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Level 2 AT.L2-3.2.2

Ensure that personnel are trained to carry out their assigned information security-related duties

📖 What This Means

This practice means that every employee, contractor, or anyone else working for your organization must be properly trained to perform their specific security-related tasks. This ensures they understand how to protect sensitive information like Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). Training should be tailored to their job responsibilities and cover relevant security policies and procedures. For example, an IT administrator should know how to secure systems, while a receptionist might need training on recognizing phishing emails. The goal is to minimize human error, which is a leading cause of security breaches.

🎯 Why It Matters

Untrained personnel are a significant security risk. They may accidentally expose sensitive data, fall for phishing scams, or mishandle security tools. For instance, in 2023, a defense contractor suffered a breach when an employee clicked on a phishing link, leading to the theft of CUI. The financial impact included fines, legal fees, and loss of contracts, while reputational damage made it harder to win future bids. The Department of Defense (DoD) emphasizes this control because human error is often the weakest link in cybersecurity. Proper training reduces risks, ensures compliance, and protects both the organization and national security.

How to Implement

  1. 1. Identify cloud-specific security roles (e.g., AWS IAM administrator, Azure security analyst).
  2. 2. Use cloud provider training resources (e.g., AWS Training, Microsoft Learn).
  3. 3. Assign role-based training modules via platforms like Coursera or Pluralsight.
  4. 4. Conduct phishing simulations using tools like KnowBe4 or Proofpoint.
  5. 5. Track completion using cloud-native tools like AWS CloudTrail or Azure Activity Log.
  6. 6. Schedule annual refresher training.
  7. 7. Document training records in cloud storage (e.g., S3 bucket, OneDrive).
⏱️
Estimated Effort
Initial setup: 10-15 hours (Intermediate skill level). Ongoing: 2-3 hours per quarter (Basic skill level).

📋 Evidence Examples

Training Curriculum

Format: PDF/DOCX
Frequency: Annual
Contents: Course titles, descriptions, and objectives
Collection: Export from LMS or manual creation

Training Completion Records

Format: CSV/PDF
Frequency: Quarterly
Contents: Employee names, course titles, completion dates
Collection: Export from LMS or HR system

Phishing Simulation Results

Format: PDF/Excel
Frequency: Quarterly
Contents: Test dates, participation rates, failure rates
Collection: Export from phishing tool

Security Policy Acknowledgment Forms

Format: PDF
Frequency: Annual
Contents: Employee signatures, policy version, date
Collection: Scan signed forms or use e-signature tool

Training Attendance Logs

Format: Excel/CSV
Frequency: Per session
Contents: Session dates, attendees, topics covered
Collection: Manual entry or LMS export

📝 SSP Guidance

Use this guidance when writing the System Security Plan (SSP) narrative for this control.

How to Write the SSP Narrative

For AT.L2-3.2.2 ("Ensure that personnel are trained to carry out their assigned information security-related duties"), your SSP narrative should specifically describe: (1) the tools and technologies you use to implement this control, (2) the configuration or process that enforces it, (3) who is responsible for maintaining it, and (4) what evidence proves it's working. Describe your security awareness and training program, including the platform used, training content, frequency, tracking mechanism, and how completion is enforced. Be specific -- name your actual products, settings, and responsible personnel.

Example SSP Narratives

Cloud (Azure/AWS)

"AT.L2-3.2.2 is implemented using cloud-native controls. [Organization] uses [specific cloud service/feature] to ensure that personnel are trained to carry out their assigned information securi.... The configuration is managed through [Azure Policy/AWS Config/Terraform] and monitored via [SIEM tool]. Responsible party: [IT Security Manager]. Evidence: [specific artifact, e.g., 'Azure AD Conditional Access policy screenshot, CloudTrail logs']."

On-Premise

"AT.L2-3.2.2 is implemented through on-premise infrastructure controls. [Organization] uses [Active Directory/Group Policy/specific tool] to ensure that personnel are trained to carry out their assigned information securi.... Configuration is documented in [location] and audited [frequency]. Responsible party: [System Administrator]. Evidence: [specific artifact, e.g., 'Group Policy export, Windows Event logs']."

Hybrid

"AT.L2-3.2.2 is implemented across both cloud and on-premise environments. [Organization] uses [Azure AD Connect/hybrid tool] to ensure consistent enforcement. Cloud resources are managed via [cloud tool] and on-premise systems via [on-prem tool]. Both environments report to [centralized SIEM]. Responsible party: [IT Director]. Evidence: [artifacts from both environments]."

System Boundary Considerations

  • Identify which personnel categories receive training (employees, contractors, vendors)
  • Document training delivery mechanism (online platform, in-person)
  • Specify how training records are maintained
  • Ensure this control covers all systems within your defined CUI boundary where ensure that personnel are trained to carry out their assigned information security-related duties applies
  • Document any systems where this control is not applicable and explain why

Key Documentation to Reference in SSP

  • 📄 Security Awareness Training Policy
  • 📄 Training completion records
  • 📄 Training materials and curriculum
  • 📄 Evidence artifacts specific to AT.L2-3.2.2
  • 📄 POA&M entry if control is not fully implemented

What the Assessor Looks For

The assessor will review training completion rates, examine training content for adequacy, and verify that training records are maintained with dates and scores.

💬 Self-Assessment Questions

Use these questions to assess your compliance. Each "NO" answer provides specific remediation guidance.

Question 1: Do all employees have assigned security-related roles?

✅ YES → Proceed to Q2
❌ NO → GAP: Define security roles for each employee. Use RACI charts for clarity.
Remediation:
Complete within 2 weeks.

Question 2: Are role-specific training materials available?

✅ YES → Proceed to Q3
❌ NO → GAP: Develop or source training materials tailored to each role.
Remediation:
Complete within 4 weeks.

Question 3: Have all employees completed their assigned training?

✅ YES → Proceed to Q4
❌ NO → GAP: Schedule training sessions and track completions.
Remediation:
Complete within 6 weeks.

Question 4: Are training records maintained and up to date?

✅ YES → Proceed to Q5
❌ NO → GAP: Centralize training records in an LMS or secure database.
Remediation:
Complete within 2 weeks.

Question 5: Has phishing simulation testing been conducted?

✅ YES → Compliance confirmed.
❌ NO → GAP: Conduct phishing simulations and document results.
Remediation:
Complete within 4 weeks.

⚠️ Common Mistakes (What Auditors Flag)

1. Incomplete training records

Why this happens: Failure to track training completions systematically.
How to avoid: Use an LMS or HR system to automate record-keeping.

2. Generic training content

Why this happens: Not tailoring training to specific roles.
How to avoid: Develop role-specific modules based on job functions.

3. Infrequent phishing simulations

Why this happens: Lack of awareness about phishing risks.
How to avoid: Conduct quarterly phishing tests and review results.

4. Missing policy acknowledgments

Why this happens: Failure to collect signed forms.
How to avoid: Use e-signature tools to streamline the process.

5. No refresher training

Why this happens: Assuming one-time training is sufficient.
How to avoid: Schedule annual or bi-annual refresher courses.

📚 Parent Policy

This practice is governed by the Awareness and Training Policy

View AT Policy →

📚 Related Controls