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Controls / Personnel Security / 3.9.2
3.9.2
PS.L2-3.9.2 · Level 2

Ensure that organizational systems containing CUI are protected during and after personnel actions…

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.

Assessment objectives

From NIST SP 800-171A · 3 objectives must be met to satisfy this control
3.9.2[a] a policy and/or process for terminating system access authorization and any credentials coincident with personnel actions is established.
Examine
[SELECT FROM: 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
[SELECT FROM: Personnel with personnel security responsibilities; personnel with account management responsibilities; system or network administrators; personnel with information security responsibilities].
Test
[SELECT FROM: Organizational processes for personnel transfer and termination; mechanisms supporting or implementing personnel transfer and termination notifications; mechanisms for disabling system access and revoking authenticators].
3.9.2[b] system access and credentials are terminated consistent with personnel actions such as termination or transfer.
Examine
[SELECT FROM: 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
[SELECT FROM: Personnel with personnel security responsibilities; personnel with account management responsibilities; system or network administrators; personnel with information security responsibilities].
Test
[SELECT FROM: Organizational processes for personnel transfer and termination; mechanisms supporting or implementing personnel transfer and termination notifications; mechanisms for disabling system access and revoking authenticators].
3.9.2[c] the system is protected during and after personnel transfer actions.
Examine
[SELECT FROM: 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
[SELECT FROM: Personnel with personnel security responsibilities; personnel with account management responsibilities; system or network administrators; personnel with information security responsibilities].
Test
[SELECT FROM: Organizational processes for personnel transfer and termination; mechanisms supporting or implementing personnel transfer and termination notifications; mechanisms for disabling system access and revoking authenticators].

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.