3.5.7—Identification and Authentication - Derived
Derived Requirement
>Control Description
Enforce a minimum password complexity and change of characters when new passwords are created.
>Discussion
This requirement applies to single-factor authentication of individuals using passwords as individual or group authenticators, and in a similar manner, when passwords are used as part of multifactor authenticators. The number of changed characters refers to the number of changes required with respect to the total number of positions in the current password. To mitigate certain brute force attacks against passwords, organizations may also consider salting passwords.
>Cross-Framework Mappings
>Assessment Interview Topics
Questions assessors commonly ask
Process & Governance:
- •What documented policies and procedures address identification and authentication - derived for CUI systems?
- •Who is accountable for implementing and maintaining identification and authentication - derived controls?
- •How frequently are identification and authentication - derived requirements reviewed, and what triggers updates?
- •What process ensures changes to systems maintain compliance with identification and authentication - derived requirements?
- •How are exceptions to identification and authentication - derived requirements documented and approved?
Technical Implementation:
- •What technical controls enforce identification and authentication - derived in your CUI environment?
- •How are identification and authentication - derived controls configured and maintained across all CUI systems?
- •What automated mechanisms support identification and authentication - derived compliance?
- •How do you validate that identification and authentication - derived implementations achieve their intended security outcome?
- •What compensating controls exist if primary identification and authentication - derived controls cannot be fully implemented?
Evidence & Documentation:
- •What documentation proves identification and authentication - derived is implemented and operating effectively?
- •Can you provide configuration evidence showing how identification and authentication - derived is technically enforced?
- •What audit logs or monitoring data demonstrate ongoing identification and authentication - derived compliance?
- •Can you show evidence of a recent review or assessment of identification and authentication - derived controls?
- •What artifacts would you provide to a CMMC assessor to demonstrate identification and authentication - derived compliance?
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