IR-9(2): Training

IR-9(2): Training requires you to provide role-appropriate training on how to recognize, report, contain, and remediate information spillage (data placed in an unauthorized system, location, or audience) and to prove that training occurs and stays current. Operationalize it by defining “spillage” for your environment, training the right roles, and retaining completion and exercise evidence. ¹

Key takeaways:

• Define “information spillage” for your data types, environments, and third parties, then bake it into incident response training. ²
• Train by role, not by generic security awareness; include reporting paths and hands-on steps. ¹
• Evidence wins audits: training content, rosters, completion logs, and spillage drill artifacts must be easy to produce. ²

IR-9(2): training requirement lives inside the Incident Response family and focuses on a specific failure mode: information spillage. “Spillage” is not a vague concept like “data breach.” It is a practical operational event where sensitive information ends up somewhere it is not authorized to be, such as in the wrong ticket, the wrong cloud tenant, the wrong email thread, the wrong collaboration space, the wrong classification label, or shared with an unauthorized third party.

For a Compliance Officer, CCO, or GRC lead, the fastest way to implement IR-9(2) is to treat it as a training-and-evidence control tied directly to your spillage handling procedure. You need two things that auditors consistently look for: (1) training content that reflects how your organization actually detects and responds to spillage, and (2) proof that the people who will touch a spillage event have been trained and can execute. The control is small on paper, but high-impact in practice because spillages often trigger containment actions, legal/contract notification obligations, and downstream incident reporting decisions.

This page translates the requirement into a short build plan you can assign to an owner, track in a GRC system, and defend during assessment. ²

Regulatory text

Excerpt (IR-9(2)): “Provide information spillage response training {{ insert: param, ir-09.02_odp }}.” ¹

What the operator must do

• Provide training that teaches personnel how to respond to an information spillage event, consistent with your organization’s incident response approach. ¹
• Treat this as more than “awareness.” Training must enable action: identification, reporting, initial containment, escalation, and coordination with the incident response function. ²

Plain-English interpretation

You must ensure that people who may cause, detect, handle, or manage a data spillage know exactly what to do and who to contact, and you must be able to prove it. A spillage response training program is “pass/fail” during many audits: either you have defined spillage response steps, trained relevant roles, and retained evidence, or you have not.

A good working definition you can operationalize: information spillage is sensitive data being stored, transmitted, processed, or displayed in a system, location, or to recipients that are not authorized for that data. Map that definition to your data classifications, environments, and third-party workflows so training matches real scenarios. ²

Who it applies to (entity and operational context)

Entity scope

• Federal information systems and organizations implementing NIST SP 800-53 controls. ²
• Contractors and other third parties operating systems that handle federal data, where NIST SP 800-53 controls are flowed down contractually or via program requirements. ²

Operational scope (where spillages happen)

• Service desks and ticketing systems (attachments, screenshots, logs, call recordings).
• Collaboration platforms (chat, shared drives, wikis).
• Cloud storage and backups (misplaced buckets, wrong tenant, wrong key access).
• DevOps pipelines (logs with secrets, production data in non-production).
• Email and file transfer (misaddressed recipients, forwarding chains).
• Third-party exchanges (support vendors, consultants, managed services).
  Tie training to the workflows above so staff can recognize spillage early and reduce propagation.

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

1) Assign ownership and define the control outcome

• Control owner: typically Incident Response lead, Security Operations, or IT Risk; GRC coordinates evidence and testing.
• Outcome statement: “Relevant personnel receive information spillage response training and can demonstrate knowledge of reporting and first actions.” ¹

Deliverable: a short control narrative (one page) you can paste into your SSP/control workbook.

2) Define “information spillage” for your environment

Build a spillage taxonomy that is teachable:

• Data types: CUI, PII, PHI, export-controlled, credentials/secrets, proprietary.
• Unauthorized locations: non-approved SaaS, personal email, non-production, public links.
• Unauthorized recipients: wrong internal group, wrong customer, wrong third party.
• Severity tiers: “suspected spillage” vs “confirmed spillage” for triage and escalation.

Deliverable: spillage definition + examples list that becomes training content.

3) Write or update a spillage response procedure that training can follow

Training cannot compensate for a missing procedure. Minimum procedure elements:

• How to identify likely spillage signals (misdirected email, shared link exposure, incorrect permissions, data in the wrong system).
• How to report: single intake path (SOC, IR hotline, ticket queue) and required fields.
• Immediate containment actions allowed by first responders (remove access, quarantine, disable link sharing, revoke tokens, stop processing).
• Evidence preservation expectations (screenshots, logs, message IDs, file hashes where applicable).
• Escalation triggers to IR/Privacy/Legal/Contracting and third-party management.
• Coordination with comms and customer notification decisioning when relevant.

Deliverable: spillage runbook or SOP referenced by the training.

4) Design role-based training (the part assessors will probe)

Create training modules by role. A practical matrix:

Role group	What they must know	How to train
All workforce	Recognize spillage; report immediately; don’t “clean up” without reporting	Short module + scenario questions
Service desk / support	Intake checklist; containment steps; preserving evidence in tickets	Job aid + tabletop
Engineering / DevOps	Stop propagation; isolate environments; log handling; secrets rotation	Workshop + code/log examples
SOC / IR team	Triage, confirmation, containment, coordination, documentation	Runbook walk-through + exercises
Data owners / Privacy	Classification, impact, notification decision support	Targeted briefing
Third parties with access	Contractual reporting path; handling requirements; their containment steps	Supplier training pack + attestation

Deliverable: training plan + module outlines mapped to these role groups.

5) Deliver training and make it auditable

• Assign training in your LMS or equivalent system.
• Track completion by role group; capture the roster source (HR feed, IAM group membership, contract staff list).
• Include a knowledge check tied to your spillage procedure (basic “what do you do next?” items).

Deliverable: completion logs and rosters that can be exported quickly during an audit.

6) Prove operational readiness with a spillage drill artifact

Even if the control only says “training,” many assessors will test whether training connects to execution. Add one practical validation:

• A tabletop focused on a common spillage scenario (mis-shared link, wrong attachment, production data in non-prod, third-party ticket attachment).
• Capture after-action notes and improvements, then update the training content or job aids accordingly.

Deliverable: exercise agenda, participant list, scenario, and lessons learned.

7) Map evidence to the control once, then run it as a cadence

You want a repeatable evidence pack. Daydream (or any GRC system) should hold:

• control owner
• procedure link
• training plan
• recurring evidence artifacts
• last/next review dates
  This is the fastest way to stay assessment-ready without rebuilding proof each cycle. ¹

Required evidence and artifacts to retain

Keep an “IR-9(2) evidence folder” with:

• Spillage response training deck(s) and/or LMS module export (content and version/date).
• Training assignment rules (who is in scope) and role mapping.
• Completion evidence (LMS reports, signed attestations for third parties, attendance sheets for live sessions).
• Knowledge check results (if used) and remediation steps for failed attempts.
• Spillage SOP/runbook referenced in training.
• Job aids (one-page intake checklist, containment do/don’t list).
• Tabletop/drill artifacts: scenario, invite/roster, facilitator guide, outcomes, action items.
• Change log showing updates after incidents or lessons learned.

Common exam/audit questions and hangups

Expect these:

• “Define information spillage in your program and show where it is documented.” ²
• “Who receives spillage response training, and how did you determine the population?”
• “Show training content that covers reporting and first actions, not only definitions.” ¹
• “Produce completion evidence for a sample of users across roles, including contractors.”
• “Show that training reflects current tooling (ticketing system, SOC intake path, collaboration platform settings).”
• “What happens if a third party causes spillage? Show contract language or onboarding materials that direct reporting.”

Hangup to avoid: giving general security awareness training as a substitute. IR-9(2) is about response behavior specific to spillage.

Frequent implementation mistakes and how to avoid them

1. No shared definition of spillage

• Fix: publish a definition with concrete examples for your tool stack and data types; use it in training and in the IR ticket taxonomy.

2. Training is generic and not role-based

• Fix: add targeted modules and job aids for support, engineering, SOC, and data owners.

3. No proof for contractors/third parties

• Fix: require completion evidence or attestation as part of onboarding; include reporting requirements in statements of work and access terms.

4. “Clean-up first” culture

• Fix: train “report first, contain second, preserve evidence always,” and clarify what containment actions are allowed without approval.

5. Evidence scattered across teams

• Fix: one evidence owner (often GRC) and one evidence location with consistent naming and exportable reports.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat enforcement risk here as indirect: spillages often escalate into incidents with contractual, regulatory, and customer impacts. The training control reduces the chance that staff silently delete evidence, delay reporting, or broaden exposure through misguided remediation steps. ²

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable control)

• Assign control owner and publish a spillage definition with environment-specific examples.
• Finalize or refresh the spillage response SOP with a single reporting path.
• Build training module v1 for all workforce plus one specialized track (service desk or engineering).
• Set up evidence collection: folder structure, LMS export process, and role-based roster rules.

Next 60 days (make it role-based and testable)

• Expand training for remaining key roles (SOC/IR, privacy/data owners, engineering/DevOps).
• Add job aids embedded in ticketing and collaboration tools (templates, macros, intake checklist).
• Run one spillage tabletop and document lessons learned.
• Update training content based on tabletop outputs and publish a version log.

By 90 days (operate it like a program)

• Integrate third-party participation: onboarding training pack and attestation process for in-scope providers.
• Establish a recurring review of training content tied to tooling changes and incident learnings.
• Produce an “audit-ready evidence pack” with a standard export set and a named evidence steward.
• Map IR-9(2) in Daydream to an owner, procedure, and recurring evidence artifacts so audits become retrieval exercises, not investigations. ¹

Frequently Asked Questions

Does annual security awareness training satisfy ir-9(2): training requirement?

Usually no. IR-9(2) expects training on spillage response actions, including reporting paths and first containment steps aligned to your spillage procedure. ¹

Who exactly must take spillage response training?

Anyone who can create, handle, detect, or respond to spillage in your workflows, including contractors and in-scope third parties with access to sensitive data or systems. Start with role groups tied to service desk, engineering, SOC/IR, and data owners. ²

What counts as “information spillage” in a cloud/SaaS environment?

Treat it as sensitive data exposed to an unauthorized tenant, location, or recipient, such as a mis-shared link, wrong workspace permissions, or data moved into an unapproved SaaS. Document your definition and train to those scenarios. ²

What evidence do assessors ask for most often?

Training content, completion logs/rosters by role, the spillage SOP referenced in the training, and proof that training stays current (version history, updates after incidents or exercises). ¹

How should we handle training for third parties who refuse our LMS?

Use an equivalent mechanism: provide your spillage training pack, require written attestation, and ensure the contract requires prompt reporting through your designated intake channel. Keep attestations with the access authorization record. ²

We have a spillage runbook, but teams don’t follow it. What’s the fastest fix?

Add role-specific job aids inside the tools where spillages surface (ticket templates, chat bot prompts, “report spillage” button macros) and run a tabletop to rehearse the first 30 minutes of response. Then update training to match the real workflow. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5