The New FISMA Standards and Guidelines or Building More Secure Information Systems A Strategy for Effectively Applying the Provisions of FISMA Dr. Ron.

The New FISMA Standards and Guidelines or Building More Secure Information Systems A Strategy for Effectively Applying the Provisions of FISMA Dr. Ron Ross & Dr. Stuart Katzke Computer Security Division Information Technology Laboratory

Presentation Contents
Part I: Overview Setting the stage/motivation/background NIST’s Federal Information Security Management Act (FISMA) of 2002 Implementation Project: A Risk Management Framework (RMF) Part II: Details FIPS 199: Security Categorization Special Publication (SP) : Categories Mapping Guidelines SP : Security Control Selection (Minimum/Baseline Controls) The Development and Vetting of SP SP : Security Certification and Accreditation SP A: Security Control Assessment

Part I: Overview

The Information Age Information systems are an integral part of government and business operations today Information systems are changing the way we do business and interact as a society Information systems are driving a reengineering of business processes in all sectors including defense, healthcare, manufacturing, financial services, etc. Information systems are driving a transition from a paper-based society to a digital society

The Protection Gap Information system protection measures have not kept pace with rapidly advancing technologies Information security programs have not kept pace with the aggressive deployment of information technologies within enterprises Two-tiered approach to security (i.e., national security community vs. everyone else) has left significant parts of the critical infrastructure vulnerable

The Global Threat Information security is not just a paperwork drill…there are dangerous adversaries out there capable of launching serious attacks on our information systems that can result in severe or catastrophic damage to the nation’s critical information infrastructure and ultimately threaten our economic and national security…

U.S. Critical Infrastructures Definition
“...systems and assets, whether physical or virtual, so vital to the United States that the incapacity or destruction of such systems and assets would have a debilitating impact on security, national economic security, national public health and safety, or any combination of those matters.” -- USA Patriot Act (P.L )

U.S. Critical Infrastructures Examples
Energy (electrical, nuclear, gas and oil, dams) Transportation (air, road, rail, port, waterways) Public Health Systems / Emergency Services Information and Telecommunications Defense Industry Banking and Finance Postal and Shipping Agriculture / Food / Water Chemical

Critical Infrastructure Protection
The U.S. critical infrastructures are over 90% owned and operated by the private sector Critical infrastructure protection must be a partnership between the public and private sectors Information security solutions must be broad-based, consensus-driven, and address the ongoing needs of government and industry

Threats to Security Connectivity Complexity

Key Security Challenges
Adequately protecting enterprise information systems within constrained budgets Changing the current culture of: “Connect first…ask security questions later” Bringing standardization to: Information system security control selection and specification Methods and procedures employed to assess the correctness and effectiveness of those controls

Why Standardization? Security Visibility Among Business/Mission Partners
Organization One Information System Organization Two Information System Business / Mission Information Flow ? ? Security Information Determining the risk to the first organization’s operations and assets and the acceptability of such risk Determining the risk to the second organization’s operations and assets and the acceptability of such risk The objective is to achieve visibility into prospective business/mission partners information security programs BEFORE critical/sensitive communications begin…establishing levels of security due diligence.

NIST’s Federal Information Security Management Act (FISMA) of 2002 Implementation Project: a Risk Management Framework (RMF)

FISMA Implementation Project Drivers
Technical Legislative and Policy

Project Drivers: Technical
NIST’s system security certification and accreditation (C&A) guidance aging (FIPS ) Proliferation of C&A guidance FIPS 102 (NIST) DITSCAP (DoD) NIACAP (NSTISSC/NSS) Attempt to achieve government-wide C&A convergence Attempt to integrate new and existing guidance in a comprehensive risk management framework

Project Drivers: Legislative and Policy
Public Law (Title III) Federal Information Security Management Act of 2002 Public Law Cyber Security Research and Development Act of 2002 Homeland Security Presidential Directive #7 Critical Infrastructure Identification, Prioritization, and Protection OMB Circular A-130 (Appendix III) Security of Federal Automated Information Resources

Security Checklists CSRDA Requirement
Develop and disseminate security configuration checklists and option selections that minimize the security risks associated with commercial information technology products that are, or are likely to become, widely used within federal information systems Publication status: NIST Special Publication , “The NIST Security Configuration Checklists Program” Initial Public Draft: August 2004

FISMA Legislation Overview
“Each federal agency shall develop, document, and implement an agency-wide information security program to provide information security for the information and information systems that support the operations and assets of the agency, including those provided or managed by another agency, contractor, or other source…” -- Federal Information Security Management Act of 2002

FISMA Tasks for NIST Standards to be used by Federal agencies to categorize information and information systems based on the objectives of providing appropriate levels of information security according to a range of risk levels Guidelines recommending the types of information and information systems to be included in each category Minimum information security requirements (management, operational, and technical security controls) for information and information systems in each such category

FISMA Implementation Project
FISMA-related standards and guidelines tightly coupled to the suite of NIST Management and Technical Guidelines Described within the context of System Development Life Cycle (SDLC)

FISMA Implementation Project Standards and Guidelines (1)
New Standards and Guidelines FIPS Publication 199 (Security Categorization) NIST Special Publication (Certification & Accreditation) NIST Special Publication (Recommended Security Controls) NIST Special Publication A (Security Control Assessment) NIST Special Publication (National Security Systems) NIST Special Publication (Security Category Mapping) FIPS Publication 200 (Minimum Security Controls)

FISMA Implementation Project Standards and Guidelines (2)
Existing Standards and Guidelines NIST Special Publication (Risk Management ) NIST Special Publication (Security Plan Development) NIST Special Publication (System Development Life Cycle) NIST Special Publication (Security Configuration Checklists)

FISMA Implementation Project Overall Goals
Helping to achieve more secure information systems within the federal government by: A better understanding of mission risks resulting from the operation of information systems A standard approach for selecting baseline controls More consistent, comparable and repeatable assessments of security controls in federal systems More complete, reliable and trustworthy information to support authorizing officials—facilitating more informed accreditation decisions

Managing Enterprise Risk
Key activities in managing organizational-level risk—risk to the organization resulting from the operation of an information system: Categorize the information system Select set of minimum (baseline) security controls Refine the security control set based on risk assessment Document security controls in system security plan Implement the security controls in the information system Assess the security controls (C&A) Determine agency-level risk and risk acceptability (C&A) Authorize information system operation (C&A) Monitor security controls on a continuous basis (C&A)

FISMA Implementation Project: Risk Management Framework (RMF)
In system security plan, provides a an overview of the security requirements for the information system and documents the security controls planned or in place SP Security Control Documentation Defines category of information system according to potential impact of loss FIPS 199 / SP Security Categorization Selects minimum security controls (i.e., safeguards and countermeasures) planned or in place to protect the information system SP / FIPS 200 Security Control Selection Determines extent to which the security controls are implemented correctly, operating as intended, and producing desired outcome with respect to meeting security requirements SP A / SP Security Control Assessment SP / FIPS 200 / SP Security Control Refinement Uses risk assessment to adjust minimum control set based on local conditions, required threat coverage, and specific agency requirements SP System Authorization Determines risk to agency operations, agency assets, or individuals and, if acceptable, authorizes information system processing Security Control Monitoring Continuously tracks changes to the information system that may affect security controls and assesses control effectiveness Implements security controls in new or legacy information systems; implements security configuration checklists Security Control Implementation SP /SP

Security Objectives Confidentiality Integrity Availability
“Preserving authorized restrictions on information access and disclosure, including means for protecting personal privacy and proprietary information…” [44 U.S.C., Sec. 3542] Integrity “Guarding against improper information modification or destruction, and includes ensuring information non-repudiation and authenticity…” [44 U.S.C., Sec. 3542] Availability “Ensuring timely and reliable access to and use of information…” [44 U.S.C., Sec. 3542]

FIPS 199 Levels of Impact The level of impact is low if—
The event could be expected to have a limited adverse effect on agency operations (including mission, functions, image or reputation), agency assets, or individuals. The event causes a negative outcome or results in limited damage to operations or assets, requiring minor corrective actions or repairs. The level of impact is moderate if— The event could be expected to have a serious adverse effect on agency operations (including mission, functions, image or reputation), agency assets, or individuals. The event causes significant degradation in mission capability, places the agency at a significant disadvantage, or results in major damage to assets, requiring extensive corrective actions or repairs. The level of impact is high if— The event could be expected to have a severe or catastrophic adverse effect on agency operations (including mission, functions, image or reputation), agency assets, or individuals. The event causes a loss of mission capability for a period that poses a threat to human life, or results in a loss of major assets.

Security Categorization
Example: An Enterprise Information System FIPS Publication 199 Low Moderate High Confidentiality The loss of confidentiality could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The loss of confidentiality could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The loss of confidentiality could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. Integrity The loss of integrity could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The loss of integrity could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The loss of integrity could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. Availability The loss of availability could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The loss of availability could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The loss of availability could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. Guidance for Mapping Types of Information and Information Systems to FIPS Publication 199 Security Categories SP

Example: An Enterprise Information System FIPS Publication 199 Low Moderate High Confidentiality The loss of confidentiality could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The loss of confidentiality could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The loss of confidentiality could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. Integrity The loss of integrity could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The loss of integrity could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The loss of integrity could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. Availability The loss of availability could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The loss of availability could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The loss of availability could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. Guidance for Mapping Types of Information and Information Systems to FIPS Publication 199 Security Categories Minimum Security Controls for High Impact Systems SP

Plan of Action and Milestones Security Assessment Report
The Desired End State Security Visibility Among Business/Mission Partners Organization One Information System Plan of Action and Milestones Security Assessment Report System Security Plan Determining the risk to the first organization’s operations and assets and the acceptability of such risk Business / Mission Information Flow The objective is to achieve visibility into prospective business/mission partners information security programs BEFORE critical/sensitive communications begin…establishing levels of security due diligence. Determining the risk to the second organization’s operations and assets and the acceptability of such risk Organization Two Security Information

System Security Plan Prepared by the information system owner
Provides an overview of the security requirements for the information system and describes the security controls in place or planned for meeting those requirements Contains (either as supporting appendices or as references) other key security-related documents for the information system (e.g., risk assessment, contingency plan, incident response plan, system interconnection agreements)

RMF: Significant Features (1)
Standard categorization method—based on worst case impact to enterprise if compromise Supports scalability and prioritization Level of effort commensurate with security categorization Apply effort to highest impact systems first Is generic Applies to all types of systems Focuses on the process for the selection, implementation, & assessment of controls

Master control catalogue derived from many public and private sector sources: CC Part 2 ISO/IEC 17799 COBIT GAO FISCAM NIST SP Self Assessment Questionnaire CMS (healthcare) D/CID 6-3 Requirements DoD Policy 8500 BITS functional packages

Minimum/ baseline controls for Low, Moderate, & High impact systems were selected from master control catalogue Hierarchical Increase in functionality Assurance requirements Baseline dependent: one for each baseline Increase control developer/implementer's analysis and evidence to demonstrate implementation quality, correctness, and confidence

Assurance requirements are related to and support control assessment approach Common security controls concept Agency-wide (e.g., training, personal security) Site-wide (e.g., physical security, contingency plan) Common subsystem (e.g., deployed at multiple sites)

C&A for low impact systems Allows self assessment Scaled level of effort Controls can be added to the control catalogue and new baselines developed to meet requirements of community-specific applications/systems SCADA/real-time processing Healthcare/HIPPA Financial/Sarbanes-Oxley

Possibility of becoming “due diligence” in commercial and other sectors through: Government critical infrastructure liaisons to private sector counterparts (e.g., energy, financial, transportation) Extension of government security standards and requirements to systems operated on behalf of the federal government State and local governments Contractors and IT service providers

Contact Information 100 Bureau Drive Mailstop 8930 Gaithersburg, MD USA Project Manager Administrative Support Dr. Ron Ross Peggy Himes (301) (301) Senior Information Security Researchers and Technical Support Marianne Swanson Dr. Stu Katzke (301) (301) Pat Toth Arnold Johnson (301) (301) Curt Barker Information and Feedback (301) Web: csrc.nist.gov/sec-cert Comments:

Part II: Details Security Categorization Categories Mapping Guidelines
Security Control Selection Security Certification and Accreditation Security Control Assessment Desired End State/Conclusion Security Control Selection Vetting Process

FIPS 199: Standards for Security Categorization of Federal Information and Information Systems

Categorization Standards FISMA Requirement
Develop standards to be used by federal agencies to categorize information and information systems based on the objectives of providing appropriate levels of information security according to a range of risk levels Publication status: Federal Information Processing Standards (FIPS) Publication 199, “Standards for Security Categorization of Federal Information and Information Systems” Final Publication: December 2003* * FIPS Publication 199 was signed by the Secretary of Commerce in February 2004.

FIPS Publication 199 FIPS 199 is critically important to enterprises because the standard— Requires prioritization of information systems according to potential impact on mission or business operations Promotes effective allocation of limited information security resources according to greatest need Facilitates effective application of security controls to achieve adequate information security Establishes appropriate expectations for information system protection

FIPS 199 Applications FIPS 199 should guide the rigor, intensity, and scope of all information security-related activities within the enterprise including— The application and allocation of security controls within information systems The assessment of security controls to determine control effectiveness Information system authorizations or accreditations Oversight, reporting requirements, and performance metrics for security effectiveness and compliance

Categories Mapping Guidelines
SP : Guide for Mapping Types of Information and Information Systems to Security Categories,

Mapping Guidelines FISMA Requirement
Develop guidelines recommending the types of information and information systems to be included in each category Publication status: NIST Special Publication , “Guide for Mapping Types of Information and Information Systems to Security Categories” Final Publication: June 2004

SP Companion to FIPS 199 Rationale by Identified Lines of Business Offers guidance on Special Factors to be considered in addressing system impact

SP 800-60 Overview Types of information
Agency-common: administrative, management and support information Mission-based: mission information and service delivery mechanisms Service delivery mechanisms provide policy, programmatic, and managerial foundation in support of Federal government operations Security attributes of information associated with mission-specific activities will often vary from agency to agency

SP 800-60 Overview (concluded)
Support services and management of resources functions are included in agency-common information types Services to citizens and modes of delivery types are included in mission-based information types

Security Control Selection (Minimum/Baseline Controls)
NIST Special Publication : Recommended Security Controls for Federal Information Systems “Building a National Consensus For Due Diligence in the Application of Minimum Security Controls for Information Systems”

Minimum Security Requirements FISMA Requirement
Develop minimum information security requirements (management, operational, and technical security controls) for information and information systems in each such category Publication status: Federal Information Processing Standards (FIPS) Publication 200, “Minimum Security Controls for Federal Information Systems”* Final Publication: December 2005 * NIST Special Publication , “Recommended Security Controls for Federal Information Systems” (Second public draft September 2004) will provide interim guidance until completion and adoption of FIPS Publication Current draft out for public comment until November 30, 2004.

Minimum Security Controls
Minimum security controls, or baseline controls, defined for low-impact, moderate-impact, and high-impact information systems— Provide a starting point for organizations and communities of interest in their security control selection process Are used in the context of the organization’s ongoing risk management process

Example: An Enterprise Information System FIPS Publication 199 Low Moderate High Confidentiality The loss of confidentiality could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The loss of confidentiality could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The loss of confidentiality could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. Integrity The loss of integrity could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The loss of integrity could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The loss of integrity could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. Availability The loss of availability could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The loss of availability could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The loss of availability could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals. Guidance for Mapping Types of Information and Information Systems to FIPS Publication 199 Security Categories Minimum Security Controls for High Impact Systems SP

Security Control Structure
Functional requirements Master Security Control Catalogue 17 Control Families Functional requirements for each control in each family Assurance requirements Dependent on the baseline the control is in Includes: Low, Moderate, High, and Additional Assurance Requirements Supplementing the High Baseline

Security Control Structure Control Requirements: Functional
Simplified structure consisting of three sections: Basic level security control statement Supplemental guidance Control enhancements Example: Contingency Planning (CP) Family CP-7 Alternate Processing Site

CP-7 ALTERNATE PROCESSING SITES
Control: The organization identifies an alternate processing site and initiates necessary agreements to permit the resumption of information system operations for critical mission/business functions within [Assignment: organization-defined time period] when the primary processing capabilities are unavailable. Supplemental Guidance: Equipment and supplies required to resume operations within the organization-defined time period are either available at the alternate site or contracts are in place to support delivery to the site. Control Enhancements: (1) The alternate processing site is geographically separated from the primary processing site so as not to be susceptible to the same hazards. (2) The organization identifies potential accessibility problems to the alternate processing site in the event of an area-wide disruption or disaster and outlines explicit mitigation actions. (3) Alternate processing site agreements contain priority-of-service provisions in accordance with the organization’s availability requirements. (4) The alternate processing site is fully configured to support a minimum required operational capability and ready to use as the operational site.

Security Control Baselines Functional
Minimum Security Controls Low Impact Information Systems High Impact Moderate Impact Information Systems Master Security Control Catalog Complete Set of Security Controls and Control Enhancements Baseline #1 Selection of a subset of security controls from the master catalog—consisting of basic level controls Baseline #2 Builds on low baseline. Selection of a subset of controls from the master catalog—basic level controls, additional controls, and control enhancements Baseline #3 Builds on moderate baseline. Selection of a subset of controls from the master catalog—basic level controls, additional controls, and control enhancements

Contingency Planning Family
Contingency Planning Policy & Procedures CP-1 Contingency Plan CP-2 CP-2 (1) Contingency Training Not Selected CP-3 CP-3 (1) (2) Contingency Plan Testing CP-4 (1) CP-4 (1) (2) (3) Contingency Plan Update CP-5 Alternate Storage Sites CP-6 (1) CP-6 (1) (2) (3) Alternate Processing Sites CP-7 (1) (2) (3) CP-7 (1) (2) (3) (4) Alternate Telecommunications Services CP-8 (1) (2) CP-8 (1) (2) (3) (4) Information System Backup CP-9 CP-9 (1) CP-9 (1) (2) (3) Information System Recovery & Reconstitution CP-10 CP-10 (1)

Security Control Structure Control Requirements: Assurance
Single assurance requirement for each baseline Applies to each control in the baseline Low impact Moderate impact High impact Additional assurance requirements for supplementing the high baseline

Assurance Rational/approach
Assurance: Specify developer and implementer actions during system development process to ensure controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for the system Assessment: Specify security control assessor’s actions during the testing and evaluation process to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for the system

Assurance Requirements (1)
Low Baseline Assurance Requirement: The security control is in effect and meets explicitly identified functional requirements in the control statement. Supplemental Guidance: For security controls in the low baseline, the focus is on the control being in place with the expectation that no obvious errors exist and that, as flaws are discovered, they are addressed in a timely manner.

Moderate Baseline Assurance Requirement: The security control is in effect and meets explicitly identified functional requirements in the control statement. The control developer/implementer provides a description of the functional properties of the control with sufficient detail to permit analysis and testing of the control. The control developer/implementer includes as an integral part of the control, assigned responsibilities and specific actions to ensure that when the control is implemented, it will meet its required function or purpose. These actions may include, for example, requiring the development of records with structure and content suitable to facilitate making this determination. Supplemental Guidance: For security controls in the moderate baseline, the focus is on ensuring correct implementation and operation of the control. While flaws are still likely to be uncovered (and addressed expeditiously), the control developer/implementer incorporates, as part of the control, specific capabilities and produces specific documentation to ensure the control meets its required function or purpose

High Baseline Assurance Requirement: The security control is in effect and meets explicitly identified functional requirements in the control statement. The control developer/implementer provides a description of the functional properties and design/implementation of the control with sufficient detail to permit analysis and testing of the control (including functional interfaces among control components). The control developer/implementer includes as an integral part of the control, assigned responsibilities and specific actions to ensure that when the control is implemented, it will continuously and consistently (i.e., across the information system) meet its required function or purpose and support improvement in the effectiveness of the control. These actions may include, for example, requiring the development of records with structure and content suitable to facilitate making this determination. Supplemental Guidance: For security controls in the high baseline, the focus is expanded to require, within the control, the capabilities that are needed to support ongoing consistent operation of the control and continuous improvement in the control’s effectiveness. The developer/implementer is expected to expend significant effort on the design, development, implementation, and testing of the controls and to produce associated design and implementation documentation to support these activities. For security controls in the high baseline, this same documentation is needed by assessors to analyze and test the internal components of the control as part of the overall assessment of the control.

Additional Requirements Supplementing the High Baseline Assurance Requirement: The security control is in effect and meets explicitly identified functional requirements in the control statement. The control developer/implementer provides a description of the functional properties and design/implementation of the control with sufficient detail to permit analysis and testing of the control (including functional interfaces among control components). The control developer/implementer includes as an integral part of the control, assigned responsibilities and specific actions to ensure that when the control is implemented, it will continuously and consistently (i.e., across the information system) meet its required function or purpose and support improvement in the effectiveness of the control. These actions include, for example, requiring the development of records with structure and content suitable to facilitate making this determination. The control is developed in a manner that supports a high degree of confidence that the control is complete, consistent, and correct. Supplemental Guidance: The additional high assurance requirements are intended to supplement the minimum assurance requirements for the high baseline, when appropriate, in order to protect against threats from highly skilled, highly motivated, and well-financed threat agents. This level of protection is required for those information systems where the organization is not willing to accept the risks associated with the type of threat agents cited above.

Minimum Baselines Low Moderate High
For each family, appropriate controls selected from control catalogue Not all controls in family selected No enhancements Low Assurance Requirements Moderate Includes all controls in Low baseline with (possibly) enhancements For each family, additional appropriate controls selected from control catalogue with (possibly) enhancements Moderate Assurance Requirements High Includes all controls in Moderate baseline with (possibly) additional enhancements High Assurance Requirements

Security Control Selection Minimum Requirements
Begin with security categorization triple from security categorization standard (FIPS 199) Reduce triple to a single security category of Low, Moderate, or High Impact Select control baselines for the impact level Apply tailoring guidance Select minimum assurance requirement for the impact level Final set is input to security control refinement (i.e., risk analysis process)

Tailoring the initial baselines
Scoping Guidance Considerations Technology-related Infrastructure-related Public access-related Scalability-related Common security control-related Risk-related /downgrading Organization-Defined Security Control Parameters Compensating Security Controls

Requirements Traceability
Security Controls SP / FIPS 200 High Level Security Requirements Derived from Legislation, Executive Orders, Policies, Directives, Regulations, Standards Examples: HIPAA, Graham-Leach-Bliley, Sarbanes-Oxley, FISMA, OMB Circular A-130 What set of security controls, if implemented within an information system and determined to be effective, can show compliance to a particular set of security requirements? Enterprise #1 Enterprise #2 Enterprise #3

The Development and Vetting of SP 800-53

Development Strategy First, develop mandatory security categorization standards for federal information and information systems (FIPS 199) Next, develop recommended (minimum) security controls for federal information systems as an 800-series guidance document (NIST SP ) Finally, develop mandatory (minimum) security control standards for federal information systems (FIPS 200)

Consensus-Building Process NIST Special Publication 800-53
Employ extensive vetting process for Special Publication Three full published drafts of document Three public comment periods to obtain feedback from the public and private sectors Carefully assess feedback received during the public comment periods; incorporate material into publication, as appropriate Provide sufficient time for organizations to become familiar with Special Publication before transitioning to FIPS 200

Special Publication Formal and informal comments received from a wide variety of constituencies in the public and private sectors including— Federal, State, and Local Governments Critical Infrastructure Entities (e.g., power companies, telecommunications providers) Fortune 500 Companies Healthcare Providers Financial Industry Consortia (e.g., National Realtors Association) Private citizens

Significant Comments Received over 800 comments on the initial public draft of Special Publication Comments indicated that— Security controls contained too much implementation detail Security control baselines (low, moderate, high) included too many controls for a minimum set There was insufficient flexibility in the security control selection process for organizations to effectively apply the controls in specific operational environments The “high-water mark” approach required organizations to employ unnecessary security controls

NIST Response In response to the initial public comments, NIST re-engineered Special Publication Fundamental changes included— Streamlining the security control structure and control content to focus on “token-level” requirements Redesigning the security control enhancement approach to facilitate ease-of-use for organizations requiring additional security controls based on risk assessment Incorporating scoping guidance to help organizations effectively apply the NIST guidance in specific operational environments Reducing the number of security controls in the control baselines

Significant Comments Received over 400 comments on the second public draft of Special Publication Comments indicated that— There was overwhelming approval of the reengineered approach and the simplification of the document Security control baselines (low, moderate, high) still contained too many controls for a minimum set The scoping guidance needed to be strengthened to added even greater flexibility in the security control selection and specification process Organizations wanted the return of the security control classes (i.e., management, operational, and technical) which had been previously eliminated

NIST Response In response to the second round of public comments, NIST made a few minor modifications— Changes included— Modifying the scoping guidance to allow organizations to eliminate security controls from the control baselines under strict terms and conditions consistent with FIPS 199 security categorizations Adjusting the security control baselines again to facilitate cost-effective, risk-based application of security controls Adding several new security controls to the control catalog; eliminating a few controls from the catalog Expanding the security control mapping table to include DCID 6/3 and DoD

Key Milestones NIST Special Publication 800-53 FIPS 200
Initial Public Draft (October 2003) Second Public Draft (September 2004) Final Public Draft (January 2005) Final Publication (February 2005) FIPS 200 Initial Public Draft (Projected for May 2005) Second Public Draft (Projected for August 2005) Final Publication (Projected for December 2005)

Summary Public vetting process proved extremely effective and allowed NIST to build a truly consensus-based security guideline to serve both public and private sector needs Extended development cycle and expanded public review periods allowed federal agencies to be better prepare for the transition to FIPS 200, when the security controls become mandatory Increasing voluntary acceptance of NIST Special Publication by the private sector will help provide greater information security for the nation’s critical infrastructure

Certification and Accreditation (C&A)
NIST Special Publication Guide for the Security Certification and Accreditation of Federal Information Systems An Introductory Tutorial

Certification and Accreditation Supporting FISMA Requirement
Conduct periodic testing and evaluation of the effectiveness of information security policies, procedures, and practices (including management, operational, and technical security controls) Publication status: NIST Special Publication , “Guide for the Security Certification and Accreditation of Federal Information Systems” Final Publication: May 2004

Contents Introduction The Fundamentals The Process Summary

C&A Part I Introduction

National Policy Office of Management and Budget Circular A-130,
Management of Federal Information Resources requires federal agencies to: Plan for security Ensure that appropriate officials are assigned security responsibility Authorize system processing prior to operations and periodically, thereafter

Security Controls The management, operational, and technical controls (i.e., safeguards or countermeasures) prescribed for an information system to protect the confidentiality, integrity, and availability of the system and its information. -- [FIPS Publication 199]

Key Questions What security controls are needed to adequately protect an information system that supports the operations and assets of the organization? Have the selected security controls been implemented or is there a realistic plan for their implementation? To what extent are the security controls implemented correctly, operating as intended, and producing the desired outcome with respect to meeting information security requirements?

Certification and Accreditation FISMA and OMB Requirements
Conduct periodic testing and evaluation of the effectiveness of information security policies, procedures, and practices (including management, operational, and technical security controls) Publication status: NIST Special Publication , “Guide for the Security Certification and Accreditation of Federal Information Systems” Final Publication: May 2004

Purpose and Applicability Special Publication 800-37
Provides guidelines for certifying and accrediting information systems supporting the executive agencies of the federal government Applies to all federal information systems other than those systems designated as national security systems as defined in FISMA Replaces Federal Information Processing Standards (FIPS) Publication 102

Significant Benefits Special Publication 800-37
Helping to achieve more secure information systems within the federal government by: Enabling more consistent, comparable, and repeatable assessments of security controls in federal information systems Promoting a better understanding of agency-related mission risks resulting from the operation of information systems Creating more complete, reliable, and trustworthy information for authorizing officials—facilitating more informed accreditation decisions

Information Security Programs
Question How do security certification and accreditation fit into an agency’s information security program?

Information Security Programs
Answer Security certification and accreditation are important activities that support a risk management process and are an integral part of an agency’s overall information security program.

Risk Management Adversaries attack the weakest link…where is yours?
Links in the Security Chain: Management, Operational, and Technical Controls Risk assessment Security planning Security policies and procedures Contingency planning Incident response planning Physical security Personnel security Security assessments Security accreditation Access control mechanisms Identification & authentication mechanisms (Biometrics, tokens, passwords) Audit mechanisms Encryption mechanisms Firewalls and network security mechanisms Intrusion detection systems Anti-viral software Smart cards Adversaries attack the weakest link…where is yours?

Managing Agency Risk Key activities in managing agency-level risk—risk resulting from the operation of an information system: Categorize the information system Select set of minimum (baseline) security controls Refine the security control set based on risk assessment Document security controls in system security plan Implement the security controls in the information system Assess the security controls (C&A) Determine agency-level risk and risk acceptability (C&A) Authorize information system operation (C&A) Monitor security controls on a continuous basis (C&A)

Plan of Action and Milestones Security Assessment Report
The Desired End State Security Visibility Among Business/Mission Partners Organization One Information System Plan of Action and Milestones Security Assessment Report System Security Plan Determining the risk to the first organization’s operations and assets and the acceptability of such risk Business / Mission Information Flow The objective is to achieve visibility into prospective business/mission partners information security programs BEFORE critical/sensitive communications begin…establishing levels of security due diligence. Determining the risk to the second organization’s operations and assets and the acceptability of such risk Organization Two Security Information

C&A Part II The Fundamentals

Security Accreditation
Official management decision given by a senior agency official to authorize operation of an information system and to explicitly accept the risk to agency operations (including mission, functions, image, or reputation), agency assets, or individuals, based on the implementation of an agreed upon set of security controls.

Security Certification
Comprehensive assessment of the management, operational, and technical security controls in an information system, made in support of security accreditation, to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for the system.

Key Roles Authorizing Official
Authorizing Official Designated Representative Chief Information Officer Senior Agency Information Security Officer Information System Owner Information System Security Officer Certification Agent User Representatives

Authorizing Official Reviews and approves the security categorizations of information systems Reviews and approves system security plans Determines agency-level risk from information generated during the security certification Makes accreditation decisions and signs associated transmittal letters for accreditation packages (authorizing official only) Reviews security status reports from continuous monitoring operations; initiates reaccreditation actions

Designated Representative
Selected by the authorizing official to coordinate and carry out the necessary activities required during the security certification and accreditation process Empowered to make certain decisions with regard to the: Planning and resourcing of the security certification and accreditation activities Acceptance of the system security plan Determination of risk to agency operations, assets, and individuals Prepares accreditation decision letter Obtains authorizing official’s signature on the accreditation decision letter and transmits accreditation package to appropriate agency officials

Chief Information Officer
Designates a senior agency information security officer Develops and maintains information security policies, procedures, and control techniques to address all applicable requirements Trains and oversees personnel with significant responsibilities for information security Assists senior agency officials concerning their security responsibilities Coordinates with other senior agency officials, reporting annually to the agency head on the effectiveness of the agency information security program

Senior Agency Information Security Officer
Serves in a position with primary responsibilities and duties related to information security Carries out the Chief Information Officer responsibilities under FISMA Possesses professional qualifications required to administer information security program functions Heads an office with the mission and resources to assist in ensuring agency compliance with FISMA

Information System Owner
Procures, develops, integrates, modifies, operates or maintains an information system Prepares system security plan and conducts risk assessment Informs agency officials of the need for certification and accreditation; ensures appropriate resources are available Provides necessary system-related documentation to the certification agent Prepares plan of action and milestones to reduce or eliminate vulnerabilities in the information system Assembles final accreditation package and submits to authorizing official

Information System Security Officer
Serves as principal staff advisor to the system owner on all matters involving the security of the information system Manages the security aspects of the information system and, in some cases, oversees the day-to-day security operations of the system Assists the system owner in: Developing and enforcing security policies for the information system Assembling the security accreditation package Managing and controlling changes to the information system and assessing the security impacts of those changes

Certification Agent Provides an independent assessment of the system security plan Assesses the security controls in the information system to determine the extent to which the controls are: Implemented correctly; Operating as intended; and Producing the desired outcome with respect to meeting the security requirements of the system Provides recommended corrective actions to reduce or eliminate vulnerabilities in the information system

User Representatives Represent the operational interests and mission needs of the user community Identify mission and operational requirements Serve as liaisons for the user community throughout the system development life cycle Assist in the security certification and accreditation process, when needed

Other Supporting Roles
Information Owner Operations Manager Facilities Manager System Administrator

Accreditation Boundaries
Uniquely assigning information resources to an information system defines the security accreditation boundary for that system Agencies have great flexibility in determining what constitutes an information system and the resulting accreditation boundary that is associated with that system

Accreditation Boundaries
If a set of information resources is identified as an information system, the resources should generally be under the same direct management control Consider if the information resources being identified as an information system— Have the same function or mission objective and essentially the same operating characteristics and security needs Reside in the same general operating environment (or in the case of a distributed information system, reside in various locations with similar operating environments)

Large and Complex Systems
Accreditation Boundary Subsystem Component Local Area Network Alpha System Guard Bravo Agency General Support System System security plan reflects information system decomposition with adequate security controls assigned to each subsystem component Security assessment methods and procedures tailored for the security controls in each subsystem component and for the combined system-level controls Security certification performed on each subsystem component and on system-level controls not covered by subsystem certifications Security accreditation performed on the information system as a whole

Common Security Controls
Common security controls are those controls that can be applied to one or more agency information systems and have the following properties: The development, implementation, and assessment of common security controls can be assigned to responsible officials or organizational elements (other than the information system owner) The results from the assessment of the common security controls can be reused in security certifications and accreditations of agency information systems where those controls have been applied

Identification of common security controls is an agency-level activity in collaboration with Chief Information Officer, senior agency information security officer, authorizing officials, information system owners, and information system security officers Potential for significant cost savings for the agency in security control development, implementation, and assessment

Common security controls can be applied agency-wide, site-wide, or to common subsystems and assessed accordingly— For example: Contingency planning Incident response planning Security training and awareness Physical and personnel security * Common hardware, software, or firmware ** * Related to the concept of site certification in certain communities ** Related to the concept of type certification in certain communities

Example: Moderate Impact Agency Information Systems Responsibility of Information System Owners Common Security Controls System Specific Security Controls Responsibility of Designated Agency Official Other Than Information System Owner (e.g., Chief Information Officer, Facilities Manager, etc.) Common security controls developed, implemented, and assessed one time by designated agency official(s) Development and implementation cost amortized across all agency information systems Results shared among all information system owners and authorizing officials where common security controls are applied Maximum re-use of assessment evidence during security certification and accreditation of information systems Security assessment reports provided to information system owners to confirm the security status of common security controls Assessments of common security controls not repeated; only system specific aspects when necessary

Accreditation Decisions
Authorization To Operate Interim Authorization To Operate Denial of Authorization to Operate

Authorization to Operate
Risk to agency operations, agency assets, or individuals is deemed acceptable to the authorizing official Information system is accredited without any significant restrictions or limitations on its operation Authorizing officials may recommend specific actions be taken to reduce or eliminate identified vulnerabilities, where it is cost effective to do so

Interim Authorization To Operate
Risk to agency operations, agency assets, or individuals is not deemed acceptable to the authorizing official, but there is an overarching mission necessity to place the information system into operation or continue its operation Significant deficiencies in the security controls in the information system but the deficiencies can be addressed in a timely manner Acknowledges greater risk to the agency for a limited period of time

Interim Authorization To Operate
Limited authorization to operate the information system under specific terms and conditions established by the authorizing official Information system is not accredited during the period of limited authorization to operate At the end of the period of limited authorization, the information system should either meet the requirements for being authorized or not be authorized for further operation

Denial of Authorization to Operate
The residual risk to the agency’s operations or assets is deemed unacceptable to the authorizing official Information system is not accredited and should not be placed into operation—or for an information system currently in operation, all activity should be halted Major deficiencies in the security controls in the information system—corrective actions should be initiated immediately

Accreditation Package
System security plan Security assessment report Plan of action and milestones

Accreditation Package
Documents the results of the security certification Provides the authorizing official with the essential information needed to make a credible risk-based decision on whether to authorize operation of the information system Uses inputs from the information system security officer and the certification agent

System Security Plan Prepared by the information system owner
Provides an overview of the security requirements for the information system and describes the security controls in place or planned for meeting those requirements Contains (either as supporting appendices or as references) other key security-related documents for the information system (e.g., risk assessment, contingency plan, incident response plan, system interconnection agreements)

Security Assessment Report
Prepared by the certification agent Provides the results of assessing the security controls in the information system to determine the extent to which the controls are: Implemented correctly Operating as intended Producing the desired outcome with respect to meeting the system security requirements Contains a list of recommended corrective actions

Plan of Action and Milestones
Prepared by the system owner Reports progress made on current outstanding items listed in the plan Addresses vulnerabilities in the information system discovered during certification, security impact analysis, or security control monitoring Describes how the information system owner intends to address those vulnerabilities (i.e., reduce, eliminate, or accept vulnerabilities)

Accreditation Decision Letter
Constructed from information provided by the information system owner in the accreditation package Consists of: Accreditation decision Supporting rationale for the decision Specific terms and conditions imposed on the system owner The contents of security certification and accreditation-related documentation (especially information dealing with system vulnerabilities) should be marked and protected appropriately in accordance with agency policy.

C&A Part III The Process

The Process Initiation Phase Security Certification Phase
Security Accreditation Phase Continuous Monitoring Phase

Initiation Phase Major Tasks and Subtasks
Task 1: Preparation Subtask 1.1: Information System Description Subtask 1.2: Security Categorization Subtask 1.3: Threat Identification Subtask 1.4: Vulnerability Identification Subtask 1.5: Security Control Identification Subtask 1.6: Initial Risk Determination Task 2: Notification and Resource Identification Subtask 2.1: Notification Subtask 2.2: Planning and Resources

Initiation Phase Major Tasks and Subtasks
Task 3: System Security Plan Analysis, Update, and Acceptance Subtask 3.1: Security Categorization Review Subtask 3.2: System Security Plan Analysis Subtask 3.3: System Security Plan Update Subtask 3.4: System Security Plan Acceptance

Security Certification Phase Major Tasks and Subtasks
Task 4: Security Control Assessment Subtask 4.1: Documentation and Supporting Materials Subtask 4.2: Methods and Procedures Subtask 4.3: Security Assessment Subtask 4.4: Security Assessment Report Task 5: Security Certification Documentation Subtask 5.1: Findings and Recommendations Subtask 5.2: System Security Plan Update Subtask 5.3: Plan of Action and Milestones Preparation Subtask 5.4: Accreditation Package Assembly

Security Accreditation Phase Major Tasks and Subtasks
Task 6: Accreditation Decision Subtask 6.1: Final Risk Determination Subtask 6.2: Risk Acceptability Task 7: Accreditation Documentation Subtask 7.1: Accreditation Package Transmission Subtask 7.2: System Security Plan Update

Continuous Monitoring Phase Major Tasks and Subtasks
Task 8: Configuration Management and Control Subtask 8.1: Documentation of System Changes Subtask 8.2: Security Impact Analysis Task 9: Security Control Monitoring Subtask 9.1: Security Control Selection Subtask 9.2: Selected Security Control Assessment Task 10: Status Reporting and Documentation Subtask 10.1: System Security Plan Update Subtask 10.2: Plan of Action and Milestones Update Subtask 10.3: Status Reporting

Certification and Accreditation For Low Impact Information Systems
Incorporates the use of self-assessment activities Reduces the associated level of supporting documentation and paperwork Decreases the time spent conducting assessment-related activities Significantly reduces costs to the agency without increasing agency-level risk or sacrificing the overall security of the information system.

C&A Part IV Summary

Special Publication 800-37 Intended to promote and facilitate—
More consistent, comparable, and repeatable assessments of information systems More complete and reliable security-related information for authorizing officials A better understanding of complex information systems and associated risks and vulnerabilities

Security Control Assessments (Currently in-development)
NIST Special Publication A: Guide for Assessing the Security Controls in Federal Information Systems A Framework for Developing Assessment Procedures for controls in SP

Security Control Assessment FISMA Requirement
Conduct periodic testing and evaluation of the effectiveness of information security policies, procedures, and practices (including management, operational, and technical security controls) Publication status: NIST Special Publication A, “Guide for Assessing the Security Controls in Federal Information Systems” Initial Public Draft: Winter

Contingency Planning Family
Contingency Planning Policy & Procedures CP-1 Contingency Plan CP-2 CP-2 (1) Contingency Training Not Selected CP-3 CP-3 (1) (2) Contingency Plan Testing CP-4 (1) CP-4 (1) (2) (3) Contingency Plan Update CP-5 Alternate Storage Sites CP-6 (1) CP-6 (1) (2) (3) Alternate Processing Sites CP-7 (1) (2) (3) CP-7 (1) (2) (3) (4) Alternate Telecommunications Services CP-8 (1) (2) CP-8 (1) (2) (3) (4) Information System Backup CP-9 CP-9 (1) CP-9 (1) (2) (3) Information System Recovery & Reconstitution CP-10 CP-10 (1)

The Conceptual Model Assessment Methods Interview Examine Test Security Control Number Baseline Assessment Procedure Input Process Output Framework Example: First security control in Contingency Planning Family {CP-1, low}  {Interview, Examine}  Assessment Procedure CP-1

Assessment Methods Interview Examine Test
The process of conducting focused discussions with organizational personnel to facilitate understanding, achieve clarification, or obtain evidence Examine The process of checking, inspecting, reviewing, observing, studying, or analyzing an assessment object to generate a verdict or to reach a conclusion Test The process of exercising an assessment object under specified conditions, observing and recording the results, and comparing the actual with the expected behavior

Assessment Objects Specifications: primarily a document-type control
Examples: policies, plans, procedures, system requirements, designs Activities: primarily a people-oriented control but may be supported by IT mechanisms Examples: system operations, system administration, management, exercises, drills Mechanisms: primarily implemented in hardware, software, firmware but may require human interaction/support Examples: I&A, Audit Trails, Access Control, physical devices, communications protection/cryptography

Interview Attributes Coverage Approach Depth
Addresses the types of individuals to be interviewed (by organizational roles and associated responsibilities) and the number of individuals to be interviewed (by type). Approach Addresses the formality of the interview process. There are two potential values for the approach attribute: (i) informal/unstructured; and (ii) formal/structured. Depth Addresses the rigor of and level of detail in the interview process. There are three possible values for the depth attribute: (i) cursory; (ii) exploratory; and (iii) comprehensive.

Examine Attributes Coverage Approach Depth
Addresses the types of assessment objects to be examined and the number of objects to be examined (by type). Approach Addresses the formality of the examination process. There are two potential values for the approach attribute: (i) informal/unstructured; and (ii) formal/structured. Depth Addresses the rigor of and level of detail in the examination process. There are three possible values for the depth attribute: (i) cursory; (ii) exploratory; and (iii) comprehensive.

Test Attributes Scope Coverage Approach Depth
Addresses the types of testing to be conducted. There are three potential values for the scope attribute: (i) black-box testing; (ii) gray-box testing; and (iii) penetration testing. Coverage Addresses the types of assessment objects to be tested and the number of objects to be tested (by type). Approach Addresses the formality of the testing process. There are two potential values for the approach attribute: (i) informal/unstructured; and (ii) formal/structured. Depth Addresses the rigor of and level of detail in the testing process. There are three possible values for the depth attribute: (i) cursory; (ii) exploratory; and (iii) comprehensive.

Assurance Attribute Applicable to all assessment methods
Addresses the expectation of the assessor in assessing the implementation of the security control Values for the assurance attributes are derived directly from the minimum assurance requirements described in NIST Special Publication

Assurance Attribute Low Impact Systems Moderate Impact Systems
The focus is on the control being in place with the expectation that no obvious errors exist and that, as flaws are discovered, they are addressed in a timely manner. Moderate Impact Systems The focus is on ensuring that the control is implemented correctly and operating as intended. While flaws are still likely to be uncovered (and addressed expeditiously), the control developer/implementer incorporates, as part of the control, specific capabilities to ensure the control meets its function or purpose. High Impact Systems The focus is expanded to require, within the control, the capabilities that are needed to support continuous and consistent operation of the control and to support continuous improvement in the control’s effectiveness.

Assessment Expectations
Low Impact Systems Interviews, examinations, and tests are conducted in an informal, unstructured manner at a cursory level of depth and seek to ensure that there are no obvious errors in the security control Moderate Impact Systems Interviews, examinations, and tests are conducted in a formal, structured manner at an exploratory level of depth, and seek to ensure that the security control is implemented correctly and operating as intended High Impact Systems Interviews, examinations, and tests are conducted in a formal, structured manner at a comprehensive level of depth, and seek to ensure that the security control is implemented correctly and operating as intended on a continuous and consistent basis with continuous improvement in control effectiveness

Development Methodology
Building an assessment procedure for every security control in SP catalog and for every control enhancement Tailoring the assessment procedures according to impact level (low, moderate, high) Assessment procedures have a well-defined numbering system to support potential tool development efforts

Publication Options and Schedule
Several options under consideration for SP A publication Option 1: Publish the assessment procedures for security controls employed in low impact systems first; conduct public review; finish the remaining procedures for moderate and high Option 2: Publish all assessment procedures for security controls at the same time; conduct public review Initial Public Draft: March-April 2005

Defined objects/ numbers
Methods: Interview, Examine, Test impact level attribute values low moderate high Coverage Specified assessment objects to be assessed (i.e., specifications, activities, mechanisms, or artifacts) and number of objects to be assessed Defined objects/ numbers Scope (Test only) Black Box √ Gray Box --- Penetration Approach Informal, unstructured Formal, structured Depth Cursory Exploratory Comprehensive Assurance No obvious errors Correct implementation, operating as intended Ongoing consistent operation and continuous improvement [1] Assessment objects are specified on a per control basis and are a function of the assessment methods employed to assess that particular control. The assessment objects are listed in the heading section of the assessment procedure for each control. Consult the supplemental guidance sections of the respective assessment method definitions for a general description of the types of assessment objects that are appropriate for those methods. The number of assessment objects assessed for each type of object is determined by the organization in collaboration with the assessor but should be consistent with level of depth of the assessment (i.e., an exploratory level of depth would typically include a greater number (or percentage) of objects assessed than a cursory level of depth but a lesser number of objects (or percentage) of objects assessed than a comprehensive level of depth).

The Conceptual Model Assessment Methods Interview Examine Test Security Control Number Baseline Assessment Procedure Input Process Output Framework Example: First security control in Contingency Planning Family {CP-1, low}  {Interview, Examine}  Assessment Procedure CP-1

ASSESSMENT PROCEDURES
CP-1 CONTINGENCY PLANNING POLICY AND PROCEDURES Control: The organization develops, disseminates, and periodically reviews/updates: (i) a formal, documented, contingency planning policy that addresses purpose, scope, roles, responsibilities, and compliance; and (ii) formal, documented procedures to facilitate the implementation of the contingency planning policy and associated contingency planning controls. ASSESSMENT METHODS: Interview, Examine ASSESSMENT OBJECTS: Specifications (policy, procedures) Apply ASSESSMENT PROCEDURES FS PS NS Low CP Interview the Chief Information Officer, Chief Information Security Officer, or their designated representatives to determine which elements of the organization are responsible for developing, disseminating, reviewing, and updating the contingency planning policy and associated procedures for implementing the policy. CP Interview the Information System Owner (or appropriate/equivalent party) to identify and arrange access to: (i) the contingency plan for the information system and any associated contingency-related procedures; (ii) individuals or groups responsible for the development, implementation, operation, and maintenance of the contingency plan and procedures; (iii) any materials (including records) associated with the implementation of the continginency plan or contingency operations; and (iv) guidance on the number/percentage of objects to be assessed by type. CP Examine the contingency planning policy to determine if the policy addresses purpose, scope, roles, responsibilities, and compliance for contingency operations. CP Interview selected organizational personnel with contingency planning responsibilities to determine if the contingency planning policy is: (i) disseminated to appropriate elements within the organization; (ii) reviewed by responsible parties within the organization; and (iii) updated, if review indicates updates are required.

Low CP Examine contingency planning policy for evidence (e.g., policy version notation or record of updates) that the policy is being updated periodically (if policy review indicates updates are required). CP Examine contingency planning procedures to determine if the necessary procedures to implement the contingency planning policy are available. CP Interview selected organizational personnel with contingency planning responsibilities to determine if the contingency planning procedures are: (i) disseminated to appropriate elements within the organization; (ii) reviewed by responsible parties within the organization; and (iii) updated, if review indicates updates are required. CP Examine contingency planning procedures for evidence (e.g., procedure version notation or record of updates) that the procedures are being updated (if procedure review indicates updates are required). CP Interview selected organizational personnel with responsibility for implementing contingency planning procedures to determine if the procedures are in effect. Control Enhancements: None.

Contact Information 100 Bureau Drive Mailstop 8930 Gaithersburg, MD USA Project Manager Administrative Support Dr. Ron Ross Peggy Himes (301) (301) Senior Information Security Researchers and Technical Support Marianne Swanson Dr. Stu Katzke (301) (301) Pat Toth Arnold Johnson (301) (301) Curt Barker Information and Feedback (301) Web: csrc.nist.gov/sec-cert Comments:

The New FISMA Standards and Guidelines or Building More Secure Information Systems A Strategy for Effectively Applying the Provisions of FISMA Dr. Ron.

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The New FISMA Standards and Guidelines or Building More Secure Information Systems A Strategy for Effectively Applying the Provisions of FISMA Dr. Ron.

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