What evidence do auditors commonly ask for on AT-3 Role-based Training?

System security plan; Privacy plan; Security and privacy awareness and training policy; Procedures addressing security and privacy training implementation; Codes of federal regulations; Security and privacy training curriculum.

What is the most common gap auditors find on AT-3?

Personnel with the organization-defined roles receive privileged access before completing role-based security and privacy training

NIST SP 800-53 Rev 5 · AT - Awareness and Training

`AT-3` Role-based Training

a. Provide role-based security and privacy training to personnel with the following roles and responsibilities: organization-defined roles and responsibilities: 1. Before authorizing access to the system, information, or performing assigned duties, and organization-defined frequency thereafter; and 2. When required by system changes; b. Update role-based training content organization-defined frequency and following organization-defined events; and c. Incorporate lessons learned from internal or external security incidents or breaches into role-based training.

Source: NIST SP 800-53 Rev 5, AT-3. 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 NIST SP 800-53 Rev 5 in the compliance library.

Base controls and their enhancements. Which apply follows the baseline you are assessed against (for example FedRAMP Moderate or High, or the low, moderate and high baselines of SP 800-53B). Text in square brackets is a parameter your organisation sets.

artefacts

held by a system

at each review

hard

to go live

HR system / LMS

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

none for this control

periodic reviewEvidence produced at each review

Training records · HR system / LMS
Test of Mechanisms managing role-based security and privacy training · HR system / LMS

governing documentDocuments that govern the control

System security plan · HR system / LMS
Privacy plan · HR system / LMS
Security and privacy awareness and training policy · HR system / LMS
Procedures addressing security and privacy training implementation · HR system / LMS
Codes of federal regulations · HR system / LMS
Security and privacy training curriculum · HR system / LMS
Security and privacy training materials · HR system / LMS

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Personnel with the organization-defined roles receive privileged access before completing role-based security and privacy training
Role-based training content is not updated after defined events and does not incorporate lessons learned from incidents or breaches

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

AT-2(6) Literacy Training and Awareness | Cyber Threat Environment · AT-3(1) Role-based Training | Environmental Controls