SC-36(1): Polling Techniques

SC-36(1): Polling Techniques requires you to actively poll specified processing and storage components to detect faults, errors, or signs of compromise, and to be able to prove the polling runs, alerts, and response actions. Operationalize it by defining the in-scope components, implementing automated polling with thresholds, and retaining run history, alert triage records, and change control. ¹

Key takeaways:

• Scope first: explicitly list the processing and storage components you poll, and tie them to system boundaries and data flows. ¹
• “Polling” must be repeatable and evidenced: schedules, thresholds, logs, and response tickets are what auditors ask for. ¹
• Treat polling as a detection control with operations muscle: alert ownership, tuning, and exception handling matter as much as the tool. ²

SC-36(1): polling techniques requirement is a practical control enhancement: you do not wait for a user to report a problem, and you do not rely only on passive logging. You proactively query (poll) defined components to spot conditions that indicate a fault, an error, or a compromise. The control is easy to “say yes” to and surprisingly easy to fail in an assessment because teams cannot show: (1) what was polled, (2) how often, (3) what “bad” looks like, and (4) what happened when “bad” occurred. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to convert this into an operational requirement with a tight control statement, named ownership across security and infrastructure, and a minimal evidence set that proves the polling is continuous and acted on. You do not need exotic tooling; you need disciplined scoping, reliable telemetry, and a workflow that turns alerts into tracked outcomes.

This page gives requirement-level implementation guidance you can hand to control owners and then assess against, with the artifacts you should retain for an ATO package, internal audit, or third-party assessment aligned to NIST SP 800-53 Rev. 5. ²

Regulatory text

Excerpt (control enhancement): “Employ polling techniques to identify potential faults, errors, or compromises to the following processing and storage components: {{ insert: param, sc-36.01_odp.01 }} ; and” ¹

What the operator must do with this text

• Resolve the open parameter. The control text contains an organization-defined parameter (ODP). You must explicitly specify which processing and storage components are in scope for polling, inside your system security boundary. ¹
• Implement polling (not just logging). Polling means an active check: a scheduled query, probe, or request that confirms a component’s state, integrity signals, or error conditions. ¹
• Use polling to detect three classes of conditions: faults (availability/reliability failures), errors (misconfigurations, data corruption signals), and compromises (indicators that a component may be under attacker control or tampered with). ¹
• Be able to show it works. In practice, that means retaining a record of polling configuration, results, alerting, and response actions, not just a statement that monitoring exists. ²

Plain-English interpretation

You must run recurring, automated checks against key compute and storage components to detect abnormal conditions early, then route those findings to people who investigate and fix them. “Polling” is the mechanism; “identify potential faults, errors, or compromises” is the outcome you must be able to demonstrate. ¹

If you can only prove that logs exist, but you cannot show regular checks with defined thresholds and follow-through, you should treat SC-36(1) as not fully implemented.

Who it applies to (entity and operational context)

Entities

• Federal information systems and contractor systems handling federal data where NIST SP 800-53 Rev. 5 is the required control baseline or assessment framework. ²

Operational contexts where auditors expect to see SC-36(1)

• Systems with production workloads where compute/storage failures create confidentiality, integrity, or availability risk.
• Environments with virtualized infrastructure, containers, managed databases, or shared storage, where compromise can present as subtle integrity or configuration drift signals.
• Programs undergoing an ATO, continuous monitoring, or independent assessment that expects you to show control operation evidence, not only design intent. ²

What you actually need to do (step-by-step)

1) Define the in-scope “processing and storage components” (the ODP)

Create a scoping table and get it approved by the system owner and security owner.

Minimum scoping fields (table)

• Component type (compute node, hypervisor, OS instance, container host, database, object store, SAN/NAS, backup repository)
• Environment (prod/non-prod)
• Ownership (team, on-call)
• Telemetry source (agent, API, SNMP, cloud-native metrics)
• Polling method (health endpoint, metrics query, checksum probe, configuration query)
• Key indicators (fault/error/compromise signals)

This step “closes” the parameter in the regulatory text and prevents the common audit failure where scope is implied but not stated. ¹

2) Choose polling techniques that map to the three detection outcomes

Build a small catalog of polling checks. Keep it concrete and testable.

Examples of polling checks (adapt to your stack)

• Fault detection: heartbeat/health checks, disk capacity thresholds, replication lag checks, backup job status checks.
• Error detection: configuration drift checks against hardened baselines, failed integrity checks, storage corruption indicators, time sync deviation checks.
• Compromise detection: unexpected privileged process checks, suspicious kernel module presence, unexpected changes to boot settings, anomalous admin access patterns surfaced via polled management-plane APIs.

Polling can be done via endpoint checks, agent-based queries, management-plane APIs, or platform monitoring solutions. The control does not mandate a product; it mandates the capability and evidence. ¹

3) Set polling frequency, thresholds, and escalation rules

Document for each check:

• Polling cadence (how often the check runs)
• Threshold (what constitutes a warning/critical)
• Routing (who gets paged/ticketed)
• Time-to-triage expectation (your internal SLO)
• Suppressions/exceptions (approved maintenance windows)

Auditors focus on whether your polling is predictable, owned, and actionable. A vague “monitored by SOC” statement will not carry the control. ²

4) Implement alert-to-action workflow (this is where controls pass or fail)

For each alert class, define the expected response path:

• Alert generates an incident ticket (or a problem ticket for chronic issues).
• Triage steps are standardized (what logs to check, what system queries to run, who to escalate to).
• Closure criteria are defined (what evidence proves resolution).
• Post-incident tuning occurs (reduce noise, improve thresholds).

If you have Daydream in your compliance operating model, this is a good place to map SC-36(1) to a named control owner, link the runbooks, and schedule recurring evidence collection so assessments do not become a screenshot scramble. ¹

5) Test polling coverage and failure modes

Run a controlled test to prove the control works:

• Simulate a storage capacity exhaustion condition in non-production.
• Stop a service to confirm heartbeat failures page correctly.
• Introduce a known configuration drift and confirm it is detected and tracked.

Keep the test results and remediation records as evidence of operational effectiveness. ²

6) Establish ongoing governance

• Quarterly review of scope (new components, decommissioned assets).
• Monthly review of top noisy alerts and tuning actions.
• Change control requirement: new platform services must register their polling checks before production go-live.

Required evidence and artifacts to retain

Auditors typically want artifacts that show both design and operation.

Design evidence

• SC-36(1) control statement and implementation procedure (who does what, with what tools). ¹
• In-scope component inventory that resolves the ODP (processing and storage components list). ¹
• Polling check catalog: cadence, thresholds, owners, routing.
• Runbooks for triage and escalation.

Operating evidence

• Polling configuration exports (monitoring-as-code, tool configuration snapshots).
• Sample polling results (time-stamped), alert history, and dashboards.
• Tickets/incidents linked to polling alerts, with investigation notes and closure.
• Exception records for disabled/suppressed checks with approvals and expiry dates.

Tip: store evidence in a single control binder (GRC system or structured repository) and standardize filenames by system and control to reduce assessment churn.

Common exam/audit questions and hangups

1. “Which components are covered by SC-36(1)?” If you cannot produce the explicit list, you have not resolved the parameter in the control text. ¹
2. “Show me that polling runs automatically and continuously.” Expect to show tool configs and historical runs, not a point-in-time screenshot.
3. “How do you distinguish faults vs errors vs compromises?” You need mapping in your check catalog (even if one check supports multiple outcomes). ¹
4. “Who responds at 2 a.m.?” Ownership and routing are control requirements in practice. अस्प This is where “shared responsibility” answers fail.

Frequent implementation mistakes and how to avoid them

• Mistake: Treating SIEM log ingestion as “polling.” Fix: implement active checks (queries/probes) and retain their run history. ¹
• Mistake: No explicit ODP scope. Fix: create a signed-off component scope table and update it under change control. ¹
• Mistake: Polling exists but nobody owns the alerts. Fix: define alert routes to on-call roles and require tickets for critical alerts.
• Mistake: Excessive alert noise leads to ignored polling. Fix: set tuning cadence, add deduplication rules, and document suppressions with expiry.
• Mistake: Third-party managed services ignored. Fix: if a third party runs storage/compute, require polling evidence via contract terms or shared dashboards, and document how you review it.

Enforcement context and risk implications

No public enforcement cases were provided for this requirement in the source catalog, so this page does not list enforcement examples. The practical risk is straightforward: if you do not poll critical compute and storage components, you detect outages, corruption, and compromise later, and you will struggle to demonstrate continuous monitoring expectations during federal assessments aligned to NIST SP 800-53 Rev. 5. ²

Practical 30/60/90-day execution plan

First 30 days (Immediate: scope + ownership)

• Name the SC-36(1) control owner and backups; document RACI across SecOps and Infrastructure. ¹
• Resolve the ODP: publish the in-scope processing and storage component list.
• Inventory current polling capabilities (cloud monitoring, NMS, EDR health checks, backup monitoring).
• Draft the polling check catalog with at least one check per component class.

Days 31–60 (Near-term: implement + evidence)

• Implement missing checks and standardize alert routing (paging/ticketing).
• Set thresholds and maintenance window rules; document suppressions process.
• Create runbooks for top alert types and train on-call responders.
• Start evidence capture: configuration snapshots, alert history exports, ticket linkage.

Days 61–90 (Ongoing readiness: test + tune + govern)

• Execute a test plan for representative failure and drift scenarios; retain results.
• Tune noisy checks and document tuning actions as part of continuous monitoring.
• Add SC-36(1) to change management gates for new infrastructure/services.
• In Daydream (or your GRC system), schedule recurring evidence pulls and map artifacts to the control so the next audit is a retrieval exercise, not a rebuild. ²

Frequently Asked Questions

What counts as “polling” for SC-36(1)?

Polling is an active, recurring check that queries a component’s state (health, integrity signals, configuration) rather than passively waiting for logs. Keep evidence of the polling schedule, results, and alerts. ¹

Do cloud-native metrics and health checks satisfy the sc-36(1): polling techniques requirement?

They can, if you can show they actively check the defined processing and storage components and that alerts generate tracked response actions. You still need to explicitly document which components are in scope. ¹

How specific does the “processing and storage components” list need to be?

Specific enough that an assessor can tie checks to real assets or services inside your system boundary (for example, database service, object storage, backup repository). Treat it as an organization-defined scope parameter you must complete and maintain. ¹

Can a third party operate the polling for us?

Yes, but you remain accountable for the control. Require access to polling outputs (dashboards, alert history, reports) and document how you review and respond to their findings. ²

What evidence is strongest for auditors?

Tool configuration exports plus time-stamped alert history, paired with tickets showing investigation and closure. A policy alone rarely demonstrates operation. ²

How do we handle planned maintenance that triggers polling alerts?

Use a documented suppression or maintenance-window process with approvals and an expiry, then retain the record. Auditors accept maintenance, but they will challenge “disabled forever.” ²

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5