3.3 — Audit & Accountability

Audit & Accountability (AU) Policy

Establishes requirements for creating, protecting, and reviewing audit records to enable monitoring, analysis, investigation, and reporting — covering 9 controls per NIST SP 800-171 Rev 2.

Family: 3.3 — Audit & AccountabilityControls: 9Owner: Kit E. Floyd, Jr.Last Review: April 3, 2026
SELF-ASSESSMENT

Control statuses below reflect an internal self-assessment prepared with AI assistance. Statuses marked "Implemented" may be organizational claims without verifiable evidence. See POA&M for known gaps.

Policy Statement

OCSI shall create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity. All auditable events shall be logged with sufficient detail to establish accountability.

Control Implementation
ControlRequirementImplementationStatus
3.3.1Create and retain system audit logs and recordsPARTIAL. Command Center logs events to localStorage key ocsi_audit_log: login attempts, logouts, lockouts, CRUD operations, exports, session timeouts. However: logs are client-side only (max 500 entries), can be deleted by the user, and have no server-side backup. Retention is browser-dependent, not guaranteed. Partial
3.3.2Ensure that the actions of individual system users can be uniquely tracedPARTIAL. Audit entries include authenticated user email and timestamps. However, only one admin account exists — all users share the same credential. Individual user attribution is impossible without individual accounts. Partial
3.3.3Review and update logged eventsNOT IMPLEMENTED. No scheduled audit log review process exists. No evidence of any log review ever being conducted. No external MSSP has been engaged for log analysis. Not Implemented
3.3.4Alert in the event of an audit logging process failurelocalStorage availability is checked at session start. If storage is unavailable, a warning banner is displayed to the admin user. Audit write operations include error handling with user notification. Implemented
3.3.5Correlate audit record review, analysis, and reporting processesPARTIAL. Compliance panel provides audit log viewer with filtering and CSV export. However, no correlation or analysis process exists. No external MSSP receives logs. No regular reporting. Partial
3.3.6Provide audit record reduction and report generationAudit log viewer supports filtering by event type, date range. Export function generates structured CSV for analysis. Compliance panel provides summary statistics. Implemented
3.3.7Provide a system capability that compares and synchronizes internal system clocksAll timestamps generated by new Date().toISOString() using the system clock, which syncs via OS-level NTP. Consistent timestamp format (ISO 8601) across all log entries. Implemented
3.3.8Protect audit information and audit logging tools from unauthorized access, modification, and deletionNOT IMPLEMENTED. Audit logs in localStorage can be deleted by the current user (via browser DevTools, clear storage, or the app’s own clear function). No server-side backup. No tamper protection. Any user with browser access can modify or delete all audit records. Not Implemented
3.3.9Limit management of audit logging functionality to a subset of privileged usersNOT IMPLEMENTED. Only one admin account exists (no privilege separation). Audit log clearing is gated behind a confirmation dialog, but any authenticated user is an admin. Browser-level access can bypass all restrictions. Not Implemented
Auditable Events
  • Login attempts (successful and failed) with email and timestamp
  • Account lockout triggers and lockout expiration
  • Session timeouts (inactivity and absolute)
  • Logout events
  • Create, update, delete operations on candidates, jobs, clients, and placements
  • Data export operations (CSV download)
  • System configuration changes
Critical Gap: Audit logs stored in client-side localStorage provide zero tamper resistance. Logs can be cleared by the user, are capped at 500 entries, and have no server-side backup. A server-side logging solution is required for CMMC compliance.