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NIST SP 800-171 CUI Protection Center

03.09.02 — Personnel Termination and Transfer

Read the official CUI requirement and assessment content, then use the separately labeled Bare Metal Cyber perspective to connect it to implementation, evidence, and sustained operation.

1Parameters
2Source controls
7Assessment objectives
3Assessment methods

03.09 — Personnel Security · NIST SP 800-171 Revision 3

Active
Official NIST requirement content

Security requirement

  1. a.When individual employment is terminated:
    1. 1.Disable system access within [Organization-defined: time period],
    2. 2.Terminate or revoke authenticators and credentials associated with the individual, and
    3. 3.Retrieve security-related system property.
  2. b.When individuals are reassigned or transferred to other positions in the organization:
    1. 1.Review and confirm the ongoing operational need for current logical and physical access authorizations to the system and facility, and
    2. 2.Modify access authorization to correspond with any changes in operational need.
Official NIST discussion

Discussion

Security-related system property includes hardware authentication tokens, system administration technical manuals, keys, identification cards, and building passes. Exit interviews ensure that terminated individuals understand the security constraints imposed by being former employees and that accountability is achieved for the organizational property. Security topics at exit interviews include reminding individuals of potential limitations on future employment and non-disclosure agreements. Exit interviews may not always be possible for some individuals, including in cases related to the unavailability of supervisors, illnesses, or job abandonment. The timely execution of termination actions is essential for individuals who have been terminated for cause. Organizations may consider disabling the accounts of individuals who are being terminated prior to the individuals being notified. This requirement applies to the reassignment or transfer of individuals when the personnel action is permanent or of such extended duration as to require protection. Protections that may be required for transfers or reassignments to other positions within organizations include returning old and issuing new identification cards, keys, and building passes; changing system access authorizations (i.e., privileges); closing system accounts and establishing new accounts; and providing access to official records to which individuals had access at previous work locations in previous system accounts.

Official organization-defined parameters

Tailoring decisions required

Resolve these values through the governing organization’s approved tailoring and risk-management process before declaring the requirement implemented.

time periodorganization-defined time periodthe time period within which to disable system access is defined.
Bare Metal Cyber interpretation

Implementation perspective

Treat Personnel Termination and Transfer as a CUI protection outcome that must be reflected in the system boundary, documented implementation, operational behavior, and assessment evidence. Pay particular attention to personnel risk, screening, agreements, transfer, termination, and timely access consequences.

  1. Confirm the requirement is in scope for the CUI system components, services, users, and external connections being assessed.
  2. Resolve every organization-defined parameter through an approved governance and tailoring process.
  3. Map each clause of the requirement to an accountable owner, implementation mechanism, and evidence source.
  4. Verify that inherited and shared implementations are supported by current provider evidence and responsibility boundaries.
  5. 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

  • screening and suitability records
  • access agreements
  • transfer and termination checklists
  • role-change and offboarding evidence

Common failure patterns

  • access persisting after transfer or separation
  • contractor lifecycle outside normal controls
  • sensitive roles not screened based on risk
  • termination actions that cannot be shown to occur promptly
Official NIST SP 800-171A content

Assessment objectives and methods

Assessment objectives (7)
  1. a.1.

    upon termination of individual employment, system access is disabled within [Organization-defined: time period].

  2. a.2.

    upon termination of individual employment, authenticators associated with the individual are terminated or revoked.

  3. a.2.

    upon termination of individual employment, credentials associated with the individual are terminated or revoked.

  4. a.3.

    upon termination of individual employment, security-related system property is retrieved.

  5. b.2.

    upon individual reassignment or transfer to other positions in the organization, access authorization is modified to correspond with any changes in operational need.

  6. b.1.

    upon individual reassignment or transfer to other positions in the organization, the ongoing operational need for current logical and physical access authorizations to the system and facility is reviewed.

  7. b.1.

    upon individual reassignment or transfer to other positions in the organization, the ongoing operational need for current logical and physical access authorizations to the system and facility is confirmed.

Examine

  • personnel security policy and procedures
  • procedures for personnel termination
  • records of personnel transfer actions
  • procedures for personnel transfer
  • list of system and facility access authorizations
  • records of personnel termination actions
  • records of terminated or revoked authenticators or credentials
  • list of system accounts
  • records of exit interviews
  • system security plan
  • other relevant documents or records

Interview

  • personnel with personnel security responsibilities
  • personnel with account management responsibilities
  • personnel with information security responsibilities
  • system administrators

Test

  • processes for personnel termination
  • processes for personnel transfer
  • mechanisms for supporting or implementing personnel transfer notifications
  • mechanisms for supporting or implementing personnel termination notifications
  • mechanisms for disabling system access and revoking authenticators
Official source-control relationships

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.

Source controlPS-4Open SP 800-53 control →Source controlPS-5Open SP 800-53 control →
Source record

Authoritative sources

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.