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Controls / Personnel Security / 3.9.1
3.9.1
PS.L2-3.9.1 · Level 2

Screen individuals prior to authorizing access to organizational systems containing CUI.

NIST SP 800-171 Rev 2 · §3.9.1

Screen individuals prior to authorizing access to organizational systems containing CUI.

Assessment objectives

From NIST SP 800-171A · 1 objective must be met to satisfy this control
3.9.1[a] Screen individuals prior to authorizing access to organizational systems containing CUI.
Examine
[SELECT FROM: Personnel security policy; procedures addressing personnel screening; records of screened personnel; security plan; other relevant documents or records].
Interview
[SELECT FROM: Personnel with personnel security responsibilities; personnel with information security responsibilities].
Test
[SELECT FROM: Organizational processes for personnel screening].

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. 3-point control under the DoD Assessment Methodology. Meaningful but more contained scoring impact. Not POA&M-eligible — must be implemented at assessment time.