Security requirement
- a.Establish a process for maintenance personnel authorization.
- b.Maintain a list of authorized maintenance organizations or personnel.
- c.Verify that non-escorted personnel who perform maintenance on the system possess the required access authorizations.
- d.Designate organizational personnel with required access authorizations and technical competence to supervise the maintenance activities of personnel who do not possess the required access authorizations.
Discussion
Maintenance personnel refers to individuals who perform hardware or software maintenance on the system, while 03.10.01 addresses physical access for individuals whose maintenance duties place them within the physical protection perimeter of the system. The technical competence of supervising individuals relates to the maintenance performed on the system, while having required access authorizations refers to maintenance on and near the system. Individuals who have not been previously identified as authorized maintenance personnel (e.g., manufacturers, consultants, systems integrators, and vendors) may require privileged access to the system, such as when they are required to conduct maintenance with little or no notice. Organizations may choose to issue temporary credentials to these individuals based on their risk assessments. Temporary credentials may be for one-time use or for very limited time periods.
Implementation perspective
Treat Maintenance Personnel as a CUI protection outcome that must be reflected in the system boundary, documented implementation, operational behavior, and assessment evidence. Pay particular attention to authorized maintenance, trusted tools, controlled support access, and protection of CUI during repair or servicing.
- Confirm the requirement is in scope for the CUI system components, services, users, and external connections being assessed.
- Resolve every organization-defined parameter through an approved governance and tailoring process.
- Map each clause of the requirement to an accountable owner, implementation mechanism, and evidence source.
- Verify that inherited and shared implementations are supported by current provider evidence and responsibility boundaries.
- Collect evidence during normal operation and review changes, exceptions, and deficiencies on a risk-based cadence.
Questions to ask
- Which CUI assets, data flows, users, and services are protected by this requirement?
- Which portions are implemented locally, inherited, shared, or not applicable, and what evidence supports that determination?
- Do the system security plan, deployed configuration, operating process, and assessment evidence tell the same story?
- What change, incident, or threshold should trigger reassessment?
Evidence and validation
- maintenance schedules and tickets
- tool approval records
- remote maintenance session logs
- maintenance personnel authorization
Common failure patterns
- vendor access left enabled permanently
- unapproved diagnostic tools introduced
- maintenance bypassing change control
- remote sessions not monitored or terminated
Assessment objectives and methods
Assessment objectives (5)
- a.
a process for maintenance personnel authorization is established.
- b.
a list of authorized maintenance organizations or personnel is maintained.
- d.
organizational personnel with required access authorizations are designated to supervise the maintenance activities of personnel who do not possess the required access authorizations.
- d.
organizational personnel with required technical competence are designated to supervise the maintenance activities of personnel who do not possess the required access authorizations.
- c.
non-escorted personnel who perform maintenance on the system possess the required access authorizations.
Examine
- maintenance policy and procedures
- service provider contracts
- service-level agreements
- list of authorized personnel
- maintenance records
- access control records
- system security plan
- other relevant documents or records
Interview
- personnel with system maintenance responsibilities
- personnel with information security responsibilities
Test
- processes for authorizing and managing maintenance personnel
- mechanisms for supporting or implementing the authorization of maintenance personnel
Source NIST SP 800-53 controls
These controls are referenced by the official SP 800-171 Rev. 3 OSCAL record. Open the corresponding control pages for complete control text, enhancements, D3FEND mappings, and related learning.
Authoritative sources
- NIST SP 800-171 Revision 3 official publication ↗
- NIST SP 800-171A Revision 3 official publication ↗
- NIST OSCAL Content release used for this import ↗
Bare Metal Cyber is an independent educational publisher and is not affiliated with or endorsed by NIST. The official publications, the responsible federal agency, and the governing contract or agreement determine applicability, tailoring, assessment depth, and required implementation.