AU-6(9): Correlation with Information from Nontechnical Sources

AU-6(9) requires you to correlate nontechnical signals (for example, HR actions, physical access events, legal notices, or third-party alerts) with technical audit logs to improve situational awareness and investigations. To operationalize it, define approved nontechnical sources, route them into your detection workflow, document correlation rules and escalation paths, and retain evidence that correlations are reviewed and acted on. ¹

Key takeaways:

• Treat “nontechnical sources” as governed inputs to your monitoring program, with owners, access controls, and retention.
• Build repeatable correlation playbooks that connect those inputs to audit records, alerts, and case management.
• Evidence matters: auditors look for documented sources, correlation logic, review cadence, and tickets showing follow-through.

The au-6(9): correlation with information from nontechnical sources requirement is a practical expectation: your security monitoring can’t rely on logs alone. Many high-impact incidents become obvious only after you connect technical telemetry to real-world context, like an employee offboarding, a terminated contractor badge still working, a legal request, a fraud hotline report, or a third party notifying you of compromise. AU-6(9) asks you to make that connection deliberately, not ad hoc. ²

For a CCO, GRC lead, or security/compliance operator, the fast path is to convert “correlate” into a defined operating procedure: (1) enumerate which nontechnical sources are in scope, (2) define how they are ingested or reviewed, (3) specify correlation rules and when they trigger escalation, and (4) prove that someone reviews outcomes and opens cases. You do not need perfect automation to satisfy the requirement, but you do need consistency, governance, and evidence that correlations improve detection and response outcomes.

This page gives requirement-level implementation guidance you can assign to owners, test in an audit, and sustain as part of continuous monitoring.

Regulatory text

Requirement (AU-6(9)): “Correlate information from nontechnical sources with audit record information to enhance organization-wide situational awareness.” ¹

What the operator must do: establish a defined set of nontechnical inputs, connect them to audit log review and analysis, and show that the organization uses the combined view to detect, investigate, and respond more effectively. The outcome is “situational awareness,” but auditors will validate it through process and evidence: documented sources, correlation methods, and operational records (alerts/tickets/reviews) that demonstrate the correlations occur. ²

Plain-English interpretation

AU-6(9) means you must add business-context signals into your audit analysis. Technical logs answer “what happened on systems.” Nontechnical sources help answer “who, why, and whether it makes sense.”

Examples of nontechnical sources that commonly matter:

• HR and identity lifecycle events: hires, terminations, role changes, disciplinary actions, leave of absence, contractor end dates.
• Physical security signals: badge access exceptions, after-hours access, tailgating reports, visitor logs.
• Legal and compliance events: litigation holds, subpoenas, regulatory inquiries, ethics hotline complaints.
• Third-party and external notifications: supplier compromise notices, customer reports, ISAC notices that reference your domains, brand abuse reports.
• Business operations anomalies: payroll exceptions, unusual purchasing, finance fraud alerts.

You are not required to ingest every possible business record. You are required to choose relevant sources, define how they are correlated with audit records, and operate the process consistently. ¹

Who it applies to

AU-6(9) applies to organizations implementing NIST SP 800-53 controls, commonly:

• Federal information systems and programs assessed against NIST SP 800-53. ²
• Contractor systems handling federal data, where NIST controls are flowed down through contracts, ATO requirements, or system security plans. ²

Operationally, it applies anywhere you perform audit analysis, including:

• SOC/SIEM operations and detection engineering
• Incident response and case management
• Insider threat programs (formal or informal)
• IAM governance (JML: joiner/mover/leaver)
• Physical security and facilities (where they exist)
• Compliance investigations (HR, legal, ethics)

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

Step 1: Assign ownership and scope

1. Name a control owner (often Security Operations or GRC with SOC execution) and approve a RACI that includes HR, Legal, Facilities/Physical Security, and third-party management where relevant.
2. Define the “system boundary” (which environments, identities, and log sources are in scope).
3. Define nontechnical sources in scope with short justifications tied to plausible threat scenarios (insider risk, account takeover, fraud, data exfiltration).

Deliverable: AU-6(9) control implementation statement with named owners and in-scope sources. ¹

Step 2: Establish governed nontechnical feeds

For each nontechnical source, document:

• Source system (HRIS, badge system, hotline platform, third-party portal, email alias)
• Data elements you will use (employee ID, manager, termination date/time, badge ID, vendor contact)
• Access controls (least privilege; who can view sensitive HR/legal data)
• Refresh method (API, scheduled report, manual review queue)
• Retention and disposal aligned to your audit log retention and investigation needs

A common operational pattern: do not pipe raw HR/legal content into the SIEM. Instead, create a sanitized event feed (for example, “termination effective timestamp,” “badge disabled timestamp,” “case opened flag”) that can be safely correlated to logs.

Deliverable: “Nontechnical Sources Register” with governance fields above.

Step 3: Define correlation use cases and rules

Create a small set of high-value correlation rules. Each rule should specify:

• Nontechnical trigger
• Technical audit records to correlate
• Time window and identity mapping logic
• Expected outcome (alert, triage task, investigation case)
• Escalation path (SOC to HR, SOC to Legal, SOC to Insider Risk)

Example rules (write these as playbooks, not ideas):

• Termination/offboarding correlation: If HR termination is effective, confirm IAM disablement and monitor for post-termination authentication attempts and privileged actions.
• Role change correlation: If a user moves to a finance/admin role, increase scrutiny of privileged group changes and high-risk transactions in audit logs.
• Physical/remote mismatch correlation: If badge records show onsite presence while VPN shows impossible travel, open an investigation.
• Third-party compromise notice correlation: If a supplier reports compromise, correlate the notice date/time with your authentication logs for their accounts, tokens, API keys, and remote access paths.

Deliverable: “AU-6(9) Correlation Playbooks” with rule logic, data mapping, and escalation.

Step 4: Implement workflows (manual is acceptable, but must be repeatable)

Pick one of these operating models based on maturity:

Model	How it works	What auditors will scrutinize
Manual correlation	Nontechnical queue reviewed; analyst pivots into logs and documents results	Consistency, review records, decisioning notes
Semi-automated	Nontechnical feed creates cases; analyst validates with log pivots	Case quality, mapping accuracy, closure codes
Automated	SIEM/SOAR correlates events and triggers alerts	Alert tuning, false positives, rule governance

Regardless of model, you need a single place to track outcomes: ticketing or case management with correlation results and dispositions.

Deliverable: SOP for correlation review + sample cases showing the workflow.

Step 5: Validate and tune

Run tabletop tests that start from nontechnical events (for example, “contractor termination” or “badge exception”) and confirm:

• Identity mapping works (employee ID ↔ username ↔ email ↔ badge ID)
• Audit logs are available for the period needed
• Escalation contacts respond and actions are recorded
• False positives are documented and rules are tuned, not ignored

Deliverable: Test records, tuning log, and approved changes to playbooks.

Step 6: Operationalize as BAU

Put AU-6(9) into a recurring operating rhythm:

• A defined review queue and documented analyst coverage
• Rule change control (who can modify correlation rules and why)
• Metrics that are qualitative if you cannot defend numbers (for example, “types of cases generated” and “top correlation drivers”)

Deliverable: recurring review evidence and change tickets for rule updates. ²

Required evidence and artifacts to retain

Keep evidence that proves both design and operation:

Design artifacts

• AU-6(9) control narrative in the SSP/control catalog and owner assignment ²
• Nontechnical Sources Register (systems, fields, access, retention)
• Correlation playbooks/rules (use cases, mapping, escalation)
• Data handling approvals for HR/Legal/Physical Security inputs (where applicable)

Operational artifacts

• Samples of correlation reviews (analyst notes, pivots performed, conclusion)
• Case/ticket records created from correlation triggers, with closure reasons
• Evidence of escalation (emails, case comments, approvals) where sensitive actions were taken
• Rule tuning/change management records (who changed what, when, why)

If you use Daydream to manage your control library, map AU-6(9) to a control owner, attach the SOP and playbooks, and schedule recurring evidence collection so you can produce auditor-ready artifacts without rebuilding the story each assessment cycle. ¹

Common exam/audit questions and hangups

Auditors and assessors tend to probe these points:

• “What are your nontechnical sources?” They will expect a list and rationale, not “we look at HR stuff sometimes.”
• “Show me correlation in practice.” Be ready with recent tickets/cases where a nontechnical input drove log review and a disposition.
• “Who can see HR/legal data?” Access controls and data minimization matter because these sources can be sensitive.
• “How do you ensure consistency?” They will look for an SOP, coverage model, and evidence of recurring operation.
• “How do you manage identity matching?” Many programs fail on brittle mappings across HRIS, IAM, and badge systems.

Frequent implementation mistakes and how to avoid them

1. Mistake: Treating AU-6(9) as “SIEM has lots of logs.”
   Fix: Document the nontechnical sources and show at least a small set of defined correlation playbooks. ¹

2. Mistake: Pulling sensitive HR/legal narrative into broad SOC tooling.
   Fix: Create sanitized event indicators and tightly control who can access underlying case details.

3. Mistake: No clear escalation path.
   Fix: For each playbook, define who gets called (HRBP, Legal, Insider Risk) and what evidence must be captured before outreach.

4. Mistake: One-time build with no operational trail.
   Fix: Treat correlation reviews as a recurring operational activity with tickets, notes, and change control.

5. Mistake: Identity mapping not documented.
   Fix: Maintain a mapping standard (unique identifiers, authoritative sources) and update it when systems change.

Risk implications (why operators get burned)

AU-6(9) failures typically show up as missed detection opportunities and weak investigations:

• Insider activity looks “normal” in logs until you add HR context (termination, role dispute, policy violation).
• Account misuse looks like “a user logging in” until you add physical access anomalies or third-party compromise notices.
• Response coordination breaks when SOC sees logs but HR/Legal holds the deciding context and there is no defined process to connect them.

In assessments, the most common risk is not “you didn’t correlate.” It’s “you can’t prove you correlated, and outcomes changed decisions.” That becomes a control effectiveness problem. ²

Practical 30/60/90-day execution plan

First 30 days (foundation)

• Assign AU-6(9) owner and RACI across SOC, HR, Legal, Physical Security, and third-party management.
• Build the Nontechnical Sources Register and pick a small set of high-signal sources you can govern.
• Draft correlation playbooks for those sources and define escalation paths.
• Stand up a case/ticket workflow for correlation-triggered reviews.

By 60 days (operational)

• Implement at least one repeatable ingestion method per source (manual queue, scheduled report, or event feed).
• Train analysts on playbooks and documentation expectations (what to record, what evidence to attach).
• Run scenario tests from nontechnical triggers through to case closure and tuning updates.

By 90 days (audit-ready and sustainable)

• Expand to additional sources or refine rules based on false positives and investigator feedback.
• Formalize change control for correlation rules and add periodic quality checks.
• Package evidence: SOP, register, playbooks, and a set of recent tickets showing correlation decisions end-to-end.
• If you manage controls in Daydream, attach the artifacts to AU-6(9), set collection reminders, and keep an evidence index so audit requests become a retrieval exercise, not a scramble. ¹

Frequently Asked Questions

What counts as a “nontechnical source” for AU-6(9)?

Any input that is not generated as a system audit log but provides operational context, such as HR lifecycle events, physical access records, legal notices, hotline reports, or third-party compromise notifications. Define your in-scope sources and document how you correlate them with audit records. ¹

Do we need SIEM automation to meet AU-6(9)?

No. A manual or semi-automated workflow can satisfy the requirement if it is repeatable, governed, and produces evidence of correlation decisions and outcomes. Automation helps with scale, but auditors will still expect documented playbooks and case records. ²

How do we handle HR and Legal sensitivity while correlating?

Minimize data shared with broad analyst groups by using sanitized indicators (for example, “termination effective”) and restricting access to underlying HR/Legal case details. Document access controls and approved data elements in your Nontechnical Sources Register.

What evidence should we show an assessor to prove correlation happened?

Provide correlation playbooks, the nontechnical source list, and representative tickets or cases where a nontechnical event triggered audit log review and an investigation disposition. Include timestamps, identity mapping notes, and escalation records where applicable.

How many correlation rules are enough?

Start with a small set that maps to your highest-risk scenarios and can be sustained operationally, then expand based on investigation learnings and recurring gaps. Assessors will prefer a few well-operated playbooks over many unused rules.

Where does third-party risk fit into AU-6(9)?

Third-party notifications (breach notices, compromise indicators, service desk escalations) are nontechnical sources you can correlate with authentication, remote access, and privileged activity logs tied to third-party accounts. Document how you intake those notices and how they trigger log review and escalation.

Footnotes

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

2. NIST SP 800-53 Rev. 5