Control statement
- a.Employ a formal sanctions process for individuals failing to comply with established information security and privacy policies and procedures; and
- b.Notify [Organization-defined: personnel or roles] within [Organization-defined: time period] when a formal employee sanctions process is initiated, identifying the individual sanctioned and the reason for the sanction.
Discussion
Organizational sanctions reflect applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Sanctions processes are described in access agreements and can be included as part of general personnel policies for organizations and/or specified in security and privacy policies. Organizations consult with the Office of the General Counsel regarding matters of employee sanctions.
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 Personnel Sanctions 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 personnel risk, screening, agreements, transfer, termination, and access consequences.
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
- screening and suitability records
- access agreements
- transfer and termination checklists
- role change and offboarding evidence
Common failure patterns
- access persists after transfer or separation
- contractor lifecycle handled outside normal controls
- sensitive-role screening not risk based
- termination actions cannot be shown to occur promptly
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
- PS-08a.a formal sanctions process is employed for individuals failing to comply with established information security and privacy policies and procedures;
- PS-08b.[Organization-defined: personnel or roles] is/are notified within [Organization-defined: time period] when a formal employee sanctions process is initiated, identifying the individual sanctioned and the reason for the sanction.
Examine
- Personnel security policy
- personnel security procedures
- procedures addressing personnel sanctions
- access agreements (including non-disclosure agreements, acceptable use agreements, rules of behavior, and conflict-of-interest agreements)
- list of personnel or roles to be notified of formal employee sanctions
- records or notifications of formal employee sanctions
- system security plan
- privacy plan
- personally identifiable information processing policy
- other relevant documents or records
Interview
- Organizational personnel with personnel security responsibilities
- legal counsel
- organizational personnel with information security and privacy responsibilities
Test
- Organizational processes for managing formal employee sanctions
- mechanisms supporting and/or implementing formal employee sanctions notifications
Related controls
These relationships come from the official OSCAL catalog. They indicate useful dependencies or context, not automatic inheritance or equivalence.
Authoritative sources
Bare Metal Cyber is an independent educational publisher and is not affiliated with or endorsed by NIST. Official control requirements and interpretations remain with NIST and the responsible authorizing organization.