What evidence do auditors commonly ask for on PS-8 Personnel Sanctions?

SSP PS-8 statement describing the formal sanctions process and who is notified when sanctions are applied; Sanctions policy and anonymised records of sanctions applied with notifications; Personnel security policy and position risk designation matrix; Background screening completion records by role tier; Termination and transfer access removal evidence within SLA; Sanctions policy with documented application history.

What is the most common gap auditors find on PS-8?

Contractor screening relies on vendor attestation without sampling

FedRAMP Moderate (NIST SP 800-53 Rev 5 baseline) · PS - Personnel Security

`PS-8` Personnel Sanctions

Employ formal sanctions for personnel failing to comply with security/privacy policies; notify defined personnel within FedRAMP timeframe.

Source: FedRAMP Moderate (NIST SP 800-53 Rev 5 baseline), PS-8. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open FedRAMP Moderate (NIST SP 800-53 Rev 5 baseline) in the compliance library.

A FedRAMP baseline is a subset of NIST SP 800-53 Rev 5, enhancements included.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

Background screening completion records by role tier · HR system / LMS

periodic reviewEvidence produced at each review

Sanctions policy and anonymised records of sanctions applied with notifications · Data governance / DLP tooling
Termination and transfer access removal evidence within SLA · HR system / LMS

governing documentDocuments that govern the control

SSP PS-8 statement describing the formal sanctions process and who is notified when sanctions are applied · Document repository
Personnel security policy and position risk designation matrix · Policy repository / GRC workspace
Sanctions policy with documented application history · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your HR system / LMS on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

Contractor screening relies on vendor attestation without sampling
Position risk designations not reviewed when responsibilities change
Background checks not re run when employees move to higher risk roles

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

PS-7 External Personnel Security · PS-9 Position Descriptions (PS-9)