AU-16 Cross-organizational Audit Logging

Guidance: nonePolicy clause: noneWhat these mean

Baselines	Implementation level	Enhancements
Not in a baseline	Organization	3 (0 in a baseline)

Related controls: AU-3, AU-6, AU-7, CA-3, PT-7

Control statement

Employ [Assignment: organization-defined methods] for coordinating [Assignment: organization-defined audit information] among external organizations when audit information is transmitted across organizational boundaries.

NIST discussion

When organizations use systems or services of external organizations, the audit logging capability necessitates a coordinated, cross-organization approach. For example, maintaining the identity of individuals who request specific services across organizational boundaries may often be difficult, and doing so may prove to have significant performance and privacy ramifications. Therefore, it is often the case that cross-organizational audit logging simply captures the identity of individuals who issue requests at the initial system, and subsequent systems record that the requests originated from authorized individuals. Organizations consider including processes for coordinating audit information requirements and protection of audit information in information exchange agreements.

Control enhancements

AU-16(1) Identity Preservation

Baselines: Not in a baseline

Preserve the identity of individuals in cross-organizational audit trails.

Discussion and assessment objectives for AU-16(1)

Identity preservation is applied when there is a need to be able to trace actions that are performed across organizational boundaries to a specific individual.

Determine if the identity of individuals in cross-organizational audit trails is preserved.

Examine: Audit and accountability policy; system security plan; privacy plan; procedures addressing cross-organizational audit trails; system design documentation; system configuration settings and associated documentation; system audit records; other relevant documents or records.

Interview: Organizational personnel with cross-organizational audit responsibilities; organizational personnel with information security and privacy responsibilities.

Test: Mechanisms implementing cross-organizational auditing (if applicable).

AU-16(2) Sharing of Audit Information

Baselines: Not in a baseline

Provide cross-organizational audit information to [Assignment: organization-defined organizations] based on [Assignment: organization-defined cross-organizational sharing agreements].

Discussion and assessment objectives for AU-16(2)

Due to the distributed nature of the audit information, cross-organization sharing of audit information may be essential for effective analysis of the auditing being performed. For example, the audit records of one organization may not provide sufficient information to determine the appropriate or inappropriate use of organizational information resources by individuals in other organizations. In some instances, only individuals’ home organizations have the appropriate knowledge to make such determinations, thus requiring the sharing of audit information among organizations.

Determine if cross-organizational audit information is provided to [Assignment: organization-defined organizations] based on [Assignment: organization-defined cross-organizational sharing agreements].

Examine: Audit and accountability policy; system security plan; privacy plan; procedures addressing cross-organizational sharing of audit information; information sharing agreements; other relevant documents or records.

Interview: Organizational personnel with responsibilities for sharing cross-organizational audit information; organizational personnel with information security and privacy responsibilities.

AU-16(3) Disassociability

Baselines: Not in a baseline

Implement [Assignment: organization-defined measures] to disassociate individuals from audit information transmitted across organizational boundaries.

Discussion and assessment objectives for AU-16(3)

Preserving identities in audit trails could have privacy ramifications, such as enabling the tracking and profiling of individuals, but may not be operationally necessary. These risks could be further amplified when transmitting information across organizational boundaries. Implementing privacy-enhancing cryptographic techniques can disassociate individuals from audit information and reduce privacy risk while maintaining accountability.

Determine if [Assignment: organization-defined measures] are implemented to disassociate individuals from audit information transmitted across organizational boundaries.

Examine: Audit and accountability policy; system security plan; privacy plan; procedures addressing cross-organizational sharing of audit information; policy and/or procedures regarding the deidentification of PII; system design documentation; system configuration settings and associated documentation; system audit records; other relevant documents or records.

Interview: Organizational personnel with responsibilities for sharing cross-organizational audit information; organizational personnel with information security and privacy responsibilities.

Test: Mechanisms implementing disassociability.

Assessment objectives (SP 800-53A)

Objectives and methods for AU-16

Determine if [Assignment: organization-defined methods] for coordinating [Assignment: organization-defined audit information] among external organizations when audit information is transmitted across organizational boundaries are employed.

Examine: Audit and accountability policy; system security plan; privacy plan; procedures addressing methods for coordinating audit information among external organizations; system design documentation; system configuration settings and associated documentation; system audit records; other relevant documents or records.

Interview: Organizational personnel with responsibilities for coordinating audit information among external organizations; organizational personnel with information security and privacy responsibilities.

Test: Mechanisms implementing cross-organizational auditing.