LLMResponse PS.L2-3.9.1.a: Difference between revisions

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I'll help you prepare for your CMMC Level 2 assessment of the PS.L2-3.9.1 - SCREEN INDIVIDUALS practice. Based on the assessment guidance you've provided and the CMMC Assessment Guide, I'll suggest what evidence would be appropriate to demonstrate compliance with this practice.
# Ranking Evidence Types for PS.L2-3.9.1


## Understanding the Requirement
Based on the assessment objective "[a] individuals are screened prior to authorizing access to organizational systems containing CUI," here's my ranking of evidence types from most to least compelling, supported by the assessment objects:


PS.L2-3.9.1 requires screening individuals before authorizing their access to organizational systems containing CUI. The assessment objective is to determine if individuals are screened prior to granting this access.
== Evidence Type Ranking ==


## Recommended Evidence Collection Approach
1. **Documents** - Highest priority
  * Personnel security policy that defines screening requirements
  * Procedures documenting personnel screening processes
  * Records of screened personnel showing completion before access granted
  * System security plan sections addressing screening requirements


### 1. Documents to Examine
2. **Artifacts** - Second priority
  * Access control records showing that system access was granted only after screening
  * HR workflow evidence showing screening verification steps
  * Authorization forms with screening verification checkpoints


I recommend collecting the following documents:
3. **Screen Share** - Third priority
  * Demonstration of the access control system showing how screening status affects permissions
  * Walkthrough of HR/security systems showing screening verification before access approval


- Personnel security policy that outlines screening requirements before granting access to systems containing CUI
4. **Physical Review** - Fourth priority
- Procedures for personnel screening (including the types of screening conducted)
  * On-site observation of screening records and their connection to access control
- Records of screened personnel (anonymized if needed for privacy)
  * Physical inspection of security controls that enforce the screening requirement
- System security plan section that describes your screening process
- Job descriptions that define screening requirements based on role/position
- Hiring process documentation that includes screening steps


### 2. Interviews to Conduct
== Assessment Approach Prioritization ==


Consider interviewing:
For this assessment objective, I recommend prioritizing the assessment approaches as follows:


- HR personnel responsible for screening processes
1. **Examine** - Highest priority
- Security manager or personnel with personnel security responsibilities
  * This approach provides direct evidence of your screening policies, procedures, and records
- IT staff responsible for granting system access
  * Documents show the design and implementation of your screening controls
- Information security officer or personnel with information security responsibilities
  * Records demonstrate that screening consistently occurs before access is granted


### 3. Tests to Perform
2. **Interview** - Second priority
  * Interviews with personnel security and HR staff explain how screening policies are implemented
  * IT staff can explain how screening status affects system access permission controls
  * Interviews validate that documented procedures are understood and followed


You could demonstrate:
3. **Test** - Third priority
  * Testing demonstrates the effectiveness of controls that prevent access before screening
  * While valuable, testing supplements rather than replaces examination of records and interviews


- The process flow for a new hire from screening to system access approval
The "examine" approach should be your primary focus because the assessment objective is fundamentally about verifying a sequence of events (screening before authorization), which is best demonstrated through documentation and records. Interviews provide context and confirmation, while testing helps prove that controls operate as intended.
- The system workflow that prevents access until screening is complete
- The access control process showing how screened status affects system access permissions
 
### 4. Specific Evidence Items
 
Based on the evidence types you've defined:
 
**Artifacts:**
- Screenshots (redacted for privacy) of your HR system showing screening status tracking
- Sample access request forms showing screening verification before approval
- Access control logs showing access was only granted after screening completion
 
**Documents:**
- Personnel security policy with screening requirements
- Screening procedures documentation
- Background check provider contracts/agreements
- System access authorization procedure showing screening verification step
 
**Physical Review:**
- On-site demonstration of HR records showing screening completion before system access
- Review of physical access records tied to screening status
 
**Screen Share:**
- Demonstration of how HR verifies screening completion
- Demonstration of IT system showing how access to CUI systems requires screening verification
 
## Important Implementation Considerations
 
1. Ensure your screening process is appropriate for the level of access required for different positions
2. Document the criteria used for screening decisions
3. Maintain records that clearly show screening was completed before system access was granted
4. Ensure your screening practices comply with applicable laws and regulations
5. Implement a process for periodic re-screening if appropriate for your organization
 
Would you like me to elaborate on any specific aspect of this evidence collection approach or provide more details on a particular type of evidence?

Latest revision as of 02:27, 3 April 2025

  1. Ranking Evidence Types for PS.L2-3.9.1

Based on the assessment objective "[a] individuals are screened prior to authorizing access to organizational systems containing CUI," here's my ranking of evidence types from most to least compelling, supported by the assessment objects:

Evidence Type Ranking

1. **Documents** - Highest priority 

  * Personnel security policy that defines screening requirements
  * Procedures documenting personnel screening processes
  * Records of screened personnel showing completion before access granted
  * System security plan sections addressing screening requirements

2. **Artifacts** - Second priority 

  * Access control records showing that system access was granted only after screening
  * HR workflow evidence showing screening verification steps
  * Authorization forms with screening verification checkpoints

3. **Screen Share** - Third priority 

  * Demonstration of the access control system showing how screening status affects permissions
  * Walkthrough of HR/security systems showing screening verification before access approval

4. **Physical Review** - Fourth priority 

  * On-site observation of screening records and their connection to access control
  * Physical inspection of security controls that enforce the screening requirement

Assessment Approach Prioritization

For this assessment objective, I recommend prioritizing the assessment approaches as follows:

1. **Examine** - Highest priority 

  * This approach provides direct evidence of your screening policies, procedures, and records
  * Documents show the design and implementation of your screening controls
  * Records demonstrate that screening consistently occurs before access is granted

2. **Interview** - Second priority 

  * Interviews with personnel security and HR staff explain how screening policies are implemented
  * IT staff can explain how screening status affects system access permission controls
  * Interviews validate that documented procedures are understood and followed

3. **Test** - Third priority 

  * Testing demonstrates the effectiveness of controls that prevent access before screening
  * While valuable, testing supplements rather than replaces examination of records and interviews

The "examine" approach should be your primary focus because the assessment objective is fundamentally about verifying a sequence of events (screening before authorization), which is best demonstrated through documentation and records. Interviews provide context and confirmation, while testing helps prove that controls operate as intended.

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