AU-16(3) Disassociability
Enhancement of: AU-16
High-Level Description
Family: Audit and Accountability (AU) Framework: NIST SP 800-53 Rev 5
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.
What to Check
- Verify AU-16(3) Disassociability is documented in SSP
- Confirm control is operating effectively
- Review evidence of continuous monitoring for AU-16(3)
- Verify enhancement builds upon base control AU-16
How to Test
Step 1: Review Documentation
Examine the System Security Plan (SSP) and related artifacts for AU-16(3) implementation details. Verify the organization has documented how this control is satisfied.
Step 2: Validate Implementation
# For cloud environments, use cloud-audit-mcp tools
# For on-premises, review system configurations directly
# Example: Check if account management policies exist
grep -r "account.management\|access.control" /etc/security/ 2>/dev/null
Step 3: Test Operating Effectiveness
Verify the control is actively functioning, not just documented. Check logs, configurations, and operational evidence.
Tools
| Tool | Purpose | Usage |
|---|---|---|
| cloud-audit-mcp | Check logging configuration | cloud_audit_logging |
| AWS CLI | Review CloudTrail/CloudWatch | aws cloudtrail describe-trails |
Remediation Guide
Control Statement
Implement [organization-defined] to disassociate individuals from audit information transmitted across organizational boundaries.
Implementation Guidance
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.
Risk Assessment
| Finding | Severity | Impact |
|---|---|---|
| AU-16(3) Disassociability not implemented | Medium | Audit and Accountability |
| AU-16(3) partially implemented | Low | Incomplete Audit and Accountability |
CWE Categories
| CWE ID | Title |
|---|---|
| CWE-778 | Insufficient Logging |
References
- NIST SP 800-53 Rev 5 - AU-16(3)
- NIST SP 800-53A Rev 5 (Assessment Procedures)
- NIST SP 800-53 Rev 5 Full Catalog
Checklist
- Control documented in SSP
- Implementation evidence collected
- Operating effectiveness validated
- Continuous monitoring in place
- Related controls (none) reviewed