Personnel Screening is the first requirement in the Personnel Security (03.09) family, and it addresses the trustworthiness of the people who are granted access to the system. It has two (2) parts: screen individuals before authorizing their access, and rescreen individuals when defined conditions occur. Personnel Screening (03.09.01) recognizes that access control is only as strong as the assurance that the person behind an account can be trusted with it. Per the NIST discussion, screening assesses an individual's conduct, integrity, judgment, loyalty, reliability, and stability before granting access or when elevating access, and screening and rescreening reflect applicable federal laws, directives, and the criteria for the level of access required.
A common difficulty with this requirement is screening at hire but never revisiting it. R3 adds rescreening as an explicit obligation tied to an Organization-Defined Parameter (ODP), so a background check performed once at onboarding is no longer sufficient on its own. For Department of Defense (DoD) contractors, the rescreening conditions are specified.
Where things stand for companies facing the transition from NIST 800-171 R2 to R3:
The following is reproduced verbatim from NIST 800-171 R3, requirement 03.09.01 Personnel Screening. Only the formatting has been adjusted for readability. This requirement has two (2) lettered parts:
The source control is PS-03 from NIST 800-53. The bracketed assignment in part b is the Organization-Defined Parameter (ODP): the conditions requiring rescreening. Per the NIST discussion, screening assesses an individual's trustworthiness before authorizing access or when elevating access, reflecting the criteria established for the level of access required for the assigned position. You can read the requirement directly at NIST 800-171 R3, 03.09.01 (p. 48).
One (1) value sits inside this requirement. Depending on your contract, your organization may be permitted to define it. Organizations in the DIB subject to CMMC are not, because the DoD has defined it as policy.
The value below comes from Attachment A of the DoD Chief Information Officer (CIO) memorandum dated 10 April 2025 (signed David W. McKeown). The memo identifies each parameter by requirement sub-part, while NIST 800-171A R3 identifies the same parameter by ODP number. Both identifiers appear below so you can match your System Security Plan (SSP) language to either document.
The memo states that its values "will be updated as necessary," so confirm against the current version before writing them into policy.
NIST 800-171A R3 breaks 03.09.01 into three (3) assessment objectives: one (1) Organization-Defined Parameter (ODP) and two (2) determination statements. These AOs are:
The determination statements are the initial screening and the rescreening. If you are a DoD contractor, the ODP is specified. Per the DoD-specified ODP value in ComplianceForge's NIST 800-171 R3 Transition Guide, the rescreening conditions (ODP[01]) are an organizational policy requiring rescreening when there is a significant incident, or a change in status, related to an individual. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.09.01 (p. 62).
Examine: personnel security policy and procedures; procedures for personnel screening and rescreening; records of screened personnel; system security plan.
Interview: personnel with personnel security responsibilities; personnel with information security responsibilities.
Test: processes for personnel screening and rescreening.
03.09.01 maps from NIST 800-171 R2 requirement 3.9.1 (screen individuals prior to authorizing access to organizational systems containing Controlled Unclassified Information (CUI)):
Mapped against the three (3) AOs, one (1) is direct (minimal effort) and two (2) are net new (significant effort), with none indirect and none with no mapping. Initial screening carries forward unchanged, but rescreening and the conditions that trigger it are new work. Define the rescreening conditions, and for DoD work adopt the specified conditions rather than treating a hire-time check as sufficient.
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.09.01 through the following SCF controls:
The crosswalks from NIST 800-171 R3 and NIST 800-171A R3 to the SCF are available at no cost through the SCF Set Theory Relationship Mapping (STRM): https://securecontrolsframework.com/start-here/set-theory-relationship-mapping-strm. The STRM also carries the relationship type for each mapping (Equal, Subset Of, Intersects With), which tells you whether an SCF control fully satisfies the requirement or only part of it. Mapping above taken from SCF 2026.3.
The following are issues teams may encounter rather than certainties. They are about rescreening, each of which needs documented evidence of due diligence and due care such as policies, standards, procedures, and configuration screenshots:
Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.09.01 are sourced from the SCF Evidence Request List (ERL), available at https://securecontrolsframework.com/free-content/scf-download. These ERL artifacts are mapped to NIST 800-171 R3 03.09.01 through SCF controls. They establish a starting point for discussions on what an organization needs to have for evidence of due diligence and due care to withstand external scrutiny by an assessor or regulator.
Alongside these, keep the System Security Plan (SSP) narrative for 03.09.01 recording the ODP values you adopted.
With one AO mapping directly and two net new, 03.09.01 is a moderate lift centered on rescreening. A realistic sequence:
What value does the DoD require for the organization-defined parameter in NIST 800-171 R3 03.09.01? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.09.01.b: an organizational policy requiring rescreening when there is a significant incident, or change in status, related to an individual.
How many assessment objectives does NIST 800-171 R3 03.09.01 have? NIST 800-171A R3 breaks 03.09.01 into three (3) assessment objectives: one (1) Organization-Defined Parameters (ODPs) and two (2) determination statements. An assessor works through each one separately, so each needs its own evidence.
Which NIST 800-53 R5 control does NIST 800-171 R3 03.09.01 come from? PS-03.
Where does NIST 800-171 R3 03.09.01 sit in the NIST 800-171 R3 Kill Chain? Phase 6b, Identify Compliance Stakeholders. The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.09.01 Personnel Screening screens individuals before granting access and rescreens them under defined conditions. It maps from R2 3.9.1 with initial screening transitioning directly, while rescreening and its conditions are new. The recurring problem is screening at hire and never again. Screen before access, define the rescreening conditions (for DoD, a significant incident or change in status), and rescreen accordingly.
Authoritative sources:
Authoritative sources:
This guide reproduces U.S. Government text from NIST 800-171 R3 and NIST 800-171A R3 and references the DoD ODP memorandum of 10 April 2025. It is educational, not legal or assessment advice. Last reviewed: 2026-09-22.
