NIST 800-171 3.2.1 (AT.L2-3.2.1): Security Awareness
Ensure that managers, systems administrators, and users of organizational systems are made aware of the security risks associated with their activities and of the applicable policies, standards, and procedures related to the security of those systems.
CMMC Level 2 practice AT.L2-3.2.1
What 3.2.1 means in practice
Everyone who uses the system, from managers to administrators, learns the security risks of their work and the policies they must follow. Awareness can come through training, briefings, posters or simulated phishing, but you need records of who received it and when.
SPRS points and the CMMC POA&M
- CMMC Level 2 practice
- AT.L2-3.2.1
- SPRS points
- 5 points. When it is not met, the DoD Assessment Methodology subtracts 5 from the score of 110.
- CMMC POA&M
- Not allowed. It is worth 5 points, and 32 CFR 170.21(a)(2)(ii) admits only requirements worth 1 point, with one exception: 3.13.11 when encryption is used but not FIPS validated.
Sources: NIST SP 800-171 DoD Assessment Methodology, version 1.2.1 (June 24, 2020), Annex A; 32 CFR 170.21, Plan of Action and Milestones requirements.
What an assessor checks for 3.2.1
NIST SP 800-171A gives 4 determination statements for 3.2.1, each found satisfied or other than satisfied. Determine if:
- 3.2.1[a] security risks associated with organizational activities involving CUI are identified.
- 3.2.1[b] policies, standards, and procedures related to the security of the system are identified.
- 3.2.1[c] managers, systems administrators, and users of the system are made aware of the security risks associated with their activities.
- 3.2.1[d] managers, systems administrators, and users of the system are made aware of the applicable policies, standards, and procedures related to the security of the system.
NIST SP 800-171A (June 2018), assessment objectives for 3.2.1
Evidence that shows 3.2.1 is met
- The awareness program content and how often it runs.
- Completion records for all users, new hires included.
- Acknowledgements of the security policies that apply to each user.
How PolicyCortex gathers the evidence
No PolicyCortex collector reads the evidence for 3.2.1. Your team provides the evidence listed above.
Meet the requirement once. Keep the evidence current.
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