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Control Acronym



Personnel Security

CMMC Level


800-171 Control #


CMMC Description

Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.

CMMC Clarification

Make sure employees no longer have access to CUI when they change jobs or leave the company. Confirm that when an employee leaves: * all company IT equipment (e.g., laptops, cell phones, storage devices) is returned * all of their identification/access cards and/or keys are returned * an exit interview is conducted to remind the employee of their obligations to not discuss CUI, even after employment. The organization will do the following: • * erase all equipment before reuse * remove access to all accounts granting access to CUI * disable or close employee accounts * limit access to physical spaces with CUI. Example You are in charge of IT operations at your company. When someone leaves the company, you remove them from any physical CUI access lists. You contact them immediately, and ask them to: * turn in their computers for proper handling which includes IT disabling all accounts * return all their identification and access cards * attend an exit interview where you remind them of their obligations to not discuss CUI.

800-171 Description

Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.

800-171 Discussion

Protecting CUI during and after personnel actions may include returning system-related property and conducting exit interviews. System-related property includes hardware authentication tokens, identification cards, system administration technical manuals, keys, and building passes. Exit interviews ensure that individuals who have been terminated understand the security constraints imposed by being former employees and that proper accountability is achieved for system-related property. Security topics of interest at exit interviews can include reminding terminated individuals of nondisclosure agreements and potential limitations on future employment. Exit interviews may not be possible for some terminated individuals, for example, in cases related to job abandonment, illnesses, and non-availability of supervisors. For termination actions, timely execution is essential for individuals terminated for cause. In certain situations, organizations consider disabling the system accounts of individuals that are being terminated prior to the individuals being notified. This requirement applies to reassignments or transfers of individuals when the personnel action is permanent or of such extended durations as to require protection. Organizations define the CUI protections appropriate for the types of reassignments or transfers, whether permanent or extended. Protections that may be required for transfers or reassignments to other positions within organizations include returning old and issuing new keys, identification cards, and building passes; changing system access authorizations (i.e., privileges); closing system accounts and establishing new accounts; and providing for access to official records to which individuals had access at previous work locations and in previous system accounts.

Other Source Discussion


CIS Control References

NIST 800-53 Control Ref.

NIST SP 800-53 Rev 4 PS-4, PS-5

CMMC Derived

NIST CSF Control References

NIST 800-171 References

NIST SP 800-171 Rev 1 3.9.2

Applicable FAR Clause

NIST CSF Control Reference


CERT RMM Reference


Modification of NIST 800-171B Reference

NIST 800-171B Reference

UK NCSCCyber Reference

AS ACSC Reference


Assessment Sub-Criteria 1

PS.2.128.[a] a policy and/or process for terminating system access and any credentials coincident with personnel actions is established;

Assessment Sub-Criteria 2

PS.2.128.[b] system access and credentials are terminated consistent with personnel actions such as termination or transfer; and

Assessment Sub-Criteria 3

PS.2.128.[c] the system is protected during and after personnel transfer actions.

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