PS.L2-3.9.2 – PERSONNEL ACTIONS

DISCUSSION [NIST SP 800-171 R2]

Protecting CUI during and after personnel actions may include returning system-related property and conducting exit interviews. System-related property includes hardware authentication tokens, identification cards, system administration technical manuals, keys, and building passes. Exit interviews ensure that individuals who have been terminated understand the security constraints imposed by being former employees and that proper accountability is achieved for system-related property. Security topics of interest at exit interviews can include reminding terminated individuals of nondisclosure agreements and potential limitations on future employment. Exit interviews may not be possible for some terminated individuals, for example, in cases related to job abandonment, illnesses, and non- availability of supervisors. For termination actions, timely execution is essential for individuals terminated for cause. In certain situations, organizations consider disabling the system accounts of individuals that are being terminated prior to the individuals being
notified.

This requirement applies to reassignments or transfers of individuals when the personnel action is permanent or of such extended durations as to require protection. Organizations define the CUI protections appropriate for the types of reassignments or transfers, whether permanent or extended. Protections that may be required for transfers or reassignments to other positions within organizations include returning old and issuing new keys, identification cards, and building passes; changing system access authorizations (i.e., privileges); closing system accounts and establishing new accounts; and providing for access to official records to which individuals had access at previous work locations and in previous system accounts.

FURTHER DISCUSSION

Employee access to CUI is removed when they change jobs or leave the company. When employment or program access is terminated for any reason, the following actions may occur within the defined time frame:

all company IT equipment (e.g., laptops, cell phones, storage devices) is returned;

all identification, access cards, and keys are returned; and

an exit interview is conducted to remind the employee of their obligations to not discuss
CUI, even after employment.

Additionally, perform the following:

remove access to all accounts granting access to CUI or modify access to CUI as appropriate for a new work role;

disable or close employee accounts for departing employees; and

limit access to physical spaces with CUI for departing employees or those who transition to a work role that does not require access to CUI.

This practice, PS.L2-3.9.2, leverages the identification of system users required by IA.L1-3.5.1 in order to ensure that all accesses are identified and removed.

Example 1

You are in charge of IT operations. Per organizational policies, when workers leave the company, you remove them from any physical CUI access lists. If you are not their supervisor, you contact their supervisor or human resources immediately and ask them to:

turn in the former employees’ computers for proper handling;

inform help desk or system administrators to have the former employees’ system access revoked;

retrieve the former employees’ identification and access cards; and

have the former employees attend an exit interview where you or human resources remind them of their obligations to not discuss CUI [b].

Example 2

An employee transfers from one working group in your company to another. Human resources team notifies IT of the transfer date, and the employee’s new manager follows procedure by submitting a ticket to the IT help desk to provide information on the access rights the employee will require in their new role. IT implements the rights for the new position and revokes the access for the prior position on the official date of the transfer [c].

Potential Considerations

Is information system access disabled upon employee termination or transfer [c]?

Are authenticators/ credentials associated with the employee revoked upon terminationor transfer within a certain time frame [b,c]?

Is all company information system-related property retrieved from the terminated or transferred employee within a certain timeframe [a,c]?

Is access to company information and information systems formerly controlled by the terminated or transferred employee retained for a certain timeframe [a,c]?

Is the information security office and data owner of the change in authorization notified within a certain timeframe [a]?52

Copyright

This material is based upon work funded and supported by the Department of Defense under Contract No. FA8702-15-D-0002 with Carnegie Mellon University for the operation of the Software Engineering Institute, a federally funded research and development center, and under Contract No. HQ0034-13-D-0003 and Contract No. N00024-13-D-6400 with the Johns Hopkins University Applied Physics Laboratory LLC, a University Affiliated Research Center.

The view, opinions, and/or findings contained in this material are those of the author(s) and should not be construed as an official Government position, policy, or decision, unless designated by other documentation.

NO WARRANTY. THIS MATERIAL IS FURNISHED ON AN “AS-IS” BASIS. CARNEGIE MELLON UNIVERSITY AND THE JOHNS HOPKINS UNIVERSITY APPLIED PHYSICS LABORATORY LLC MAKE NO WARRANTIES OF ANY KIND, EITHER EXPRESSED OR IMPLIED, AS TO ANY MATTER INCLUDING, BUT NOT LIMITED TO, WARRANTY OF FITNESS FOR PURPOSE OR MERCHANTABILITY, EXCLUSIVITY, OR RESULTS OBTAINED FROM USE OF THE MATERIAL NOR ANY WARRANTY OF ANY KIND WITH RESPECT TO FREEDOM FROM PATENT, TRADEMARK, OR COPYRIGHT INFRINGEMENT.