IA.L1-B.1.V
Identification
FCI Data
Security Requirement
Identify information system users, processes acting on behalf of users, or devices.
USU Policy, Procedures, and Standards
University Policy 5200: Information Security and Appropriate Use
- Section 2.2 - Appropriate Use and Terms of Use
- Section 2.3 - Device and Endpoint Management and Security
- Section 3.3 - Information Technology and IT Staff
States that access is tied to a user’s role and managed via credentials. IT staff (central or department) are responsible for enforcing role-based access and device security controls.
NIST Cybersecurity Framework v2
- Protect (PR): PR.AA-01 - Identities of authorized users, processes, and devices are created and managed.
- Protect (PR): PR.AA-02 - Identities are proofed and bound to credentials.
Implementation Details
Documentation should include details to meet the Security Requirement for this control. Complete this list for each system or systems that process or access FCI data:
- List your process for assigning unique user identifiers to individuals who require system access.
- List how service accounts or processes acting on behalf of users are identified and differentiated.
- List your method for identifying and approving devices that may connect to FCI systems.
- List any additional procedures in place to track user, device, or service account identities.
Document How
- system users are identified
- processes acting on behalf of users are identified
- users are uniquely identified before being granted system access
Example
Each USU employee is issued a unique A# that serves as their NetID. This identifier is used across all institutional systems for authentication and role assignment. Entra ID (Azure AD) and Active Directory are used to enforce identity policies. MFA is required for access to all SSO-enabled services. Devices accessing FCI must be USU-managed and registered in device compliance systems. Service accounts are clearly labeled and reviewed quarterly.
How might an auditor assess this control?
Method
- Examine:
- Review account provisioning policies, system configuration, user lists, and device registration records.
- Interview:
- Ask administrators how they manage unique user identifiers, service accounts, and approved devices.
- Test:
- Attempt to access a system using an unregistered or shared account or an unauthorized device.
Objects (examples of items you could present to the auditor)
- User Provisioning Policy: Describes how new user accounts are created and assigned.
- User Account Listings: Exports from Entra ID or Active Directory showing account details.
- Service Account Documentation: Listing of non-user accounts and their purpose.
- Device Inventory: List of approved and managed devices connected to FCI systems.
- Authentication Configuration: Screenshots or settings showing required identity validation.
- MFA Logs: Showing identity enforcement at time of login.