Control statement
Employ [Organization-defined: methods] for coordinating [Organization-defined: audit information] among external organizations when audit information is transmitted across organizational boundaries.
Discussion
When organizations use systems or services of external organizations, the audit logging capability necessitates a coordinated, cross-organization approach. For example, maintaining the identity of individuals who request specific services across organizational boundaries may often be difficult, and doing so may prove to have significant performance and privacy ramifications. Therefore, it is often the case that cross-organizational audit logging simply captures the identity of individuals who issue requests at the initial system, and subsequent systems record that the requests originated from authorized individuals. Organizations consider including processes for coordinating audit information requirements and protection of audit information in information exchange agreements.
Organization-defined parameters
These values must be resolved through the organization’s tailoring and governance process. Bracketed parameter references in the control text identify where a decision is required.
From control text to operational evidence
Use Cross-organizational Audit Logging as a testable risk decision. Translate the official statement into accountable people, repeatable processes, configured technology, and evidence that demonstrates the outcome over time. In this family, pay particular attention to audit event design, trustworthy collection, retention, review, and investigation support.
Implementation workflow
- Define the control boundary, responsible owner, inherited portions, and systems or processes in scope.
- Resolve each organization-defined parameter before declaring the control implemented.
- Document how the implementation satisfies every clause of the official control statement.
- Collect evidence as a normal byproduct of operation rather than only before an assessment.
- Review exceptions, changes, and monitoring results on a risk-based cadence.
Evidence examples
- logging standards and event-selection decisions
- sample audit records and retention settings
- time-synchronization evidence
- alert and review records
Common failure patterns
- collecting logs without defined use cases
- critical events missing from the audit trail
- retention shorter than investigative needs
- logs accessible to the same administrators being monitored
Questions practitioners should ask
- What risk decision is this control intended to support in this system?
- Which parts are implemented locally, inherited, shared, or not applicable—and what evidence supports that decision?
- Do the documented narrative, deployed configuration, operating process, and collected evidence agree?
- What event or threshold requires the implementation to be reviewed or changed?
Assessment objectives and methods
Show the assessment objective
[Organization-defined: methods] for coordinating [Organization-defined: audit information] among external organizations when audit information is transmitted across organizational boundaries are employed.
Examine
- Audit and accountability policy
- system security plan
- privacy plan
- procedures addressing methods for coordinating audit information among external organizations
- system design documentation
- system configuration settings and associated documentation
- system audit records
- other relevant documents or records
Interview
- Organizational personnel with responsibilities for coordinating audit information among external organizations
- organizational personnel with information security and privacy responsibilities
Test
- Mechanisms implementing cross-organizational auditing
Related controls
These relationships come from the official OSCAL catalog. They indicate useful dependencies or context, not automatic inheritance or equivalence.
Control enhancements
Enhancements add specificity, strength, or scope to the base control. Baseline badges show explicit selections in the official SP 800-53B OSCAL profiles.
AU-16(1) — Identity Preservation
Preserve the identity of individuals in cross-organizational audit trails.
Official discussion
Identity preservation is applied when there is a need to be able to trace actions that are performed across organizational boundaries to a specific individual.
Assessment objectives and methods
the identity of individuals in cross-organizational audit trails is preserved.
Examine
- Audit and accountability policy
- system security plan
- privacy plan
- procedures addressing cross-organizational audit trails
- system design documentation
- system configuration settings and associated documentation
- system audit records
- other relevant documents or records
Interview
- Organizational personnel with cross-organizational audit responsibilities
- organizational personnel with information security and privacy responsibilities
Test
- Mechanisms implementing cross-organizational auditing (if applicable)
Related controls
AU-16(2) — Sharing of Audit Information
Provide cross-organizational audit information to [Organization-defined: organizations] based on [Organization-defined: cross-organizational sharing agreements].
Official discussion
Due to the distributed nature of the audit information, cross-organization sharing of audit information may be essential for effective analysis of the auditing being performed. For example, the audit records of one organization may not provide sufficient information to determine the appropriate or inappropriate use of organizational information resources by individuals in other organizations. In some instances, only individuals’ home organizations have the appropriate knowledge to make such determinations, thus requiring the sharing of audit information among organizations.
Organization-defined parameters (2)
Assessment objectives and methods
cross-organizational audit information is provided to [Organization-defined: organizations] based on [Organization-defined: cross-organizational sharing agreements].
Examine
- Audit and accountability policy
- system security plan
- privacy plan
- procedures addressing cross-organizational sharing of audit information
- information sharing agreements
- other relevant documents or records
Interview
- Organizational personnel with responsibilities for sharing cross-organizational audit information
- organizational personnel with information security and privacy responsibilities
Related controls
AU-16(3) — Disassociability
Implement [Organization-defined: measures] to disassociate individuals from audit information transmitted across organizational boundaries.
Official discussion
Preserving identities in audit trails could have privacy ramifications, such as enabling the tracking and profiling of individuals, but may not be operationally necessary. These risks could be further amplified when transmitting information across organizational boundaries. Implementing privacy-enhancing cryptographic techniques can disassociate individuals from audit information and reduce privacy risk while maintaining accountability.
Organization-defined parameters (1)
Assessment objectives and methods
[Organization-defined: measures] are implemented to disassociate individuals from audit information transmitted across organizational boundaries.
Examine
- Audit and accountability policy
- system security plan
- privacy plan
- procedures addressing cross-organizational sharing of audit information
- policy and/or procedures regarding the deidentification of PII
- system design documentation
- system configuration settings and associated documentation
- system audit records
- other relevant documents or records
Interview
- Organizational personnel with responsibilities for sharing cross-organizational audit information
- organizational personnel with information security and privacy responsibilities
Test
- Mechanisms implementing disassociability
Authoritative sources
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