Harvey Newstrom ensures compliance to cybersecurity controls extracted from NIST, 800-53, 800-53A, and 800-53B
Assessment, authorization, and monitoring policy and procedures address the controls in the CA family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of assessment, authorization, and monitoring policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to assessment, authorization, and monitoring policy and procedures include assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.
Organizations ensure that control assessors possess the required skills and technical expertise to develop effective assessment plans and to conduct assessments of system-specific, hybrid, common, and program management controls, as appropriate. The required skills include general knowledge of risk management concepts and approaches as well as comprehensive knowledge of and experience with the hardware, software, and firmware system components implemented.
Organizations assess controls in systems and the environments in which those systems operate as part of initial and ongoing authorizations, continuous monitoring, FISMA annual assessments, system design and development, systems security engineering, privacy engineering, and the system development life cycle. Assessments help to ensure that organizations meet information security and privacy requirements, identify weaknesses and deficiencies in the system design and development process, provide essential information needed to make risk-based decisions as part of authorization processes, and comply with vulnerability mitigation procedures. Organizations conduct assessments on the implemented controls as documented in security and privacy plans. Assessments can also be conducted throughout the system development life cycle as part of systems engineering and systems security engineering processes. The design for controls can be assessed as RFPs are developed, responses assessed, and design reviews conducted. If a design to implement controls and subsequent implementation in accordance with the design are assessed during development, the final control testing can be a simple confirmation utilizing previously completed control assessment and aggregating the outcomes.
Organizations may develop a single, consolidated security and privacy assessment plan for the system or maintain separate plans. A consolidated assessment plan clearly delineates the roles and responsibilities for control assessment. If multiple organizations participate in assessing a system, a coordinated approach can reduce redundancies and associated costs.
Organizations can use other types of assessment activities, such as vulnerability scanning and system monitoring, to maintain the security and privacy posture of systems during the system life cycle. Assessment reports document assessment results in sufficient detail, as deemed necessary by organizations, to determine the accuracy and completeness of the reports and whether the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting requirements. Assessment results are provided to the individuals or roles appropriate for the types of assessments being conducted. For example, assessments conducted in support of authorization decisions are provided to authorizing officials, senior agency officials for privacy, senior agency information security officers, and authorizing official designated representatives.
To satisfy annual assessment requirements, organizations can use assessment results from the following sources: initial or ongoing system authorizations, continuous monitoring, systems engineering processes, or system development life cycle activities. Organizations ensure that assessment results are current, relevant to the determination of control effectiveness, and obtained with the appropriate level of assessor independence. Existing control assessment results can be reused to the extent that the results are still valid and can also be supplemented with additional assessments as needed. After the initial authorizations, organizations assess controls during continuous monitoring. Organizations also establish the frequency for ongoing assessments in accordance with organizational continuous monitoring strategies. External audits, including audits by external entities such as regulatory agencies, are outside of the scope of CA-2.
System information exchange requirements apply to information exchanges between two or more systems. System information exchanges include connections via leased lines or virtual private networks, connections to internet service providers, database sharing or exchanges of database transaction information, connections and exchanges with cloud services, exchanges via web-based services, or exchanges of files via file transfer protocols, network protocols (e.g., IPv4, IPv6), email, or other organization-to-organization communications. Organizations consider the risk related to new or increased threats that may be introduced when systems exchange information with other systems that may have different security and privacy requirements and controls. This includes systems within the same organization and systems that are external to the organization. A joint authorization of the systems exchanging information, as described in CA-6(1) or CA-6(2), may help to communicate and reduce risk.
Authorizing officials determine the risk associated with system information exchange and the controls needed for appropriate risk mitigation. The types of agreements selected are based on factors such as the impact level of the information being exchanged, the relationship between the organizations exchanging information (e.g., government to government, government to business, business to business, government or business to service provider, government or business to individual), or the level of access to the organizational system by users of the other system. If systems that exchange information have the same authorizing official, organizations need not develop agreements. Instead, the interface characteristics between the systems (e.g., how the information is being exchanged. how the information is protected) are described in the respective security and privacy plans. If the systems that exchange information have different authorizing officials within the same organization, the organizations can develop agreements or provide the same information that would be provided in the appropriate agreement type from CA-3a in the respective security and privacy plans for the systems. Organizations may incorporate agreement information into formal contracts, especially for information exchanges established between federal agencies and nonfederal organizations (including service providers, contractors, system developers, and system integrators). Risk considerations include systems that share the same networks.
Plans of action and milestones are useful for any type of organization to track planned remedial actions. Plans of action and milestones are required in authorization packages and subject to federal reporting requirements established by OMB.
Authorizations are official management decisions by senior officials to authorize operation of systems, authorize the use of common controls for inheritance by organizational systems, and explicitly accept the risk to organizational operations and assets, individuals, other organizations, and the Nation based on the implementation of agreed-upon controls. Authorizing officials provide budgetary oversight for organizational systems and common controls or assume responsibility for the mission and business functions supported by those systems or common controls. The authorization process is a federal responsibility, and therefore, authorizing officials must be federal employees. Authorizing officials are both responsible and accountable for security and privacy risks associated with the operation and use of organizational systems. Nonfederal organizations may have similar processes to authorize systems and senior officials that assume the authorization role and associated responsibilities.
Authorizing officials issue ongoing authorizations of systems based on evidence produced from implemented continuous monitoring programs. Robust continuous monitoring programs reduce the need for separate reauthorization processes. Through the employment of comprehensive continuous monitoring processes, the information contained in authorization packages (i.e., security and privacy plans, assessment reports, and plans of action and milestones) is updated on an ongoing basis. This provides authorizing officials, common control providers, and system owners with an up-to-date status of the security and privacy posture of their systems, controls, and operating environments. To reduce the cost of reauthorization, authorizing officials can leverage the results of continuous monitoring processes to the maximum extent possible as the basis for rendering reauthorization decisions.
Continuous monitoring at the system level facilitates ongoing awareness of the system security and privacy posture to support organizational risk management decisions. The terms continuous
and ongoing
imply that organizations assess and monitor their controls and risks at a frequency sufficient to support risk-based decisions. Different types of controls may require different monitoring frequencies. The results of continuous monitoring generate risk response actions by organizations. When monitoring the effectiveness of multiple controls that have been grouped into capabilities, a root-cause analysis may be needed to determine the specific control that has failed. Continuous monitoring programs allow organizations to maintain the authorizations of systems and common controls in highly dynamic environments of operation with changing mission and business needs, threats, vulnerabilities, and technologies. Having access to security and privacy information on a continuing basis through reports and dashboards gives organizational officials the ability to make effective and timely risk management decisions, including ongoing authorization decisions.
Automation supports more frequent updates to hardware, software, and firmware inventories, authorization packages, and other system information. Effectiveness is further enhanced when continuous monitoring outputs are formatted to provide information that is specific, measurable, actionable, relevant, and timely. Continuous monitoring activities are scaled in accordance with the security categories of systems. Monitoring requirements, including the need for specific monitoring, may be referenced in other controls and control enhancements, such as AC-2g, AC-2(7), AC-2(12)(a), AC-2(7)(b), AC-2(7)(c), AC-17(1), AT-4a, AU-13, AU-13(1), AU-13(2), CM-3f, CM-6d, CM-11c, IR-5, MA-2b, MA-3a, MA-4a, PE-3d, PE-6, PE-14b, PE-16, PE-20, PM-6, PM-23, PM-31, PS-7e, SA-9c, SR-4, SC-5(3)(b), SC-7a, SC-7(24)(b), SC-18b, SC-43b, and SI-4.
Penetration testing is a specialized type of assessment conducted on systems or individual system components to identify vulnerabilities that could be exploited by adversaries. Penetration testing goes beyond automated vulnerability scanning and is conducted by agents and teams with demonstrable skills and experience that include technical expertise in network, operating system, and/or application level security. Penetration testing can be used to validate vulnerabilities or determine the degree of penetration resistance of systems to adversaries within specified constraints. Such constraints include time, resources, and skills. Penetration testing attempts to duplicate the actions of adversaries and provides a more in-depth analysis of security- and privacy-related weaknesses or deficiencies. Penetration testing is especially important when organizations are transitioning from older technologies to newer technologies (e.g., transitioning from IPv4 to IPv6 network protocols).
Organizations can use the results of vulnerability analyses to support penetration testing activities. Penetration testing can be conducted internally or externally on the hardware, software, or firmware components of a system and can exercise both physical and technical controls. A standard method for penetration testing includes a pretest analysis based on full knowledge of the system, pretest identification of potential vulnerabilities based on the pretest analysis, and testing designed to determine the exploitability of vulnerabilities. All parties agree to the rules of engagement before commencing penetration testing scenarios. Organizations correlate the rules of engagement for the penetration tests with the tools, techniques, and procedures that are anticipated to be employed by adversaries. Penetration testing may result in the exposure of information that is protected by laws or regulations, to individuals conducting the testing. Rules of engagement, contracts, or other appropriate mechanisms can be used to communicate expectations for how to protect this information. Risk assessments guide the decisions on the level of independence required for the personnel conducting penetration testing.
Internal system connections are connections between organizational systems and separate constituent system components (i.e., connections between components that are part of the same system) including components used for system development. Intra-system connections include connections with mobile devices, notebook and desktop computers, tablets, printers, copiers, facsimile machines, scanners, sensors, and servers. Instead of authorizing each internal system connection individually, organizations can authorize internal connections for a class of system components with common characteristics and/or configurations, including printers, scanners, and copiers with a specified processing, transmission, and storage capability or smart phones and tablets with a specific baseline configuration. The continued need for an internal system connection is reviewed from the perspective of whether it provides support for organizational missions or business functions.
Planning policy and procedures for the controls in the PL family implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on their development. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission level or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission/business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to planning policy and procedures include, but are not limited to, assessment or audit findings, security incidents or breaches, or changes in laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.
System security and privacy plans are scoped to the system and system components within the defined authorization boundary and contain an overview of the security and privacy requirements for the system and the controls selected to satisfy the requirements. The plans describe the intended application of each selected control in the context of the system with a sufficient level of detail to correctly implement the control and to subsequently assess the effectiveness of the control. The control documentation describes how system-specific and hybrid controls are implemented and the plans and expectations regarding the functionality of the system. System security and privacy plans can also be used in the design and development of systems in support of life cycle-based security and privacy engineering processes. System security and privacy plans are living documents that are updated and adapted throughout the system development life cycle (e.g., during capability determination, analysis of alternatives, requests for proposal, and design reviews). Section 2.1 describes the different types of requirements that are relevant to organizations during the system development life cycle and the relationship between requirements and controls.
Organizations may develop a single, integrated security and privacy plan or maintain separate plans. Security and privacy plans relate security and privacy requirements to a set of controls and control enhancements. The plans describe how the controls and control enhancements meet the security and privacy requirements but do not provide detailed, technical descriptions of the design or implementation of the controls and control enhancements. Security and privacy plans contain sufficient information (including specifications of control parameter values for selection and assignment operations explicitly or by reference) to enable a design and implementation that is unambiguously compliant with the intent of the plans and subsequent determinations of risk to organizational operations and assets, individuals, other organizations, and the Nation if the plan is implemented.
Security and privacy plans need not be single documents. The plans can be a collection of various documents, including documents that already exist. Effective security and privacy plans make extensive use of references to policies, procedures, and additional documents, including design and implementation specifications where more detailed information can be obtained. The use of references helps reduce the documentation associated with security and privacy programs and maintains the security- and privacy-related information in other established management and operational areas, including enterprise architecture, system development life cycle, systems engineering, and acquisition. Security and privacy plans need not contain detailed contingency plan or incident response plan information but can instead provide—explicitly or by reference—sufficient information to define what needs to be accomplished by those plans.
Security- and privacy-related activities that may require coordination and planning with other individuals or groups within the organization include assessments, audits, inspections, hardware and software maintenance, acquisition and supply chain risk management, patch management, and contingency plan testing. Planning and coordination include emergency and nonemergency (i.e., planned or non-urgent unplanned) situations. The process defined by organizations to plan and coordinate security- and privacy-related activities can also be included in other documents, as appropriate.
Rules of behavior represent a type of access agreement for organizational users. Other types of access agreements include nondisclosure agreements, conflict-of-interest agreements, and acceptable use agreements (see PS-6). Organizations consider rules of behavior based on individual user roles and responsibilities and differentiate between rules that apply to privileged users and rules that apply to general users. Establishing rules of behavior for some types of non-organizational users, including individuals who receive information from federal systems, is often not feasible given the large number of such users and the limited nature of their interactions with the systems. Rules of behavior for organizational and non-organizational users can also be established in AC-8. The related controls section provides a list of controls that are relevant to organizational rules of behavior. PL-4b, the documented acknowledgment portion of the control, may be satisfied by the literacy training and awareness and role-based training programs conducted by organizations if such training includes rules of behavior. Documented acknowledgements for rules of behavior include electronic or physical signatures and electronic agreement check boxes or radio buttons.
The CONOPS may be included in the security or privacy plans for the system or in other system development life cycle documents. The CONOPS is a living document that requires updating throughout the system development life cycle. For example, during system design reviews, the concept of operations is checked to ensure that it remains consistent with the design for controls, the system architecture, and the operational procedures. Changes to the CONOPS are reflected in ongoing updates to the security and privacy plans, security and privacy architectures, and other organizational documents, such as procurement specifications, system development life cycle documents, and systems engineering documents.
The security and privacy architectures at the system level are consistent with the organization-wide security and privacy architectures described in PM-7, which are integral to and developed as part of the enterprise architecture. The architectures include an architectural description, the allocation of security and privacy functionality (including controls), security- and privacy-related information for external interfaces, information being exchanged across the interfaces, and the protection mechanisms associated with each interface. The architectures can also include other information, such as user roles and the access privileges assigned to each role; security and privacy requirements; types of information processed, stored, and transmitted by the system; supply chain risk management requirements; restoration priorities of information and system services; and other protection needs.
SP 800-160-1 provides guidance on the use of security architectures as part of the system development life cycle process. OMB M-19-03 requires the use of the systems security engineering concepts described in SP 800-160-1 for high value assets. Security and privacy architectures are reviewed and updated throughout the system development life cycle, from analysis of alternatives through review of the proposed architecture in the RFP responses to the design reviews before and during implementation (e.g., during preliminary design reviews and critical design reviews).
In today’s modern computing architectures, it is becoming less common for organizations to control all information resources. There may be key dependencies on external information services and service providers. Describing such dependencies in the security and privacy architectures is necessary for developing a comprehensive mission and business protection strategy. Establishing, developing, documenting, and maintaining under configuration control a baseline configuration for organizational systems is critical to implementing and maintaining effective architectures. The development of the architectures is coordinated with the senior agency information security officer and the senior agency official for privacy to ensure that the controls needed to support security and privacy requirements are identified and effectively implemented. In many circumstances, there may be no distinction between the security and privacy architecture for a system. In other circumstances, security objectives may be adequately satisfied, but privacy objectives may only be partially satisfied by the security requirements. In these cases, consideration of the privacy requirements needed to achieve satisfaction will result in a distinct privacy architecture. The documentation, however, may simply reflect the combined architectures.
PL-8 is primarily directed at organizations to ensure that architectures are developed for the system and, moreover, that the architectures are integrated with or tightly coupled to the enterprise architecture. In contrast, SA-17 is primarily directed at the external information technology product and system developers and integrators. SA-17, which is complementary to PL-8, is selected when organizations outsource the development of systems or components to external entities and when there is a need to demonstrate consistency with the organization’s enterprise architecture and security and privacy architectures.
Central management refers to organization-wide management and implementation of selected controls and processes. This includes planning, implementing, assessing, authorizing, and monitoring the organization-defined, centrally managed controls and processes. As the central management of controls is generally associated with the concept of common (inherited) controls, such management promotes and facilitates standardization of control implementations and management and the judicious use of organizational resources. Centrally managed controls and processes may also meet independence requirements for assessments in support of initial and ongoing authorizations to operate and as part of organizational continuous monitoring.
Automated tools (e.g., security information and event management tools or enterprise security monitoring and management tools) can improve the accuracy, consistency, and availability of information associated with centrally managed controls and processes. Automation can also provide data aggregation and data correlation capabilities; alerting mechanisms; and dashboards to support risk-based decision-making within the organization.
As part of the control selection processes, organizations determine the controls that may be suitable for central management based on resources and capabilities. It is not always possible to centrally manage every aspect of a control. In such cases, the control can be treated as a hybrid control with the control managed and implemented centrally or at the system level. The controls and control enhancements that are candidates for full or partial central management include but are not limited to: AC-2(1), AC-2(2), AC-2(3), AC-2(4), AC-4(all), AC-17(1), AC-17(2), AC-17(3), AC-17(9), AC-18(1), AC-18(3), AC-18(4), AC-18(5), AC-19(4), AC-22, AC-23, AT-2(1), AT-2(2), AT-3(1), AT-3(2), AT-3(3), AT-4, AU-3, AU-6(1), AU-6(3), AU-6(5), AU-6(6), AU-6(9), AU-7(1), AU-7(2), AU-11, AU-13, AU-16, CA-2(1), CA-2(2), CA-2(3), CA-3(1), CA-3(2), CA-3(3), CA-7(1), CA-9, CM-2(2), CM-3(1), CM-3(4), CM-4, CM-6, CM-6(1), CM-7(2), CM-7(4), CM-7(5), CM-8(all), CM-9(1), CM-10, CM-11, CP-7(all), CP-8(all), SC-43, SI-2, SI-3, SI-4(all), SI-7, SI-8.
Control baselines are predefined sets of controls specifically assembled to address the protection needs of a group, organization, or community of interest. Controls are chosen for baselines to either satisfy mandates imposed by laws, executive orders, directives, regulations, policies, standards, and guidelines or address threats common to all users of the baseline under the assumptions specific to the baseline. Baselines represent a starting point for the protection of individuals’ privacy, information, and information systems with subsequent tailoring actions to manage risk in accordance with mission, business, or other constraints (see PL-11). Federal control baselines are provided in SP 800-53B. The selection of a control baseline is determined by the needs of stakeholders. Stakeholder needs consider mission and business requirements as well as mandates imposed by applicable laws, executive orders, directives, policies, regulations, standards, and guidelines. For example, the control baselines in SP 800-53B are based on the requirements from FISMA and PRIVACT. The requirements, along with the NIST standards and guidelines implementing the legislation, direct organizations to select one of the control baselines after the reviewing the information types and the information that is processed, stored, and transmitted on the system; analyzing the potential adverse impact of the loss or compromise of the information or system on the organization’s operations and assets, individuals, other organizations, or the Nation; and considering the results from system and organizational risk assessments. CNSSI 1253 provides guidance on control baselines for national security systems.
The concept of tailoring allows organizations to specialize or customize a set of baseline controls by applying a defined set of tailoring actions. Tailoring actions facilitate such specialization and customization by allowing organizations to develop security and privacy plans that reflect their specific mission and business functions, the environments where their systems operate, the threats and vulnerabilities that can affect their systems, and any other conditions or situations that can impact their mission or business success. Tailoring guidance is provided in SP 800-53B. Tailoring a control baseline is accomplished by identifying and designating common controls, applying scoping considerations, selecting compensating controls, assigning values to control parameters, supplementing the control baseline with additional controls as needed, and providing information for control implementation. The general tailoring actions in SP 800-53B can be supplemented with additional actions based on the needs of organizations. Tailoring actions can be applied to the baselines in SP 800-53B in accordance with the security and privacy requirements from FISMA, PRIVACT, and OMB A-130. Alternatively, other communities of interest adopting different control baselines can apply the tailoring actions in SP 800-53B to specialize or customize the controls that represent the specific needs and concerns of those entities.
An information security program plan is a formal document that provides an overview of the security requirements for an organization-wide information security program and describes the program management controls and common controls in place or planned for meeting those requirements. An information security program plan can be represented in a single document or compilations of documents. Privacy program plans and supply chain risk management plans are addressed separately in PM-18 and SR-2, respectively.
An information security program plan documents implementation details about program management and common controls. The plan provides sufficient information about the controls (including specification of parameters for assignment and selection operations, explicitly or by reference) to enable implementations that are unambiguously compliant with the intent of the plan and a determination of the risk to be incurred if the plan is implemented as intended. Updates to information security program plans include organizational changes and problems identified during plan implementation or control assessments.
Program management controls may be implemented at the organization level or the mission or business process level, and are essential for managing the organization’s information security program. Program management controls are distinct from common, system-specific, and hybrid controls because program management controls are independent of any particular system. Together, the individual system security plans and the organization-wide information security program plan provide complete coverage for the security controls employed within the organization.
Common controls available for inheritance by organizational systems are documented in an appendix to the organization’s information security program plan unless the controls are included in a separate security plan for a system. The organization-wide information security program plan indicates which separate security plans contain descriptions of common controls.
Events that may precipitate an update to the information security program plan include, but are not limited to, organization-wide assessment or audit findings, security incidents or breaches, or changes in laws, executive orders, directives, regulations, policies, standards, and guidelines.
The senior agency information security officer is an organizational official. For federal agencies (as defined by applicable laws, executive orders, regulations, directives, policies, and standards), this official is the senior agency information security officer. Organizations may also refer to this official as the senior information security officer or chief information security officer.
Organizations consider establishing champions for information security and privacy and, as part of including the necessary resources, assign specialized expertise and resources as needed. Organizations may designate and empower an Investment Review Board or similar group to manage and provide oversight for the information security and privacy aspects of the capital planning and investment control process.
The plan of action and milestones is a key organizational document and is subject to reporting requirements established by the Office of Management and Budget. Organizations develop plans of action and milestones with an organization-wide perspective, prioritizing risk response actions and ensuring consistency with the goals and objectives of the organization. Plan of action and milestones updates are based on findings from control assessments and continuous monitoring activities. There can be multiple plans of action and milestones corresponding to the information system level, mission/business process level, and organizational/governance level. While plans of action and milestones are required for federal organizations, other types of organizations can help reduce risk by documenting and tracking planned remediations. Specific guidance on plans of action and milestones at the system level is provided in CA-5.
Measures of performance are outcome-based metrics used by an organization to measure the effectiveness or efficiency of the information security and privacy programs and the controls employed in support of the program. To facilitate security and privacy risk management, organizations consider aligning measures of performance with the organizational risk tolerance as defined in the risk management strategy.
The integration of security and privacy requirements and controls into the enterprise architecture helps to ensure that security and privacy considerations are addressed throughout the system development life cycle and are explicitly related to the organization’s mission and business processes. The process of security and privacy requirements integration also embeds into the enterprise architecture and the organization’s security and privacy architectures consistent with the organizational risk management strategy. For PM-7, security and privacy architectures are developed at a system-of-systems level, representing all organizational systems. For PL-8, the security and privacy architectures are developed at a level that represents an individual system. The system-level architectures are consistent with the security and privacy architectures defined for the organization. Security and privacy requirements and control integration are most effectively accomplished through the rigorous application of the Risk Management Framework SP 800-37 and supporting security standards and guidelines.
Protection strategies are based on the prioritization of critical assets and resources. The requirement and guidance for defining critical infrastructure and key resources and for preparing an associated critical infrastructure protection plan are found in applicable laws, executive orders, directives, policies, regulations, standards, and guidelines.
An organization-wide risk management strategy includes an expression of the security and privacy risk tolerance for the organization, security and privacy risk mitigation strategies, acceptable risk assessment methodologies, a process for evaluating security and privacy risk across the organization with respect to the organization’s risk tolerance, and approaches for monitoring risk over time. The senior accountable official for risk management (agency head or designated official) aligns information security management processes with strategic, operational, and budgetary planning processes. The risk executive function, led by the senior accountable official for risk management, can facilitate consistent application of the risk management strategy organization-wide. The risk management strategy can be informed by security and privacy risk-related inputs from other sources, both internal and external to the organization, to ensure that the strategy is broad-based and comprehensive. The supply chain risk management strategy described in PM-30 can also provide useful inputs to the organization-wide risk management strategy.
Authorization processes for organizational systems and environments of operation require the implementation of an organization-wide risk management process and associated security and privacy standards and guidelines. Specific roles for risk management processes include a risk executive (function) and designated authorizing officials for each organizational system and common control provider. The authorization processes for the organization are integrated with continuous monitoring processes to facilitate ongoing understanding and acceptance of security and privacy risks to organizational operations, organizational assets, individuals, other organizations, and the Nation.
Protection needs are technology-independent capabilities that are required to counter threats to organizations, individuals, systems, and the Nation through the compromise of information (i.e., loss of confidentiality, integrity, availability, or privacy). Information protection and personally identifiable information processing needs are derived from the mission and business needs defined by organizational stakeholders, the mission and business processes designed to meet those needs, and the organizational risk management strategy. Information protection and personally identifiable information processing needs determine the required controls for the organization and the systems. Inherent to defining protection and personally identifiable information processing needs is an understanding of the adverse impact that could result if a compromise or breach of information occurs. The categorization process is used to make such potential impact determinations. Privacy risks to individuals can arise from the compromise of personally identifiable information, but they can also arise as unintended consequences or a byproduct of the processing of personally identifiable information at any stage of the information life cycle. Privacy risk assessments are used to prioritize the risks that are created for individuals from system processing of personally identifiable information. These risk assessments enable the selection of the required privacy controls for the organization and systems. Mission and business process definitions and the associated protection requirements are documented in accordance with organizational policies and procedures.
Organizations that handle classified information are required, under Executive Order 13587 EO 13587 and the National Insider Threat Policy ODNI NITP, to establish insider threat programs. The same standards and guidelines that apply to insider threat programs in classified environments can also be employed effectively to improve the security of controlled unclassified and other information in non-national security systems. Insider threat programs include controls to detect and prevent malicious insider activity through the centralized integration and analysis of both technical and nontechnical information to identify potential insider threat concerns. A senior official is designated by the department or agency head as the responsible individual to implement and provide oversight for the program. In addition to the centralized integration and analysis capability, insider threat programs require organizations to prepare department or agency insider threat policies and implementation plans, conduct host-based user monitoring of individual employee activities on government-owned classified computers, provide insider threat awareness training to employees, receive access to information from offices in the department or agency for insider threat analysis, and conduct self-assessments of department or agency insider threat posture.
Insider threat programs can leverage the existence of incident handling teams that organizations may already have in place, such as computer security incident response teams. Human resources records are especially important in this effort, as there is compelling evidence to show that some types of insider crimes are often preceded by nontechnical behaviors in the workplace, including ongoing patterns of disgruntled behavior and conflicts with coworkers and other colleagues. These precursors can guide organizational officials in more focused, targeted monitoring efforts. However, the use of human resource records could raise significant concerns for privacy. The participation of a legal team, including consultation with the senior agency official for privacy, ensures that monitoring activities are performed in accordance with applicable laws, executive orders, directives, regulations, policies, standards, and guidelines.
Security and privacy workforce development and improvement programs include defining the knowledge, skills, and abilities needed to perform security and privacy duties and tasks; developing role-based training programs for individuals assigned security and privacy roles and responsibilities; and providing standards and guidelines for measuring and building individual qualifications for incumbents and applicants for security- and privacy-related positions. Such workforce development and improvement programs can also include security and privacy career paths to encourage security and privacy professionals to advance in the field and fill positions with greater responsibility. The programs encourage organizations to fill security- and privacy-related positions with qualified personnel. Security and privacy workforce development and improvement programs are complementary to organizational security awareness and training programs and focus on developing and institutionalizing the core security and privacy capabilities of personnel needed to protect organizational operations, assets, and individuals.
A process for organization-wide security and privacy testing, training, and monitoring helps ensure that organizations provide oversight for testing, training, and monitoring activities and that those activities are coordinated. With the growing importance of continuous monitoring programs, the implementation of information security and privacy across the three levels of the risk management hierarchy and the widespread use of common controls, organizations coordinate and consolidate the testing and monitoring activities that are routinely conducted as part of ongoing assessments supporting a variety of controls. Security and privacy training activities, while focused on individual systems and specific roles, require coordination across all organizational elements. Testing, training, and monitoring plans and activities are informed by current threat and vulnerability assessments.
Ongoing contact with security and privacy groups and associations is important in an environment of rapidly changing technologies and threats. Groups and associations include special interest groups, professional associations, forums, news groups, users’ groups, and peer groups of security and privacy professionals in similar organizations. Organizations select security and privacy groups and associations based on mission and business functions. Organizations share threat, vulnerability, and incident information as well as contextual insights, compliance techniques, and privacy problems consistent with applicable laws, executive orders, directives, policies, regulations, standards, and guidelines.
Because of the constantly changing and increasing sophistication of adversaries, especially the advanced persistent threat (APT), it may be more likely that adversaries can successfully breach or compromise organizational systems. One of the best techniques to address this concern is for organizations to share threat information, including threat events (i.e., tactics, techniques, and procedures) that organizations have experienced, mitigations that organizations have found are effective against certain types of threats, and threat intelligence (i.e., indications and warnings about threats). Threat information sharing may be bilateral or multilateral. Bilateral threat sharing includes government-to-commercial and government-to-government cooperatives. Multilateral threat sharing includes organizations taking part in threat-sharing consortia. Threat information may require special agreements and protection, or it may be freely shared.
Controlled unclassified information is defined by the National Archives and Records Administration along with the safeguarding and dissemination requirements for such information and is codified in 32 CFR 2002 and, specifically for systems external to the federal organization, 32 CFR 2002.14h. The policy prescribes the specific use and conditions to be implemented in accordance with organizational procedures, including via its contracting processes.
A privacy program plan is a formal document that provides an overview of an organization’s privacy program, including a description of the structure of the privacy program, the resources dedicated to the privacy program, the role of the senior agency official for privacy and other privacy officials and staff, the strategic goals and objectives of the privacy program, and the program management controls and common controls in place or planned for meeting applicable privacy requirements and managing privacy risks. Privacy program plans can be represented in single documents or compilations of documents.
The senior agency official for privacy is responsible for designating which privacy controls the organization will treat as program management, common, system-specific, and hybrid controls. Privacy program plans provide sufficient information about the privacy program management and common controls (including the specification of parameters and assignment and selection operations explicitly or by reference) to enable control implementations that are unambiguously compliant with the intent of the plans and a determination of the risk incurred if the plans are implemented as intended.
Program management controls are generally implemented at the organization level and are essential for managing the organization’s privacy program. Program management controls are distinct from common, system-specific, and hybrid controls because program management controls are independent of any particular information system. Together, the privacy plans for individual systems and the organization-wide privacy program plan provide complete coverage for the privacy controls employed within the organization.
Common controls are documented in an appendix to the organization’s privacy program plan unless the controls are included in a separate privacy plan for a system. The organization-wide privacy program plan indicates which separate privacy plans contain descriptions of privacy controls.
The privacy officer is an organizational official. For federal agencies—as defined by applicable laws, executive orders, directives, regulations, policies, standards, and guidelines—this official is designated as the senior agency official for privacy. Organizations may also refer to this official as the chief privacy officer. The senior agency official for privacy also has roles on the data management board (see PM-23) and the data integrity board (see PM-24).
For federal agencies, the webpage is located at www.[agency].gov/privacy. Federal agencies include public privacy impact assessments, system of records notices, computer matching notices and agreements, PRIVACT exemption and implementation rules, privacy reports, privacy policies, instructions for individuals making an access or amendment request, email addresses for questions/complaints, blogs, and periodic publications.
The purpose of accounting of disclosures is to allow individuals to learn to whom their personally identifiable information has been disclosed, to provide a basis for subsequently advising recipients of any corrected or disputed personally identifiable information, and to provide an audit trail for subsequent reviews of organizational compliance with conditions for disclosures. For federal agencies, keeping an accounting of disclosures is required by the PRIVACT; agencies should consult with their senior agency official for privacy and legal counsel on this requirement and be aware of the statutory exceptions and OMB guidance relating to the provision.
Organizations can use any system for keeping notations of disclosures, if it can construct from such a system, a document listing of all disclosures along with the required information. Automated mechanisms can be used by organizations to determine when personally identifiable information is disclosed, including commercial services that provide notifications and alerts. Accounting of disclosures may also be used to help organizations verify compliance with applicable privacy statutes and policies governing the disclosure or dissemination of information and dissemination restrictions.
Personally identifiable information quality management includes steps that organizations take to confirm the accuracy and relevance of personally identifiable information throughout the information life cycle. The information life cycle includes the creation, collection, use, processing, storage, maintenance, dissemination, disclosure, and disposition of personally identifiable information. Organizational policies and procedures for personally identifiable information quality management are important because inaccurate or outdated personally identifiable information maintained by organizations may cause problems for individuals. Organizations consider the quality of personally identifiable information involved in business functions where inaccurate information may result in adverse decisions or the denial of benefits and services, or the disclosure of the information may cause stigmatization. Correct information, in certain circumstances, can cause problems for individuals that outweigh the benefits of organizations maintaining the information. Organizations consider creating policies and procedures for the removal of such information.
The senior agency official for privacy ensures that practical means and mechanisms exist and are accessible for individuals or their authorized representatives to seek the correction or deletion of personally identifiable information. Processes for correcting or deleting data are clearly defined and publicly available. Organizations use discretion in determining whether data is to be deleted or corrected based on the scope of requests, the changes sought, and the impact of the changes. Additionally, processes include the provision of responses to individuals of decisions to deny requests for correction or deletion. The responses include the reasons for the decisions, a means to record individual objections to the decisions, and a means of requesting reviews of the initial determinations.
Organizations notify individuals or their designated representatives when their personally identifiable information is corrected or deleted to provide transparency and confirm the completed action. Due to the complexity of data flows and storage, other entities may need to be informed of the correction or deletion. Notice supports the consistent correction and deletion of personally identifiable information across the data ecosystem.
A Data Governance Body can help ensure that the organization has coherent policies and the ability to balance the utility of data with security and privacy requirements. The Data Governance Body establishes policies, procedures, and standards that facilitate data governance so that data, including personally identifiable information, is effectively managed and maintained in accordance with applicable laws, executive orders, directives, regulations, policies, standards, and guidance. Responsibilities can include developing and implementing guidelines that support data modeling, quality, integrity, and the de-identification needs of personally identifiable information across the information life cycle as well as reviewing and approving applications to release data outside of the organization, archiving the applications and the released data, and performing post-release monitoring to ensure that the assumptions made as part of the data release continue to be valid. Members include the chief information officer, senior agency information security officer, and senior agency official for privacy. Federal agencies are required to establish a Data Governance Body with specific roles and responsibilities in accordance with the EVIDACT and policies set forth under OMB M-19-23.
A Data Integrity Board is the board of senior officials designated by the head of a federal agency and is responsible for, among other things, reviewing the agency’s proposals to conduct or participate in a matching program and conducting an annual review of all matching programs in which the agency has participated. As a general matter, a matching program is a computerized comparison of records from two or more automated PRIVACT systems of records or an automated system of records and automated records maintained by a non-federal agency (or agent thereof). A matching program either pertains to Federal benefit programs or Federal personnel or payroll records. At a minimum, the Data Integrity Board includes the Inspector General of the agency, if any, and the senior agency official for privacy.
The use of personally identifiable information in testing, research, and training increases the risk of unauthorized disclosure or misuse of such information. Organizations consult with the senior agency official for privacy and/or legal counsel to ensure that the use of personally identifiable information in testing, training, and research is compatible with the original purpose for which it was collected. When possible, organizations use placeholder data to avoid exposure of personally identifiable information when conducting testing, training, and research.
Complaints, concerns, and questions from individuals can serve as valuable sources of input to organizations and ultimately improve operational models, uses of technology, data collection practices, and controls. Mechanisms that can be used by the public include telephone hotline, email, or web-based forms. The information necessary for successfully filing complaints includes contact information for the senior agency official for privacy or other official designated to receive complaints. Privacy complaints may also include personally identifiable information which is handled in accordance with relevant policies and processes.
Through internal and external reporting, organizations promote accountability and transparency in organizational privacy operations. Reporting can also help organizations to determine progress in meeting privacy compliance requirements and privacy controls, compare performance across the federal government, discover vulnerabilities, identify gaps in policy and implementation, and identify models for success. For federal agencies, privacy reports include annual senior agency official for privacy reports to OMB, reports to Congress required by Implementing Regulations of the 9/11 Commission Act, and other public reports required by law, regulation, or policy, including internal policies of organizations. The senior agency official for privacy consults with legal counsel, where appropriate, to ensure that organizations meet all applicable privacy reporting requirements.
Risk framing is most effective when conducted at the organization level and in consultation with stakeholders throughout the organization including mission, business, and system owners. The assumptions, constraints, risk tolerance, priorities, and trade-offs identified as part of the risk framing process inform the risk management strategy, which in turn informs the conduct of risk assessment, risk response, and risk monitoring activities. Risk framing results are shared with organizational personnel, including mission and business owners, information owners or stewards, system owners, authorizing officials, senior agency information security officer, senior agency official for privacy, and senior accountable official for risk management.
The senior accountable official for risk management leads the risk executive (function) in organization-wide risk management activities.
An organization-wide supply chain risk management strategy includes an unambiguous expression of the supply chain risk appetite and tolerance for the organization, acceptable supply chain risk mitigation strategies or controls, a process for consistently evaluating and monitoring supply chain risk, approaches for implementing and communicating the supply chain risk management strategy, and the associated roles and responsibilities. Supply chain risk management includes considerations of the security and privacy risks associated with the development, acquisition, maintenance, and disposal of systems, system components, and system services. The supply chain risk management strategy can be incorporated into the organization’s overarching risk management strategy and can guide and inform supply chain policies and system-level supply chain risk management plans. In addition, the use of a risk executive function can facilitate a consistent, organization-wide application of the supply chain risk management strategy. The supply chain risk management strategy is implemented at the organization and mission/business levels, whereas the supply chain risk management plan (see SR-2) is implemented at the system level.
Continuous monitoring at the organization level facilitates ongoing awareness of the security and privacy posture across the organization to support organizational risk management decisions. The terms continuous
and ongoing
imply that organizations assess and monitor their controls and risks at a frequency sufficient to support risk-based decisions. Different types of controls may require different monitoring frequencies. The results of continuous monitoring guide and inform risk response actions by organizations. Continuous monitoring programs allow organizations to maintain the authorizations of systems and common controls in highly dynamic environments of operation with changing mission and business needs, threats, vulnerabilities, and technologies. Having access to security- and privacy-related information on a continuing basis through reports and dashboards gives organizational officials the capability to make effective, timely, and informed risk management decisions, including ongoing authorization decisions. To further facilitate security and privacy risk management, organizations consider aligning organization-defined monitoring metrics with organizational risk tolerance as defined in the risk management strategy. Monitoring requirements, including the need for monitoring, may be referenced in other controls and control enhancements such as, AC-2g, AC-2(7), AC-2(12)(a), AC-2(7)(b), AC-2(7)(c), AC-17(1), AT-4a, AU-13, AU-13(1), AU-13(2), CA-7, CM-3f, CM-6d, CM-11c, IR-5, MA-2b, MA-3a, MA-4a, PE-3d, PE-6, PE-14b, PE-16, PE-20, PM-6, PM-23, PS-7e, SA-9c, SC-5(3)(b), SC-7a, SC-7(24)(b), SC-18b, SC-43b, SI-4.
Systems are designed to support a specific mission or business function. However, over time, systems and system components may be used to support services and functions that are outside of the scope of the intended mission or business functions. This can result in exposing information resources to unintended environments and uses that can significantly increase threat exposure. In doing so, the systems are more vulnerable to compromise, which can ultimately impact the services and functions for which they were intended. This is especially impactful for mission-essential services and functions. By analyzing resource use, organizations can identify such potential exposures.
Risk assessment policy and procedures address the controls in the RA family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of risk assessment policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies reflecting the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to risk assessment policy and procedures include assessment or audit findings, security incidents or breaches, or changes in laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.
Security categories describe the potential adverse impacts or negative consequences to organizational operations, organizational assets, and individuals if organizational information and systems are compromised through a loss of confidentiality, integrity, or availability. Security categorization is also a type of asset loss characterization in systems security engineering processes that is carried out throughout the system development life cycle. Organizations can use privacy risk assessments or privacy impact assessments to better understand the potential adverse effects on individuals. CNSSI 1253 provides additional guidance on categorization for national security systems.
Organizations conduct the security categorization process as an organization-wide activity with the direct involvement of chief information officers, senior agency information security officers, senior agency officials for privacy, system owners, mission and business owners, and information owners or stewards. Organizations consider the potential adverse impacts to other organizations and, in accordance with USA PATRIOT and Homeland Security Presidential Directives, potential national-level adverse impacts.
Security categorization processes facilitate the development of inventories of information assets and, along with CM-8, mappings to specific system components where information is processed, stored, or transmitted. The security categorization process is revisited throughout the system development life cycle to ensure that the security categories remain accurate and relevant.
Risk assessments consider threats, vulnerabilities, likelihood, and impact to organizational operations and assets, individuals, other organizations, and the Nation. Risk assessments also consider risk from external parties, including contractors who operate systems on behalf of the organization, individuals who access organizational systems, service providers, and outsourcing entities.
Organizations can conduct risk assessments at all three levels in the risk management hierarchy (i.e., organization level, mission/business process level, or information system level) and at any stage in the system development life cycle. Risk assessments can also be conducted at various steps in the Risk Management Framework, including preparation, categorization, control selection, control implementation, control assessment, authorization, and control monitoring. Risk assessment is an ongoing activity carried out throughout the system development life cycle.
Risk assessments can also address information related to the system, including system design, the intended use of the system, testing results, and supply chain-related information or artifacts. Risk assessments can play an important role in control selection processes, particularly during the application of tailoring guidance and in the earliest phases of capability determination.
Security categorization of information and systems guides the frequency and comprehensiveness of vulnerability monitoring (including scans). Organizations determine the required vulnerability monitoring for system components, ensuring that the potential sources of vulnerabilities—such as infrastructure components (e.g., switches, routers, guards, sensors), networked printers, scanners, and copiers—are not overlooked. The capability to readily update vulnerability monitoring tools as new vulnerabilities are discovered and announced and as new scanning methods are developed helps to ensure that new vulnerabilities are not missed by employed vulnerability monitoring tools. The vulnerability monitoring tool update process helps to ensure that potential vulnerabilities in the system are identified and addressed as quickly as possible. Vulnerability monitoring and analyses for custom software may require additional approaches, such as static analysis, dynamic analysis, binary analysis, or a hybrid of the three approaches. Organizations can use these analysis approaches in source code reviews and in a variety of tools, including web-based application scanners, static analysis tools, and binary analyzers.
Vulnerability monitoring includes scanning for patch levels; scanning for functions, ports, protocols, and services that should not be accessible to users or devices; and scanning for flow control mechanisms that are improperly configured or operating incorrectly. Vulnerability monitoring may also include continuous vulnerability monitoring tools that use instrumentation to continuously analyze components. Instrumentation-based tools may improve accuracy and may be run throughout an organization without scanning. Vulnerability monitoring tools that facilitate interoperability include tools that are Security Content Automated Protocol (SCAP)-validated. Thus, organizations consider using scanning tools that express vulnerabilities in the Common Vulnerabilities and Exposures (CVE) naming convention and that employ the Open Vulnerability Assessment Language (OVAL) to determine the presence of vulnerabilities. Sources for vulnerability information include the Common Weakness Enumeration (CWE) listing and the National Vulnerability Database (NVD). Control assessments, such as red team exercises, provide additional sources of potential vulnerabilities for which to scan. Organizations also consider using scanning tools that express vulnerability impact by the Common Vulnerability Scoring System (CVSS).
Vulnerability monitoring includes a channel and process for receiving reports of security vulnerabilities from the public at-large. Vulnerability disclosure programs can be as simple as publishing a monitored email address or web form that can receive reports, including notification authorizing good-faith research and disclosure of security vulnerabilities. Organizations generally expect that such research is happening with or without their authorization and can use public vulnerability disclosure channels to increase the likelihood that discovered vulnerabilities are reported directly to the organization for remediation.
Organizations may also employ the use of financial incentives (also known as bug bounties
) to further encourage external security researchers to report discovered vulnerabilities. Bug bounty programs can be tailored to the organization’s needs. Bounties can be operated indefinitely or over a defined period of time and can be offered to the general public or to a curated group. Organizations may run public and private bounties simultaneously and could choose to offer partially credentialed access to certain participants in order to evaluate security vulnerabilities from privileged vantage points.
A technical surveillance countermeasures survey is a service provided by qualified personnel to detect the presence of technical surveillance devices and hazards and to identify technical security weaknesses that could be used in the conduct of a technical penetration of the surveyed facility. Technical surveillance countermeasures surveys also provide evaluations of the technical security posture of organizations and facilities and include visual, electronic, and physical examinations of surveyed facilities, internally and externally. The surveys also provide useful input for risk assessments and information regarding organizational exposure to potential adversaries.
Organizations have many options for responding to risk including mitigating risk by implementing new controls or strengthening existing controls, accepting risk with appropriate justification or rationale, sharing or transferring risk, or avoiding risk. The risk tolerance of the organization influences risk response decisions and actions. Risk response addresses the need to determine an appropriate response to risk before generating a plan of action and milestones entry. For example, the response may be to accept risk or reject risk, or it may be possible to mitigate the risk immediately so that a plan of action and milestones entry is not needed. However, if the risk response is to mitigate the risk, and the mitigation cannot be completed immediately, a plan of action and milestones entry is generated.
A privacy impact assessment is an analysis of how personally identifiable information is handled to ensure that handling conforms to applicable privacy requirements, determine the privacy risks associated with an information system or activity, and evaluate ways to mitigate privacy risks. A privacy impact assessment is both an analysis and a formal document that details the process and the outcome of the analysis.
Organizations conduct and develop a privacy impact assessment with sufficient clarity and specificity to demonstrate that the organization fully considered privacy and incorporated appropriate privacy protections from the earliest stages of the organization’s activity and throughout the information life cycle. In order to conduct a meaningful privacy impact assessment, the organization’s senior agency official for privacy works closely with program managers, system owners, information technology experts, security officials, counsel, and other relevant organization personnel. Moreover, a privacy impact assessment is not a time-restricted activity that is limited to a particular milestone or stage of the information system or personally identifiable information life cycles. Rather, the privacy analysis continues throughout the system and personally identifiable information life cycles. Accordingly, a privacy impact assessment is a living document that organizations update whenever changes to the information technology, changes to the organization’s practices, or other factors alter the privacy risks associated with the use of such information technology.
To conduct the privacy impact assessment, organizations can use security and privacy risk assessments. Organizations may also use other related processes that may have different names, including privacy threshold analyses. A privacy impact assessment can also serve as notice to the public regarding the organization’s practices with respect to privacy. Although conducting and publishing privacy impact assessments may be required by law, organizations may develop such policies in the absence of applicable laws. For federal agencies, privacy impact assessments may be required by EGOV; agencies should consult with their senior agency official for privacy and legal counsel on this requirement and be aware of the statutory exceptions and OMB guidance relating to the provision.
Not all system components, functions, or services necessarily require significant protections. For example, criticality analysis is a key tenet of supply chain risk management and informs the prioritization of protection activities. The identification of critical system components and functions considers applicable laws, executive orders, regulations, directives, policies, standards, system functionality requirements, system and component interfaces, and system and component dependencies. Systems engineers conduct a functional decomposition of a system to identify mission-critical functions and components. The functional decomposition includes the identification of organizational missions supported by the system, decomposition into the specific functions to perform those missions, and traceability to the hardware, software, and firmware components that implement those functions, including when the functions are shared by many components within and external to the system.
The operational environment of a system or a system component may impact the criticality, including the connections to and dependencies on cyber-physical systems, devices, system-of-systems, and outsourced IT services. System components that allow unmediated access to critical system components or functions are considered critical due to the inherent vulnerabilities that such components create. Component and function criticality are assessed in terms of the impact of a component or function failure on the organizational missions that are supported by the system that contains the components and functions.
Criticality analysis is performed when an architecture or design is being developed, modified, or upgraded. If such analysis is performed early in the system development life cycle, organizations may be able to modify the system design to reduce the critical nature of these components and functions, such as by adding redundancy or alternate paths into the system design. Criticality analysis can also influence the protection measures required by development contractors. In addition to criticality analysis for systems, system components, and system services, criticality analysis of information is an important consideration. Such analysis is conducted as part of security categorization in RA-2.
Threat hunting is an active means of cyber defense in contrast to traditional protection measures, such as firewalls, intrusion detection and prevention systems, quarantining malicious code in sandboxes, and Security Information and Event Management technologies and systems. Cyber threat hunting involves proactively searching organizational systems, networks, and infrastructure for advanced threats. The objective is to track and disrupt cyber adversaries as early as possible in the attack sequence and to measurably improve the speed and accuracy of organizational responses. Indications of compromise include unusual network traffic, unusual file changes, and the presence of malicious code. Threat hunting teams leverage existing threat intelligence and may create new threat intelligence, which is shared with peer organizations, Information Sharing and Analysis Organizations (ISAO), Information Sharing and Analysis Centers (ISAC), and relevant government departments and agencies.
System and services acquisition policy and procedures address the controls in the SA family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of system and services acquisition policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to system and services acquisition policy and procedures include assessment or audit findings, security incidents or breaches, or changes in laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.
Resource allocation for information security and privacy includes funding for system and services acquisition, sustainment, and supply chain-related risks throughout the system development life cycle.
A system development life cycle process provides the foundation for the successful development, implementation, and operation of organizational systems. The integration of security and privacy considerations early in the system development life cycle is a foundational principle of systems security engineering and privacy engineering. To apply the required controls within the system development life cycle requires a basic understanding of information security and privacy, threats, vulnerabilities, adverse impacts, and risk to critical mission and business functions. The security engineering principles in SA-8 help individuals properly design, code, and test systems and system components. Organizations include qualified personnel (e.g., senior agency information security officers, senior agency officials for privacy, security and privacy architects, and security and privacy engineers) in system development life cycle processes to ensure that established security and privacy requirements are incorporated into organizational systems. Role-based security and privacy training programs can ensure that individuals with key security and privacy roles and responsibilities have the experience, skills, and expertise to conduct assigned system development life cycle activities.
The effective integration of security and privacy requirements into enterprise architecture also helps to ensure that important security and privacy considerations are addressed throughout the system life cycle and that those considerations are directly related to organizational mission and business processes. This process also facilitates the integration of the information security and privacy architectures into the enterprise architecture, consistent with the risk management strategy of the organization. Because the system development life cycle involves multiple organizations, (e.g., external suppliers, developers, integrators, service providers), acquisition and supply chain risk management functions and controls play significant roles in the effective management of the system during the life cycle.
Security and privacy functional requirements are typically derived from the high-level security and privacy requirements described in SA-2. The derived requirements include security and privacy capabilities, functions, and mechanisms. Strength requirements associated with such capabilities, functions, and mechanisms include degree of correctness, completeness, resistance to tampering or bypass, and resistance to direct attack. Assurance requirements include development processes, procedures, and methodologies as well as the evidence from development and assessment activities that provide grounds for confidence that the required functionality is implemented and possesses the required strength of mechanism. SP 800-160-1 describes the process of requirements engineering as part of the system development life cycle.
Controls can be viewed as descriptions of the safeguards and protection capabilities appropriate for achieving the particular security and privacy objectives of the organization and for reflecting the security and privacy requirements of stakeholders. Controls are selected and implemented in order to satisfy system requirements and include developer and organizational responsibilities. Controls can include technical, administrative, and physical aspects. In some cases, the selection and implementation of a control may necessitate additional specification by the organization in the form of derived requirements or instantiated control parameter values. The derived requirements and control parameter values may be necessary to provide the appropriate level of implementation detail for controls within the system development life cycle.
Security and privacy documentation requirements address all stages of the system development life cycle. Documentation provides user and administrator guidance for the implementation and operation of controls. The level of detail required in such documentation is based on the security categorization or classification level of the system and the degree to which organizations depend on the capabilities, functions, or mechanisms to meet risk response expectations. Requirements can include mandated configuration settings that specify allowed functions, ports, protocols, and services. Acceptance criteria for systems, system components, and system services are defined in the same manner as the criteria for any organizational acquisition or procurement.
System documentation helps personnel understand the implementation and operation of controls. Organizations consider establishing specific measures to determine the quality and completeness of the content provided. System documentation may be used to support the management of supply chain risk, incident response, and other functions. Personnel or roles that require documentation include system owners, system security officers, and system administrators. Attempts to obtain documentation include contacting manufacturers or suppliers and conducting web-based searches. The inability to obtain documentation may occur due to the age of the system or component or the lack of support from developers and contractors. When documentation cannot be obtained, organizations may need to recreate the documentation if it is essential to the implementation or operation of the controls. The protection provided for the documentation is commensurate with the security category or classification of the system. Documentation that addresses system vulnerabilities may require an increased level of protection. Secure operation of the system includes initially starting the system and resuming secure system operation after a lapse in system operation.
Systems security and privacy engineering principles are closely related to and implemented throughout the system development life cycle (see SA-3). Organizations can apply systems security and privacy engineering principles to new systems under development or to systems undergoing upgrades. For existing systems, organizations apply systems security and privacy engineering principles to system upgrades and modifications to the extent feasible, given the current state of hardware, software, and firmware components within those systems.
The application of systems security and privacy engineering principles helps organizations develop trustworthy, secure, and resilient systems and reduces the susceptibility to disruptions, hazards, threats, and the creation of privacy problems for individuals. Examples of system security engineering principles include: developing layered protections; establishing security and privacy policies, architecture, and controls as the foundation for design and development; incorporating security and privacy requirements into the system development life cycle; delineating physical and logical security boundaries; ensuring that developers are trained on how to build secure software; tailoring controls to meet organizational needs; and performing threat modeling to identify use cases, threat agents, attack vectors and patterns, design patterns, and compensating controls needed to mitigate risk.
Organizations that apply systems security and privacy engineering concepts and principles can facilitate the development of trustworthy, secure systems, system components, and system services; reduce risk to acceptable levels; and make informed risk management decisions. System security engineering principles can also be used to protect against certain supply chain risks, including incorporating tamper-resistant hardware into a design.
External system services are provided by an external provider, and the organization has no direct control over the implementation of the required controls or the assessment of control effectiveness. Organizations establish relationships with external service providers in a variety of ways, including through business partnerships, contracts, interagency agreements, lines of business arrangements, licensing agreements, joint ventures, and supply chain exchanges. The responsibility for managing risks from the use of external system services remains with authorizing officials. For services external to organizations, a chain of trust requires that organizations establish and retain a certain level of confidence that each provider in the consumer-provider relationship provides adequate protection for the services rendered. The extent and nature of this chain of trust vary based on relationships between organizations and the external providers. Organizations document the basis for the trust relationships so that the relationships can be monitored. External system services documentation includes government, service providers, end user security roles and responsibilities, and service-level agreements. Service-level agreements define the expectations of performance for implemented controls, describe measurable outcomes, and identify remedies and response requirements for identified instances of noncompliance.
Organizations consider the quality and completeness of configuration management activities conducted by developers as direct evidence of applying effective security controls. Controls include protecting the master copies of material used to generate security-relevant portions of the system hardware, software, and firmware from unauthorized modification or destruction. Maintaining the integrity of changes to the system, system component, or system service requires strict configuration control throughout the system development life cycle to track authorized changes and prevent unauthorized changes.
The configuration items that are placed under configuration management include the formal model; the functional, high-level, and low-level design specifications; other design data; implementation documentation; source code and hardware schematics; the current running version of the object code; tools for comparing new versions of security-relevant hardware descriptions and source code with previous versions; and test fixtures and documentation. Depending on the mission and business needs of organizations and the nature of the contractual relationships in place, developers may provide configuration management support during the operations and maintenance stage of the system development life cycle.
Developmental testing and evaluation confirms that the required controls are implemented correctly, operating as intended, enforcing the desired security and privacy policies, and meeting established security and privacy requirements. Security properties of systems and the privacy of individuals may be affected by the interconnection of system components or changes to those components. The interconnections or changes—including upgrading or replacing applications, operating systems, and firmware—may adversely affect previously implemented controls. Ongoing assessment during development allows for additional types of testing and evaluation that developers can conduct to reduce or eliminate potential flaws. Testing custom software applications may require approaches such as manual code review, security architecture review, and penetration testing, as well as and static analysis, dynamic analysis, binary analysis, or a hybrid of the three analysis approaches.
Developers can use the analysis approaches, along with security instrumentation and fuzzing, in a variety of tools and in source code reviews. The security and privacy assessment plans include the specific activities that developers plan to carry out, including the types of analyses, testing, evaluation, and reviews of software and firmware components; the degree of rigor to be applied; the frequency of the ongoing testing and evaluation; and the types of artifacts produced during those processes. The depth of testing and evaluation refers to the rigor and level of detail associated with the assessment process. The coverage of testing and evaluation refers to the scope (i.e., number and type) of the artifacts included in the assessment process. Contracts specify the acceptance criteria for security and privacy assessment plans, flaw remediation processes, and the evidence that the plans and processes have been diligently applied. Methods for reviewing and protecting assessment plans, evidence, and documentation are commensurate with the security category or classification level of the system. Contracts may specify protection requirements for documentation.
Development tools include programming languages and computer-aided design systems. Reviews of development processes include the use of maturity models to determine the potential effectiveness of such processes. Maintaining the integrity of changes to tools and processes facilitates effective supply chain risk assessment and mitigation. Such integrity requires configuration control throughout the system development life cycle to track authorized changes and prevent unauthorized changes.
Developer-provided training applies to external and internal (in-house) developers. Training personnel is essential to ensuring the effectiveness of the controls implemented within organizational systems. Types of training include web-based and computer-based training, classroom-style training, and hands-on training (including micro-training). Organizations can also request training materials from developers to conduct in-house training or offer self-training to organizational personnel. Organizations determine the type of training necessary and may require different types of training for different security and privacy functions, controls, and mechanisms.
Developer security and privacy architecture and design are directed at external developers, although they could also be applied to internal (in-house) development. In contrast, PL-8 is directed at internal developers to ensure that organizations develop a security and privacy architecture that is integrated with the enterprise architecture. The distinction between SA-17 and PL-8 is especially important when organizations outsource the development of systems, system components, or system services and when there is a requirement to demonstrate consistency with the enterprise architecture and security and privacy architecture of the organization. ISO 15408-2, ISO 15408-3, and SP 800-160-1 provide information on security architecture and design, including formal policy models, security-relevant components, formal and informal correspondence, conceptually simple design, and structuring for least privilege and testing.
Organizations determine that certain system components likely cannot be trusted due to specific threats to and vulnerabilities in those components for which there are no viable security controls to adequately mitigate risk. Reimplementation or custom development of such components may satisfy requirements for higher assurance and is carried out by initiating changes to system components (including hardware, software, and firmware) such that the standard attacks by adversaries are less likely to succeed. In situations where no alternative sourcing is available and organizations choose not to reimplement or custom develop critical system components, additional controls can be employed. Controls include enhanced auditing, restrictions on source code and system utility access, and protection from deletion of system and application files.
Developer screening is directed at external developers. Internal developer screening is addressed by PS-3. Because the system, system component, or system service may be used in critical activities essential to the national or economic security interests of the United States, organizations have a strong interest in ensuring that developers are trustworthy. The degree of trust required of developers may need to be consistent with that of the individuals who access the systems, system components, or system services once deployed. Authorization and personnel screening criteria include clearances, background checks, citizenship, and nationality. Developer trustworthiness may also include a review and analysis of company ownership and relationships that the company has with entities that may potentially affect the quality and reliability of the systems, components, or services being developed. Satisfying the required access authorizations and personnel screening criteria includes providing a list of all individuals who are authorized to perform development activities on the selected system, system component, or system service so that organizations can validate that the developer has satisfied the authorization and screening requirements.
Support for system components includes software patches, firmware updates, replacement parts, and maintenance contracts. An example of unsupported components includes when vendors no longer provide critical software patches or product updates, which can result in an opportunity for adversaries to exploit weaknesses in the installed components. Exceptions to replacing unsupported system components include systems that provide critical mission or business capabilities where newer technologies are not available or where the systems are so isolated that installing replacement components is not an option.
Alternative sources for support address the need to provide continued support for system components that are no longer supported by the original manufacturers, developers, or vendors when such components remain essential to organizational mission and business functions. If necessary, organizations can establish in-house support by developing customized patches for critical software components or, alternatively, obtain the services of external providers who provide ongoing support for the designated unsupported components through contractual relationships. Such contractual relationships can include open-source software value-added vendors. The increased risk of using unsupported system components can be mitigated, for example, by prohibiting the connection of such components to public or uncontrolled networks, or implementing other forms of isolation.
It is often necessary for a system or system component that supports mission-essential services or functions to be enhanced to maximize the trustworthiness of the resource. Sometimes this enhancement is done at the design level. In other instances, it is done post-design, either through modifications of the system in question or by augmenting the system with additional components. For example, supplemental authentication or non-repudiation functions may be added to the system to enhance the identity of critical resources to other resources that depend on the organization-defined resources.
Supply chain risk management policy and procedures address the controls in the SR family as well as supply chain-related controls in other families that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of supply chain risk management policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to supply chain risk management policy and procedures include assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.
The dependence on products, systems, and services from external providers, as well as the nature of the relationships with those providers, present an increasing level of risk to an organization. Threat actions that may increase security or privacy risks include unauthorized production, the insertion or use of counterfeits, tampering, theft, insertion of malicious software and hardware, and poor manufacturing and development practices in the supply chain. Supply chain risks can be endemic or systemic within a system element or component, a system, an organization, a sector, or the Nation. Managing supply chain risk is a complex, multifaceted undertaking that requires a coordinated effort across an organization to build trust relationships and communicate with internal and external stakeholders. Supply chain risk management (SCRM) activities include identifying and assessing risks, determining appropriate risk response actions, developing SCRM plans to document response actions, and monitoring performance against plans. The SCRM plan (at the system-level) is implementation specific, providing policy implementation, requirements, constraints and implications. It can either be stand-alone, or incorporated into system security and privacy plans. The SCRM plan addresses managing, implementation, and monitoring of SCRM controls and the development/sustainment of systems across the SDLC to support mission and business functions.
Because supply chains can differ significantly across and within organizations, SCRM plans are tailored to the individual program, organizational, and operational contexts. Tailored SCRM plans provide the basis for determining whether a technology, service, system component, or system is fit for purpose, and as such, the controls need to be tailored accordingly. Tailored SCRM plans help organizations focus their resources on the most critical mission and business functions based on mission and business requirements and their risk environment. Supply chain risk management plans include an expression of the supply chain risk tolerance for the organization, acceptable supply chain risk mitigation strategies or controls, a process for consistently evaluating and monitoring supply chain risk, approaches for implementing and communicating the plan, a description of and justification for supply chain risk mitigation measures taken, and associated roles and responsibilities. Finally, supply chain risk management plans address requirements for developing trustworthy, secure, privacy-protective, and resilient system components and systems, including the application of the security design principles implemented as part of life cycle-based systems security engineering processes (see SA-8).
Supply chain elements include organizations, entities, or tools employed for the research and development, design, manufacturing, acquisition, delivery, integration, operations and maintenance, and disposal of systems and system components. Supply chain processes include hardware, software, and firmware development processes; shipping and handling procedures; personnel security and physical security programs; configuration management tools, techniques, and measures to maintain provenance; or other programs, processes, or procedures associated with the development, acquisition, maintenance and disposal of systems and system components. Supply chain elements and processes may be provided by organizations, system integrators, or external providers. Weaknesses or deficiencies in supply chain elements or processes represent potential vulnerabilities that can be exploited by adversaries to cause harm to the organization and affect its ability to carry out its core missions or business functions. Supply chain personnel are individuals with roles and responsibilities in the supply chain.
Every system and system component has a point of origin and may be changed throughout its existence. Provenance is the chronology of the origin, development, ownership, location, and changes to a system or system component and associated data. It may also include personnel and processes used to interact with or make modifications to the system, component, or associated data. Organizations consider developing procedures (see SR-1) for allocating responsibilities for the creation, maintenance, and monitoring of provenance for systems and system components; transferring provenance documentation and responsibility between organizations; and preventing and monitoring for unauthorized changes to the provenance records. Organizations have methods to document, monitor, and maintain valid provenance baselines for systems, system components, and related data. These actions help track, assess, and document any changes to the provenance, including changes in supply chain elements or configuration, and help ensure non-repudiation of provenance information and the provenance change records. Provenance considerations are addressed throughout the system development life cycle and incorporated into contracts and other arrangements, as appropriate.
The use of the acquisition process provides an important vehicle to protect the supply chain. There are many useful tools and techniques available, including obscuring the end use of a system or system component, using blind or filtered buys, requiring tamper-evident packaging, or using trusted or controlled distribution. The results from a supply chain risk assessment can guide and inform the strategies, tools, and methods that are most applicable to the situation. Tools and techniques may provide protections against unauthorized production, theft, tampering, insertion of counterfeits, insertion of malicious software or backdoors, and poor development practices throughout the system development life cycle. Organizations also consider providing incentives for suppliers who implement controls, promote transparency into their processes and security and privacy practices, provide contract language that addresses the prohibition of tainted or counterfeit components, and restrict purchases from untrustworthy suppliers. Organizations consider providing training, education, and awareness programs for personnel regarding supply chain risk, available mitigation strategies, and when the programs should be employed. Methods for reviewing and protecting development plans, documentation, and evidence are commensurate with the security and privacy requirements of the organization. Contracts may specify documentation protection requirements.
An assessment and review of supplier risk includes security and supply chain risk management processes, foreign ownership, control or influence (FOCI), and the ability of the supplier to effectively assess subordinate second-tier and third-tier suppliers and contractors. The reviews may be conducted by the organization or by an independent third party. The reviews consider documented processes, documented controls, all-source intelligence, and publicly available information related to the supplier or contractor. Organizations can use open-source information to monitor for indications of stolen information, poor development and quality control practices, information spillage, or counterfeits. In some cases, it may be appropriate or required to share assessment and review results with other organizations in accordance with any applicable rules, policies, or inter-organizational agreements or contracts.
Supply chain OPSEC expands the scope of OPSEC to include suppliers and potential suppliers. OPSEC is a process that includes identifying critical information, analyzing friendly actions related to operations and other activities to identify actions that can be observed by potential adversaries, determining indicators that potential adversaries might obtain that could be interpreted or pieced together to derive information in sufficient time to cause harm to organizations, implementing safeguards or countermeasures to eliminate or reduce exploitable vulnerabilities and risk to an acceptable level, and considering how aggregated information may expose users or specific uses of the supply chain. Supply chain information includes user identities; uses for systems, system components, and system services; supplier identities; security and privacy requirements; system and component configurations; supplier processes; design specifications; and testing and evaluation results. Supply chain OPSEC may require organizations to withhold mission or business information from suppliers and may include the use of intermediaries to hide the end use or users of systems, system components, or system services.
The establishment of agreements and procedures facilitates communications among supply chain entities. Early notification of compromises and potential compromises in the supply chain that can potentially adversely affect or have adversely affected organizational systems or system components is essential for organizations to effectively respond to such incidents. The results of assessments or audits may include open-source information that contributed to a decision or result and could be used to help the supply chain entity resolve a concern or improve its processes.
Anti-tamper technologies, tools, and techniques provide a level of protection for systems, system components, and services against many threats, including reverse engineering, modification, and substitution. Strong identification combined with tamper resistance and/or tamper detection is essential to protecting systems and components during distribution and when in use.
The inspection of systems or systems components for tamper resistance and detection addresses physical and logical tampering and is applied to systems and system components removed from organization-controlled areas. Indications of a need for inspection include changes in packaging, specifications, factory location, or entity in which the part is purchased, and when individuals return from travel to high-risk locations.
Sources of counterfeit components include manufacturers, developers, vendors, and contractors. Anti-counterfeiting policies and procedures support tamper resistance and provide a level of protection against the introduction of malicious code. External reporting organizations include CISA.
Data, documentation, tools, or system components can be disposed of at any time during the system development life cycle (not only in the disposal or retirement phase of the life cycle). For example, disposal can occur during research and development, design, prototyping, or operations/maintenance and include methods such as disk cleaning, removal of cryptographic keys, partial reuse of components. Opportunities for compromise during disposal affect physical and logical data, including system documentation in paper-based or digital files; shipping and delivery documentation; memory sticks with software code; or complete routers or servers that include permanent media, which contain sensitive or proprietary information. Additionally, proper disposal of system components helps to prevent such components from entering the gray market.
Awareness and training policy and procedures address the controls in the AT family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of awareness and training policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to awareness and training policy and procedures include assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.
Organizations provide basic and advanced levels of literacy training to system users, including measures to test the knowledge level of users. Organizations determine the content of literacy training and awareness based on specific organizational requirements, the systems to which personnel have authorized access, and work environments (e.g., telework). The content includes an understanding of the need for security and privacy as well as actions by users to maintain security and personal privacy and to respond to suspected incidents. The content addresses the need for operations security and the handling of personally identifiable information.
Awareness techniques include displaying posters, offering supplies inscribed with security and privacy reminders, displaying logon screen messages, generating email advisories or notices from organizational officials, and conducting awareness events. Literacy training after the initial training described in AT-2a.1 is conducted at a minimum frequency consistent with applicable laws, directives, regulations, and policies. Subsequent literacy training may be satisfied by one or more short ad hoc sessions and include topical information on recent attack schemes, changes to organizational security and privacy policies, revised security and privacy expectations, or a subset of topics from the initial training. Updating literacy training and awareness content on a regular basis helps to ensure that the content remains relevant. Events that may precipitate an update to literacy training and awareness content include, but are not limited to, assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines.
Organizations determine the content of training based on the assigned roles and responsibilities of individuals as well as the security and privacy requirements of organizations and the systems to which personnel have authorized access, including technical training specifically tailored for assigned duties. Roles that may require role-based training include senior leaders or management officials (e.g., head of agency/chief executive officer, chief information officer, senior accountable official for risk management, senior agency information security officer, senior agency official for privacy), system owners; authorizing officials; system security officers; privacy officers; acquisition and procurement officials; enterprise architects; systems engineers; software developers; systems security engineers; privacy engineers; system, network, and database administrators; auditors; personnel conducting configuration management activities; personnel performing verification and validation activities; personnel with access to system-level software; control assessors; personnel with contingency planning and incident response duties; personnel with privacy management responsibilities; and personnel with access to personally identifiable information.
Comprehensive role-based training addresses management, operational, and technical roles and responsibilities covering physical, personnel, and technical controls. Role-based training also includes policies, procedures, tools, methods, and artifacts for the security and privacy roles defined. Organizations provide the training necessary for individuals to fulfill their responsibilities related to operations and supply chain risk management within the context of organizational security and privacy programs. Role-based training also applies to contractors who provide services to federal agencies. Types of training include web-based and computer-based training, classroom-style training, and hands-on training (including micro-training). Updating role-based training on a regular basis helps to ensure that the content remains relevant and effective. Events that may precipitate an update to role-based training content include, but are not limited to, assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines.
Documentation for specialized training may be maintained by individual supervisors at the discretion of the organization. The National Archives and Records Administration provides guidance on records retention for federal agencies.
Training feedback includes awareness training results and role-based training results. Training results, especially failures of personnel in critical roles, can be indicative of a potentially serious problem. Therefore, it is important that senior managers are made aware of such situations so that they can take appropriate response actions. Training feedback supports the evaluation and update of organizational training described in AT-2b and AT-3b.
Configuration management policy and procedures address the controls in the CM family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of configuration management policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission/business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to configuration management policy and procedures include, but are not limited to, assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.
Baseline configurations for systems and system components include connectivity, operational, and communications aspects of systems. Baseline configurations are documented, formally reviewed, and agreed-upon specifications for systems or configuration items within those systems. Baseline configurations serve as a basis for future builds, releases, or changes to systems and include security and privacy control implementations, operational procedures, information about system components, network topology, and logical placement of components in the system architecture. Maintaining baseline configurations requires creating new baselines as organizational systems change over time. Baseline configurations of systems reflect the current enterprise architecture.
Configuration change control for organizational systems involves the systematic proposal, justification, implementation, testing, review, and disposition of system changes, including system upgrades and modifications. Configuration change control includes changes to baseline configurations, configuration items of systems, operational procedures, configuration settings for system components, remediate vulnerabilities, and unscheduled or unauthorized changes. Processes for managing configuration changes to systems include Configuration Control Boards or Change Advisory Boards that review and approve proposed changes. For changes that impact privacy risk, the senior agency official for privacy updates privacy impact assessments and system of records notices. For new systems or major upgrades, organizations consider including representatives from the development organizations on the Configuration Control Boards or Change Advisory Boards. Auditing of changes includes activities before and after changes are made to systems and the auditing activities required to implement such changes. See also SA-10.
Organizational personnel with security or privacy responsibilities conduct impact analyses. Individuals conducting impact analyses possess the necessary skills and technical expertise to analyze the changes to systems as well as the security or privacy ramifications. Impact analyses include reviewing security and privacy plans, policies, and procedures to understand control requirements; reviewing system design documentation and operational procedures to understand control implementation and how specific system changes might affect the controls; reviewing the impact of changes on organizational supply chain partners with stakeholders; and determining how potential changes to a system create new risks to the privacy of individuals and the ability of implemented controls to mitigate those risks. Impact analyses also include risk assessments to understand the impact of the changes and determine if additional controls are required.
Changes to the hardware, software, or firmware components of systems or the operational procedures related to the system can potentially have significant effects on the security of the systems or individuals’ privacy. Therefore, organizations permit only qualified and authorized individuals to access systems for purposes of initiating changes. Access restrictions include physical and logical access controls (see AC-3 and PE-3), software libraries, workflow automation, media libraries, abstract layers (i.e., changes implemented into external interfaces rather than directly into systems), and change windows (i.e., changes occur only during specified times).
Configuration settings are the parameters that can be changed in the hardware, software, or firmware components of the system that affect the security and privacy posture or functionality of the system. Information technology products for which configuration settings can be defined include mainframe computers, servers, workstations, operating systems, mobile devices, input/output devices, protocols, and applications. Parameters that impact the security posture of systems include registry settings; account, file, or directory permission settings; and settings for functions, protocols, ports, services, and remote connections. Privacy parameters are parameters impacting the privacy posture of systems, including the parameters required to satisfy other privacy controls. Privacy parameters include settings for access controls, data processing preferences, and processing and retention permissions. Organizations establish organization-wide configuration settings and subsequently derive specific configuration settings for systems. The established settings become part of the configuration baseline for the system.
Common secure configurations (also known as security configuration checklists, lockdown and hardening guides, and security reference guides) provide recognized, standardized, and established benchmarks that stipulate secure configuration settings for information technology products and platforms as well as instructions for configuring those products or platforms to meet operational requirements. Common secure configurations can be developed by a variety of organizations, including information technology product developers, manufacturers, vendors, federal agencies, consortia, academia, industry, and other organizations in the public and private sectors.
Implementation of a common secure configuration may be mandated at the organization level, mission and business process level, system level, or at a higher level, including by a regulatory agency. Common secure configurations include the United States Government Configuration Baseline USGCB and security technical implementation guides (STIGs), which affect the implementation of CM-6 and other controls such as AC-19 and CM-7. The Security Content Automation Protocol (SCAP) and the defined standards within the protocol provide an effective method to uniquely identify, track, and control configuration settings.
Systems provide a wide variety of functions and services. Some of the functions and services routinely provided by default may not be necessary to support essential organizational missions, functions, or operations. Additionally, it is sometimes convenient to provide multiple services from a single system component, but doing so increases risk over limiting the services provided by that single component. Where feasible, organizations limit component functionality to a single function per component. Organizations consider removing unused or unnecessary software and disabling unused or unnecessary physical and logical ports and protocols to prevent unauthorized connection of components, transfer of information, and tunneling. Organizations employ network scanning tools, intrusion detection and prevention systems, and end-point protection technologies, such as firewalls and host-based intrusion detection systems, to identify and prevent the use of prohibited functions, protocols, ports, and services. Least functionality can also be achieved as part of the fundamental design and development of the system (see SA-8, SC-2, and SC-3).
System components are discrete, identifiable information technology assets that include hardware, software, and firmware. Organizations may choose to implement centralized system component inventories that include components from all organizational systems. In such situations, organizations ensure that the inventories include system-specific information required for component accountability. The information necessary for effective accountability of system components includes the system name, software owners, software version numbers, hardware inventory specifications, software license information, and for networked components, the machine names and network addresses across all implemented protocols (e.g., IPv4, IPv6). Inventory specifications include date of receipt, cost, model, serial number, manufacturer, supplier information, component type, and physical location.
Preventing duplicate accounting of system components addresses the lack of accountability that occurs when component ownership and system association is not known, especially in large or complex connected systems. Effective prevention of duplicate accounting of system components necessitates use of a unique identifier for each component. For software inventory, centrally managed software that is accessed via other systems is addressed as a component of the system on which it is installed and managed. Software installed on multiple organizational systems and managed at the system level is addressed for each individual system and may appear more than once in a centralized component inventory, necessitating a system association for each software instance in the centralized inventory to avoid duplicate accounting of components. Scanning systems implementing multiple network protocols (e.g., IPv4 and IPv6) can result in duplicate components being identified in different address spaces. The implementation of CM-8(7) can help to eliminate duplicate accounting of components.
Configuration management activities occur throughout the system development life cycle. As such, there are developmental configuration management activities (e.g., the control of code and software libraries) and operational configuration management activities (e.g., control of installed components and how the components are configured). Configuration management plans satisfy the requirements in configuration management policies while being tailored to individual systems. Configuration management plans define processes and procedures for how configuration management is used to support system development life cycle activities.
Configuration management plans are generated during the development and acquisition stage of the system development life cycle. The plans describe how to advance changes through change management processes; update configuration settings and baselines; maintain component inventories; control development, test, and operational environments; and develop, release, and update key documents.
Organizations can employ templates to help ensure the consistent and timely development and implementation of configuration management plans. Templates can represent a configuration management plan for the organization with subsets of the plan implemented on a system by system basis. Configuration management approval processes include the designation of key stakeholders responsible for reviewing and approving proposed changes to systems, and personnel who conduct security and privacy impact analyses prior to the implementation of changes to the systems. Configuration items are the system components, such as the hardware, software, firmware, and documentation to be configuration-managed. As systems continue through the system development life cycle, new configuration items may be identified, and some existing configuration items may no longer need to be under configuration control.
Software license tracking can be accomplished by manual or automated methods, depending on organizational needs. Examples of contract agreements include software license agreements and non-disclosure agreements.
If provided the necessary privileges, users can install software in organizational systems. To maintain control over the software installed, organizations identify permitted and prohibited actions regarding software installation. Permitted software installations include updates and security patches to existing software and downloading new applications from organization-approved app stores.
Prohibited software installations include software with unknown or suspect pedigrees or software that organizations consider potentially malicious. Policies selected for governing user-installed software are organization-developed or provided by some external entity. Policy enforcement methods can include procedural methods and automated methods.
Information location addresses the need to understand where information is being processed and stored. Information location includes identifying where specific information types and information reside in system components and how information is being processed so that information flow can be understood and adequate protection and policy management provided for such information and system components. The security category of the information is also a factor in determining the controls necessary to protect the information and the system component where the information resides (see FIPS 199). The location of the information and system components is also a factor in the architecture and design of the system (see SA-4, SA-8, SA-17).
Data actions are system operations that process personally identifiable information. The processing of such information encompasses the full information life cycle, which includes collection, generation, transformation, use, disclosure, retention, and disposal. A map of system data actions includes discrete data actions, elements of personally identifiable information being processed in the data actions, system components involved in the data actions, and the owners or operators of the system components. Understanding what personally identifiable information is being processed (e.g., the sensitivity of the personally identifiable information), how personally identifiable information is being processed (e.g., if the data action is visible to the individual or is processed in another part of the system), and by whom (e.g., individuals may have different privacy perceptions based on the entity that is processing the personally identifiable information) provides a number of contextual factors that are important to assessing the degree of privacy risk created by the system. Data maps can be illustrated in different ways, and the level of detail may vary based on the mission and business needs of the organization. The data map may be an overlay of any system design artifact that the organization is using. The development of this map may necessitate coordination between the privacy and security programs regarding the covered data actions and the components that are identified as part of the system.
Software and firmware components prevented from installation unless signed with recognized and approved certificates include software and firmware version updates, patches, service packs, device drivers, and basic input/output system updates. Organizations can identify applicable software and firmware components by type, by specific items, or a combination of both. Digital signatures and organizational verification of such signatures is a method of code authentication.
Contingency planning policy and procedures address the controls in the CP family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of contingency planning policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to contingency planning policy and procedures include assessment or audit findings, security incidents or breaches, or changes in laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.
Contingency planning for systems is part of an overall program for achieving continuity of operations for organizational mission and business functions. Contingency planning addresses system restoration and implementation of alternative mission or business processes when systems are compromised or breached. Contingency planning is considered throughout the system development life cycle and is a fundamental part of the system design. Systems can be designed for redundancy, to provide backup capabilities, and for resilience. Contingency plans reflect the degree of restoration required for organizational systems since not all systems need to fully recover to achieve the level of continuity of operations desired. System recovery objectives reflect applicable laws, executive orders, directives, regulations, policies, standards, guidelines, organizational risk tolerance, and system impact level.
Actions addressed in contingency plans include orderly system degradation, system shutdown, fallback to a manual mode, alternate information flows, and operating in modes reserved for when systems are under attack. By coordinating contingency planning with incident handling activities, organizations ensure that the necessary planning activities are in place and activated in the event of an incident. Organizations consider whether continuity of operations during an incident conflicts with the capability to automatically disable the system, as specified in IR-4(5). Incident response planning is part of contingency planning for organizations and is addressed in the IR (Incident Response) family.
Contingency training provided by organizations is linked to the assigned roles and responsibilities of organizational personnel to ensure that the appropriate content and level of detail is included in such training. For example, some individuals may only need to know when and where to report for duty during contingency operations and if normal duties are affected; system administrators may require additional training on how to establish systems at alternate processing and storage sites; and organizational officials may receive more specific training on how to conduct mission-essential functions in designated off-site locations and how to establish communications with other governmental entities for purposes of coordination on contingency-related activities. Training for contingency roles or responsibilities reflects the specific continuity requirements in the contingency plan. Events that may precipitate an update to contingency training content include, but are not limited to, contingency plan testing or an actual contingency (lessons learned), assessment or audit findings, security incidents or breaches, or changes in laws, executive orders, directives, regulations, policies, standards, and guidelines. At the discretion of the organization, participation in a contingency plan test or exercise, including lessons learned sessions subsequent to the test or exercise, may satisfy contingency plan training requirements.
Methods for testing contingency plans to determine the effectiveness of the plans and identify potential weaknesses include checklists, walk-through and tabletop exercises, simulations (parallel or full interrupt), and comprehensive exercises. Organizations conduct testing based on the requirements in contingency plans and include a determination of the effects on organizational operations, assets, and individuals due to contingency operations. Organizations have flexibility and discretion in the breadth, depth, and timelines of corrective actions.
Alternate storage sites are geographically distinct from primary storage sites and maintain duplicate copies of information and data if the primary storage site is not available. Similarly, alternate processing sites provide processing capability if the primary processing site is not available. Geographically distributed architectures that support contingency requirements may be considered alternate storage sites. Items covered by alternate storage site agreements include environmental conditions at the alternate sites, access rules for systems and facilities, physical and environmental protection requirements, and coordination of delivery and retrieval of backup media. Alternate storage sites reflect the requirements in contingency plans so that organizations can maintain essential mission and business functions despite compromise, failure, or disruption in organizational systems.