PS-6(1): Information Requiring Special Protection

PS-6 is in the Personnel Security (PS) family, so examiners read it as a people-and-process control that protects sensitive information against insider risk, negligent handling, and improper disclosure. Enhancement PS-6(1) narrows your focus to information that needs “special protection,” which forces an uncomfortable but necessary move: you must stop relying on broad policy language (“treat sensitive data carefully”) and instead specify which information qualifies, who can touch it, and what gates prove you enforced that rule.

For a CCO or GRC lead, the fastest route is to treat PS-6(1) as a requirement to (1) define special-protection information classes, (2) define eligible personnel populations and approval criteria, (3) harden access workflows so the rule is enforced by systems and HR operations, and (4) retain audit-ready evidence. This page gives you a requirement-level runbook you can hand to HR, Security, and system owners, with concrete artifacts to produce and common audit traps to avoid. ¹

Regulatory text

Control reference: “NIST SP 800-53 control PS-6.1.” ²

Operator interpretation of what you must do:
PS-6(1): information requiring special protection requirement expects you to (a) determine what information requires special protection in your environment, and (b) implement personnel security conditions around that information so access and handling are limited to appropriately authorized individuals and are enforceable in day-to-day operations. Treat this as a binding rule that connects data classification to personnel eligibility and access control gates, not as a stand-alone HR checklist. ¹

Plain-English interpretation (what PS-6(1) is really asking)

You need a defensible answer to three questions, and you need to prove you apply it consistently:

1. What information requires special protection here?
   Examples in practice include classified or controlled government data, export-controlled technical data, sensitive law enforcement information, and other categories where mishandling creates disproportionate harm. Your job is to define the categories you actually hold and process, then document the handling requirements for each.

2. Which people can access it, and why?
   Eligibility is usually driven by role need-to-know, background screening level, contract clauses, citizenship or residency constraints, training completion, and formal approval.

3. How do you enforce it operationally?
   Enforcement means access control configurations, provisioning approvals, logging, supervision expectations, and termination/offboarding steps that remove access promptly.

Who it applies to (entity and operational context)

PS-6(1) is most relevant if you operate:

• Federal information systems or environments supporting federal missions. ¹
• Contractor systems handling federal data, including cloud/SaaS and managed services that store, process, or transmit federal information. ¹

Operationally, it applies anywhere “special protection” information might appear:

• Identity systems (IdP), HRIS, ticketing, and access request tools
• Source code repos and CI/CD logs
• Data warehouses, analytics tools, customer support systems
• Collaboration platforms (email, chat, docs) and endpoint storage

If your scoping is unclear, default to mapping where sensitive federal data can land (including logs and exports), then work backward to the people and access paths.

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

Use this as a build sheet you can assign to owners.

Step 1: Define “special protection” information categories and handling rules

1. Create a short list of categories relevant to your contracts and system boundary. Keep it small enough to enforce.
2. Write handling rules per category in plain language: allowed storage locations, allowed sharing methods, encryption expectations, printing/export rules, and whether access requires additional approvals.
3. Assign a data owner for each category who can approve exceptions.

Deliverable: “Information Requiring Special Protection Standard” (one-pager + appendix).
Exam focus: If you cannot name the categories and the rules, PS-6(1) becomes untestable and auditors treat it as not implemented.

Step 2: Map eligible personnel populations (who can touch what)

1. Define eligibility criteria per category (examples: role-based need-to-know, screening completion, training, contract assignment).
2. Document “disqualifiers” (examples: not on the contract, incomplete screening, offboarded, role change).
3. Name approvers (data owner, security, program lead) and required approval sequence.

Deliverable: Role-to-data eligibility matrix (table).
Practical note: Keep the matrix aligned with how your IAM groups are structured. If the matrix is too nuanced for the tooling, it won’t be enforced.

Step 3: Convert the policy into access gates (technical + procedural)

1. Provisioning workflow: Require an access request ticket with (a) category requested, (b) justification, (c) approver sign-off(s), and (d) evidence of eligibility (screening/training status).
2. IAM implementation: Use groups/roles that correspond to the categories; avoid one-off user grants.
3. Session and data controls: Ensure “special protection” repositories have stronger controls (restricted sharing, external collaboration disabled where appropriate, download limits where feasible).
4. Monitoring and logging: Log access and administrative actions for systems holding special-protection data, and make logs reviewable.

Deliverables: Access request template, IAM role catalog entries, system configuration screenshots/exports, logging configuration evidence.

Step 4: Bind HR events to security outcomes (joiners, movers, leavers)

1. Joiners: No access to special-protection categories until eligibility checks and approvals are complete.
2. Movers: Role change triggers revalidation; remove legacy access automatically if possible.
3. Leavers: Offboarding removes access to all special-protection repositories and rotates shared secrets where applicable.

Deliverables: HR-to-IT workflow diagram, offboarding checklist with control steps, sample deprovisioning records.

Step 5: Build the control “card” so it runs the same way every time

Create a control card that includes:

• Objective tied to PS-6(1)
• Control owner (named role) and backups
• Trigger events (new hire, role change, new system, new data type, contract award)
• Operating cadence (event-driven + periodic review)
• Exception path (who can approve, how long it lasts, required compensating controls)

This is the fastest way to avoid the most common risk factor: teams cannot show ownership, cadence, or evidence. ²

Step 6: Define the minimum evidence bundle and retention location

For each execution cycle (an access grant, a review, an exception), define what you will retain:

• Input (request, justification, data category)
• Eligibility proof (screening/training/assignment)
• Approvals (names, dates, decision)
• Output (role/group added, config change, access grant record)
• Retention location (GRC repository, ticketing system, secure drive) and retention period per your policy

A tight evidence bundle prevents the “we did it but can’t prove it” failure mode. ²

Step 7: Run recurring control health checks and track remediation

At a minimum, perform a control health check that tests:

• A sample of access grants for required approvals and eligibility proof
• A sample of terminations/role changes for timely access removal
• A scan for direct user permissions that bypass groups/roles
• Exceptions that expired but were never removed

Track findings to closure with owners and due dates; keep validation evidence. ²

Required evidence and artifacts to retain (audit-ready list)

Use this as your “show me” binder:

Artifact	What it proves	Where it usually lives
Information Requiring Special Protection Standard	You defined what qualifies and how it must be handled	Policy repository / GRC tool
Role-to-data eligibility matrix	You defined who can access what and why	GRC tool / controlled doc
Access request tickets (samples)	Approvals + justification + eligibility	ITSM/ticketing
IAM role/group mappings	Enforcement via roles, not ad hoc grants	IAM system exports
System configuration evidence	Repos/spaces are restricted appropriately	Admin console exports
Training completion reports (for required training)	Personnel met prerequisites	LMS/HR
Offboarding/deprovisioning records	Access is removed on exit	HRIS + IAM logs
Exception register	Exceptions are controlled, approved, time-bound	GRC tool

Common exam/audit questions and hangups

Expect these questions, and prepare scripted answers plus evidence links:

• “Define ‘information requiring special protection’ for your system boundary.”
  Hangup: teams answer with generic “confidential data” without categories or handling rules.

• “Show me how an engineer gets access to this dataset.”
  Hangup: access granted via chat message or informal approval, no durable evidence.

• “How do you know contractors aren’t over-permissioned?”
  Hangup: no recurring review, or reviews happen but are not recorded.

• “What happens when someone changes roles or leaves?”
  Hangup: HR offboarding is not connected to security deprovisioning, or shared accounts muddy accountability.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating PS-6(1) as a policy-only control.
   Fix: Make it enforceable through IAM roles, ticket approvals, and system restrictions.

2. Mistake: Creating too many “special” categories.
   Fix: Start with a small set you can implement cleanly; expand only when you can enforce each one.

3. Mistake: Relying on tribal knowledge for eligibility.
   Fix: Put eligibility in an explicit matrix and require evidence in the access workflow.

4. Mistake: Exceptions with no expiration or compensating controls.
   Fix: Require end dates, documented rationale, and a named approver; review exceptions routinely.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat PS-6(1) as an auditability and contractual compliance risk rather than a cited enforcement trend in this page. The practical risk is straightforward: mishandling high-sensitivity information often triggers mandatory reporting, contract penalties, loss of authorization to operate, or customer trust failures. Your best defense is clean scoping, strong access governance, and evidence that stands on its own. ¹

Practical execution plan (30/60/90-day)

First 30 days (stabilize and define)

• Assign an owner for the ps-6(1): information requiring special protection requirement and name backups.
• Draft the “special protection” categories and handling rules for your environment; get data owner approval.
• Build the role-to-data eligibility matrix for the highest-risk systems first.
• Standardize the access request template to capture category, justification, approver, and eligibility proof.

By 60 days (enforce through workflows)

• Implement IAM groups/roles that map to the categories; migrate away from direct grants.
• Put required approvals into the ticketing workflow; block provisioning without them.
• Connect joiner/mover/leaver events to access outcomes; document the workflow and test it with real samples.
• Create the exception register and start tracking exceptions centrally.

By 90 days (prove operation and close gaps)

• Run a control health check: sample access grants, offboarding events, and exceptions; document findings and remediation.
• Validate logging is on for sensitive repositories and that access trails are retrievable.
• Package the minimum evidence bundle in a single auditor-friendly location (GRC system or controlled repository).
• If you use Daydream, convert the above into a control card with embedded evidence requirements and recurring health-check tasks so the control keeps running without heroics.

Frequently Asked Questions

How do I decide what counts as “information requiring special protection”?

Start with what your contracts, system authorization boundary, and data owners already treat as restricted. Document a short, enforceable list of categories and the handling rules, then map each category to systems and roles. ¹

Does PS-6(1) require background checks for everyone?

PS-6(1) drives eligibility conditions for personnel who access special-protection information, not a blanket requirement for all staff. Define which roles require which prerequisites, then enforce that through your access workflow. ¹

What evidence do auditors usually want first?

They typically start with your definition of special-protection information, the access approval workflow, and a few real access grant examples that show eligibility proof and approvals. Keep those artifacts linked and easy to retrieve. ²

How do we handle third-party contractors who need temporary access?

Require the same eligibility evidence and approvals, then issue time-bound access via role membership with an expiration process. Track the access grant and the revocation evidence in your ticketing system or GRC repository.

Can we satisfy PS-6(1) with encryption alone?

Encryption helps, but PS-6(1) is personnel security-focused and expects you to restrict who can access and handle the information. You still need role-based access, approvals, and joiner/mover/leaver controls. ¹

What’s the cleanest way to operationalize this in a GRC program?

Create a control card that names the owner, trigger events, steps, and exception rules, then define a minimum evidence bundle for each run. Daydream is a natural fit for maintaining the control card, collecting evidence, and tracking health checks to closure. ²

Footnotes

1. NIST SP 800-53 Rev. 5

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