3.3.9—Audit and Accountability - Derived
Derived Requirement
>Control Description
Limit management of audit logging functionality to a subset of privileged users.
>Discussion
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
>Cross-Framework Mappings
>Assessment Interview Topics
Questions assessors commonly ask
Process & Governance:
- •What documented policies and procedures address audit and accountability - derived for CUI systems?
- •Who is accountable for implementing and maintaining audit and accountability - derived controls?
- •How frequently are audit and accountability - derived requirements reviewed, and what triggers updates?
- •What process ensures changes to systems maintain compliance with audit and accountability - derived requirements?
- •How are exceptions to audit and accountability - derived requirements documented and approved?
Technical Implementation:
- •What technical controls enforce audit and accountability - derived in your CUI environment?
- •How are audit and accountability - derived controls configured and maintained across all CUI systems?
- •What automated mechanisms support audit and accountability - derived compliance?
- •How do you validate that audit and accountability - derived implementations achieve their intended security outcome?
- •What compensating controls exist if primary audit and accountability - derived controls cannot be fully implemented?
Evidence & Documentation:
- •What documentation proves audit and accountability - derived is implemented and operating effectively?
- •Can you provide configuration evidence showing how audit and accountability - derived is technically enforced?
- •What audit logs or monitoring data demonstrate ongoing audit and accountability - derived compliance?
- •Can you show evidence of a recent review or assessment of audit and accountability - derived controls?
- •What artifacts would you provide to a CMMC assessor to demonstrate audit and accountability - derived compliance?
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