SC.L2-3.13.3 · NIST SP 800-171 3.13.3

Role Separation

Separate user functionality from system management functionality.

1 point if not metPOA&M eligible3 assessment objectives

What an assessor scores, the objectives

SC.L2-3.13.3 is met only when every one of these 3 objectives, from NIST SP 800-171A, is satisfied. A single missed objective makes the whole requirement not met.

  • a.user functionality is identified
  • b.system management functionality is identified
  • c.user functionality is separated from system management functionality

How a C3PAO checks it

NIST SP 800-171A defines three assessment methods. For SC.L2-3.13.3, an assessor uses these:

Examine

System and communications protection policy; procedures addressing application partitioning; system design documentation; system configuration settings and associated documentation; system security plan; system audit logs and records; other relevant documents or records

Interview

System or network administrators; personnel with information security responsibilities; system developer

Test

Separation of user functionality from system management functionality

What it means, in context

System management functionality includes functions necessary to administer databases, network components, workstations, or servers, and typically requires privileged user access. The separation of user functionality from system management functionality is physical or logical. Organizations can implement separation of system management functionality from user functionality by using different computers, different central processing units, different instances of operating systems, or different network addresses; virtualization techniques; or combinations of these or other methods, as appropriate . This type of separation includes web administrative interfaces that use separate authentication methods for users of any other system resources . Separation of system and user functionality may include isolating administrative interfaces on different domains and with additional access controls.

Prevent users and user services from accessing system management functionality on IT components (e.g., databases, network components, workstations, servers). This reduces the attack surface to those critical interfaces by limiting who can access and how they can be accessed. By separating the user functionality from system management functionality, the administrator or privileged functions are not available to the general user. The intent of this requirement is to ensure: • general users are not permitted to perform system administration functions; and • system administrators only perform system administration functions from their privileged account. This can be accomplished using separation like VLANs or logical separation using strong access control methods. Example As a system administrator, you are responsible for managing a number of core systems. Policy prevents you from conducting any administration from the computer or system account you use for day -to-day work [a,b]. The servers you manage also are isolated from the main corporate network. To work with them you use a special unique account to connect to a “jump” server that has access to the systems you routinely administer. Potential Assessment Considerations • Are physical or logical controls used to separate user functionality from system management-related functionality (e.g., to ensure that administration (e.g., privilege) options are not available to general users) [c]?

What passing evidence looks like

User functionality separated from management: admin interfaces and accounts distinct from user surfaces, shown with the separate admin accounts and restricted admin portals.

Common ways contractors fail SC.L2-3.13.3

  • !You mostly earned this at IA and AC: separate admin accounts, admin portals restricted by Conditional Access. Reference that work; the objective wants the separation visible.

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SC.L2-3.13.3 questions, answered

How many points is CMMC requirement SC.L2-3.13.3 worth?+

SC.L2-3.13.3 is worth 1 point in the CMMC Level 2 score under 32 CFR 170.24. If it is not met, you lose 1 from your total of 110.

Can SC.L2-3.13.3 be placed on a POA&M?+

Yes. A gap on SC.L2-3.13.3 can be deferred to a Plan of Action and Milestones, provided your overall score is 88 or better and the item closes within 180 days.

What family does SC.L2-3.13.3 belong to?+

SC.L2-3.13.3 is in the System & Communications Protection (SC) family, one of the 14 families of NIST SP 800-171 that make up CMMC Level 2.

Key references
  • NIST SP 800-171 Rev. 2 3.13.3