SI-6: Security and Privacy Function Verification

SI-6 requires you to verify that key security and privacy functions (for example, logging, alerting, malware protection, access controls, and privacy monitoring features) operate correctly, and to keep evidence that you perform this verification on a repeatable basis. Operationalize it by defining an inventory of in-scope functions, testing methods, ownership, frequency, pass/fail criteria, and retention of results. ¹

Key takeaways:

• Treat SI-6 as a testable control: define “what functions,” “how verified,” and “what evidence proves it.”
• Prioritize functions that detect, prevent, or record security/privacy events; verify both configuration and end-to-end behavior.
• Make verification auditable: recurring tickets, test scripts, results, exception handling, and corrective action tracking.

The si-6: security and privacy function verification requirement is an operations requirement disguised as a one-line control statement. Assessors won’t accept “we have tool X” as compliance; they will ask how you know the tool is working, how often you check, what “working” means, and what you do when it fails. SI-6, in plain terms, is about proving that your protective and detective capabilities perform as intended in your environment, not in a vendor datasheet.

This is most painful in modern stacks because security and privacy functions are distributed: endpoint agents, cloud logs, SIEM correlation, DLP rules, IAM policies, encryption, backups, privacy preference enforcement, and ticket routing. Break one link in the chain and the function “exists” but doesn’t operate. SI-6 closes that gap by forcing routine verification with retained evidence.

Below is requirement-level guidance written for a Compliance Officer, CCO, or GRC lead: who should own it, what to implement, what artifacts to retain, how auditors probe it, and a practical execution plan you can run without turning SI-6 into a multi-quarter engineering project. ²

Regulatory text

Control requirement (excerpt): “Verify the correct operation of {{ insert: param, si-6_prm_1 }};” ¹

What the operator must do

Because the excerpt parameterizes “what” must be verified, you have to define the set of security and privacy functions that matter in your system boundary, then verify correct operation using repeatable checks and retain evidence. In practice, “correct operation” should include:

• The function is enabled and configured as intended.
• The function produces expected outputs (alerts, logs, blocks, encrypts, routes, retains, deletes) under test conditions.
• Failures are detected, triaged, and corrected with tracked remediation.

Your SI-6 deliverable is not a narrative. It’s a verification program: inventory → test approach → results → remediation. ²

Plain-English interpretation of the requirement

SI-6 asks one question: How do you know your security and privacy controls are actually working today? Not “installed,” not “licensed,” not “configured once last year.”

Examples of functions commonly treated as in-scope for SI-6 verification in real assessments:

• Centralized logging pipelines (cloud audit logs, server logs, application logs)
• Alerting and paging routes (SIEM/SOAR rules, on-call integrations)
• Endpoint security agents (EDR status, signature updates, real-time protection)
• Network protections (firewall rules, WAF policies, IDS/IPS detections)
• Identity protections (MFA enforcement, conditional access, privileged access workflows)
• Privacy-related enforcement (retention/deletion jobs, consent preference enforcement, data loss controls)

You decide scope based on system risk and boundary, but you must be able to defend the decision and show that verification happens in operations, not just during audits. ²

Who it applies to (entity and operational context)

SI-6 is most directly applicable when you align to NIST SP 800-53 for:

• Federal information systems and components within an authorization boundary. ²
• Contractor systems handling federal data, including systems supporting federal missions or processing regulated federal information. ¹

Operationally, SI-6 applies to environments where:

• Controls are implemented through tools and configurations that drift over time.
• Detection and response depends on multi-system integrations.
• You rely on third parties for critical security or privacy functions (managed detection, logging, IDP, email security). The requirement still lands on you to verify operation, even if a third party runs the toolset.

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

Step 1: Define “security and privacy functions” in scope

Create an SI-6 scope table that lists each function, where it is implemented, and why it matters. Keep it short and risk-driven.

Minimum fields:

• Function name (e.g., “Cloud audit logging to SIEM”)
• System(s)/boundary coverage
• Primary owner (Security Ops, IT, Privacy, Platform)
• Tool(s) involved
• Verification method (config review, functional test, synthetic event, sampling)
• Evidence artifact(s) produced

Step 2: Set “correct operation” criteria (pass/fail)

For each function, define objective criteria:

• Configuration checks (settings exist and are enforced)
• Behavior checks (events/transactions produce expected outputs)
• Completeness checks (coverage exists for in-scope assets/accounts)
• Timeliness checks (outputs arrive within your operational tolerance; document your tolerance)

Write these criteria so an auditor can re-perform or observe them.

Step 3: Choose verification techniques that match the function

Use a mix of:

• Direct functional testing (generate a benign test event and confirm detection/alert/log)
• Configuration validation (export policy configuration, compare to baseline)
• Coverage validation (agent check-in reports, log source inventory vs asset inventory)
• Failure-mode tests (pause an agent, revoke a permission, break an integration in a test environment and confirm you detect the failure)

Avoid relying only on dashboards that say “healthy” without demonstrating end-to-end effect.

Step 4: Operationalize cadence and ownership

Assign control ownership and embed tasks into normal workflows:

• Create a recurring verification ticket series ¹.
• Require recorded results, screenshots/exports, and sign-off.
• Define escalation paths and remediation SLAs as internal expectations (no need to publish numbers; make them actionable).

Daydream tip (earned mention): Daydream can help you map SI-6 to a named owner, a repeatable procedure, and a recurring evidence set so the control doesn’t degrade into “tribal knowledge” when staff changes. ¹

Step 5: Track exceptions and remediation to closure

Verification without follow-up fails in exams. Build a lightweight loop:

• Record failed verifications as issues.
• Tie issues to a corrective action ticket.
• Retest and attach evidence of restored operation.
• Document risk acceptance when you can’t remediate promptly.

Step 6: Make it assessable (package evidence)

Create an SI-6 “audit-ready packet”:

• Scope/inventory list
• Verification procedures (runbooks)
• Last verification results per function
• Exceptions log and remediation tickets
• Change records for major control changes

Required evidence and artifacts to retain

Retain artifacts that prove both design (what you intended) and operation (what you did and what happened):

Core artifacts

• SI-6 scope inventory with owners and methods
• Runbooks/test scripts per function
• Recurring task records (ticket exports, change records)
• Test outputs (screenshots, logs, SIEM search exports, alert IDs)
• Configuration exports or policy snapshots (where feasible)
• Exception register and remediation evidence

Evidence quality checks (what auditors look for)

• Timestamps and immutable provenance (who ran it, when)
• Clear linkage between test action and observed output
• Repeatability (another operator could follow the steps)

Common exam/audit questions and hangups

Expect questions like:

1. “What security and privacy functions are in scope for SI-6, and why?” Hangup: vague scope such as “all security tools.”
2. “Show me the last time you verified logging/alerting works end-to-end.” Hangup: you can show configuration, but not a test event flowing through.
3. “How do you detect when the function stops working?” Hangup: no monitoring for ingestion failures, agent drop-off, or integration errors.
4. “Who owns verification and what happens on failure?” Hangup: shared responsibility with no accountable owner.
5. “How do you verify privacy-related functions?” Hangup: privacy is omitted or treated as a policy-only topic.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Treating SI-6 as “tool installed”	Presence ≠ operation	Require a functional test or observed output per function
No defined pass/fail criteria	Auditors can’t judge “correct”	Write measurable checks (config + behavior)
Verifying only once	Drift breaks controls	Put verifications on a recurring schedule and retain each run
No coverage reconciliation	Blind spots remain	Compare asset inventory to log sources/agent coverage
Evidence is screenshots with no context	Hard to re-perform	Add runbook steps, timestamps, and test identifiers

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite enforcement actions.

Risk-wise, SI-6 failures tend to show up as:

• Undetected incidents because telemetry never arrived.
• “We thought MFA was enforced” situations caused by policy exceptions.
• Privacy control failures where deletion/retention jobs silently fail.

From a governance perspective, SI-6 is a control-health program. If you cannot prove operation, you should assume degraded detection and higher incident impact. ²

Practical 30/60/90-day execution plan

Days 0–30: Establish scope, ownership, and minimum viable verification

• Name an SI-6 control owner and backups.
• Build the first SI-6 scope list focused on high-risk functions (logging, alerting, endpoint, IAM enforcement, privacy retention/deletion if applicable).
• Write runbooks for each scoped function with pass/fail criteria.
• Run a baseline verification and store evidence in a centralized repository.

Days 31–60: Make it repeatable and measurable

• Convert runbooks into recurring tasks (ticketing system or GRC workflow).
• Add coverage reconciliation: log source inventory vs asset inventory; agent deployment vs endpoints.
• Define failure handling: create issue templates, escalation, and retest requirements.
• Start a simple exception register with risk acceptance workflow for unresolved gaps.

Days 61–90: Expand coverage and harden evidence quality

• Add remaining functions and third-party-dependent functions (MDR alert routing, cloud security tooling outputs).
• Improve evidence: export queries, attach log IDs, preserve configuration snapshots.
• Dry-run an assessor walkthrough: pick one function and demonstrate end-to-end verification plus remediation history.
• If you use Daydream, map SI-6 to recurring evidence artifacts and automate collection reminders so the control stays alive between audits. ¹

Frequently Asked Questions

What counts as a “security and privacy function” for SI-6?

Any capability that prevents, detects, records, or enforces security or privacy requirements in your system boundary can qualify. Define the list explicitly, then defend it based on risk and system scope. ²

Do we have to test every control, or only tools like SIEM and EDR?

SI-6 is scoped to “functions” you identify, so focus first on controls where failure would materially reduce detection, prevention, or privacy enforcement. Document your rationale and expand over time. ¹

What evidence is “good enough” for an auditor?

Evidence should show the test action and the resulting expected output, with a date/time and operator attribution. A runbook plus a ticket record plus a SIEM search export is typically stronger than screenshots alone.

How do we handle third-party managed security services under SI-6?

You can delegate operation, but you cannot delegate accountability for verification. Require contractual reporting, obtain test results or service attestations, and perform periodic independent spot checks in your environment.

How do we verify privacy functions if we don’t have a dedicated privacy tool?

Verify the actual mechanisms you rely on: retention configuration, deletion workflows, access request handling, and data export controls. Treat these as testable functions with pass/fail outcomes, not policy statements.

What’s the fastest way to stand up SI-6 without creating a huge testing program?

Start with a small, risk-based function list and standardize the verification format: runbook, recurring ticket, and evidence attachment. Expand scope only after you can consistently execute and retain proof.

Footnotes

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

2. NIST SP 800-53 Rev. 5