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.

Priority: Medium

Category: Personnel Security 

Services Associated with AWS:   


Objective Evidence: 

  • Administrative: documented policies, standards & procedures
  • Administrative: supporting documentation to demonstrate Human Resources (HR) practices to screen individuals
  • Administrative: supporting documentation to demonstrate how Identity & Access Management (IAM) practices are implemented
  • Administrative: supporting documentation to demonstrate the "secure practices" used to build technology platform-specific secure baseline configurations
  • Technical: screenshot of AD settings, or other IAM interface 

Possible Technology Considerations : 


What needs to be answered :  

Does the company disable information system access prior to employee termination or transfer? Does the company revoke authenticators/ credentials associated with the employee upon termination or transfer with in a certain time frame? Does the company retrieve all company information system-related property from the terminated or transferred employee within a certain timeframe? Does the company retain access to company information and information systems formerly controlled by the terminated or transferred employee within a certain timeframe? Does the company notify the information security office and data owner of the change in authorization within a certain timeframe? Are electronic and physical access permissions reviewed when employees are reassigned or transferred? (hours) 

  • Protection of CUI during and after Personnel Actions
    Description: This check ensures that organizational systems containing Controlled Unclassified Information (CUI) are adequately protected during and after personnel actions, such as terminations and transfers. The protection measures include the proper handling of system-related property, conducting exit interviews, and implementing necessary security controls.

More Details:   

IT support staff is notified of personnel action prior to action taking place so appropriate changes can be made securely.