is protected during and after personnel transfer actions

NIST SP 800-171A, determination statements for 3.9.2.

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
  • Personnel security policy
  • procedures addressing personnel transfer and termination
  • records of personnel transfer and termination actions
  • list of system accounts
  • records of terminated or revoked authenticators and credentials
  • records of exit interviews
  • other relevant documents or records
Interview
  • Personnel with personnel security responsibilities
  • personnel with account management responsibilities
  • system or network administrators
  • personnel with information security responsibilities
Test
  • Organizational processes for personnel transfer and termination
  • mechanisms supporting or implementing personnel transfer and termination notifications
  • mechanisms for disabling system access and revoking authenticators

NIST SP 800-171A, potential assessment methods and objects for 3.9.2.

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: 03.09.02 Personnel Termination and Transfer. 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)