Asset Management Checklist

This page contains controls:

  • AC-4 – Information Flow Enforcement
  • AC-20 – Use of External Systems
  • CA-3 – Information Exchange
  • CA-9 – Internal System Connections
  • CM-8 – System Component Inventory
  • CP-2 – Contingency Plan
  • PL-8 – Security and Privacy Architectures
  • PM-5 – System Inventory
  • PM-11 – Mission and Business Process Definition
  • PS-7 – External Personnel Security
  • RA-2 – Security Categorization
  • SA-9 – External System Services
  • SC-6 – Resource Availability

[AC-4] Information Flow Enforcement

Information flow control regulates where information can travel within a system and between systems (in contrast to who is allowed to access the information) and without regard to subsequent accesses to that information. Flow control restrictions include blocking external traffic that claims to be from within the organization, keeping export-controlled information from being transmitted in the clear to the Internet, restricting web requests that are not from the internal web proxy server, and limiting information transfers between organizations based on data structures and content. Transferring information between organizations may require an agreement specifying how the information flow is enforced (see CA-3). Transferring information between systems in different security or privacy domains with different security or privacy policies introduces the risk that such transfers violate one or more domain security or privacy policies. In such situations, information owners/stewards provide guidance at designated policy enforcement points between connected systems. Organizations consider mandating specific architectural solutions to enforce specific security and privacy policies. Enforcement includes prohibiting information transfers between connected systems (i.e., allowing access only), verifying write permissions before accepting information from another security or privacy domain or connected system, employing hardware mechanisms to enforce one-way information flows, and implementing trustworthy regrading mechanisms to reassign security or privacy attributes and labels.

Organizations commonly employ information flow control policies and enforcement mechanisms to control the flow of information between designated sources and destinations within systems and between connected systems. Flow control is based on the characteristics of the information and/or the information path. Enforcement occurs, for example, in boundary protection devices that employ rule sets or establish configuration settings that restrict system services, provide a packet-filtering capability based on header information, or provide a message-filtering capability based on message content. Organizations also consider the trustworthiness of filtering and/or inspection mechanisms (i.e., hardware, firmware, and software components) that are critical to information flow enforcement. Control enhancements 3 through 32 primarily address cross-domain solution needs that focus on more advanced filtering techniques, in-depth analysis, and stronger flow enforcement mechanisms implemented in cross-domain products, such as high-assurance guards. Such capabilities are generally not available in commercial off-the-shelf products. Information flow enforcement also applies to control plane traffic (e.g., routing and DNS).

  1. Enforce approved authorizations for controlling the flow of information within the system and between connected systems based on [TODO: organization-defined information flow control policies].

[AC-4.1] Object Security and Privacy Attributes

Information flow enforcement mechanisms compare security and privacy attributes associated with information (i.e., data content and structure) and source and destination objects and respond appropriately when the enforcement mechanisms encounter information flows not explicitly allowed by information flow policies. For example, an information object labeled Secret would be allowed to flow to a destination object labeled Secret, but an information object labeled Top Secret would not be allowed to flow to a destination object labeled Secret. A dataset of personally identifiable information may be tagged with restrictions against combining with other types of datasets and, thus, would not be allowed to flow to the restricted dataset. Security and privacy attributes can also include source and destination addresses employed in traffic filter firewalls. Flow enforcement using explicit security or privacy attributes can be used, for example, to control the release of certain types of information.

  1. Use [Assignment: organization-defined security and privacy attributes] associated with [Assignment: organization-defined information, source, and destination objects] to enforce [Assignment: organization-defined information flow control policies] as a basis for flow control decisions.

[AC-4.2] Processing Domains

Protected processing domains within systems are processing spaces that have controlled interactions with other processing spaces, enabling control of information flows between these spaces and to/from information objects. A protected processing domain can be provided, for example, by implementing domain and type enforcement. In domain and type enforcement, system processes are assigned to domains, information is identified by types, and information flows are controlled based on allowed information accesses (i.e., determined by domain and type), allowed signaling among domains, and allowed process transitions to other domains.

  1. Use protected processing domains to enforce [Assignment: organization-defined information flow control policies] as a basis for flow control decisions.

[AC-4.3] Dynamic Information Flow Control

Organizational policies regarding dynamic information flow control include allowing or disallowing information flows based on changing conditions or mission or operational considerations. Changing conditions include changes in risk tolerance due to changes in the immediacy of mission or business needs, changes in the threat environment, and detection of potentially harmful or adverse events.

  1. Enforce [Assignment: organization-defined information flow control policies].

[AC-4.4] Flow Control of Encrypted Information

Flow control mechanisms include content checking, security policy filters, and data type identifiers. The term encryption is extended to cover encoded data not recognized by filtering mechanisms.

  1. Prevent encrypted information from bypassing [Assignment: organization-defined information flow control mechanisms] by [Selection (one or more): decrypting the information; blocking the flow of the encrypted information; terminating communications sessions attempting to pass encrypted information; [Assignment: organization-defined procedure or method]].

[AC-4.5] Embedded Data Types

Embedding data types within other data types may result in reduced flow control effectiveness. Data type embedding includes inserting files as objects within other files and using compressed or archived data types that may include multiple embedded data types. Limitations on data type embedding consider the levels of embedding and prohibit levels of data type embedding that are beyond the capability of the inspection tools.

  1. Enforce [Assignment: organization-defined limitations] on embedding data types within other data types.

[AC-4.6] Metadata

Metadata is information that describes the characteristics of data. Metadata can include structural metadata describing data structures or descriptive metadata describing data content. Enforcement of allowed information flows based on metadata enables simpler and more effective flow control. Organizations consider the trustworthiness of metadata regarding data accuracy (i.e., knowledge that the metadata values are correct with respect to the data), data integrity (i.e., protecting against unauthorized changes to metadata tags), and the binding of metadata to the data payload (i.e., employing sufficiently strong binding techniques with appropriate assurance).

  1. Enforce information flow control based on [Assignment: organization-defined metadata].

[AC-4.7] One-way Flow Mechanisms

One-way flow mechanisms may also be referred to as a unidirectional network, unidirectional security gateway, or data diode. One-way flow mechanisms can be used to prevent data from being exported from a higher impact or classified domain or system while permitting data from a lower impact or unclassified domain or system to be imported.

  1. Enforce one-way information flows through hardware-based flow control mechanisms.

[AC-4.8] Security and Privacy Policy Filters

Organization-defined security or privacy policy filters can address data structures and content. For example, security or privacy policy filters for data structures can check for maximum file lengths, maximum field sizes, and data/file types (for structured and unstructured data). Security or privacy policy filters for data content can check for specific words, enumerated values or data value ranges, and hidden content. Structured data permits the interpretation of data content by applications. Unstructured data refers to digital information without a data structure or with a data structure that does not facilitate the development of rule sets to address the impact or classification level of the information conveyed by the data or the flow enforcement decisions. Unstructured data consists of bitmap objects that are inherently non-language-based (i.e., image, video, or audio files) and textual objects that are based on written or printed languages. Organizations can implement more than one security or privacy policy filter to meet information flow control objectives.

  1. Enforce information flow control using [TODO: organization-defined security or privacy policy filters] as a basis for flow control decisions for [TODO: organization-defined information flows]; and
  2. Selection (one or more) data after a filter processing failure in accordance with [TODO: organization-defined security or privacy policy].
    • Block
    • Strip
    • Modify
    • Quarantine

[AC-4.9] Human Reviews

Organizations define security or privacy policy filters for all situations where automated flow control decisions are possible. When a fully automated flow control decision is not possible, then a human review may be employed in lieu of or as a complement to automated security or privacy policy filtering. Human reviews may also be employed as deemed necessary by organizations.

  1. Enforce the use of human reviews for [Assignment: organization-defined information flows] under the following conditions: [Assignment: organization-defined conditions].

[AC-4.10] Enable and Disable Security or Privacy Policy Filters

For example, as allowed by the system authorization, administrators can enable security or privacy policy filters to accommodate approved data types. Administrators also have the capability to select the filters that are executed on a specific data flow based on the type of data that is being transferred, the source and destination security domains, and other security or privacy relevant features, as needed.

  1. Provide the capability for privileged administrators to enable and disable [Assignment: organization-defined security or privacy policy filters] under the following conditions: [Assignment: organization-defined conditions].

[AC-4.11] Configuration of Security or Privacy Policy Filters

Documentation contains detailed information for configuring security or privacy policy filters. For example, administrators can configure security or privacy policy filters to include the list of inappropriate words that security or privacy policy mechanisms check in accordance with the definitions provided by organizations.

  1. Provide the capability for privileged administrators to configure [Assignment: organization-defined security or privacy policy filters] to support different security or privacy policies.

[AC-4.12] Data Type Identifiers

Data type identifiers include filenames, file types, file signatures or tokens, and multiple internal file signatures or tokens. Systems only allow transfer of data that is compliant with data type format specifications. Identification and validation of data types is based on defined specifications associated with each allowed data format. The filename and number alone are not used for data type identification. Content is validated syntactically and semantically against its specification to ensure that it is the proper data type.

  1. When transferring information between different security domains, use [Assignment: organization-defined data type identifiers] to validate data essential for information flow decisions.

[AC-4.13] Decomposition into Policy-relevant Subcomponents

Decomposing information into policy-relevant subcomponents prior to information transfer facilitates policy decisions on source, destination, certificates, classification, attachments, and other security- or privacy-related component differentiators. Policy enforcement mechanisms apply filtering, inspection, and/or sanitization rules to the policy-relevant subcomponents of information to facilitate flow enforcement prior to transferring such information to different security domains.

  1. When transferring information between different security domains, decompose information into [Assignment: organization-defined policy-relevant subcomponents] for submission to policy enforcement mechanisms.

[AC-4.14] Security or Privacy Policy Filter Constraints

Data structure and content restrictions reduce the range of potential malicious or unsanctioned content in cross-domain transactions. Security or privacy policy filters that restrict data structures include restricting file sizes and field lengths. Data content policy filters include encoding formats for character sets, restricting character data fields to only contain alpha-numeric characters, prohibiting special characters, and validating schema structures.

  1. When transferring information between different security domains, implement [Assignment: organization-defined security or privacy policy filters] requiring fully enumerated formats that restrict data structure and content.

[AC-4.15] Detection of Unsanctioned Information

Unsanctioned information includes malicious code, information that is inappropriate for release from the source network, or executable code that could disrupt or harm the services or systems on the destination network.

  1. When transferring information between different security domains, examine the information for the presence of [Assignment: organization-defined unsanctioned information] and prohibit the transfer of such information in accordance with the [Assignment: organization-defined security or privacy policy].

[AC-4.17] Domain Authentication

Attribution is a critical component of a security and privacy concept of operations. The ability to identify source and destination points for information flowing within systems allows the forensic reconstruction of events and encourages policy compliance by attributing policy violations to specific organizations or individuals. Successful domain authentication requires that system labels distinguish among systems, organizations, and individuals involved in preparing, sending, receiving, or disseminating information. Attribution also allows organizations to better maintain the lineage of personally identifiable information processing as it flows through systems and can facilitate consent tracking, as well as correction, deletion, or access requests from individuals.

  1. Uniquely identify and authenticate source and destination points by [Selection (one or more): organization; system; application; service; individual] for information transfer.

[AC-4.19] Validation of Metadata

All information (including metadata and the data to which the metadata applies) is subject to filtering and inspection. Some organizations distinguish between metadata and data payloads (i.e., only the data to which the metadata is bound). Other organizations do not make such distinctions and consider metadata and the data to which the metadata applies to be part of the payload.

  1. When transferring information between different security domains, implement [Assignment: organization-defined security or privacy policy filters] on metadata.

[AC-4.20] Approved Solutions

Organizations define approved solutions and configurations in cross-domain policies and guidance in accordance with the types of information flows across classification boundaries. The National Security Agency (NSA) National Cross Domain Strategy and Management Office provides a listing of approved cross-domain solutions. Contact [email protected] for more information.

  1. Employ [Assignment: organization-defined solutions in approved configurations] to control the flow of [Assignment: organization-defined information] across security domains.

[AC-4.21] Physical or Logical Separation of Information Flows

Enforcing the separation of information flows associated with defined types of data can enhance protection by ensuring that information is not commingled while in transit and by enabling flow control by transmission paths that are not otherwise achievable. Types of separable information include inbound and outbound communications traffic, service requests and responses, and information of differing security impact or classification levels.

  1. Separate information flows logically or physically using [Assignment: organization-defined mechanisms and/or techniques] to accomplish [Assignment: organization-defined required separations by types of information].

[AC-4.22] Access Only

The system provides a capability for users to access each connected security domain without providing any mechanisms to allow users to transfer data or information between the different security domains. An example of an access-only solution is a terminal that provides a user access to information with different security classifications while assuredly keeping the information separate.

  1. Provide access from a single device to computing platforms, applications, or data residing in multiple different security domains, while preventing information flow between the different security domains.

[AC-4.23] Modify Non-releasable Information

Modifying non-releasable information can help prevent a data spill or attack when information is transferred across security domains. Modification actions include masking, permutation, alteration, removal, or redaction.

  1. When transferring information between different security domains, modify non-releasable information by implementing [Assignment: organization-defined modification action].

[AC-4.24] Internal Normalized Format

Converting data into normalized forms is one of most of effective mechanisms to stop malicious attacks and large classes of data exfiltration.

  1. When transferring information between different security domains, parse incoming data into an internal normalized format and regenerate the data to be consistent with its intended specification.

[AC-4.25] Data Sanitization

Data sanitization is the process of irreversibly removing or destroying data stored on a memory device (e.g., hard drives, flash memory/solid state drives, mobile devices, CDs, and DVDs) or in hard copy form.

  1. When transferring information between different security domains, sanitize data to minimize [Selection (one or more): delivery of malicious content, command and control of malicious code, malicious code augmentation, and steganography encoded data; spillage of sensitive information] in accordance with [Assignment: organization-defined policy]].

[AC-4.26] Audit Filtering Actions

Content filtering is the process of inspecting information as it traverses a cross-domain solution and determines if the information meets a predefined policy. Content filtering actions and the results of filtering actions are recorded for individual messages to ensure that the correct filter actions were applied. Content filter reports are used to assist in troubleshooting actions by, for example, determining why message content was modified and/or why it failed the filtering process. Audit events are defined in AU-2. Audit records are generated in AU-12.

  1. When transferring information between different security domains, record and audit content filtering actions and results for the information being filtered.

[AC-4.27] Redundant/independent Filtering Mechanisms

Content filtering is the process of inspecting information as it traverses a cross-domain solution and determines if the information meets a predefined policy. Redundant and independent content filtering eliminates a single point of failure filtering system. Independence is defined as the implementation of a content filter that uses a different code base and supporting libraries (e.g., two JPEG filters using different vendors’ JPEG libraries) and multiple, independent system processes.

  1. When transferring information between different security domains, implement content filtering solutions that provide redundant and independent filtering mechanisms for each data type.

[AC-4.28] Linear Filter Pipelines

Content filtering is the process of inspecting information as it traverses a cross-domain solution and determines if the information meets a predefined policy. The use of linear content filter pipelines ensures that filter processes are non-bypassable and always invoked. In general, the use of parallel filtering architectures for content filtering of a single data type introduces bypass and non-invocation issues.

  1. When transferring information between different security domains, implement a linear content filter pipeline that is enforced with discretionary and mandatory access controls.

[AC-4.29] Filter Orchestration Engines

Content filtering is the process of inspecting information as it traverses a cross-domain solution and determines if the information meets a predefined security policy. An orchestration engine coordinates the sequencing of activities (manual and automated) in a content filtering process. Errors are defined as either anomalous actions or unexpected termination of the content filter process. This is not the same as a filter failing content due to non-compliance with policy. Content filter reports are a commonly used mechanism to ensure that expected filtering actions are completed successfully.

  1. When transferring information between different security domains, employ content filter orchestration engines to ensure that:
    • (a) Content filtering mechanisms successfully complete execution without errors; and
    • (b) Content filtering actions occur in the correct order and comply with [TODO: organization-defined policy].

[AC-4.30] Filter Mechanisms Using Multiple Processes

The use of multiple processes to implement content filtering mechanisms reduces the likelihood of a single point of failure.

  1. When transferring information between different security domains, implement content filtering mechanisms using multiple processes.

[AC-4.31] Failed Content Transfer Prevention

Content that failed filtering checks can corrupt the system if transferred to the receiving domain.

  1. When transferring information between different security domains, prevent the transfer of failed content to the receiving domain.

[AC-4.32] Process Requirements for Information Transfer

The processes transferring information between filter pipelines have minimum complexity and functionality to provide assurance that the processes operate correctly.

  1. When transferring information between different security domains, the process that transfers information between filter pipelines:
    • Does not filter message content;
    • Validates filtering metadata;
    • Ensures the content associated with the filtering metadata has successfully completed filtering; and
    • Transfers the content to the destination filter pipeline.

[AC-20] Use of External Systems

External systems are systems that are used by but not part of organizational systems, and for which the organization has no direct control over the implementation of required controls or the assessment of control effectiveness. External systems include personally owned systems, components, or devices; privately owned computing and communications devices in commercial or public facilities; systems owned or controlled by nonfederal organizations; systems managed by contractors; and federal information systems that are not owned by, operated by, or under the direct supervision or authority of the organization. External systems also include systems owned or operated by other components within the same organization and systems within the organization with different authorization boundaries. Organizations have the option to prohibit the use of any type of external system or prohibit the use of specified types of external systems, (e.g., prohibit the use of any external system that is not organizationally owned or prohibit the use of personally-owned systems).
For some external systems (i.e., systems operated by other organizations), the trust relationships that have been established between those organizations and the originating organization may be such that no explicit terms and conditions are required. Systems within these organizations may not be considered external. These situations occur when, for example, there are pre-existing information exchange agreements (either implicit or explicit) established between organizations or components or when such agreements are specified by applicable laws, executive orders, directives, regulations, policies, or standards. Authorized individuals include organizational personnel, contractors, or other individuals with authorized access to organizational systems and over which organizations have the authority to impose specific rules of behavior regarding system access. Restrictions that organizations impose on authorized individuals need not be uniform, as the restrictions may vary depending on trust relationships between organizations. Therefore, organizations may choose to impose different security restrictions on contractors than on state, local, or tribal governments.
External systems used to access public interfaces to organizational systems are outside the scope of AC-20. Organizations establish specific terms and conditions for the use of external systems in accordance with organizational security policies and procedures. At a minimum, terms and conditions address the specific types of applications that can be accessed on organizational systems from external systems and the highest security category of information that can be processed, stored, or transmitted on external systems. If the terms and conditions with the owners of the external systems cannot be established, organizations may impose restrictions on organizational personnel using those external systems.

  1. [Selection (one or more): Establish [Assignment: organization-defined terms and conditions]; Identify [Assignment: organization-defined controls asserted to be implemented on external systems]], consistent with the trust relationships established with other organizations owning, operating, and/or maintaining external systems, allowing authorized individuals to:
    • Access the system from external systems; and
    • Process, store, or transmit organization-controlled information using external systems; or
  2. Prohibit the use of [Assignment: organizationally-defined types of external systems].

[AC-20.1] Limits on Authorized Use

Limiting authorized use recognizes circumstances where individuals using external systems may need to access organizational systems. Organizations need assurance that the external systems contain the necessary controls so as not to compromise, damage, or otherwise harm organizational systems. Verification that the required controls have been implemented can be achieved by external, independent assessments, attestations, or other means, depending on the confidence level required by organizations.

  1. Permit authorized individuals to use an external system to access the system or to process, store, or transmit organization-controlled information only after:
    • Verification of the implementation of controls on the external system as specified in the organization’s security and privacy policies and security and privacy plans; or
    • Retention of approved system connection or processing agreements with the organizational entity hosting the external system.

[AC-20.2] Portable Storage Devices — Restricted Use

Limits on the use of organization-controlled portable storage devices in external systems include restrictions on how the devices may be used and under what conditions the devices may be used.

  1. Restrict the use of organization-controlled portable storage devices by authorized individuals on external systems using [Assignment: organization-defined restrictions].

[AC-20.3] Non-organizationally Owned Systems — Restricted Use

Non-organizationally owned systems or system components include systems or system components owned by other organizations as well as personally owned devices. There are potential risks to using non-organizationally owned systems or components. In some cases, the risk is sufficiently high as to prohibit such use (see AC-20 b.). In other cases, the use of such systems or system components may be allowed but restricted in some way. Restrictions include requiring the implementation of approved controls prior to authorizing the connection of non-organizationally owned systems and components; limiting access to types of information, services, or applications; using virtualization techniques to limit processing and storage activities to servers or system components provisioned by the organization; and agreeing to the terms and conditions for usage. Organizations consult with the Office of the General Counsel regarding legal issues associated with using personally owned devices, including requirements for conducting forensic analyses during investigations after an incident.

  1. Restrict the use of non-organizationally owned systems or system components to process, store, or transmit organizational information using [Assignment: organization-defined restrictions].

[AC-20.4] Network Accessible Storage Devices — Prohibited Use

Network-accessible storage devices in external systems include online storage devices in public, hybrid, or community cloud-based systems.

  1. Prohibit the use of [Assignment: organization-defined network accessible storage devices] in external systems.

[AC-20.5] Portable Storage Devices — Prohibited Use

Limits on the use of organization-controlled portable storage devices in external systems include a complete prohibition of the use of such devices. Prohibiting such use is enforced using technical methods and/or nontechnical (i.e., process-based) methods.

  1. Prohibit the use of organization-controlled portable storage devices by authorized individuals on external systems.

[CA-3] Information Exchange

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.

  1. Approve and manage the exchange of information between the system and other systems using [Selection (one or more): interconnection security agreements; information exchange security agreements; memoranda of understanding or agreement; service level agreements; user agreements; nondisclosure agreements; [Assignment: organization-defined type of agreement]];
  2. Document, as part of each exchange agreement, the interface characteristics, security and privacy requirements, controls, and responsibilities for each system, and the impact level of the information communicated; and
  3. Review and update the agreements [Assignment: organization-defined frequency].

[CA-3.6] Transfer Authorizations

To prevent unauthorized individuals and systems from making information transfers to protected systems, the protected system verifies—via independent means— whether the individual or system attempting to transfer information is authorized to do so. Verification of the authorization to transfer information also applies to control plane traffic (e.g., routing and DNS) and services (e.g., authenticated SMTP relays).

  1. Verify that individuals or systems transferring data between interconnecting systems have the requisite authorizations (i.e., write permissions or privileges) prior to accepting such data.

[CA-3.7] Transitive Information Exchanges

Transitive or downstream information exchanges are information exchanges between the system or systems with which the organizational system exchanges information and other systems. For mission-essential systems, services, and applications, including high value assets, it is necessary to identify such information exchanges. The transparency of the controls or protection measures in place in such downstream systems connected directly or indirectly to organizational systems is essential to understanding the security and privacy risks resulting from those information exchanges. Organizational systems can inherit risk from downstream systems through transitive connections and information exchanges, which can make the organizational systems more susceptible to threats, hazards, and adverse impacts.

  1. Identify transitive (downstream) information exchanges with other systems through the systems identified in CA-3a; and
  2. Take measures to ensure that transitive (downstream) information exchanges cease when the controls on identified transitive (downstream) systems cannot be verified or validated.

[CA-9] Internal System Connections

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.

  1. a. Authorize internal connections of [Assignment: organization-defined system components or classes of components] to the system;
  2. b. Document, for each internal connection, the interface characteristics, security and privacy requirements, and the nature of the information communicated;
  3. c. Terminate internal system connections after [Assignment: organization-defined conditions]; and
  4. d. Review [Assignment: organization-defined frequency] the continued need for each internal connection.

[CA-9.1] Compliance Checks

Compliance checks include verification of the relevant baseline configuration.

  1. Perform security and privacy compliance checks on constituent system components prior to the establishment of the internal connection.

[CM-8] System Component Inventory

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.

  1. Develop and document an inventory of system components that:
    • Accurately reflects the system
    • Includes all components within the system
    • Does not include duplicate accounting of components or components assigned to any other system
    • Is at the level of granularity deemed necessary for tracking and reporting
    • Includes the following information to achieve system component accountability [TODO]
  2. Review and update the system component inventory [TODO: How often?]

[CM-8.1] Updates During Installation and Removal

Organizations can improve the accuracy, completeness, and consistency of system component inventories if the inventories are updated as part of component installations or removals or during general system updates. If inventories are not updated at these key times, there is a greater likelihood that the information will not be appropriately captured and documented. System updates include hardware, software, and firmware components.

  1. Update the inventory of system components as part of component installations, removals, and system updates.

[CM-8.2] Automated Maintenance

Organizations maintain system inventories to the extent feasible. For example, virtual machines can be difficult to monitor because such machines are not visible to the network when not in use. In such cases, organizations maintain as up-to-date, complete, and accurate an inventory as is deemed reasonable. Automated maintenance can be achieved by the implementation of CM-2.2 for organizations that combine system component inventory and baseline configuration activities.

  1. Maintain the currency, completeness, accuracy, and availability of the inventory of system components using [Assignment: organization-defined automated mechanisms].

[CM-8.3] Automated Unauthorized Component Detection

Automated unauthorized component detection is applied in addition to the monitoring for unauthorized remote connections and mobile devices. Monitoring for unauthorized system components may be accomplished on an ongoing basis or by the periodic scanning of systems for that purpose. Automated mechanisms may also be used to prevent the connection of unauthorized components (see CM-7(9)). Automated mechanisms can be implemented in systems or in separate system components. When acquiring and implementing automated mechanisms, organizations consider whether such mechanisms depend on the ability of the system component to support an agent or supplicant in order to be detected since some types of components do not have or cannot support agents (e.g., IoT devices, sensors). Isolation can be achieved , for example, by placing unauthorized system components in separate domains or subnets or quarantining such components. This type of  component isolation is commonly referred to as sandboxing.

  1. Detect the presence of unauthorized hardware, software, and firmware components within the system using
    • [TODO: organization-defined automated mechanisms]
    • [TODO: organization-defined frequency]
  2. Take the following actions when unauthorized components are detected: [Selection (one or more): disable network access by such components; isolate the components; notify
    • [TODO: organization-defined personnel or roles]].

[CM-8.4] Accountability Information

Identifying individuals who are responsible and accountable for administering system components ensures that the assigned components are properly administered and that organizations can contact those individuals if some action is required (e.g., when the component is determined to be the source of a breach, needs to be recalled or replaced, or needs to be relocated).

  1. Include in the system component inventory information, a means for identifying by [Selection (one or more): name; position; role], individuals responsible and accountable for administering those components.

[CM-8.5] deprecated

[CM-8.6] Assessed Configurations and Approved Deviations

Assessed configurations and approved deviations focus on configuration settings established by organizations for system components, the specific components that have been assessed to determine compliance with the required configuration settings, and any approved deviations from established configuration settings.

  1. Include assessed component configurations and any approved deviations to current deployed configurations in the system component inventory.

[CM-8.7] Centralized Repository

Organizations may implement centralized system component inventories that include components from all organizational systems. Centralized repositories of component inventories provide opportunities for efficiencies in accounting for organizational hardware, software, and firmware assets. Such repositories may also help organizations rapidly identify the location and responsible individuals of components that have been compromised, breached, or are otherwise in need of mitigation actions. Organizations ensure that the resulting centralized inventories include system-specific information required for proper component accountability.

  1. Provide a centralized repository for the inventory of system components.

[CM-8.8] Automated Location Tracking

The use of automated mechanisms to track the location of system components can increase the accuracy of component inventories. Such capability may help organizations rapidly identify the location and responsible individuals of system components that have been compromised, breached, or are otherwise in need of mitigation actions. The use of tracking mechanisms can be coordinated with senior agency officials for privacy if there are implications that affect individual privacy.

  1. Support the tracking of system components by geographic location using
    • [TODO: organization-defined automated mechanisms].

[CM-8.9] Assignment of Components to Systems

System components that are not assigned to a system may be unmanaged, lack the required protection, and become an organizational vulnerability.

  1. (a) Assign system components to a system; and
  2. (b) Receive an acknowledgement from
    • [TODO: organization-defined personnel or roles] of this assignment.

[CP-2] Contingency Plan

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.

  1. Develop a contingency plan for the system that:
    • Identifies essential mission and business functions and associated contingency requirements;
    • Provides recovery objectives, restoration priorities, and metrics;
    • Addresses contingency roles, responsibilities, assigned individuals with contact information;
    • Addresses maintaining essential mission and business functions despite a system disruption, compromise, or failure;
    • Addresses eventual, full system restoration without deterioration of the controls originally planned and implemented;
    • Addresses the sharing of contingency information; and
    • Is reviewed and approved by [Assignment: organization-defined personnel or roles];
  2. Distribute copies of the contingency plan to [Assignment: organization-defined key contingency personnel (identified by name and/or by role) and organizational elements];
  3. Coordinate contingency planning activities with incident handling activities;
  4. Review the contingency plan for the system [Assignment: organization-defined frequency];
  5. Update the contingency plan to address changes to the organization, system, or environment of operation and problems encountered during contingency plan implementation, execution, or testing;
  6. Communicate contingency plan changes to [Assignment: organization-defined key contingency personnel (identified by name and/or by role) and organizational elements];
  7. Incorporate lessons learned from contingency plan testing, training, or actual contingency activities into contingency testing and training; and
  8. Protect the contingency plan from unauthorized disclosure and modification.

[CP-2.1] Coordinate with Related Plans

Plans that are related to contingency plans include Business Continuity Plans, Disaster Recovery Plans, Critical Infrastructure Plans, Continuity of Operations Plans, Crisis Communications Plans, Insider Threat Implementation Plans, Data Breach Response Plans, Cyber Incident Response Plans, Breach Response Plans, and Occupant Emergency Plans.

  1. Coordinate contingency plan development with organizational elements responsible for related plans.

[CP-2.2] Capacity Planning

Capacity planning is needed because different threats can result in a reduction of the available processing, telecommunications, and support services intended to support essential mission and business functions. Organizations anticipate degraded operations during contingency operations and factor the degradation into capacity planning. For capacity planning, environmental support refers to any environmental factor for which the organization determines that it needs to provide support in a contingency situation, even if in a degraded state. Such determinations are based on an organizational assessment of risk, system categorization (impact level), and organizational risk tolerance.

  1. Conduct capacity planning so that necessary capacity for information processing, telecommunications, and environmental support exists during contingency operations.

[CP-2.3] Resume Mission and Business Functions

Organizations may choose to conduct contingency planning activities to resume mission and business functions as part of business continuity planning or as part of business impact analyses. Organizations prioritize the resumption of mission and business functions. The time period for resuming mission and business functions may be dependent on the severity and extent of the disruptions to the system and its supporting infrastructure.

  1. Plan for the resumption of [Selection: all; essential] mission and business functions within [Assignment: organization-defined time period] of contingency plan activation.

[CP-2.4] <deprecated>

[CP-2.5] Continue Mission and Business Functions

Organizations may choose to conduct the contingency planning activities to continue mission and business functions as part of business continuity planning or business impact analyses. Primary processing and/or storage sites defined by organizations as part of contingency planning may change depending on the circumstances associated with the contingency.

  1. Plan for the continuance of [Selection: all; essential] mission and business functions with minimal or no loss of operational continuity and sustains that continuity until full system restoration at primary processing and/or storage sites.

[CP-2.6] Alternate Processing and Storage Sites

Organizations may choose to conduct contingency planning activities for alternate processing and storage sites as part of business continuity planning or business impact analyses. Primary processing and/or storage sites defined by organizations as part of contingency planning may change depending on the circumstances associated with the contingency.

  1. Plan for the transfer of [Selection: all; essential] mission and business functions to alternate processing and/or storage sites with minimal or no loss of operational continuity and sustain that continuity through system restoration to primary processing and/or storage sites.

[CP-2.7] Coordinate with External Service Providers

When the capability of an organization to carry out its mission and business functions is dependent on external service providers, developing a comprehensive and timely contingency plan may become more challenging. When mission and business functions are dependent on external service providers, organizations coordinate contingency planning activities with the external entities to ensure that the individual plans reflect the overall contingency needs of the organization.

  1. Coordinate the contingency plan with the contingency plans of external service providers to ensure that contingency requirements can be satisfied.

[CP-2.8] Identify Critical Assets

Organizations may choose to identify critical assets as part of criticality analysis, business continuity planning, or business impact analyses. Organizations identify critical system assets so that additional controls can be employed (beyond the controls routinely implemented) to help ensure that organizational mission and business functions can continue to be conducted during contingency operations. The identification of critical information assets also facilitates the prioritization of organizational resources. Critical system assets include technical and operational aspects. Technical aspects include system components, information technology services, information technology products, and mechanisms. Operational aspects include procedures (i.e., manually executed operations) and personnel (i.e., individuals operating technical controls and/or executing manual procedures). Organizational program protection plans can assist in identifying critical assets. If critical assets are resident within or supported by external service providers, organizations consider implementing CP-2(7) as a control enhancement.

  1. Identify critical system assets supporting [Selection: all; essential] mission and business functions.

[PL-8] Security and Privacy Architectures

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.

  1. Develop security and privacy architectures for the system that:
    • Describe the requirements and approach to be taken for protecting the confidentiality, integrity, and availability of organizational information;
    • Describe the requirements and approach to be taken for processing personally identifiable information to minimize privacy risk to individuals;
    • Describe how the architectures are integrated into and support the enterprise architecture; and
    • Describe any assumptions about, and dependencies on, external systems and services;
  2. Review and update the architectures [Assignment: organization-defined frequency] to reflect changes in the enterprise architecture; and
  3. Reflect planned architecture changes in security and privacy plans, Concept of Operations (CONOPS), criticality analysis, organizational procedures, and procurements and acquisitions.

[PL-8.1] Defense in Depth

Organizations strategically allocate security and privacy controls in the security and privacy architectures so that adversaries must overcome multiple controls to achieve their objective. Requiring adversaries to defeat multiple controls makes it more difficult to attack information resources by increasing the work factor of the adversary; it also increases the likelihood of detection. The coordination of allocated controls is essential to ensure that an attack that involves one control does not create adverse, unintended consequences by interfering with other controls. Unintended consequences can include system lockout and cascading alarms. The placement of controls in systems and organizations is an important activity that requires thoughtful analysis. The value of organizational assets is an important consideration in providing additional layering. Defense-in-depth architectural approaches include modularity and layering (see SA-8(3)), separation of system and user functionality (see SC-2), and security function isolation (see SC-3).

  1. Design the security and privacy architectures for the system using a defense-in-depth approach that:
    • Allocates [Assignment: organization-defined controls] to [Assignment: organization-defined locations and architectural layers]; and
    • Ensures that the allocated controls operate in a coordinated and mutually reinforcing manner.

[PL-8.2] Supplier Diversity

Information technology products have different strengths and weaknesses. Providing a broad spectrum of products complements the individual offerings. For example, vendors offering malicious code protection typically update their products at different times, often developing solutions for known viruses, Trojans, or worms based on their priorities and development schedules. By deploying different products at different locations, there is an increased likelihood that at least one of the products will detect the malicious code. With respect to privacy, vendors may offer products that track personally identifiable information in systems. Products may use different tracking methods. Using multiple products may result in more assurance that personally identifiable information is inventoried.

  1. Require that [Assignment: organization-defined controls] allocated to [Assignment: organization-defined locations and architectural layers] are obtained from different suppliers.

[PM-5] System Inventory

  1. Develop and update an inventory of organizational systems
    • [TODO: How often?]

[PM-5.1] Inventory of Personally Identifiable Information (PII)

  1. Establish, maintain, and update an inventory of all systems, applications, and projects that process personally identifiable information
    • [TODO: How often?].

[PM-11] Mission and Business Process Definition

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.

  1. Define organizational mission and business processes with consideration for information security and privacy and the resulting risk to organizational operations, organizational assets, individuals, other organizations, and the Nation; and
  2. Determine information protection and personally identifiable information processing needs arising from the defined mission and business processes; and
  3. Review and revise the mission and business processes [Assignment: organization-defined frequency].

[PS-7] External Personnel Security

External provider refers to organizations other than the organization operating or acquiring the system. External providers include service bureaus, contractors, and other organizations that provide system development, information technology services, testing or assessment services, outsourced applications, and network/security management. Organizations explicitly include personnel security requirements in acquisition-related documents. External providers may have personnel working at organizational facilities with credentials, badges, or system privileges issued by organizations. Notifications of external personnel changes ensure the appropriate termination of privileges and credentials. Organizations define the transfers and terminations deemed reportable by security-related characteristics that include functions, roles, and the nature of credentials or privileges associated with transferred or terminated individuals.

  1. Establish personnel security requirements, including security roles and responsibilities for external providers;
  2. Require external providers to comply with personnel security policies and procedures established by the organization;
  3. Document personnel security requirements;
  4. Require external providers to notify [Assignment: organization-defined personnel or roles] of any personnel transfers or terminations of external personnel who possess organizational credentials and/or badges, or who have system privileges within [Assignment: organization-defined time period]; and
  5. Monitor provider compliance with personnel security requirements.

[RA-2] Security Categorization

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.

  1. Categorize the system and information it processes, stores, and transmits;
  2. Document the security categorization results, including supporting rationale, in the security plan for the system; and
  3. Verify that the authorizing official or authorizing official designated representative reviews and approves the security categorization decision.

[RA-2.1] Impact-level Prioritization

Organizations apply the high-water mark concept to each system categorized in accordance with FIPS 199, resulting in systems designated as low impact, moderate impact, or high impact. Organizations that desire additional granularity in the system impact designations for risk-based decision-making, can further partition the systems into sub-categories of the initial system categorization. For example, an impact-level prioritization on a moderate-impact system can produce three new sub-categories: low-moderate systems, moderate-moderate systems, and high-moderate systems. Impact-level prioritization and the resulting sub-categories of the system give organizations an opportunity to focus their investments related to security control selection and the tailoring of control baselines in responding to identified risks. Impact-level prioritization can also be used to determine those systems that may be of heightened interest or value to adversaries or represent a critical loss to the federal enterprise, sometimes described as high value assets. For such high value assets, organizations may be more focused on complexity, aggregation, and information exchanges. Systems with high value assets can be prioritized by partitioning high-impact systems into low-high systems, moderate-high systems, and high-high systems. Alternatively, organizations can apply the guidance in CNSSI 1253 for security objective-related categorization.

  1. Conduct an impact-level prioritization of organizational systems to obtain additional granularity on system impact levels.

[SA-9] External System Services

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.

  1. Require that providers of external system services comply with organizational security and privacy requirements and employ the following controls: [Assignment: organization-defined controls];
  2. Define and document organizational oversight and user roles and responsibilities with regard to external system services; and
  3. Employ the following processes, methods, and techniques to monitor control compliance by external service providers on an ongoing basis: [Assignment: organization-defined processes, methods, and techniques].

[SA-9.1] Risk Assessments and Organizational Approvals

Information security services include the operation of security devices, such as firewalls or key management services as well as incident monitoring, analysis, and response. Risks assessed can include system, mission or business, security, privacy, or supply chain risks.

  1. Conduct an organizational assessment of risk prior to the acquisition or outsourcing of information security services; and
  2. Verify that the acquisition or outsourcing of dedicated information security services is approved by Post288 Officers.

[SA-9.2] Identification of Functions, Ports, Protocols, and Services

Information from external service providers regarding the specific functions, ports, protocols, and services used in the provision of such services can be useful when the need arises to understand the trade-offs involved in restricting certain functions and services or blocking certain ports and protocols.

  1. Require providers of the following external system services to identify the functions, ports, protocols, and other services required for the use of such services: [Assignment: organization-defined external system services].

[SA-9.3] Establish and Maintain Trust Relationship with Providers

Trust relationships between organizations and external service providers reflect the degree of confidence that the risk from using external services is at an acceptable level. Trust relationships can help organizations gain increased levels of confidence that service providers are providing adequate protection for the services rendered and can also be useful when conducting incident response or when planning for upgrades or obsolescence. Trust relationships can be complicated due to the potentially large number of entities participating in the consumer-provider interactions, subordinate relationships and levels of trust, and types of interactions between the parties. In some cases, the degree of trust is based on the level of control that organizations can exert on external service providers regarding the controls necessary for the protection of the service, information, or individual privacy and the evidence brought forth as to the effectiveness of the implemented controls. The level of control is established by the terms and conditions of the contracts or service-level agreements.

  1. Establish, document, and maintain trust relationships with external service providers based on the following requirements, properties, factors, or conditions: [Assignment: organization-defined security and privacy requirements, properties, factors, or conditions defining acceptable trust relationships].

[SA-9.4] Consistent Interests of Consumers and Providers

As organizations increasingly use external service providers, it is possible that the interests of the service providers may diverge from organizational interests. In such situations, simply having the required technical, management, or operational controls in place may not be sufficient if the providers that implement and manage those controls are not operating in a manner consistent with the interests of the consuming organizations. Actions that organizations take to address such concerns include requiring background checks for selected service provider personnel; examining ownership records; employing only trustworthy service providers, such as providers with which organizations have had successful trust relationships; and conducting routine, periodic, unscheduled visits to service provider facilities.

  1. Take the following actions to verify that the interests of [Assignment: organization-defined external service providers] are consistent with and reflect organizational interests: [Assignment: organization-defined actions].

[SA-9.5] Processing, Storage, and Service Location

The location of information processing, information and data storage, or system services can have a direct impact on the ability of organizations to successfully execute their mission and business functions. The impact occurs when external providers control the location of processing, storage, or services. The criteria that external providers use for the selection of processing, storage, or service locations may be different from the criteria that organizations use. For example, organizations may desire that data or information storage locations be restricted to certain locations to help facilitate incident response activities in case of information security incidents or breaches. Incident response activities, including forensic analyses and after-the-fact investigations, may be adversely affected by the governing laws, policies, or protocols in the locations where processing and storage occur and/or the locations from which system services emanate.

  1. Restrict the location of [Selection (one or more): information processing; information or data; system services] to [Assignment: organization-defined locations] based on [Assignment: organization-defined requirements or conditions].

[SA-9.6] Organization-controlled Cryptographic Keys

Maintaining exclusive control of cryptographic keys in an external system prevents decryption of organizational data by external system staff. Organizational control of cryptographic keys can be implemented by encrypting and decrypting data inside the organization as data is sent to and received from the external system or by employing a component that permits encryption and decryption functions to be local to the external system but allows exclusive organizational access to the encryption keys.

  1. Maintain exclusive control of cryptographic keys for encrypted material stored or transmitted through an external system.

[SA-9.7] Organization-controlled Integrity Checking

Storage of organizational information in an external system could limit visibility into the security status of its data. The ability of the organization to verify and validate the integrity of its stored data without transferring it out of the external system provides such visibility.

  1. Provide the capability to check the integrity of information while it resides in the external system.

[SA-9.8] Processing and Storage Location — U.S. Jurisdiction

The geographic location of information processing and data storage can have a direct impact on the ability of organizations to successfully execute their mission and business functions. A compromise or breach of high impact information and systems can have severe or catastrophic adverse impacts on organizational assets and operations, individuals, other organizations, and the Nation. Restricting the processing and storage of high-impact information to facilities within the legal jurisdictional boundary of the United States provides greater control over such processing and storage.

  1. Restrict the geographic location of information processing and data storage to facilities located within in the legal jurisdictional boundary of the United States.

[SC-6] Resource Availability

Priority protection prevents lower-priority processes from delaying or interfering with the system that services higher-priority processes. Quotas prevent users or processes from obtaining more than predetermined amounts of resources.

  1. Protect the availability of resources by allocating [Assignment: organization-defined resources] by [Selection (one or more): priority; quota; [Assignment: organization-defined controls]].