Audit and Accountability 3.3.5 (3.3.5)
Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity.
Get Full GuidanceWhat Is This CMMC Control?
This control requires organizations to connect their audit log review, analysis, and reporting activities so they work together rather than in isolation. When security events are detected, the organization must be able to investigate and respond by correlating information across different audit sources and processes. This ensures that suspicious patterns or security incidents can be identified and addressed effectively, whether the correlation happens at the individual system level or across the entire organization.
Control Intent
Ensure that audit record review, analysis, and reporting processes work together cohesively to enable effective investigation and response to security incidents, rather than operating as disconnected activities.
Who This Control Applies To
- •Organizations processing, storing, or transmitting CUI
- •All systems within the assessment boundary that generate audit records
- •Security operations teams responsible for monitoring and incident response
- •Centralized logging and SIEM platforms
- •Individual systems with local audit capabilities
Not Applicable When
- •The organization has no systems that generate audit records (extremely rare)
- •The system is completely isolated with no audit logging capability and no CUI (must be documented and justified)
- •Audit records are generated but the organization has documented that correlation is performed at a higher organizational level outside the system boundary
Key Objectives
- 1Enable detection of security incidents by correlating audit information across multiple sources and processes.
- 2Support timely investigation and response to unlawful, unauthorized, suspicious, or unusual activity through integrated audit processes.
- 3Ensure audit review, analysis, and reporting activities inform each other to provide comprehensive security visibility.
Sample Self-Assessment Questions (Partial)
Do you review security logs from your systems and applications?
Do you use any tools or processes to compare security events across different systems?
Implementation Approaches (High-Level)
SIEM-Based Correlation
Deploy a Security Information and Event Management (SIEM) platform that aggregates logs from all in-scope systems and provides correlation rules, alerting, and investigation capabilities.
Manual Correlation with Documented Procedures
Establish documented procedures for security analysts to manually correlate audit records across systems during investigations, using log aggregation tools or direct system access.
Hybrid Correlation Approach
Combine automated correlation tools for routine monitoring with manual correlation procedures for in-depth investigations, leveraging both centralized and per-system capabilities.
Managed Security Service Provider (MSSP) Correlation
Outsource audit correlation to a managed security service provider that performs 24/7 monitoring, correlation, and investigation services using their centralized platform.
Evidence & Assessment Notes
Expected Evidence
Organizations should maintain documentation and evidence demonstrating compliance with this control. This may include policy documentation, configuration records, audit logs, access reviews, and other relevant artifacts that show how the control is implemented and maintained.
Plan of Action & Milestones (POA&M)
If correlation capability does not exist, prioritize implementing basic log aggregation and manual correlation procedures as interim step Document specific systems or log sources not currently included in correlation process and timeline for inclusion If SIEM is planned but not yet deployed, document interim manual correlation procedures and implementation timeline For cloud services not yet integrated into correlation process, document plan and timeline for integration If correlation procedures exist but are not consistently followed, focus POA&M on training and process enforcement rather than technical implementation Consider phased approach: implement correlation for highest-risk systems first, then expand coverage If time synchronization issues prevent correlation, address as prerequisite before implementing correlation processes Document specific correlation use cases or scenarios to be implemented and prioritization rationale
Frequently Asked Questions
Does this control require a SIEM or can we meet it with manual processes?
The control does not mandate a specific technology. Organizations can meet this requirement through manual correlation procedures if they are documented and consistently followed. However, as environments grow, manual correlation becomes impractical and error-prone. The key requirement is that correlation actually happens during investigations, regardless of whether it is automated or manual.
Can we satisfy this control by correlating logs only during major incidents?
No. The control requires correlation as part of routine audit record review, analysis, and reporting processes, not just during major incidents. Correlation must be integrated into regular security monitoring activities to detect suspicious patterns before they become major incidents. Reactive-only correlation does not meet the control intent.
If we use a managed security service provider (MSSP), does that satisfy this control?
An MSSP can satisfy this control if the service agreement clearly specifies correlation requirements and the organization can demonstrate that the MSSP performs correlation across all in-scope systems. However, the organization must also maintain documented procedures for how MSSP correlation findings are escalated and responded to internally. Simply having an MSSP contract is not sufficient without evidence of active correlation and response.
Does correlation need to happen at the system level or organization level?
The control is agnostic about whether correlation happens at the system level or organization level. Organizations can implement correlation centrally across all systems or at individual system levels, as long as the processes work together cohesively. Most organizations find centralized correlation more effective, but the key requirement is that audit review, analysis, and reporting processes inform each other rather than operating independently.
What types of suspicious activity should our correlation process detect?
Correlation processes should be designed to detect patterns that indicate unlawful, unauthorized, suspicious, or unusual activity. Common examples include: multiple failed login attempts across systems from the same source, privilege escalation followed by unusual data access, lateral movement between systems, or coordinated attacks across multiple entry points. The specific correlation scenarios should be based on your organization's risk assessment and the types of threats relevant to your environment.
How do we demonstrate that our correlation processes work together rather than independently?
Provide evidence that shows information flows between review, analysis, and reporting activities. This might include investigation reports that reference findings from routine audit reviews, correlation rules that were created based on analysis of previous incidents, or reports that synthesize correlated findings across multiple systems. The assessor is looking for evidence that these activities inform each other, not that they happen in isolation.
How ConformatIQ Helps With CMMC Readiness
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Request Full GuidanceInformation sourced from NIST SP 800-171 Rev. 2. See full disclaimer.