3.5.1
IA.L1-3.5.1 · Level 1 + 2

Identify system users, processes acting on behalf of users, and devices.

NIST SP 800-171 Rev 2 · §3.5.1

Identify system users, processes acting on behalf of users, and devices.

Assessment objectives

3.5.1[a] system users are identified.
Examine
[SELECT FROM: Identification and authentication policy; procedures addressing user identification and authentication; security plan, system design documentation; system configuration settings and associated documentation; system audit logs and records; list of system accounts; other relevant documents or records].
Interview
[SELECT FROM: Personnel with system operations responsibilities; personnel with information security responsibilities; system or network administrators; personnel with account management responsibilities; system developers].
Test
[SELECT FROM: Organizational processes for uniquely identifying and authenticating users; mechanisms supporting or implementing identification and authentication capability].
3.5.1[b] processes acting on behalf of users are identified.
Examine
[SELECT FROM: Identification and authentication policy; procedures addressing user identification and authentication; security plan, system design documentation; system configuration settings and associated documentation; system audit logs and records; list of system accounts; other relevant documents or records].
Interview
[SELECT FROM: Personnel with system operations responsibilities; personnel with information security responsibilities; system or network administrators; personnel with account management responsibilities; system developers].
Test
[SELECT FROM: Organizational processes for uniquely identifying and authenticating users; mechanisms supporting or implementing identification and authentication capability].
3.5.1[c] devices accessing the system are identified.
Examine
[SELECT FROM: Identification and authentication policy; procedures addressing user identification and authentication; security plan, system design documentation; system configuration settings and associated documentation; system audit logs and records; list of system accounts; other relevant documents or records].
Interview
[SELECT FROM: Personnel with system operations responsibilities; personnel with information security responsibilities; system or network administrators; personnel with account management responsibilities; system developers].
Test
[SELECT FROM: Organizational processes for uniquely identifying and authenticating users; mechanisms supporting or implementing identification and authentication capability].

What we look for in practice

The following are placeholder notes that should be refined based on practice experience.

What assessors look for in practice. Documented evidence that this control is implemented across all CUI-handling systems within scope. Specific artifacts vary, but expect requests for written procedures, system configurations, and operational records demonstrating the control is active.

Common failure patterns. Typical issues include incomplete documentation, inconsistent implementation across systems, and missing periodic review records. Refine this section as your practice accumulates direct assessment experience.

Strong evidence looks like. Formal policy referencing this control, technical configurations demonstrating enforcement, periodic review logs with sign-off, and procedures for handling exceptions.

Scoring and POA&M context. 5-point control under the DoD Assessment Methodology. Highest scoring impact — treat as a foundational requirement. Not POA&M-eligible — must be implemented at assessment time.