PE-5(2): Link to Individual Identity

PE-5(2) requires you to link a specific person’s identity to the act of receiving printed or otherwise generated output from an output device (for example, printers, copiers, fax/MFPs, plotters). Operationally, you implement authenticated or otherwise attributable release/collection, log who retrieved the output, and retain evidence that retrieval events can be traced to an individual. ¹

Key takeaways:

• Tie output pickup/release events to a named user identity, not a shared device or generic queue. ¹
• Engineer for attribution: authentication at release, audit logging, and exception handling for break-glass and service accounts. ²
• Keep assessor-ready artifacts: device inventory, configurations, logs, and a tested procedure that proves traceability. ²

PE-5(2): link to individual identity requirement is a physical and operational control with a very practical objective: eliminate “mystery output” and reduce the risk of data exposure through unattended or misdirected device output. If your environment prints regulated data (federal information, CUI, sensitive internal reports, customer records), the weakest point is often the moment paper leaves a device and becomes unaccounted for.

Assessors typically look for two things: (1) a clear mechanism that links output receipt to a unique individual, and (2) evidence that the mechanism is consistently used where it matters. This is rarely solved by policy text alone. You need a workflow that forces attribution (or records it reliably), plus logs and operational procedures that show you can investigate a specific incident quickly.

This page translates the control enhancement into actions a CCO, compliance officer, or GRC lead can assign to IT and facilities, then verify with artifacts. It also highlights common design traps (shared badges, generic accounts, “secure print” that nobody uses) and a practical execution plan that gets you to audit-ready operation without boiling the ocean. ¹

Regulatory text

Requirement: “Link individual identity to receipt of output from output devices.” ¹

Operator translation: For any output device in scope (printers, copiers/MFPs, fax servers, label printers, plotters, specialty devices that produce hardcopy or other output), you must be able to answer: “Which specific person picked up or received this output?” The design goal is individual attribution at the time of release/receipt, supported by logs or other records that can stand up in an audit. ²

Plain-English interpretation

PE-5(2) is about chain of custody for device output. If a document is printed, scanned to a destination, faxed, or otherwise produced as “output,” you need a control that connects that output to a specific user identity at the moment it becomes accessible to humans. In practice, this usually means:

• Authenticated release (badge/PIN/SSO) at the device, or
• A controlled distribution process where staff identity is recorded at handoff, plus
• Audit logs that map job/output events to a unique user. ¹

Who it applies to

Entity types: Federal information systems and contractor systems handling federal data. ¹

Operational contexts where this comes up:

• Offices with networked printers or multifunction devices (MFPs)
• Shared work areas where printouts can be viewed or taken
• Facilities that print onboarding packets, payroll, or customer correspondence
• SOC/NOC environments printing incident reports or diagrams
• Any environment printing CUI or sensitive system data tied to federal work ²

Scoping tip (practical): Don’t attempt to retrofit every printer on day one. Start by scoping devices that handle sensitive content (federal data, security reports, HR/legal) and any device in public or shared areas. Then expand coverage based on risk and assessor expectations.

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

1) Assign ownership and define scope

1. Name a control owner (usually IT Security or IT Ops for print services; Facilities may co-own device placement).
2. Build an output device inventory: device type, location, owner, network segment, print server/MFP solution, and whether it can support authentication and logging.
3. Define in-scope output types (at minimum: printed pages; also consider scan-to-email/folder and faxing if those workflows exist). ²

2) Choose an attribution method (decision matrix)

Pick the method per device/location, document the rationale, and standardize where feasible.

Environment	Preferred method	Why assessors like it	Key caveat
Shared office MFPs	Badge/PIN + secure release	Strong identity binding + logs	Prevent shared badges/PINs
High-sensitivity teams	SSO-integrated print management	Central policy, consistent logging	Requires directory hygiene
Low-volume, controlled room	Attended printing with sign-out log	Clear chain-of-custody	Must be enforced daily
Legacy/specialty devices	Compensating process (supervised pickup)	Practical workaround	Document exceptions tightly

3) Implement authenticated release or controlled handoff

For “secure print release” implementations:

1. Enable hold-and-release so jobs do not print until the user authenticates at the device.
2. Integrate authentication with your identity system (directory, SSO, badge system) so the log identity matches a real person.
3. Configure the device/print server to record:
   • user identity
   • device name/location
   • time of release/receipt
   • job identifier (and metadata as appropriate)
4. Set and document rules for job expiry (so abandoned print jobs are purged) and reprint controls (so reprints are attributable). ¹

For “attended printing” or manual distribution (compensating control):

1. Restrict printing of sensitive categories to specific devices/rooms.
2. Require the recipient to present ID/badge and record:
   • printed item identifier (job ID or cover sheet ID)
   • recipient name
   • date/time
   • staff member who handed it over
3. Periodically review the sign-out log for completeness and anomalies.

4) Build exception handling that still preserves attribution

Most programs fail on edge cases. Decide and document:

• Service accounts: Prohibit them for user printing; if unavoidable, require named-user request ticket and pickup log tying the output to an individual.
• Break-glass printing: Define who can approve, how it’s logged, and how you reconcile it after the fact.
• Guests/contractors: Issue time-bound identities or require escort + manual sign-out.
• Device downtime: Define an alternate device/workflow and the documentation required when secure release is unavailable. ²

5) Turn the control into an assessable routine

1. Create a short implementation standard: approved authentication methods, logging minimums, and where the control is mandatory (by device location/data type).
2. Add recurring checks:
   • Monthly spot-check of devices for secure release enabled and working
   • Quarterly sample of logs showing user-to-output mapping
   • Joiner/mover/leaver checks to confirm badge/SSO printing follows identity lifecycle
3. Train users on “how to print securely” and train IT on “how to evidence it.”

Daydream fit (earned, practical): If you manage many controls and struggle to keep “owner + procedure + recurring evidence” aligned, Daydream can act as the control record system where PE-5(2) is mapped to an owner, a repeatable procedure, and an evidence request cadence that matches your assessment calendar. That directly addresses the common failure mode: missing or inconsistent artifacts at audit time. ¹

Required evidence and artifacts to retain

Keep artifacts that prove both design and operating effectiveness:

Design evidence

• Output device inventory with scope labels (in-scope vs. out-of-scope rationale)
• Standard/configuration baseline for print release and authentication
• Data classification/handling rule that triggers secure printing (if applicable)
• Exception register for devices/workflows that cannot support authenticated release ²

Operating evidence

• Device configuration screenshots/exports showing:
  • secure release enabled
  • authentication method enabled
  • logging enabled
• Central print management configuration and directory integration evidence
• Sample logs demonstrating: user identity → device → timestamp → job/release event
• Review records: spot-check results, remediation tickets, and closure evidence
• Training/communications records for affected user groups

Retention note: Align retention to your internal audit/log retention standards. The control text does not prescribe a duration. ¹

Common exam/audit questions and hangups

Expect these, and prepare answers with artifacts:

1. “Show me how you link output receipt to an individual.” Demonstrate at a device: print held, badge/PIN release, then show the log record.
2. “Are there shared accounts or shared badges?” Auditors will treat shared credentials as a failure of “individual identity.”
3. “Which devices are in scope and why?” They want risk-based scoping, not “everything everywhere.”
4. “How do you handle exceptions?” Missing an exceptions process is a frequent finding.
5. “Can you investigate a suspected data leak via printing?” Provide a sample workflow: query logs, identify user/device/time, correlate with badge access/CCTV if available. ²

Frequent implementation mistakes and how to avoid them

• Mistake: “Secure print” enabled but optional. Fix: enforce hold-and-release by policy on in-scope devices; block direct print where feasible.
• Mistake: Identity mismatch (badge system identity ≠ directory identity). Fix: ensure the release identity maps to a unique person in your authoritative identity source.
• Mistake: Logs exist but aren’t retained or searchable. Fix: centralize print logs and test retrieval during a tabletop scenario.
• Mistake: Ignoring scan/fax output paths. Fix: decide whether “output” includes scan-to-email/folder and faxing in your environment; document the boundary and controls.
• Mistake: Exceptions become the norm. Fix: maintain an exceptions register with an owner and review cadence; remediate root causes (device refresh, relocation, workflow change). ²

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so treat “enforcement” here as assessment and contractual risk: failure typically shows up as an audit finding, a customer security gap, or a federal assessment deficiency. Operationally, weak attribution increases the blast radius of a printing-related incident because you cannot confidently reconstruct who accessed the output. ²

Practical 30/60/90-day execution plan

First 30 days (stabilize and scope)

• Appoint control owner and stakeholders (IT, Security, Facilities).
• Inventory output devices and rank by sensitivity/location.
• Select your standard attribution method (secure release where possible; documented compensating controls where not).
• Draft the PE-5(2) procedure: how printing works, how identity is captured, how logs are reviewed. ²

Days 31–60 (implement and evidence)

• Roll out authenticated release on priority devices (shared areas and sensitive teams).
• Centralize logs and test that you can retrieve a user-to-release record.
• Stand up the exception register and close the first wave of exceptions (relocate devices, retire unsupported devices, or implement supervised pickup).
• Produce the first “audit packet”: inventory, configs, log samples, and review checklist.

Days 61–90 (operate and harden)

• Expand coverage to remaining in-scope devices.
• Run a tabletop test: “Unattended sensitive printout found.” Prove you can trace receipt to an individual or demonstrate your compensating chain-of-custody.
• Establish recurring reviews and integrate into your GRC system so evidence collection is consistent across quarters and assessments.
• Tune controls based on findings: reduce shared printers, tighten guest handling, improve user training. ¹

Frequently Asked Questions

Does PE-5(2) require badge-based printing specifically?

No. The requirement is to link receipt of output to an individual identity, and badge-based release is one common way to do it. If you use another method, document how it uniquely ties output pickup to a person and retain logs or records. ¹

Are personal desktop printers in scope?

Scope depends on whether they process sensitive or federal data and whether output could be accessed by others. If they print sensitive content in shared spaces, they often need the same attribution controls or a documented compensating process. ²

What counts as “receipt of output” for MFPs that scan to email or folders?

If your program interprets those actions as “output,” you should ensure the initiating user identity is captured and logged for the scan/fax action. If you exclude certain outputs, document the boundary and the risk rationale. ²

How do we handle third-party managed print services?

Treat the print provider as a third party supporting a security control. Require contractual and technical evidence that their solution records individual identity at release and that you can access logs for investigations and audits. ²

What’s the minimum evidence an auditor will accept?

Expect to show a working mechanism (authenticated release or controlled handoff), a device inventory with scope, and log samples that clearly map a user identity to a specific output receipt event. Keep exception documentation for devices that can’t technically comply. ¹

If we already have physical access controls (badges, cameras), is PE-5(2) covered?

Physical access controls reduce who can reach a printer, but they do not automatically link a specific printout to an individual recipient. PE-5(2) expects attribution tied to output receipt, typically through release controls and logging. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5