NIST SP 800-37 Rev. 2 日本語訳

NIST Special Publication 800-37

Revision 2

A System Life Cycle Approach for Security and Privacy

This publication contains comprehensive updates to the Risk Management Framework. The updates include an alignment with the constructs in the NIST Cybersecurity Framework; the integration of privacy risk management processes; an alignment with system life cycle security engineering processes; and the incorporation of supply chain risk management processes. Organizations can use the frameworks and processes in a complementary manner within the RMF to effectively manage security and privacy risks to organizational operations and assets, individuals, other organizations, and the Nation. Revision 2 includes a set of organization-wide RMF tasks that are designed to prepare information system owners to conduct system-level risk management activities. The intent is to increase the effectiveness, efficiency, and cost-effectiveness of the RMF by establishing a closer connection to the organization’s missions and business functions and improving the communications among senior leaders, managers, and operational personnel.

JOINT TASK FORCE

This publication is available free of charge from: https://doi.org/10.6028/NIST.SP.800-37r2

NIST Special Publication 800-37

Revision 2

A System Life Cycle Approach for Security and Privacy

This publication is available free of charge from: https://doi.org/10.6028/NIST.SP.800-37r2

December 2018

U.S. Department of Commerce Wilbur L. Ross, Jr., Secretary

National Institute of Standards and Technology

Walter Copan, NIST Director and Under Secretary of Commerce for Standards and Technology

This publication has been developed by NIST to further its statutory responsibilities under the Federal Information Security Modernization Act (FISMA), 44 U.S.C. § 3551 et seq., Public Law (P.L.) 113-283. NIST is responsible for developing information security standards and guidelines, including minimum requirements for federal information systems, but such standards and guidelines shall not apply to national security systems without the express approval of the appropriate federal officials exercising policy authority over such systems. This guideline is consistent with requirements of the Office of Management and Budget (OMB) Circular A-130.

Nothing in this publication should be taken to contradict the standards and guidelines made mandatory and binding on federal agencies by the Secretary of Commerce under statutory authority. Nor should these guidelines be interpreted as altering or superseding the existing authorities of the Secretary of Commerce, OMB Director, or any other federal official. This publication may be used by nongovernmental organizations on a voluntary basis and is not subject to copyright in the United States. Attribution would, however, be appreciated by NIST.

National Institute of Standards and Technology Special Publication 800-37, Revision 2 Natl. Inst. Stand. Technol. Spec. Publ. 800-37, Rev. 2, 183 pages (December 2018)

CODEN: NSPUE2

This publication is available free of charge from: https://doi.org/10.6028/NIST.SP.800-37r2

Certain commercial entities, equipment, or materials may be identified in this document to describe an experimental procedure or concept adequately. Such identification is not intended to imply recommendation or endorsement by NIST, nor is it intended to imply that the entities, materials, or equipment are necessarily the best available for the purpose.

There may be references in this publication to other publications currently under development by NIST in accordance with its assigned statutory responsibilities. The information in this publication, including concepts, practices, and methodologies, may be used by federal agencies even before the completion of such companion publications. Thus, until each publication is completed, current requirements, guidelines, and procedures, where they exist, remain operative. For planning and transition purposes, federal agencies may wish to closely follow the development of these new publications by NIST.

Organizations are encouraged to review draft publications during the designated public comment periods and provide feedback to NIST. Many NIST publications, other than the ones noted above, are available at https://csrc.nist.gov/publications.

Comments on this publication may be submitted to:

National Institute of Standards and Technology Attn: Computer Security Division, Information Technology Laboratory 100 Bureau Drive (Mail Stop 8930) Gaithersburg, MD 20899-8930 Email: sec-cert@nist.gov

All comments are subject to release under the Freedom of Information Act (FOIA) [FOIA96].

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The National Institute of Standards and Technology (NIST) Information Technology Laboratory (ITL) promotes the U.S. economy and public welfare by providing technical leadership for the Nation’s measurement and standards infrastructure. ITL develops tests, test methods, reference data, proof of concept implementations, and technical analyses to advance the development and productive use of information technology (IT). ITL’s responsibilities include the development of management, administrative, technical, and physical standards and guidelines for the cost-effective security of other than national security-related information in federal information systems. The Special Publication 800-series reports on ITL’s research, guidelines, and outreach efforts in information systems security and privacy and its collaborative activities with industry, government, and academic organizations.

This publication describes the Risk Management Framework (RMF) and provides guidelines for applying the RMF to information systems and organizations. The RMF provides a disciplined, structured, and flexible process for managing security and privacy risk that includes information security categorization; control selection, implementation, and assessment; system and common control authorizations; and continuous monitoring. The RMF includes activities to prepare organizations to execute the framework at appropriate risk management levels. The RMF also promotes near real-time risk management and ongoing information system and common control authorization through the implementation of continuous monitoring processes; provides senior leaders and executives with the necessary information to make efficient, cost-effective, risk management decisions about the systems supporting their missions and business functions; and incorporates security and privacy into the system development life cycle. Executing the RMF tasks links essential risk management processes at the system level to risk management processes at the organization level. In addition, it establishes responsibility and accountability for the controls implemented within an organization’s information systems and inherited by those systems.

assess; authorization to operate; authorization to use; authorizing official; categorize; common control; common control authorization; common control provider; continuous monitoring; control assessor; control baseline; cybersecurity framework profile; hybrid control; information owner or steward; information security; monitor; ongoing authorization; plan of action and milestones; privacy; privacy assessment report; privacy control; privacy plan; privacy risk; risk assessment; risk executive function; risk management; risk management framework; security; security assessment report; security control; security engineering; security plan; security risk; senior agency information security officer; senior agency official for privacy; supply chain risk management; system development life cycle; system owner; system privacy officer; system security officer; system-specific control.

This publication was developed by the Joint Task Force Interagency Working Group. The group includes representatives from the Civil, Defense, and Intelligence Communities. The National Institute of Standards and Technology wishes to acknowledge and thank the senior leaders from the Departments of Commerce and Defense, the Office of the Director of National Intelligence, the Committee on National Security Systems, and the members of the interagency working group whose dedicated efforts contributed significantly to the publication.

Dana Deasy — Chief Information Officer

Essye B. Miller — Principal Deputy CIO and DoD Senior Information Security Officer

Thomas P. Michelli — Acting Deputy Chief Information Officer for Cybersecurity

Vicki Michetti — Director, Cybersecurity Policy, Strategy, International, and Defense Industrial Base Directorate

Charles H. Romine — Director, Information Technology Laboratory

Donna Dodson — Cybersecurity Advisor, Information Technology Laboratory

Matt Scholl — Chief, Computer Security Division

Kevin Stine — Chief, Applied Cybersecurity Division

Ron Ross — FISMA Implementation Project Leader

John Sherman — Chief Information Officer

Vacant — Deputy Chief Information Officer

Susan Dorr — Director, Cybersecurity Division and Chief Information Security Officer

Wallace Coggins — Director, Security Coordination Center

Thomas Michelli — Chair—Defense Community

Susan Dorr—Intelligence Community — Co-Chair

Vicki Michetti — Tri-Chair—Defense Community

Chris Johnson — Tri-Chair—Intelligence Community

Paul Cunningham — Tri-Chair—Civil Agencies

Ron Ross — NIST, JTF Leader

Taylor Roberts — OMB

Jordan Burris — OMB

Jeff Marron — NIST

Dorian Pappas — CNSS

Daniel Faigin — The Aerospace Corporation

Kevin Dulany — DoD

Ellen Nadeau — NIST

Charles Cutshall — OMB

Kaitlin Boeckl — NIST

Dominic Cussatt — Veterans Affairs

Christina Sames — The MITRE Corporation

Peter Duspiva — Intelligence Community

Victoria Pillitteri — NIST

Kevin Herms — OMB

Kirsten Moncada — OMB

Esten Porter — The MITRE Corporation

Julie Snyder — The MITRE Corporation

Kelley Dempsey — NIST

Naomi Lefkovitz — NIST

Carol Bales — OMB

Jon Boyens — NIST

Celia Paulsen — NIST

Martin Stanley — Homeland Security

The authors also wish to recognize Matt Barrett, Kathleen Coupe, Jeff Eisensmith, Chris Enloe, Ned Goren, Matthew Halstead, Jody Jacobs, Ralph Jones, Martin Kihiko, Raquel Leone, and the scientists, engineers, and research staff from the Computer Security Division and the Applied Cybersecurity Division for their exceptional contributions in helping to improve the content of the publication. A special note of thanks to Jim Foti and the NIST web team for their outstanding administrative support.

In addition, the authors wish to acknowledge the United States Air Force and the “RMF Next” initiative, facilitated by Air Force CyberWorx, that provided the inspiration for some of the new ideas in this update to the RMF. The working group, led by Lauren Knausenberger, Bill Bryant, and Venice Goodwine, included government and industry representatives Jake Ames, Chris Bailey, James Barnett, Steve Bogue, Wes Chiu, Kurt Danis, Shane Deichman; Joe Erskine, Terence Goodman, Jason Howe, Brandon Howell, Todd Jacobs, Peter Klabe, William Kramer, Bryon Kroger, Kevin LaSalle, Dinh Le, Noam Liran, Sam Miles, Michael Morrison, Raymond Tom Nagley, Wendy Nather, Jasmine Neal, Ryan Perry, Eugene Peterson, Lawrence Rampaul, Jessica Rheinschmidt, Greg Roman, Susanna Scarveles, Justin Schoenthal, Christian Sorenson, Stacy Studstill, Charles Wade, Shawn Whitney, David Wilcox, and Thomas Woodring.

Finally, the authors also gratefully acknowledge the significant contributions from individuals and organizations in both the public and private sectors, nationally and internationally, whose thoughtful and constructive comments improved the overall quality, thoroughness, and usefulness of this publication.

The authors acknowledge the many individuals who contributed to previous versions of Special Publication 800-37 since its inception in 2005. They include Marshall Abrams, William Barker, Beckie Koonge, Roger Caslow, John Gilligan, Peter Gouldmann, Richard Graubart, John Grimes, Gus Guissanie, Priscilla Guthrie, Jennifer Fabius, Cita Furlani, Richard Hale, Peggy Himes, William Hunteman, Arnold Johnson, Donald Jones, Stuart Katzke, Eustace King, Mark Morrison, Sherrill Nicely, Karen Quigg, George Rogers, Cheryl Roby, Gary Stoneburner, Marianne Swanson, Glenda Turner, and Peter Williams.

As we push computers to “the edge,” building a complex world of interconnected information systems and devices, security and privacy risks (including supply chain risks) continue to be a large part of the national conversation and topics of great importance. The significant increase in the complexity of the hardware, software, firmware, and systems within the public and private sectors (including the U.S. critical infrastructure) represents a significant increase in attack surface that can be exploited by adversaries. Moreover, adversaries are using the supply chain as an attack vector and effective means of penetrating our systems, compromising the integrity of system elements, and gaining access to critical assets.

The Defense Science Board Report, Resilient Military Systems and the Advanced Cyber Threat [DSB 2013], provides a sobering assessment of the vulnerabilities in the United States Government, the U.S. critical infrastructure, and the systems supporting the mission-essential operations and assets in the public and private sectors.

“…The Task Force notes that the cyber threat to U.S. critical infrastructure is outpacing efforts to reduce pervasive vulnerabilities, so that for the next decade at least the United States must lean significantly on deterrence to address the cyber threat posed by the most capable U.S. adversaries. It is clear that a more proactive and systematic approach to U.S. cyber deterrence is urgently needed…”

There is an urgent need to further strengthen the underlying information systems, component products, and services that we depend on in every sector of the critical infrastructure—ensuring that the systems, products, and services are sufficiently trustworthy throughout the system development life cycle (SDLC) and can provide the necessary resilience to support the economic and national security interests of the United States. System modernization, the increased use of automation, and the consolidation, standardization, and optimization of federal systems and networks to strengthen the protection for high value assets [OMB M-19-03], are key objectives for the federal government.

Executive Order (E.O.) 13800, Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure [EO 13800] recognizes the increasing interconnectedness of Federal information systems and requires heads of agencies to ensure appropriate risk management not only for the Federal agency’s enterprise, but also for the Executive Branch as a whole. The E.O. states:

“…The executive branch operates its information technology (IT) on behalf of the American people. Its IT and data should be secured responsibly using all United States Government capabilities...”

“…Cybersecurity risk management comprises the full range of activities undertaken to protect IT and data from unauthorized access and other cyber threats, to maintain awareness of cyber threats, to detect anomalies and incidents adversely affecting IT and data, and to mitigate the impact of, respond to, and recover from incidents…”

OMB Memorandum M-17-25, Reporting Guidance for Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure [OMB M-17-25] provides implementation guidance to Federal agencies for E.O. 13800. The memorandum states: “… An effective enterprise risk management program promotes a common understanding for recognizing and describing potential risks that can impact an agency’s mission and the delivery of services to the public. Such risks include, but are not limited to, strategic, market, cyber, legal, reputational, political, and a broad range of operational risks such as information security, human capital, business continuity, and related risks…”

“… Effective management of cybersecurity risk requires that agencies align information security management processes with strategic, operational, and budgetary planning processes…”

OMB Circular A-130, Managing Information as a Strategic Resource [OMB A-130], addresses responsibilities for protecting federal information resources and for managing personally identifiable information (PII). Circular A-130 requires agencies to implement the RMF that is described in this guideline and requires agencies to integrate privacy into the RMF process. In establishing requirements for information security programs and privacy programs, the OMB circular emphasizes the need for both programs to collaborate on shared objectives:

“While security and privacy are independent and separate disciplines, they are closely related, and it is essential for agencies to take a coordinated approach to identifying and managing security and privacy risks and complying with applicable requirements….”

This update to NIST Special Publication 800-37 (Revision 2) responds to the call by the Defense Science Board, the Executive Order, and the OMB policy memorandum to develop the next-generation Risk Management Framework (RMF) for information systems, organizations, and individuals.

There are seven major objectives for this update:

The addition of the Prepare step is one of the key changes to the RMF—incorporated to achieve more effective, efficient, and cost-effective security and privacy risk management processes. The primary objectives for institutionalizing organization-level and system-level preparation are:

By achieving the above objectives, organizations can simplify RMF execution, employ innovative approaches for managing risk, and increase the level of automation when carrying out specific tasks. Organizations implementing the RMF will be able to:

Recognizing that the preparation for RMF execution may vary from organization to organization, achieving the above objectives can reduce the overall IT/OT footprint and attack surface of organizations, promote IT modernization objectives, conserve resources, prioritize security activities to focus protection strategies on the most critical assets and systems, and promote privacy protections for individuals.

In developing standards and guidelines, NIST consults with federal agencies, state, local, and tribal governments, and private sector organizations; avoids unnecessary and costly duplication of effort; and ensures that its publications are complementary with the standards and guidelines used for the protection of national security systems. In addition to implementing a transparent public review process for its publications, NIST collaborates with the Office of Management and Budget, the Office of the Director of National Intelligence, the Department of Defense, and the Committee on National Security Systems, and has established a unified risk management framework for the federal government. This common foundation provides the Civil, Defense, and Intelligence Communities of the federal government and their contractors, cost-effective, flexible, and consistent methods and techniques to manage security and privacy risks to organizational operations and assets, individuals, other organizations, and the Nation. The unified framework also provides a strong basis for reciprocal acceptance of assessment results and authorization decisions and facilitates information sharing and collaboration. NIST continues to work with public and private sector entities to establish mappings and relationships between its security and privacy standards and guidelines and those developed by external organizations.

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The Risk Management Framework addresses security and privacy risk from two perspectives— an information system perspective and a common controls perspective. For an information system, authorizing officials issue an authorization to operate or authorization to use for the system, accepting the security and privacy risks to the organization’s operations and assets, individuals, other organizations, and the Nation. For common controls, authorizing officials issue a common control authorization for a specific set of controls that can be inherited by designated organizational systems, accepting the security and privacy risks to the organization’s operations and assets, individuals, other organizations, and the Nation. Authorizing officials also consider the risk of inheriting common controls as part of their system authorizations. The different types of authorizations are described in Appendix F.

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The RMF is purposefully designed to be technology neutral so that the methodology can be applied to any type of information system* without modification. While the specific controls selected, control implementation details, and control assessment methods and objects may vary with different types of IT resources, there is no need to adjust the RMF process to accommodate specific technologies.

All information systems process, store, or transmit some type of information. For example, information about the temperature in a remote facility collected and transmitted by a sensor to a monitoring station, location coordinates transmitted by radio to a controller on a weapons system, photographic images transmitted by a remote camera (land/satellite-based) to a server, or health IT devices transmitting patient information via a hospital network, require protection. This information can be protected by: categorizing the information to determine the impact of loss; assessing whether the processing of the information could impact individuals’ privacy; and selecting and implementing controls that are applicable to the IT resources in use. Therefore, cloud-based systems, industrial/process control systems, weapons systems, cyber-physical systems, applications, IoT devices, or mobile devices/systems, do not require a separate risk management process but rather a tailored set of controls and specific implementation details determined by applying the existing RMF process.

The RMF is applied iteratively, as applicable, during the system development life cycle for any type of system development approach (including Agile and DevOps approaches). The security and privacy requirements and controls are implemented, verified, and validated as development progresses throughout the life cycle. This flexibility allows the RMF to support rapid technology cycles, innovation, and the use of current best practices in system and system component development.

* Note: The publication pertains to information systems, which are discrete sets of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information, whether such information is in digital or non-digital form. Information resources include information and related resources, such as personnel, equipment, funds, and information technology. Therefore, information systems may or may not include hardware, firmware, and software.

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Organizations should maximize the use of automation, wherever possible, to increase the speed, effectiveness, and efficiency of executing the steps in the Risk Management Framework (RMF). Automation is particularly useful in the assessment and continuous monitoring of controls, the preparation of authorization packages for timely decision-making, and the implementation of ongoing authorization approaches—together facilitating a real-time or near real-time risk-based decision-making process for senior leaders. Organizations have significant flexibility in deciding when, where, and how to use automation or automated support tools for their security and privacy programs. In some situations, automated assessments and monitoring of controls may not be possible or feasible.

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This publication is intended to help organizations manage security and privacy risk, and to satisfy the requirements in the Federal Information Security Modernization Act of 2014 (FISMA), the Privacy Act of 1974, OMB policies, and Federal Information Processing Standards, among other laws, regulations, and policies. The scope of this publication pertains to federal information systems, which are discrete sets of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information, whether such information is in digital or non-digital form. Information resources include information and related resources, such as personnel, equipment, funds, and information technology.

While mandatory for federal government use, the RMF can be applied to any type of nonfederal organization (e.g., business, industry, academia). As such, State, local, and tribal governments, as well as private sector organizations are encouraged to use these guidelines on a voluntary basis, as appropriate. In addition, nonfederal organizations that have adopted and implemented the Cybersecurity Framework might find value in using the RMF as a risk management process for execution of the Framework—providing the essential tasks for control implementation, assessment, and monitoring, as well as system authorizations (for risk-based decision making).

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Using the Cybersecurity Framework

Executive Order (E.O.) 13800 requires federal agencies to modernize their IT infrastructure and systems and recognizes the increasing interconnectedness of federal information systems and networks. The E.O. also requires heads of agencies to manage risk at the agency level and across the Executive Branch using the Framework for Improving Critical Infrastructure Cybersecurity (i.e., Cybersecurity Framework). And finally, the E.O. reinforces the Federal Information Security Modernization Act (FISMA) of 2014 by holding heads of agencies responsible and accountable for managing the cybersecurity risk to their organizations.

The Cybersecurity Framework is adaptive to provide a flexible and risk-based implementation that can be used with a broad array of cybersecurity risk management processes. Therefore, consistent with OMB Memorandum M-17-25, the federal implementation of the Cybersecurity Framework fully supports the use of and is consistent with the risk management processes and approaches defined in [SP 800-39] and NIST Special Publication 800-37. This allows agencies to meet their concurrent obligations to comply with the requirements of FISMA and E.O. 13800.

Each task in the RMF includes references to specific sections in the Cybersecurity Framework. For example, Task P-2, Risk Management Strategy, aligns with the Cybersecurity Framework Core [Identify Function]; Task P-4, Organizationally-Tailored Control Baselines and Cybersecurity Framework Profiles, aligns with the Cybersecurity Framework Profile construct; and Task R-5, Authorization Reporting, and Task M-5, Security and Privacy Reporting, support OMB reporting and risk management requirements organization-wide by using the Cybersecurity Framework constructs of Functions, Categories, and Subcategories. The Subcategory mappings to the [SP 800-53] controls are available at: https://www.nist.gov/cyberframework/federal-resources.

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Organizations are encouraged to collaborate on the plans, assessments, and plans of action and milestones (POAM) for security and privacy issues to maximize efficiency and reduce duplication of effort. The objective is to ensure that security and privacy requirements derived from laws, executive orders, directives, regulations, policies, standards, or missions and business functions are adequately addressed, and the appropriate controls are selected, implemented, assessed, and monitored on an ongoing basis. The authorization decision, a key step in the RMF, depends on the development of credible and actionable security and privacy evidence generated for the authorization package. Creating such evidence in a cost-effective and efficient manner is important.

The unified and collaborative approach to bring security and privacy evidence together in a single authorization package will support authorizing officials with critical information from security and privacy professionals to help inform the authorization decision. In the end, it is not about generating additional paperwork, artifacts, or documentation. Rather, it is about ensuring greater visibility into the implementation of security and privacy controls which will promote more informed, risk-based authorization decisions.

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This table contains changes that have been incorporated into Special Publication 800-37. Errata updates can include corrections, clarifications, or other minor changes in the publication that are either editorial or substantive in nature.

THE NEED TO MANAGE SECURITY AND PRIVACY RISK

Organizations depend on information systems¹ to carry out their missions and business functions. The success of the missions and business functions depends on protecting the confidentiality, integrity, availability of information processed, stored, and transmitted by those systems and the privacy of individuals. The threats to information systems include equipment failure, environmental disruptions, human or machine errors, and purposeful attacks that are often sophisticated, disciplined, well-organized, and well-funded.² When successful, attacks on information systems can result in serious or catastrophic damage to organizational operations³ and assets, individuals, other organizations, and the Nation.⁴ Therefore, it is imperative that organizations remain vigilant and that senior executives, leaders, and managers throughout the organization understand their responsibilities and are accountable for protecting organizational assets and for managing risk.⁵

In addition to the responsibility to protect organizational assets from the threats that exist in today’s environment, organizations have a responsibility to consider and manage the risks to individuals when information systems process personally identifiable information (PII).⁶ 7 The information security and privacy programs implemented by organizations have complementary objectives with respect to managing the confidentiality, integrity, and availability of PII. While many privacy risks arise from unauthorized activities that lead to the loss of confidentiality, integrity, or availability of PII, other privacy risks result from authorized activities involving the creation, collection, use, processing, storage, maintenance, dissemination, disclosure, or disposal of PII that enables an organization to meet its mission or business objectives. For example, organizations could fail to provide appropriate notice of PII processing depriving an individual of knowledge of such processing or an individual could be embarrassed or stigmatized by the authorized disclosure of PII. While managing privacy risk requires close coordination between information security and privacy programs due to the complementary nature of the programs’ objectives around the confidentiality, integrity, and availability of PII, privacy risks also raise distinct concerns that require specialized expertise and approaches. Therefore, it is critical that organizations also establish and maintain robust privacy programs to ensure compliance with applicable privacy requirements and to manage the risk to individuals associated with the processing of PII.

Closely related to, and a part of security and privacy risks, supply chain risk⁸ is also of growing concern to organizations. Because of the increased reliance on third-party or external providers and commercial-off-the-shelf products, systems, and services, attacks or disruptions in the supply chain which impact an organization’s systems are increasing. Such attacks can be difficult to trace or manage and can result in serious, severe, or catastrophic consequences for an organization’s systems. Supply chain risk management (SCRM) overlaps and works in harmony with security and privacy risk management. This publication integrates security and privacy risk management practices associated with SCRM into the RMF to help promote a comprehensive approach to managing security and privacy risk. While the publication is principally focused on managing information security and privacy risk, SCRM concepts that support security and privacy risk management are specifically called out in several areas to add emphasis and to clarify how they can be addressed using the RMF.

NIST in its partnership with the Department of Defense, the Office of the Director of National Intelligence, and the Committee on National Security Systems, developed a Risk Management Framework (RMF) to improve information security, strengthen risk management processes, and encourage reciprocity⁹ among organizations. In July 2016, the Office of Management and Budget (OMB) revised Circular A-130 to include responsibilities for privacy programs under the RMF.

The RMF emphasizes risk management by promoting the development of security and privacy capabilities into information systems throughout the system development life cycle (SDLC);¹⁰ by maintaining situational awareness of the security and privacy posture of those systems on an ongoing basis through continuous monitoring processes; and by providing information to senior leaders and executives to facilitate decisions regarding the acceptance of risk to organizational operations and assets, individuals, other organizations, and the Nation arising from the use and operation of their systems. The RMF:

The RMF provides a dynamic and flexible approach to effectively manage security and privacy risks in diverse environments with complex and sophisticated threats, evolving missions and business functions, and changing system and organizational vulnerabilities. The framework is policy and technology neutral, which facilitates ongoing upgrades to IT resources¹⁵ and to IT modernization efforts—to support and help ensure essential missions and services are provided during such transition periods.

This publication describes the RMF and provides guidelines for managing security and privacy risks and applying the RMF to information systems and organizations. The guidelines have been developed:

This publication is intended to help organizations¹⁹ manage security and privacy risk and to satisfy the requirements in the Federal Information Security Modernization Act of 2014 [FISMA], the Privacy Act of 1974 [PRIVACT], OMB policies, and designated Federal Information Processing Standards, among other laws, regulations, and policies.

The scope of this publication pertains to federal information systems, which are discrete sets of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information, whether such information is in digital or non-digital form. Information resources include information and related resources, such as personnel, equipment, funds, and information technology. The guidelines have been developed from a technical perspective to complement guidelines for national security systems and may be used for such systems with the approval of appropriate federal officials with policy authority over such systems. State, local, and tribal governments, as well as private sector organizations are encouraged to use these guidelines, as appropriate.

This publication serves individuals associated with the design, development, implementation, assessment, operation, maintenance, and disposition of information systems including:

For a comprehensive list and description of roles and responsibilities associated with the RMF, see Appendix D.

The remainder of this special publication is organized as follows:

HOW TO MANAGE SECURITY AND PRIVACY RISK

This chapter describes the basic concepts associated with managing information system-related security and privacy risk in organizations. These concepts include the RMF steps and task structure; information security and privacy programs in the RMF; information system, system elements, and how authorization boundaries are established; security and privacy posture; and security and privacy risk management practices associated with the supply chain.

Managing information system-related security and privacy risk is a complex undertaking that requires the involvement of the entire organization—from senior leaders providing the strategic vision and top-level goals and objectives for the organization, to mid-level leaders planning, executing, and managing projects, to individuals developing, implementing, operating, and maintaining the systems supporting the organization’s missions and business functions. Risk management is a holistic activity that affects every aspect of the organization including the mission and business planning activities, the enterprise architecture, the SDLC processes, and the systems engineering activities that are integral to those system life cycle processes. Figure 1 illustrates a multi-level approach to risk management described in [SP 800-39] that addresses security and privacy risk at the organization level, the mission/business process level, and the information system level. Communication and reporting are bi-directional information flows across the three levels to ensure that risk is addressed throughout the organization.

FIGURE 1: ORGANIZATION-WIDE RISK MANAGEMENT APPROACH

The activities conducted at Levels 1 and 2 are critical to preparing the organization to execute the RMF. Such preparation involves a wide range of activities that go beyond simply managing the security and privacy risk associated with operating or using specific systems and includes activities that are essential to managing security and privacy risk appropriately throughout the organization. Decisions about how to manage such risk at the system level cannot be made in isolation. Such decisions are closely linked to the:

Preparing the organization to execute the RMF can include:

In contrast to the Level 1 and 2 activities that prepare the organization for the execution of the RMF, Level 3 addresses risk from an information system perspective and is guided and informed by the risk decisions at the organization and mission/business process levels. The risk decisions at Levels 1 and 2 can impact the selection and implementation of controls at the system level. Controls are designated by the organization as system-specific, hybrid, or common (inherited) controls in accordance with the enterprise architecture, security or privacy architecture, and any tailored control baselines or overlays that have been developed by the organization.²⁴

Organizations establish traceability of controls to the security and privacy requirements that the controls are intended to satisfy. Establishing such traceability ensures that all requirements are addressed during system design, development, implementation, operations, maintenance, and disposition.²⁵ Each level of the risk management hierarchy is a beneficiary of a successful RMF execution—reinforcing the iterative nature of the risk management process where security and privacy risks are framed, assessed, responded to, and monitored at various organizational levels.

Without adequate risk management preparation at the organizational level, security and privacy activities can become too costly, demand too many skilled security and privacy professionals, and produce ineffective solutions. For example, organizations that fail to implement an effective enterprise architecture will have difficulty in consolidating, optimizing, and standardizing their information technology infrastructures. Additionally, the effect of architectural and design decisions can adversely affect the ability of organizations to implement effective security and privacy solutions. A lack of adequate preparation by organizations could result in unnecessary redundancy as well as inefficient, costly and vulnerable systems, services, and applications.

There are seven steps in the RMF; a preparatory step to ensure that organizations are ready to execute the process and six main steps. All seven steps are essential for the successful execution of the RMF. The steps are:

Figure 2 illustrates the steps in the RMF. The RMF operates at all levels in the risk management hierarchy illustrated in Figure 1. Chapter Three provides a detailed description of each of the tasks necessary to carry out the steps in the RMF.

FIGURE 2: RISK MANAGEMENT FRAMEWORK

While the RMF steps are listed in sequential order above and in Chapter Three, the steps following the Prepare step can be carried out in a nonsequential order. After completing the tasks in the Prepare step, organizations executing the RMF for the first time for a system or set of common controls typically carry out the remaining steps in sequential order. However, there could be many points in the risk management process where there is a need to diverge from the sequential order due to the type of system, risk decisions made by senior leadership, or to allow for iterative cycles between tasks or revisiting of tasks (e.g., during agile development). Once the organization is in the Monitor step, events may dictate a nonsequential execution of steps. For example, changes in risk or in system functionality may necessitate revisiting one or more of the steps in the RMF to address the change.

Organizations are expected to execute all steps and tasks in the RMF (apart from tasks labeled as optional). However, organizations have significant flexibility in how each of the RMF steps and tasks are carried out, as long as organizations are meeting all applicable requirements and effectively managing security and privacy risk. The intent is to allow organizations to implement the RMF in the most efficient, effective, and cost-effective manner to support mission and business needs in a way that promotes effective security and privacy. Flexible implementation may include executing tasks in a different (potentially nonsequential) order, emphasizing certain tasks over other tasks, or combining certain tasks where appropriate. It can also include the use of the Cybersecurity Framework to enhance RMF task execution. Flexibility of implementation can also be applied to control selection, control tailoring to meet organizational security and privacy needs, or conducting control assessments throughout the SDLC. For example, the selection, tailoring, implementation, and assessments of controls can be done incrementally as a system is being developed. The implementation of control tailoring helps to ensure that security and privacy solutions are customized for the specific missions, business functions, risks, and operating environments of the organization. In the end, the flexibility inherent in RMF execution promotes effective security and privacy that helps to protect the systems that organizations depend on for mission and business success and the individuals whose information is processed by those systems.

Although the risk management approach in Figure 1 is conveyed as hierarchical, project and organization dynamics are typically more complex. The risk management approach selected by an organization may vary on a continuum from top-down command to decentralized consensus among peers. However, in all cases, organizations use a consistent approach that is applied to risk management processes organization-wide from the organization level to the information system level. Organizational officials identify and secure the needed resources to complete the risk management tasks described in this publication and ensure that those resources are made available to the appropriate personnel. Resource allocation includes funding to conduct risk management tasks and assigning qualified personnel that are needed to accomplish the tasks.

Each step in the RMF has a purpose statement, a defined set of outcomes, and a set of tasks that are carried out to achieve those outcomes. The outcomes can be achieved by different risk management levels—that is, some of the outcomes are universal to the entire organization, while others are system-focused or mission/business unit-focused. Figure 3 provides an example of the purpose statement and outcomes for the RMF Prepare step—Organization-Level.

The purpose of the Prepare step is to carry out essential activities at the organization, mission and business process, and information system levels of the organization to help prepare the organization to manage its security and privacy risks using the Risk Management Framework.

Table 1 provides a summary of tasks and expected outcomes for the RMF Prepare step at the organization level. Applicable Cybersecurity Framework constructs are also provided.

TABLE 1: PREPARE TASKS AND OUTCOMES—ORGANIZATION LEVEL

Quick link to summary table for RMF tasks, responsibilities, and supporting roles.

FIGURE 3: RISK MANAGEMENT FRAMEWORK TASK STRUCTURE

Each task contains a set of potential inputs needed to execute the task and a set of expected outputs generated from task execution.²⁷ In addition, each task describes the risk management roles and responsibilities associated with the task and the phase of the SDLC where task execution occurs.²⁸ A discussion section provides information related to the task to facilitate understanding and to promote effective task execution. Finally, completing the RMF task description, there is a list of references to provide organizations with supplemental information for each task. Where applicable, the references also identify systems security engineering tasks that correlate with the RMF task.²⁹ Figure 4 illustrates the structure of a typical RMF task.

FIGURE 4: RISK MANAGEMENT FRAMEWORK TASK STRUCTURE

In 2016, OMB revised Circular A-130, the circular establishing general policy for the planning, budgeting, governance, acquisition, and management of federal information, personnel, equipment, funds, information technology resources, and supporting infrastructure and services. The circular addresses responsibilities for protecting federal information resources and managing personally identifiable information (PII). In establishing requirements for information security programs and privacy programs, the circular emphasizes the need for both programs to collaborate on shared objectives:

While security and privacy are independent and separate disciplines, they are closely related, and it is essential for agencies to take a coordinated approach to identifying and managing security and privacy risks and complying with applicable requirements.

[OMB A-130] requires organizations to implement the RMF that is described in this guideline. With the 2016 revision to the circular, OMB also requires organizations to integrate privacy into the RMF process:

The RMF provides a disciplined and structured process that integrates information security, privacy, and risk management activities into the SDLC. This Circular requires organizations to use the RMF to manage privacy risks beyond those that are typically included under the “confidentiality” objective of the term “information security.” While many privacy risks relate to the unauthorized access or disclosure of PII, privacy risks may also result from other activities, including the creation, collection, use, and retention of PII; the inadequate quality or integrity of PII; and the lack of appropriate notice, transparency, or participation.

This section of the guideline describes the relationship between information security programs and privacy programs under the RMF. However, subject to OMB policy, organizations retain the flexibility to undertake the integration of privacy into the RMF in the most effective manner, considering the organization’s mission and circumstances.

Executing the RMF requires close collaboration between information security programs and privacy programs. While information security programs and privacy programs have different objectives, those objectives are overlapping and complementary. Information security programs are responsible for protecting information and information systems from unauthorized access, use, disclosure, disruption, modification, or destruction (i.e., unauthorized system activity or behavior) in order to provide confidentiality, integrity, and availability. Privacy programs are responsible for ensuring compliance with applicable privacy requirements and for managing the risks to individuals associated with the creation, collection, use, processing, dissemination, storage, maintenance, disclosure, or disposal (collectively referred to as “processing”) of PII.³⁰ When preparing to execute the steps of the RMF, organizations consider how to best promote and institutionalize collaboration between the two programs to ensure that the objectives of both disciplines are met at every step of the process.

When an information system processes PII, the organization’s information security program and privacy program have a shared responsibility for managing the risks to individuals that may arise from unauthorized system activity or behavior. This requires the two programs to collaborate when selecting, implementing, assessing, and monitoring security controls.³¹ However, while information security programs and privacy programs have complementary objectives with respect to managing the confidentiality, integrity, and availability of PII, protecting individuals’ privacy cannot be achieved solely by securing PII.

Not all privacy risks arise from unauthorized system activity or behavior, such as unauthorized access or disclosure of PII. Some privacy risks may result from authorized activity that is beyond the scope of information security. For example, privacy programs are responsible for managing the risks to individuals that may result from the creation, collection, use, and retention of PII; the inadequate quality or integrity of PII; and the lack of appropriate notice, transparency, or participation. Therefore, to help ensure compliance with applicable privacy requirements and to manage privacy risks from authorized and unauthorized processing of PII, organizations’ privacy programs also select, implement, assess, and monitor privacy controls.³²

[OMB A-130] defines a privacy control as an administrative, technical, or physical safeguard employed within an agency to ensure compliance with applicable privacy requirements and to manage privacy risks. A privacy control is different from a security control, which the Circular defines as a safeguard or countermeasure prescribed for an information system or an organization to protect the confidentiality, integrity, and availability of the system and its information. Due to the shared responsibility that organizations’ information security programs and privacy programs have to manage the risks to individuals arising from unauthorized system activity or behavior, controls that achieve both security and privacy objectives are both privacy and security controls. This guideline refers to such controls that achieve both sets of objectives simply as “controls.” When this guideline uses the descriptors “privacy” and “security” with the term control, it is referring to those controls in circumstances where the controls are selected, implemented, and assessed for particular objectives.

The risk management processes described in this publication are equally applicable to security and privacy programs. However, the risks that security and privacy programs are required to manage are overlapping in some areas, but not in others. Consequently, it is important that organizations understand the interplay between privacy and security to promote effective collaboration between privacy and security officials at every level of the organization.

This publication uses the statutory definition of information system for RMF execution. It is important, however, to describe information systems in the context of the SDLC process and how security and privacy capabilities are implemented within the components of those systems. Therefore, organizations executing the RMF take a broad view of the life cycle of information system development to provide a contextual relationship and linkage to architectural and engineering concepts that allow security and privacy risks (including supply chain risks) to be addressed throughout the life cycle and at the appropriate level of detail to help ensure that such capabilities are achieved. [ISO 15288] provides an engineering view of an information system and the entities with which the system interacts in its environment of operation.³³

Similar to how federal law defines information system as a discrete set of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information. [ISO 15288] defines a system as a set of interacting elements that are organized to achieve one or more stated purposes. Just as the information resources that comprise an information system include information and other resources (e.g., personnel, equipment, funds, and information technology), system elements include technology or machine elements, human elements, and physical or environmental elements. Each of the system elements³⁴ within the system fulfills specified requirements and may be implemented via hardware, software, or firmware;³⁵ physical structures or devices; or people, processes, policies, and procedures. Individual system elements or a combination of system elements may satisfy stated system requirements. Interconnections between system elements allow those elements to interact as necessary to produce a capability as specified by the system requirements. Finally, every system operates within an environment that influences the system and its operation.

The authorization boundary defines the system³⁶ for RMF execution to facilitate risk management and accountability. The system may be supported by one or more enabling systems that provide support during the system life cycle. Enabling systems are not contained within the authorization boundary of the system and do not necessarily exist in the system’s environment of operation. An enabling system may provide common (i.e., inherited) controls for the system or may include any type of service or functionality used by the system such as identification and authentication services, network services, or monitoring functionality. Finally, there are other systems the system interacts with in the operational environment. The other systems are also outside of the authorization boundary and may be the beneficiaries of services provided by the system or may simply have some general interaction.³⁷

Figure 5 illustrates the conceptual view of the system and the relationships among the system, system elements, enabling systems, other systems, and the environment of operation.³⁸

FIGURE 5: CONCEPTUAL VIEW OF THE SYSTEM

Certain parts of the environment of operation may be included in the authorization boundary (i.e., determined to be “in scope” for the authorization) while other parts may be excluded. For example, if the facility (i.e., environment of operation) that provides protection for the system elements is determined to be in scope for the authorization of the system, the physical and environmental protection controls (e.g., physical access controls at entry points, perimeter protection devices) are included in the authorization boundary and therefore, are included in the system security plan. If the facility provides physical and environmental protections as common controls to be inherited by the system, the environment of operation is out of scope for the system and is not included in the authorization boundary for the system.³⁹

The system may also communicate or have other interactions with enabling systems and other systems that are part of the extended environment of operation but are outside of the scope of authorization for the system.⁴⁰ Organizations determine which parts of the environment of operation are within the authorization boundary. These determinations are typically specific to the system and are context-driven.

The authorization boundary establishes the scope of protection for an information system (i.e., what the organization agrees to protect under its direct management or within the scope of its responsibilities).⁴¹ The authorization boundary includes the people, processes, and information technologies (i.e., system elements) that are part of each system supporting the organization’s missions and business functions. Authorization boundaries that are too expansive (i.e., include too many system elements or components) make the risk management process unnecessarily complex. Conversely, authorization boundaries that are too limited (i.e., include too few system elements or components) increase the number of systems that must be separately managed and therefore, may unnecessarily inflate the information security and privacy costs for the organization.

The authorization boundary for a system is established during the RMF Prepare Task – System level, Task P-11. Organizations have flexibility in determining what constitutes the authorization boundary for a system. The set of system elements included within an authorization boundary defines the system (i.e., the scope of the authorization). When a set of system elements is identified as an authorization boundary for a system, the elements are generally under the same direct management.⁴² Other considerations for determining the authorization boundary include identifying system elements that:

The scope of the authorization boundary is revisited periodically as part of the continuous monitoring process carried out by the organization. While the above considerations may be useful to organizations in determining authorization boundaries for purposes of managing risk, the considerations are not intended to limit the organization’s flexibility in establishing authorization boundaries that promote effective security and privacy with the available resources of the organization.

The process of establishing authorization boundaries carries significant risk management implications and is therefore an organization-wide activity that requires coordination among key participants. The process considers mission and business requirements, security and privacy requirements, and the costs to the organization. Appendix G provides additional information and considerations for determining authorization boundaries, including boundaries for complex systems and software applications.

Establishing meaningful authorization boundaries for systems and common controls is one of the most important risk management activities carried out by an organization. The authorization boundary defines the specific scope of an authorizing official’s responsibility and accountability for protecting information resources and individuals’ privacy—including the use of systems, components, and services from external providers. Establishment of meaningful authorization boundaries is a foundation for assuring mission and business success for the organization.

Before executing the RMF, it is important to understand the concept of security and privacy requirements and the relationship between requirements and controls. The term requirements can be used in different contexts. In the context of federal information security and privacy policies, the term is generally used to refer to information security and privacy obligations imposed on organizations. For example, OMB Circular A-130 imposes a series of information security and privacy requirements with which federal agencies must comply when managing information resources. In addition to the use of the term requirements in the context of federal policy, the term requirements is used in this guideline in a broader sense to refer to an expression of the set of stakeholder protection needs for a particular system or organization. Stakeholder protection needs and corresponding security and privacy requirements may be derived from many sources (e.g., laws, executive orders, directives, regulations, policies, standards, mission and business needs, or risk assessments). The term requirements, as used in this guideline, includes both legal and policy requirements, as well as an expression of the broader set of stakeholder protection needs that may be derived from other sources. All of these requirements, when applied to a system, help determine the required characteristics of the system—encompassing security, privacy, and assurance.

Organizations may choose to divide security and privacy requirements into more granular categories depending on where the requirements are employed in the SDLC and for what purpose. Organizations may use the term capability requirement to describe a capability that the system or organization must provide to satisfy a stakeholder protection need. In addition, organizations may refer to system requirements that pertain to particular hardware, software, and firmware components of a system as specification requirements—that is, capabilities that implement all or part of a control and that may be assessed (i.e., as part of the verification, validation, testing, and evaluation processes). Finally, organizations may use the term statement of work requirements to refer to actions that must be performed operationally or during system development.

Controls can be viewed as descriptions of the safeguards and protection capabilities appropriate for achieving the particular security and privacy objectives of the organization and reflecting the protection needs of organizational stakeholders. Controls are selected and implemented by the organization in order to satisfy the system requirements. Controls can include technical aspects, administrative aspects, and physical aspects. In some cases, the selection and implementation of a control may necessitate additional specification by the organization in the form of derived requirements or instantiated control parameter values. The derived requirements and control parameter values may be necessary to provide the appropriate level of implementation detail for particular controls within the SDLC.

Security and privacy requirements and risks identified by the organization, lead to the need for security and privacy controls to respond to the risk. The controls selected by the organization subsequently lead to both specification requirements and statement of work requirements in the systems engineering context. This is an important aspect of how systems engineers develop, derive, and decompose requirements as part of the SDLC process. Thus, organizations manage security and privacy requirements at various levels of granularity and specificity during the life cycle of the system. Controls play an important part in the life cycle by providing high-level statements of protection capability that can be refined and expanded upon by the organization.

The purpose of the RMF is to help ensure that, throughout the SDLC, information systems, organizations, and individuals are adequately protected, and that authorizing officials have the information needed to make credible, risk-based decisions regarding the operation or use of systems or the provision of common controls. A key aspect of risk-based decision making for authorizing officials is understanding the security and privacy posture of information systems and the common controls that are available for inheritance by those systems. The security and privacy posture represents the status of information systems and information resources (e.g., personnel, equipment, funds, and information technology) within an organization based on information assurance resources (e.g., people, hardware, software, policies, procedures) and the capabilities in place to manage the defense of the organization in its operation or use of systems; comply with applicable privacy requirements and manage privacy risks; and react as the situation changes.

The security and privacy posture of information systems and organizations is determined on an ongoing basis by assessing and continuously monitoring system-specific, hybrid, and common controls.⁴⁴ The control assessments and monitoring activities provide evidence that the controls selected by the organization are implemented correctly, operating as intended, and satisfying the security and privacy requirements in response to laws, executive orders, regulations, directives, policies, standards, or mission and business requirements. Authorizing officials use the security and privacy posture to determine if the risk to organizational operations and assets, individuals, other organizations, or the Nation are acceptable based on the organization’s risk management strategy and organizational risk tolerance.⁴⁵

Organizations are becoming increasingly reliant on products, systems, and services provided by external providers to carry out missions and business functions. Organizations are responsible and accountable for the risk incurred when using such component products, systems, and services.⁴⁶ Relationships with external providers can be established in a variety of ways, for example, through joint ventures, business partnerships, various types of formal agreements (e.g., contracts, interagency agreements, lines of business arrangements, licensing agreements), or outsourcing arrangements.

The growing dependence on products, systems, and services from external providers, along with the nature of the relationships with those providers, present an increasing amount of risk to an organization. Risk may increase based on the likelihood of occurrence and adverse impact from threat events such as the insertion of counterfeits, unauthorized production, tampering, theft, insertion of malicious software and hardware, as well as poor manufacturing and development practices in the supply chain, including the failure to build in security or privacy capabilities that enable an organization to better manage risk in its environment.

Supply chain risks can be endemic or systemic within a system element, system, organization, sector, or nation. While the singular use of a system element or service within a system may present an acceptable risk to an organization, its common or extended use throughout a system, organization, sector or nation can raise the risk to an unacceptable level. These risks are often associated with the global and distributed nature of product and service supply chains and an organization’s decreased visibility into, and understanding of, how the technology that they acquire is developed, integrated, and deployed. This includes the processes, procedures, and practices used to assure the integrity, security, resilience, privacy capabilities, and quality of the acquired products, systems, and services.

To address supply chain risks, organizations develop an SCRM policy, which is an important vehicle for directing SCRM activities. Guided and informed by applicable laws, executive orders, directives, policies, and regulations, the SCRM policy supports applicable organizational policies (e.g., acquisition and procurement, information security and privacy, logistics, quality, and supply chain). The policy addresses the goals and objectives in the organization’s strategic plan, missions and business functions, and the internal and external customer requirements. It also defines the integration points for SCRM with the risk management and the SDLC processes for the organization. Finally, the SCRM policy defines the SCRM roles and responsibilities within the organization, any dependencies among those roles, and the interaction among the roles. SCRM roles specify the responsibilities for procurement, conducting risk assessments, collecting supply chain threat intelligence, identifying and implementing risk-based mitigations, and performing monitoring functions.

[FISMA] and [OMB A-130] require external providers handling federal information or operating systems on behalf of the federal government to meet the same security and privacy requirements as federal agencies. Security and privacy requirements for external providers including the controls for systems processing, storing, or transmitting federal information are expressed in contracts or other formal agreements. The RMF can be effectively used to manage supply chain risk.⁴⁷ The conceptual view of the system in Figure 5 can guide and inform security, privacy, and risk management activities for all elements of the supply chain. Every step in the RMF can be executed by nonfederal external providers except for the Authorize step—that is, the acceptance of risk is an inherent federal responsibility for which senior executives are held responsible and accountable. The authorization decision is directly linked to the management of risk related to the acquisition and use of component products, systems, and services from external providers.⁴⁸ [OMB A-130] also requires organizations to develop and implement SCRM plans.⁴⁹

Managing supply chain risk is a complex, multifaceted undertaking requiring a coordinated effort across an organization—building trust relationships and communicating with both internal and external stakeholders. SCRM activities involve identifying and assessing applicable risks, determining appropriate mitigating actions, developing appropriate SCRM plans to document selected mitigating actions, and monitoring performance against SCRM plans. Because supply chains differ across and within organizations, SCRM plans are tailored to the individual program, organizational, and operational contexts. Tailored plans provide the basis for determining whether a system is “fit for purpose” and as such, the controls need to be tailored accordingly. Tailored SCRM plans help organizations to focus their resources on the most critical missions and business functions based on mission and business requirements and their risk environment.

The determination that the risk from acquiring products, systems, or services from external providers is acceptable depends on the level of assurance⁵⁰ that the organization can gain from the providers. The level of assurance is based on the degree of control the organization can exert on the external provider regarding the controls needed for the protection of the product, system, or service and the evidence brought forth by the provider as to the effectiveness of those controls.

The degree of control is established by the specific terms and conditions of the contract or service-level agreement. Some organizations have extensive control through contract vehicles or other agreements that specify the security and privacy requirements for the external provider. Other organizations, in contrast, have limited control because they are purchasing commodity services or commercial off-the-shelf products. The level of assurance can also be based on many other factors that convince the organization that the requisite controls have been implemented and that a credible determination of control effectiveness exists. For example, an authorized external cloud service provided to an organization through a well-established line-of-business relationship may provide a level of trust in the service that is within the risk tolerance of the organization. Ultimately, the responsibility for responding to risks from the use of component products, systems, and services from external providers remains with the organization and the authorizing official. Organizations require that an appropriate chain of trust be established with external providers when dealing with the issues associated with system security or privacy risks.

Organizations have flexibility on how the details of SCRM strategies and plans are documented. SCRM strategy details for Levels 1 and 2 (organization and mission/business process levels), can be documented in the information security program plan for the organization or in a separate organization-level and/or mission/business process-level SCRM strategy. SCRM plan details for Level 3 (information system level) can be documented in the information system security plan or in a separate system-level SCRM plan. An SCRM strategy template is provided in [SP 800-161].

EXECUTING THE RISK MANAGEMENT FRAMEWORK TASKS

This chapter describes the steps and associated tasks that comprise the RMF and the selected individuals or groups (defined organizational roles) that carry out such tasks.⁵¹ Organizations align their risk management roles with complementary or similar roles defined for the SDLC whenever possible, and consistent with missions and business functions. RMF tasks are executed concurrently with, or as part of, the SDLC processes in the organization. Executing RMF tasks concurrently with SDLC processes helps to ensure that organizations are effectively integrating the process of managing information security and privacy risks into SDLC processes. Moreover, the expected outputs required by the RMF (e.g., security and privacy plans, assessment reports, plans of action and milestones), can be routinely obtained from the SDLC processes in place within organizations and may not need to be developed solely for RMF implementation.

The best RMF implementation is one that is indistinguishable from the routine SDLC processes carried out by organizations. That is, RMF tasks are closely aligned with the ongoing activities in the SDLC processes, ensuring the seamless integration of security and privacy protections into organizational systems—and taking maximum advantage of the artifacts generated by the SDLC processes to produce the necessary evidence in authorization packages to facilitate credible, risk-based decision making by senior leaders in organizations.

The process of implementing RMF tasks may vary from organization to organization. While the tasks appear in sequential order, there can be many points in the risk management process that require divergence from the sequential order, including the need for iterative cycles between initial task execution and revisiting tasks. For example, control assessment results can trigger a set of remediation actions by system owners and common control providers, which can in turn require the reassessment of selected controls. Monitoring controls can generate a cycle of tracking changes to the system and its environment of operation; assessing the information security and privacy impact; reassessing controls, taking remediation actions, and reporting the security and privacy posture of the system and the organization.

There may be other opportunities to diverge from the sequential nature of the tasks when it is more effective, efficient, or cost-effective to do so. For example, while the control assessment tasks are listed after the control implementation tasks, organizations may begin the assessment of controls as soon as they are implemented but prior to the complete implementation of all controls described in the system security plans and privacy plans. Assessing controls as soon as they are implemented may result in organizations assessing the physical and environmental protection controls within a facility prior to assessing the controls implemented in the hardware, firmware, or software components of the system (which may be implemented later). Regardless of the task ordering, the final action before a system is placed into operation is the explicit acceptance of risk by the authorizing official.

The RMF steps and associated tasks can be applied to new development systems and existing systems at appropriate phases in the SDLC. For new and existing systems, organizations ensure that the designated tasks have been completed to prepare for the execution of the RMF. For existing systems, organizations confirm that the security categorization and (for information systems processing PII) a privacy risk assessment have been completed and are appropriate; and that the needed controls have been selected, tailored, and implemented.

Applying the RMF steps and associated tasks to existing systems can serve as a gap analysis to determine if the organization’s security and privacy risks have been effectively managed. Deficiencies in controls can be addressed in the RMF steps for implementation, assessment, authorization, and monitoring in the same manner as in new development systems. If no deficiencies are discovered during the gap analysis and there is a current authorization in effect, the organization can move directly to the continuous monitoring step in the RMF. If a current authorization is not in effect, the organization continues in the usual sequence with the assessment, authorization, and monitoring steps.

The roles specified in the Primary Responsibility section for each RMF task are responsible for ensuring that the task is completed. The roles with primary responsibility may complete a task or may delegate completion of a task to one or more supporting roles except where delegation is specifically prohibited or disallowed in the task Discussion section or Appendix D. If completion of a task is delegated, the role with primary responsibility for that task remains accountable for task completion.

The RMF is an SDLC-based process that can be effectively used to help ensure that security and privacy requirements are satisfied for information systems or organizations. Defining clear, consistent, and unambiguous security and privacy requirements is an important element in the successful execution of the RMF. The requirements are defined early in the SDLC in collaboration with the senior leaders and are integrated into the acquisition and procurement processes. For example, organizations can use the [SP 800-160 v1] life cycle-based systems engineering process to define an initial set of security and privacy requirements, which in turn, can be used to select a set of controls* to satisfy the requirements. The requirements or the controls can be stated in the Request for Proposal or other contractual agreement when organizations acquire systems, system components, or services. Requirements can also be added throughout the life cycle, such as with the agile development methodology where new features are continuously deployed.

The NIST Cybersecurity Framework [NIST CSF] (i.e., Core, Profiles) can also be used to identify, align, and deconflict security requirements and to subsequently inform the selection of security controls for an organization. Cybersecurity Framework Profiles can provide a link between cybersecurity activities and organizational mission/business objectives, which supports risk-based decision-making throughout the RMF. While Profiles may be used as a starting point to inform control selection and tailoring activities, further evaluation is needed to ensure the appropriate controls are selected. Some organizations may choose to use the Cybersecurity Framework in concert with the NIST Systems Security Engineering publications—identifying, aligning, and deconflicting requirements across a sector, an industry, or an organization—and subsequently employing a systems engineering approach to further refine the requirements and obtain trustworthy secure solutions to help protect the organization’s operations, assets, individuals.

* See Section 2.3 for specific guidance on privacy control selection and managing privacy risk.

Preparation can achieve effective, efficient, and cost-effective execution of risk management processes. The primary objectives of the Prepare step include:

These objectives, if achieved, significantly reduce the information technology footprint and the attack surface of organizations, promote IT modernization objectives, and prioritize security and privacy activities to focus protection strategies on the most critical assets and systems.

Finally, certain tasks in the Prepare step at the organization level are designated as optional. These tasks are included to provide organizations additional options to help make their RMF implementations more effective, efficient, and cost-effective.

The purpose of the Prepare step is to carry out essential activities at the organization, mission and business process, and information system levels of the organization to help prepare the organization to manage its security and privacy risks using the Risk Management Framework.

Table 1 provides a summary of tasks and expected outcomes for the RMF Prepare step at the organization level. Applicable Cybersecurity Framework constructs are also provided.

TABLE 1: PREPARE TASKS AND OUTCOMES—ORGANIZATION LEVEL

Quick link to summary table for RMF tasks, responsibilities, and supporting roles.

TASK P-1 Identify and assign individuals to specific roles associated with security and privacy risk management.

Potential Inputs: Organizational security and privacy policies and procedures; organizational charts.

Expected Outputs: Documented Risk Management Framework role assignments.

Primary Responsibility: Head of Agency; Chief Information Officer; Senior Agency Official for Privacy.

Supporting Roles: Authorizing Official or Authorizing Official Designated Representative; Senior Accountable Official for Risk Management or Risk Executive (Function); Senior Agency Information Security Officer.

Discussion: The roles and responsibilities of key participants in risk management processes are described in Appendix D. The roles and responsibilities may include personnel that are internal or external to the organization, as appropriate. Since organizations have different missions, functions, and organizational structures, there may be differences in naming conventions for risk management roles and how specific responsibilities are allocated among organizational personnel (e.g., multiple individuals filling a single role or one individual filling multiple roles). In either situation, the basic risk management functions remain the same. Organizations ensure that there are no conflicts of interest when assigning the same individual to multiple risk management roles. For example, authorizing officials cannot occupy the role of system owner or common control provider for systems or common controls they are authorizing. In addition, combining multiple roles for security and privacy requires care because the two disciplines may require different expertise, and in some circumstances, the priorities may be competing. Some roles may be allocated to a group or an office rather than to an individual, for example, control assessor, risk executive (function), or system administrator.

References: [SP 800-160 v1] (Human Resource Management Process); [SP 800-181]; [NIST CSF] (Core [Identify Function]).

TASK P-2 Establish a risk management strategy for the organization that includes a determination of risk tolerance.

Potential Inputs: Organizational mission statement; organizational policies; organizational risk assumptions, constraints, priorities and trade-offs.

Expected Outputs: Risk management strategy and statement of risk tolerance inclusive of information security and privacy risk.

Primary Responsibility: Head of Agency.

Supporting Roles: Senior Accountable Official for Risk Management or Risk Executive (Function); Chief Information Officer; Senior Agency Information Security Officer; Senior Agency Official for Privacy.

Discussion: Risk tolerance is the degree of risk or uncertainty that is acceptable to an organization. Risk tolerance affects all parts of the organization’s risk management process, having a direct impact on the risk management decisions made by senior leaders or executives throughout the organization and providing important constraints on those decisions. The risk management strategy guides and informs risk-based decisions including how security and privacy risk is framed, assessed, responded to, and monitored. The risk management strategy may be composed of a single document, or separate security and privacy risk management documents.⁵⁴ The risk management strategy makes explicit the threats, assumptions, constraints, priorities, trade-offs, and risk tolerance used for making investment and operational decisions. This strategy includes the strategic-level decisions and considerations for how senior leaders and executives are to manage security and privacy risks (including supply chain risks) to organizational operations, organizational assets, individuals, other organizations, and the Nation. The risk management strategy includes an expression of organizational risk tolerance; acceptable risk assessment methodologies and risk response strategies; a process for consistently evaluating security and privacy risks organization-wide; and approaches for monitoring risk over time. As organizations define and implement the risk management strategies, policies, procedures, and processes, it is important that they include SCRM considerations. The risk management strategy for security and privacy connects security and privacy programs with the management control systems established in the organization’s Enterprise Risk Management strategy.⁵⁵

References: [SP 800-30]; [SP 800-39] (Organization Level); [SP 800-160 v1] (Risk Management, Decision Management, Quality Assurance, Quality Management, Project Assessment and Control Processes); [SP 800-161]; [IR 8062]; [IR 8179] (Criticality Analysis Process B); [NIST CSF] (Core [Identify Function]).

TASK P-3 Assess organization-wide security and privacy risk and update the risk assessment results on an ongoing basis.

Potential Inputs: Risk management strategy; mission or business objectives; current threat information; system-level security and privacy risk assessment results; supply chain risk assessment results; previous organization-level security and privacy risk assessment results; information sharing agreements or memoranda of understanding; security and privacy information from continuous monitoring.

Expected Outputs: Organization-level risk assessment results.

Primary Responsibility: Senior Accountable Official for Risk Management or Risk Executive (Function); Senior Agency Information Security Officer; Senior Agency Official for Privacy.

Supporting Roles: Chief Information Officer; Mission or Business Owner; Authorizing Official or Authorizing Official Designated Representative.

Discussion: Risk assessment at the organizational level leverages aggregated information from system-level risk assessment results, continuous monitoring, and any strategic risk considerations relevant to the organization. The organization considers the totality of risk from the operation and use of its information systems, from information exchange and connections with other internally and externally owned systems, and from the use of external providers. For example, the organization may review the risk related to its enterprise architecture and information systems of varying impact levels residing on the same network and whether higher impact systems are segregated from lower impact systems or systems operated and maintained by external providers. The organization may also consider the variability of environments that may exist within the organization (e.g., different locations serving different missions/business processes) and the need to account for such variability in risk assessments. Risk assessments of the organization’s supply chain may be conducted as well. Risk assessment results may be used to help organizations establish a Cybersecurity Framework Profile.

References: [SP 800-30]; [SP 800-39] (Organization Level, Mission/Business Process Level); [SP 800-161]; [IR 8062].

TASK P-4 Establish, document, and publish organizationally-tailored control baselines and/or Cybersecurity Framework Profiles.

Potential Inputs: Documented security and privacy requirements directing the use of organizationally-tailored control baselines; mission or business objectives; enterprise architecture; security architecture; privacy architecture; organization- and system-level risk assessment results; list of common control providers and common controls available for inheritance; NIST Special Publication 800-53B control baselines.⁵⁶

Expected Outputs: List of approved or directed organizationally-tailored control baselines; [NIST CSF] Profiles.

Primary Responsibility: Mission or Business Owner; Senior Accountable Official for Risk Management or Risk Executive (Function).

Supporting Roles: Chief Information Officer; Authorizing Official or Authorizing Official Designated Representative; Senior Agency Information Security Officer; Senior Agency Official for Privacy.

Discussion: To address the organizational mission or business need for specialized sets of controls to reduce risk, organizationally-tailored control baselines may be developed for organization-wide use.⁵⁷ An organizationally-tailored baseline provides a fully specified set of controls, control enhancements, and supplemental guidance derived from established control baselines described in [SP 800-53B]. The tailoring process can also be guided and informed by the requirements engineering process described in [SP 800-160 v1]. Organizations can use the tailored control baseline concept when there is divergence from the specific assumptions used to create the initial control baselines in [SP 800-53B]. This would include, for example, situations when the organization has specific security or privacy risks, has specific mission or business needs, or plans to operate in environments that are not addressed in the initial baselines.

Organizationally-tailored baselines and overlays complement the NIST control baselines by providing an opportunity to add or eliminate controls to accommodate organizational requirements while continuing to protect information commensurate with risk. Organizations can use tailored baselines and overlays to customize control baselines by describing control applicability and by providing interpretations for specific technologies; types of missions or business functions, operations, systems, environments of operation, and operating modes; and statutory or regulatory requirements. Multiple customized baselines may be useful for organizations with heterogeneous systems (e.g., organizations that maintain systems with different operating or processing characteristics, or mission or business characteristics).

Organizationally-tailored baselines can establish organization-defined control parameter values for assignment or selection statements in controls and control enhancements that are agreeable to specific communities of interest and can also extend the supplemental guidance where necessary. Tailored baselines may be more stringent or less stringent than the baselines identified in [SP 800-53B] and are applied to multiple systems.

Tailored baselines developed outside the organization may also be mandated for use by certain laws, executive orders, directives, regulations, policies, or standards. In some situations, tailoring actions may be restricted or limited by the developer of the tailored baseline or by the issuing authority for the tailored baseline. Tailored baselines (or overlays) have been developed by communities of interest for cloud and shared systems, services, and applications; industrial control systems; privacy; national security systems; weapons and space-based systems; high value assets;⁵⁸ mobile device management; federal public key infrastructure; and privacy risks.

Organizations may also benefit from developing one or more Cybersecurity Framework Profiles. A Cybersecurity Framework Profile uses the Subcategories in the Framework Core to align cybersecurity outcomes with mission or business requirements, risk tolerance, and resources of the organization.⁵⁹ The prioritized list of cybersecurity outcomes developed at the organization and mission/business process levels can be helpful in facilitating consistent, risk-based decisions at the system level. The Subcategories identified in the applicable Cybersecurity Framework Profiles can also be used to guide and inform the development of the tailored control baselines described above.

References: [SP 800-53]; [SP 800-53B]; [SP 800-160 v1] (Business or Mission Analysis and Stakeholder Needs and Requirements Definition Processes); [NIST CSF] (Core, Profiles).

TASK P-5 Identify, document, and publish organization-wide common controls that are available for inheritance by organizational systems.

Potential Inputs: Documented security and privacy requirements; existing common control providers and associated security and privacy plans; information security and privacy program plans; organization- and system-level security and privacy risk assessment results.

Expected Outputs: List of common control providers and common controls available for inheritance; security and privacy plans (or equivalent documents) providing a description of the common control implementation (including inputs, expected behavior, and expected outputs).

Primary Responsibility: Senior Agency Information Security Officer; Senior Agency Official for Privacy.

Supporting Roles: Mission or Business Owner; Senior Accountable Official for Risk Management or Risk Executive (Function); Chief Information Officer; Authorizing Official or Authorizing Official Designated Representative; Common Control Provider; System Owner.

Discussion: Common controls are controls that can be inherited by one or more information systems.⁶⁰ Common controls can include controls from any [SP 800-53] control family, for example, physical and environmental protection controls, system boundary and monitoring controls, personnel security controls, policies and procedures, acquisition controls, account and identity management controls, audit log and accountability controls, or complaint management controls for receiving privacy inquiries from the public. Organizations identify and select the set of common controls and allocate those controls to the organizational entities designated as common control providers. Common controls may differ based upon a variety of factors, such as hosting location, system architecture, and the structure of the organization. The organization-wide list of common controls takes these factors into account. Common controls can also be identified at different levels of the organization (e.g., corporate, department, or agency level; bureau or subcomponent level; or individual program level). Organizations may establish one or more lists of common controls that can be inherited by information systems. A requirement may not be fully met by a common control. In such cases, the control is considered a hybrid control and is noted as such by the organization, including specifying which parts of the control requirement are provided for inheritance by the common control and which parts are to be provided at the system level.

When there are multiple sources of common controls, organizations specify the common control provider (i.e., who is providing the controls and through what venue, for example, shared services, specific systems, or within a specific type of architecture) and which systems or types of systems can inherit the controls. Common control listings are communicated to system owners, so they are aware of the security and privacy capabilities that are available from the organization through inheritance. System owners are not required to assess common controls that are inherited by their systems or document common control implementation details; that is the responsibility of the common control providers. Likewise, common control providers are not required to have visibility into the system-level details of those systems that are inheriting the common controls they are providing.

Risk assessment results can be used when identifying common controls to determine if the controls available for inheritance satisfy the security and privacy requirements for organizational systems and the environments in which those systems operate (including the identification of potential single points of failure). When the common controls provided by the organization are determined to be insufficient for the information systems inheriting those controls, system owners can supplement the common controls with system-specific or hybrid controls to achieve the required protection for their systems or accept greater risk with the acknowledgement and approval of the organization.

Common control providers execute the RMF steps to implement, assess, and monitor the controls designated as common controls. Common control providers may also be system owners when the common controls are resident within an information system. Organizations select senior officials or executives to serve as authorizing officials for common controls. The senior agency official for privacy is responsible for designating common privacy controls and for documenting them in the organization’s privacy program plan. Authorizing officials are responsible for accepting security and privacy risk resulting from the use of common controls inherited by organizational systems.

Common control providers are responsible for documenting common controls in security and privacy plans (or equivalent documents prescribed by the organization); ensuring that the common controls are implemented and assessed for effectiveness by qualified assessors and that assessment findings are documented in assessment reports; producing a plan of action and milestones for common controls determined to have unacceptable deficiencies and targeted for remediation; receiving authorization for the common controls from the designated authorizing official; and monitoring control effectiveness on an ongoing basis. Plans, assessment reports, and plans of action and milestones for common controls (or a summary of such information) are made available to system owners and can be used by authorizing officials to guide and inform authorization decisions for systems inheriting common controls. For information about the authorization of common controls, see Task R-4 and Appendix F.

References: [SP 800-53].

TASK P-6 Prioritize organizational systems with the same impact level.

Potential Inputs: Security categorization information for organizational systems; system descriptions; organization- and system-level risk assessment results; mission or business objectives; Cybersecurity Framework Profiles.

Expected Outputs: Organizational systems prioritized into low-, moderate-, and high-impact subcategories.

Primary Responsibility: Senior Accountable Official for Risk Management or Risk Executive (Function).

Supporting Roles: Senior Agency Information Security Officer; Senior Agency Official for Privacy; Mission or Business Owner; System Owner; Chief Information Officer; Authorizing Official or Authorizing Official Designated Representative.

Discussion: This task is carried out only after organizational systems have been categorized (see Task C1). This task requires organizations to first apply the high-water mark concept to each of their information systems categorized in accordance with [FIPS 199] and [FIPS 200].⁶² The application of the high-water mark concept results in systems designated as low impact, moderate impact, or high impact. Organizations desiring additional granularity in their impact designations for risk-based decision making can use this task to prioritize their systems within each impact level.⁶³ For example, an organization may decide to prioritize its moderate-impact systems by assigning each moderate system to one of three new subcategories: low-moderate systems, moderate-moderate systems, and high-moderate systems. The high-moderate systems assume a higher priority than the moderate-moderate systems and low-moderate systems assume a lower priority than the moderate-moderate systems. The prioritization of its moderate systems gives organizations an opportunity to make more informed decisions regarding control selection and the tailoring of control baselines when responding to identified risks.

Impact-level prioritization can also be used to determine those systems that are critical or essential to organizational missions and business operations and therefore, organizations can focus on the factors of complexity, aggregation, and system interconnections. Such systems can be identified, for example, by prioritizing high-impact systems into low-high systems, moderate-high systems, and high-high systems. Impact-level prioritizations can be conducted at any level of the organization and are based on security categorization data reported by individual system owners. Impact-level prioritization may necessitate the development of organizationally-tailored baselines to designate the appropriate set of controls for the additional, more granular impact levels.

Cybersecurity Framework Profiles can be used by organizations to support the impact-level prioritization task. The mission and business objectives and prioritized outcomes defined in applicable Cybersecurity Framework Profiles can help distinguish relative priority between systems with the same impact level. Cybersecurity Framework Profiles can be organized around the priority of mission/business objectives of an organization, and those objectives are assigned a relative priority among them. For example, human and environmental safety objectives may be the two most important objectives relevant to a Profile's context. In this example, when performing Task P-6, a system that relates to a human safety objective may be prioritized higher than a system that has the same impact levels but does not relate to the human safety objective.

References: [FIPS 199]; [FIPS 200]; [SP 800-30]; [SP 800-39] (Organization and System Levels); [SP 800-59]; [SP 800-60 v1]; [SP 800-60 v2]; [SP 800-160 v1] (System Requirements Definition Process); [IR 8179] (Criticality Analysis Process B); [CNSSI 1253]; [NIST CSF] (Core [Identify Function]; Profiles).

TASK P-7 Develop and implement an organization-wide strategy for continuously monitoring control effectiveness.

Potential Inputs: Risk management strategy; organization- and system-level risk assessment results; organizational security and privacy policies.

Expected Outputs: An implemented organizational continuous monitoring strategy.

Primary Responsibility: Senior Accountable Official for Risk Management or Risk Executive (Function).

Supporting Roles: Chief Information Officer; Senior Agency Information Security Officer; Senior Agency Official for Privacy; Mission or Business Owner; System Owner; Authorizing Official or Authorizing Official Designated Representative.

Discussion: An important aspect of risk management is the ability to monitor the security and privacy posture across the organization and the effectiveness of controls implemented within or inherited by organizational systems on an ongoing basis.⁶⁴ An effective organization-wide continuous monitoring strategy is essential to efficiently and cost-effectively carry out such monitoring. Continuous monitoring strategies can also include supply chain risk considerations, for example, regularly reviewing supplier foreign ownership, control, or influence (FOCI), monitoring inventory forecasts, or requiring on-going audits of suppliers. The implementation of a robust and comprehensive continuous monitoring program helps an organization understand the security and privacy posture of its information systems. It also facilitates ongoing authorization after the initial system or common control authorizations. This includes the potential for changing missions or business functions, stakeholders, technologies, vulnerabilities, threats, risks, and suppliers of systems, components, or services.

The organizational continuous monitoring strategy addresses monitoring requirements at the organization, mission/business process, and information system levels. The continuous monitoring strategy identifies the minimum monitoring frequency for implemented controls across the organization; defines the ongoing control assessment approach; and describes how ongoing assessments are to be conducted (e.g., addressing the use and management of automated tools, and instructions for ongoing assessment of controls for which monitoring cannot be automated). The continuous monitoring strategy may also define security and privacy reporting requirements including recipients of the reports. The criteria for determining the minimum frequency for control monitoring is established in collaboration with organizational officials (e.g., senior accountable official for risk management or risk executive [function)]; senior agency information security officer; senior agency official for privacy; chief information officer; system owners; common control providers; and authorizing officials or their designated representatives). An organizational risk assessment can be used to guide and inform the frequency of monitoring.

The use of automation facilitates a greater frequency and volume of control assessments as part of the monitoring process. The ongoing monitoring of controls using automated tools and supporting databases facilitates near real-time risk management for information systems and supports ongoing authorization and efficient use of resources. The senior accountable official for risk management or the risk executive (function) approves the continuous monitoring strategy including the minimum frequency with which controls are to be monitored.

References: [SP 800-30]; [SP 800-39] (Organization, Mission or Business Process, System Levels); [SP 800-53]; [SP 800-53A]; [SP 800-137]; [SP 800-161]; [IR 8011 v1]; [IR 8062]; [NIST CSF] (Core [Identify, Detect Functions]); [CNSSI 1253].

Mission/business process considerations are addressed in the RMF Prepare-Organization Level step and the RMF Prepare-System Level step by specifying mission/business process concerns; by identifying the mission or business owners in primary or supporting roles; and by identifying the mission or business objectives. Task P-8 and Task P-9 from the RMF Prepare-System Level step are mission/business process level tasks conducted with a system-level specific focus.

Table 2 provides a summary of tasks and expected outcomes for the RMF Prepare step at the system level. Applicable Cybersecurity Framework constructs are also provided.

TABLE 2: PREPARE TASKS AND OUTCOMES—SYSTEM LEVEL

Quick link to summary table for RMF tasks, responsibilities, and supporting roles.

TASK P-8 Identify the missions, business functions, and mission/business processes that the system is intended to support.

Potential Inputs: Organizational mission statement; organizational policies; mission/business process information; system stakeholder information; Cybersecurity Framework Profiles; requests for proposal or other acquisition documents; concept of operations.

Expected Outputs: Missions, business functions, and mission/business processes that the system will support.

Primary Responsibility: Mission or Business Owner.

Supporting Roles: Authorizing Official or Authorizing Official Designated Representative; System Owner; Information Owner or Steward; Chief Information Officer; Senior Agency Information Security Officer; Senior Agency Official for Privacy.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: Organizational missions and business functions influence the design and development of the mission or business processes that are created to carry out those missions and business functions. The prioritization of missions and business functions drives investment strategies, funding decisions, resource prioritization, and risk decisions—and thus affects the existing enterprise architecture and development of the associated security and privacy architectures. Information is elicited from stakeholders to acquire a more thorough understanding of the missions, business functions, and mission/business processes of the organization from a system security and privacy perspective.

References: [SP 800-39] (Organization and Mission/Business Process Levels); [SP 800-64]; [SP 800-160 v1] (Business or Mission Analysis, Portfolio Management, and Project Planning Processes); [NIST CSF] (Core [Identify Function]); [IR 8179] (Criticality Analysis Process B).

TASK P-9 Identify stakeholders who have an interest in the design, development, implementation, assessment, operation, maintenance, or disposal of the system.

Potential Inputs: Organizational mission statement; mission or business objectives; missions, business functions, and mission/business processes that the system will support; other mission/business process information; organizational security and privacy policies and procedures; organizational charts; information about individuals or groups (internal and external) that have an interest in and decision-making responsibility for the system.

Expected Outputs: List of system stakeholders.

Primary Responsibility: Mission or Business Owner; System Owner.

Supporting Roles: Chief Information Officer; Authorizing Official or Authorizing Official Designated Representative; Information Owner or Steward; Senior Agency Information Security Officer; Senior Agency Official for Privacy; Chief Acquisition Officer.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: Stakeholders include individuals, organizations, or representatives that have an interest in the system throughout the system life cycle—for design, development, implementation, delivery, operation, and sustainment of the system. It also includes all aspects of the supply chain. Stakeholders may reside in the same organization or they may reside in different organizations in situations when there is a common interest by those organizations in the information system. For example, this may occur during the development, operation, and maintenance of cloud-based systems, shared service systems, or any system where organizations may be adversely impacted by a breach or a compromise to the system or for a variety of considerations related to the supply chain. Communication among stakeholders is important during every step in the RMF and throughout the SDLC to ensure that security and privacy requirements are satisfied, concerns and issues are addressed expeditiously, and risk management processes are carried out effectively.

References: [SP 800-39] (Organization Level); [SP 800-64]; [SP 800-160 v1] (Stakeholder Needs and Requirements Definition and Portfolio Management Processes); [SP 800-161]; [NIST CSF] (Core [Identify Function]).

TASK P-10 Identify assets that require protection.

Potential Inputs: Missions, business functions, and mission/business processes the information system will support; business impact analyses; internal stakeholders; system stakeholder information; system information; information about other systems that interact with the system.

Expected Outputs: Set of assets to be protected.

Primary Responsibility: System Owner.

Supporting Roles: Authorizing Official or Authorizing Official Designated Representative; Mission or Business Owner; Information Owner or Steward; Senior Agency Information Security Officer; Senior Agency Official for Privacy; System Administrator.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: Assets are tangible and intangible items that are of value to achievement of mission or business objectives. Tangible assets are physical in nature and include physical/environmental elements (e.g., non-digital information, structures, facilities), human elements, and technology/machine elements (e.g., hardware elements, mechanisms, and networks). In contrast, intangible assets are not physical in nature and include mission and business processes, functions, digital information and data, firmware, software, and services. Information assets can be tangible or intangible assets, and can include the information needed to carry out missions or business functions, to deliver services, and for system management/operation; controlled unclassified information and classified information; and all forms of documentation associated with the information system. Intangible assets can also include the image or reputation of an organization, and the privacy interests of the individuals whose information will be processed by the system. The organization defines the scope of stakeholder assets to be considered for protection. The assets that require protection are identified based on stakeholder concerns and the contexts in which the assets are used. This includes the missions or business functions of the organization; the other systems that interact with the system; and stakeholders whose assets are utilized by the mission or business functions or by the system. Assets can be documented in the system security and privacy plans.

References: [SP 800-39] (Organization Level); [SP 800-64]; [SP 800-160 v1] (Stakeholder Needs and Requirements Definition Process); [IR 8179] (Criticality Analysis Process C); [NIST CSF] (Core [Identify Function]); [NARA CUI].

TASK P-11 Determine the authorization boundary of the system.

Potential Inputs: System design documentation; network diagrams; system stakeholder information; asset information; network and/or enterprise architecture diagrams; organizational structure (charts, information).

Expected Outputs: Documented authorization boundary.

Primary Responsibility: Authorizing Official.

Supporting Roles: Chief Information Officer; System Owner; Mission or Business Owner; Senior Agency Information Security Officer; Senior Agency Official for Privacy; Enterprise Architect.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: Authorization boundaries establish the scope of protection for information systems (i.e., what the organization agrees to protect under its management control or within the scope of its responsibilities). Authorization boundaries are determined by authorizing officials with input from the system owner based on mission, management, or budgetary responsibility (see Appendix F). A clear delineation of authorization boundaries is important for accountability and for security categorization, especially in situations where lower-impact systems are connected to higher-impact systems, or when external providers are responsible for the operation or maintenance of a system. Each system includes a set of elements (i.e., information resources)⁶⁵ organized to achieve one or more purposes and to support the organization’s missions and business processes. Each system element is implemented in a way that allows the organization to satisfy specified security and privacy requirements. System elements include human elements, technology/machine elements, and physical/environmental elements.

The term system is used to define the set of system elements, system element interconnections, and the environment that is the focus of the RMF implementation (see Figure 5). The system is included in a single authorization boundary to ensure accountability. For systems processing PII, the privacy and security programs collaborate to develop a common understanding of authorization boundaries. To conduct effective risk assessments and select appropriate controls, privacy and security programs provide a clear and consistent understanding of what constitutes the authorization boundary. Understanding the authorization boundary and what will occur beyond it may influence controls selected and how they are implemented. For example, if a function of the system includes sharing PII externally, robust encryption controls may be selected for PII transmitted from the system.

Similarly, for systems either partially or wholly managed, maintained, or operated by external providers, an agreement clearly describing authorization boundaries ensures accountability. Privacy and security programs collaborate with providers to develop a common understanding of authorization boundaries. Formal agreements with external providers (e.g. contracts) may be used to delineate what constitutes authorization boundaries. Understanding such boundaries facilitates the selection of appropriate controls to manage supply chain risk.

References: [SP 800-18]; [SP 800-39] (System Level); [SP 800-47]; [SP 800-64]; [SP 800-160 v1] (System Requirements Definition Process); [NIST CSF] (Core [Identify Function]).

TASK P-12 Identify the types of information to be processed, stored, and transmitted by the system.

Potential Inputs: System design documentation; assets to be protected; mission/business process information; system design documentation.

Expected Outputs: A list of information types for the system.

Primary Responsibility: System Owner; Information Owner or Steward.

Supporting Role: Mission or Business Owner; System Security Officer; System Privacy Officer.⁶⁶

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: Identifying the types of information needed to support organizational missions, business functions, and mission/business processes is an important step in developing security and privacy plans for the system and a precondition for determining the security categorization. [NARA CUI] defines the information types that require protection as part of its Controlled Unclassified Information (CUI) program, in accordance with laws, regulations, or governmentwide policies. Organizations may define additional information types needed to support organizational missions, business functions, and mission/business processes that are not defined in the CUI Registry or in [SP 800-60 v2]. Identified information types are confirmed by the information owners or stewards and documented in the system security and privacy plans.

References: [OMB A-130]; [NARA CUI]; [SP 800-39] (System Level); [SP 800-60 v1]; [SP 800-60 v2]; [NIST CSF] (Core [Identify Function]).

TASK P-13 Identify and understand all stages of the information life cycle for each information type processed, stored, or transmitted by the system.

Potential Inputs: Missions, business functions, and mission/business processes the system will support; system stakeholder information; authorization boundary information; information about other systems that interact with the system (e.g., information exchange/connection agreements); system design documentation; system element information; list of system information types.

Expected Outputs: Documentation of the stages through which information passes in the system, such as a data map or model illustrating how information is structured or is processed by the system throughout its life cycle. Such documentation includes, for example, data flow diagrams, entity relationship diagrams, database schemas, and data dictionaries.

Primary Responsibility: Senior Agency Official for Privacy; System Owner; Information Owner or Steward.

Supporting Roles: Chief Information Officer; Mission or Business Owner; Security Architect; Privacy Architect; Enterprise Architect; Systems Security Engineer; Privacy Engineer.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition). Existing – Operations/Maintenance.

Discussion: The information life cycle describes the stages through which information passes, typically characterized as creation or collection, processing, dissemination, use, storage, and disposition, to include destruction and deletion [OMB A-130]. Identifying and understanding how each information type is processed during all stages of the life cycle helps organizations identify considerations for protecting the information, informs the organization’s security and privacy risk assessments, and informs the selection and implementation of controls. Identification and understanding of the information life cycle facilitates the employment of practices to help ensure, for example, that organizations have the authority to collect or create information, develop rules related to the processing of information in accordance with its impact level, create agreements for information sharing, and follow retention schedules for the storage and disposition of information.

Using tools such as a data map enables organizations to understand how information is being processed so that organizations can better assess where security and privacy risks could arise and where controls could be applied most effectively. It is important for organizations to consider the appropriate delineation of the authorization boundary and the information system’s interaction with other systems because the way information enters and leaves the system can affect the security and privacy risk assessments. The elements of the system are identified with sufficient granularity to support such risk assessments.

Identifying and understanding the information life cycle is particularly relevant for the assessment of security and privacy risks since information may be processed by a system in any of the SDLC phases. For example, in the testing and integration phase of the SDLC, processing actual (i.e., live) data would likely raise security and privacy risks, but using substitute (i.e., synthetic) data may allow an equivalent benefit in terms of system testing while reducing risk.

References: [OMB A-130]; [OMB M-13-13]; [NARA RECM]; [NIST CSF] (Core [Identify Function]); [IR 8062].

TASK P-14 Conduct a system-level risk assessment and update the risk assessment results on an ongoing basis.

Potential Inputs: Assets to be protected; missions, business functions, and mission/business processes the system will support; business impact analyses or criticality analyses; system stakeholder information; information about other systems that interact with the system; provider information; threat information; data map; system design documentation; Cybersecurity Framework Profiles; risk management strategy; organization-level risk assessment results.

Expected Outputs: Security and privacy risk assessment reports.

Primary Responsibility: System Owner; System Security Officer; System Privacy Officer.

Supporting Roles: Senior Accountable Official for Risk Management or Risk Executive (Function); Authorizing Official or Authorizing Official Designated Representative; Mission or Business Owner; Information Owner or Steward; Control Assessor.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition). Existing – Operations/Maintenance.

Discussion: This task may require that organizations conduct security and privacy risk assessments to ensure that each type of risk is fully assessed. Assessment of security risk includes identification of threat sources⁶⁷ and threat events affecting assets, whether and how the assets are vulnerable to the threats, the likelihood that an asset vulnerability will be exploited by a threat, and the impact (or consequence) of loss of the assets. As a key part of the risk assessment, assets are prioritized based on the adverse impact or consequence of asset loss. The meaning of loss is defined for each asset type to enable a determination of the loss consequence (i.e., the adverse impact of the loss). Loss consequences may be tangible (e.g., monetary, industrial casualties) or intangible (e.g., reputation) and constitute a continuum that spans from partial loss to total loss relative to the asset. Interpretations of information loss may include, for example, loss of possession, destruction, or loss of precision or accuracy. The loss of a function or service may be interpreted as a loss of control, loss of accessibility, loss of the ability to deliver normal function, performance, or behavior, or a limited loss of capability resulting in a level of degradation of function, performance, or behavior. Physical consequences of compromise can include unscheduled production downtime, industrial equipment damage, casualties at the site, environmental disasters and public safety threats. Prioritization of assets is based on asset value, physical consequences, cost of replacement, criticality, impact on image or reputation, or trust by users, by collaborating organizations, or by mission or business partners. The asset priority translates to precedence in allocating resources, determining strength of mechanisms, and defining levels of assurance.

Privacy risk assessments are conducted to determine the likelihood that a given operation the system is taking when processing PII could create an adverse effect on individuals—and the potential impact on individuals.⁶⁸ These adverse effects can arise from unauthorized activities that lead to the loss of confidentiality, integrity, or availability in information systems processing PII, or may arise as a byproduct of authorized activities. Privacy risk assessments are influenced by contextual factors. Contextual factors can include, but are not limited to, the sensitivity level of the PII, including specific elements or in aggregate; the types of organizations using or interacting with the system and individuals’ perceptions about the organizations with respect to privacy; individuals’ understanding about the nature and purpose of the processing; and the privacy interests of individuals, technological expertise or demographic characteristics that influence their understanding or behavior. The privacy risks to individuals may affect individuals’ decisions to engage with the system thereby impacting mission or business objectives, or create legal liability, reputational risks, or other types of risks for the organization. Impacts to the organization are not privacy risks. However, these impacts can guide and inform organizational decision-making and influence prioritization and resource allocation for risk response.

Risk assessments are also conducted to determine the potential that the use of an external provider for the development, implementation, maintenance, management, operation, or disposition of a system, system element, or service could create a loss, and the potential impact of that loss. The impact may be immediate (e.g., physical theft) or on-going (e.g., the ability of adversaries to replicate critical equipment because of theft). The impact may be endemic (e.g., limited to a single system) or systemic (e.g., including any system that uses a specific type of system component). Supply chain risk assessments consider vulnerabilities which may arise related to the disposition of a system or system element and from the use of external providers. Vulnerabilities in the supply chain may include a lack of traceability or accountability leading to the potential use of counterfeits, insertion of malware, or poor-quality systems. The use of external providers may result in a loss of visibility and control over how systems, system elements, and services are developed, deployed, and maintained. A clear understanding of the threats, vulnerabilities, and potential impacts of an adverse supply chain event can help organizations appropriately balance supply chain risk with risk tolerance. Supply chain risk assessments can include information from supplier audits, reviews, and supply chain intelligence. Organizations develop a strategy for collecting information, including a strategy for collaborating with providers on supply chain risk assessments. Such collaboration helps organizations leverage information from providers, reduce redundancy, identify potential courses of action for risk responses, and reduce the burden on providers.

Risk assessments are conducted throughout the SDLC and support various RMF steps and tasks. Risk assessment results are used to inform security and privacy requirements definition; categorization decisions; the selection, tailoring, implementation, and assessment of controls; authorization decisions; potential courses of action and prioritization for risk responses; and continuous monitoring strategy. Organizations determine the form of risk assessment conducted (including the scope, rigor, and formality of such assessments) and method of reporting results.

References: [FIPS 199]; [FIPS 200]; [SP 800-30]; [SP 800-39] (Organization Level); [SP 800-59]; [SP 800-60 v1]; [SP 800-60 v2]; [SP 800-64]; [SP 800-160 v1] (Stakeholder Needs and Requirements Definition and Risk Management Processes); [SP 800-161] (Assess); [IR 8062]; [IR 8179]; [NIST CSF] (Core [Identify Function]); [CNSSI 1253].

TASK P-15 Define the security and privacy requirements for the system and the environment of operation.

Potential Inputs: System design documentation; organization- and system-level risk assessment results; known set of stakeholder assets to be protected; missions, business functions, and mission/business processes the system will support; business impact analyses or criticality analyses; system stakeholder information; data map of the information life cycle for PII; Cybersecurity Framework Profiles; information about other systems that interact with the system; supply chain information; threat information; laws, executive orders, directives, regulations, or policies that apply to the system; risk management strategy.

Expected Outputs: Documented security and privacy requirements.

Primary Responsibility: Mission or Business Owner; System Owner; Information Owner or Steward; System Privacy Officer.⁶⁹

Supporting Roles: Authorizing Official or Authorizing Official Designated Representative; System Security Officer; Senior Agency Information Security Officer; Senior Agency Official for Privacy; Chief Acquisition Officer; Security Architect; Privacy Architect; Enterprise Architect.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: Protection needs are an expression of the protection capability required for the system in order to reduce security and privacy risk to an acceptable level while supporting mission or business needs. Protection needs include the security characteristics⁷⁰ of the system and the security behavior of the system in its intended operational environment and across all system life cycle phases. The protection needs reflect the priorities of stakeholders, results of negotiations among stakeholders in response to conflicts, opposing priorities, contradictions, and stated objectives, and thus, are inherently subjective. The protection needs are documented to help ensure that the reasoning, assumptions, and constraints associated with those needs are available for future reference and to provide traceability to the security and privacy requirements. Security and privacy requirements⁷¹ constitute a formal, more granular expression of protection needs across all SDLC phases, the associated life cycle processes, and protections for the assets associated with the system. Security and privacy requirements are obtained from many sources (e.g., laws, executive orders, directives, regulations, policies, standards, mission and business needs, or risk assessments). Security and privacy requirements are an important part of the formal expression of the required characteristics of the system.⁷² The security and privacy requirements guide and inform the selection of controls for a system and the tailoring activities associated with those controls.

Organizations can use the Cybersecurity Framework to manage security and privacy requirements and express those requirements in Cybersecurity Framework Profiles defined for the organization. For instance, multiple requirements can be aligned and even deconflicted using the Function-Category-Subcategory structure of the Framework Core. The Profiles can then be used to inform the development of organizationally-tailored control baselines described in the RMF Prepare-Organization Level step, Task P-4.

References: [SP 800-39] (Organization Level); [SP 800-64]; [SP 800-160 v1] (Stakeholder Needs and Requirements Definition Process); [SP 800-161] (Multi-Tiered Risk Management); [IR 8179]; [NIST CSF] (Core [Protect, Detect, Respond, Recover Functions]; Profiles).

TASK P-16 Determine the placement of the system within the enterprise architecture.

Potential Inputs: Security and privacy requirements; organization- and system-level risk assessment results; enterprise architecture information; security architecture information; privacy architecture information; asset information.

Expected Outputs: Updated enterprise architecture; updated security architecture; updated privacy architecture; plans to use cloud-based systems and shared systems, services, or applications.

Primary Responsibility: Mission or Business Owner; Enterprise Architect; Security Architect; Privacy Architect.

Supporting Roles: Chief Information Officer; Authorizing Official or Authorizing Official Designated Representative; Senior Agency Information Security Officer; Senior Agency Official for Privacy; System Owner; Information Owner or Steward.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition). Existing – Operations/Maintenance.

Discussion: Enterprise architecture is a management practice used to maximize the effectiveness of mission/business processes and information resources and to achieve mission and business success. An enterprise architecture can provide greater understanding of information and operational technologies included in the initial design and development of information systems and is a prerequisite for achieving resilience and survivability of those systems in an environment of increasingly sophisticated threats. Enterprise architecture also provides an opportunity for organizations to consolidate, standardize, and optimize information and technology assets. An effectively implemented architecture produces systems that are more transparent and therefore, easier to understand and protect. Enterprise architecture also establishes an unambiguous connection from investments to measurable performance improvements. The placement of a system within the enterprise architecture is important as it provides greater visibility and understanding about the other systems (internal and external) that are connected to the system and can also be used to establish security domains for increased levels of protection for the system.

The security architecture and the privacy architecture are integral parts of the enterprise architecture. These architectures represent the parts of the enterprise architecture related to the implementation of security and privacy requirements. The primary purpose of the security and privacy architectures is to ensure that security and privacy requirements are consistently and cost-effectively met in organizational systems and are aligned with the risk management strategy. The security and privacy architectures provide a roadmap that facilitates traceability from the strategic goals and objectives of organizations, through protection needs and security and privacy requirements, to specific security and privacy solutions provided by people, processes, and technologies.

References: [SP 800-39] (Mission/Business Process Level); [SP 800-64]; [SP 800-160 v1] (System Requirements Definition Process); [NIST CSF] (Core [Identify Function]; Profiles); [OMB FEA].

TASK P-17 Allocate security and privacy requirements to the system and to the environment of operation.

Potential Inputs: Organization- and system-level risk assessment results; documented security and privacy requirements; organization- and system-level risk assessment results; list of common control providers and common controls available for inheritance; system description; system element information; system component inventory; relevant laws, executive orders, directives, regulations, and policies.

Expected Outputs: List of security and privacy requirements allocated to the system, system elements, and the environment of operation.

Primary Responsibility: Security Architect; Privacy Architect; System Security Officer; System Privacy Officer.

Supporting Roles: Chief Information Officer; Authorizing Official or Authorizing Official Designated Representative; Mission or Business Owner; Senior Agency Information Security Officer; Senior Agency Official for Privacy; System Owner.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition). Existing – Operations/Maintenance.

Discussion: Security and privacy requirements are allocated to guide and inform control selection and implementation for the organization, system, system elements, and/or environment of operation.⁷³ Requirements allocation identifies where controls will be implemented. The allocation of requirements conserves resources and helps to streamline the risk management process by ensuring that requirements are not implemented on multiple systems or system elements when implementation of a common control or a system-level control on a specific system element provides the needed protection capability.

References: [SP 800-39] (Organization, Mission/Business Process, and System Levels); [SP 800-64]; [SP 800-160 v1] (System Requirements Definition Process); [NIST CSF] (Core [Identify Function]; Profiles); [OMB FEA].

TASK P-18 Register the system with organizational program or management offices.

Potential Inputs: Organizational policy on system registration; system information.

Expected Outputs: Registered system in accordance with organizational policy.

Primary Responsibility: System Owner.

Supporting Role: Mission or Business Owner; Chief Information Officer; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: System registration, in accordance with organizational policy, serves to inform the governing organization of plans to develop the system or the existence of the system; the key characteristics of the system; and the expected security and privacy implications for the organization due to the operation and use of the system. System registration provides organizations with a management and tracking tool to facilitate bringing the system into the enterprise architecture, implementation of protections that are commensurate with risk, and security and privacy posture reporting in accordance with applicable laws, executive orders, directives, regulations, policies, or standards. As part of the system registration process, organizations add the system to the organization-wide system inventory. System registration information is updated with security categorization and system characterization information upon completion of the Categorize step.

References: None.

Purpose

The purpose of the Categorize step is to inform organizational risk management processes and tasks by determining the adverse impact to organizational operations and assets, individuals, other organizations, and the Nation with respect to the loss of confidentiality, integrity, and availability of organizational systems and the information processed, stored, and transmitted by those systems.

Table 3 provides a summary of tasks and expected outcomes for the RMF Categorize step. Applicable Cybersecurity Framework constructs are also provided.

TABLE 3: CATEGORIZE TASKS AND OUTCOMES

Quick link to summary table for RMF tasks, responsibilities, and supporting roles.

TASK C-1 Document the characteristics of the system.

Potential Inputs: System design and requirements documentation; authorization boundary information; list of security and privacy requirements allocated to the system, system elements, and the environment of operation; physical or other processes controlled by system elements; system element information; system component inventory; system element supply chain information, including inventory and supplier information; security categorization; data map of the information life cycle for information types processed, stored, and transmitted by the system; information on system use, users, and roles.

Expected Outputs: Documented system description.

Primary Responsibility: System Owner.

Supporting Roles: Authorizing Official or Authorizing Official Designated Representative; Information Owner or Steward; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: A description of the system characteristics is documented in the security and privacy plans, included in attachments to the plans, or referenced in other standard sources for the information generated as part of the SDLC. Duplication of information is avoided, whenever possible. The level of detail in the security and privacy plans is determined by the organization and is commensurate with the security categorization and the security and privacy risk assessments of the system. Information may be added to or updated in the system description as it becomes available during the system life cycle, during the execution of the RMF steps, and as any system characteristics change.

Examples of different types of descriptive information that organizations can include in security and privacy plans include: descriptive name of the system and system identifier; system version or release number; manufacturer and supplier information; individual responsible for the system; system contact information; organization that manages, owns, or controls the system; system location; purpose of the system and missions/business processes supported; how the system is integrated into the enterprise architecture; SDLC phase; results of the categorization process and privacy risk assessment; authorization boundary; laws, directives, policies, regulations, or standards affecting individuals’ privacy and the security of the system; architectural description of the system including network topology; information types; hardware, firmware, and software components that are part of the system; hardware, software, and system interfaces (internal and external); information flows within the system; network connection rules for communicating with external systems; interconnected systems and identifiers for those systems; physical or other processes, components and equipment controlled by system elements; system users (including affiliations, access rights, privileges, citizenship); system provenance in the supply chain; maintenance or other relevant agreements; potential suppliers for replacement components for the system; alternative compatible system components; number and location in inventory of replacement system components; ownership or operation of the system (government-owned, government-operated; government-owned, contractor-operated; contractor-owned, contractor-operated; nonfederal [state and local governments, grantees]); incident response points of contact; authorization date and authorization termination date; and ongoing authorization status. System registration information is updated with the system characterization information (see Task P-18).

References: [SP 800-18]; [NIST CSF] (Core [Identify Function]).

TASK C-2 Categorize the system and document the security categorization results.

Potential Inputs: Risk management strategy; organizational risk tolerance; authorization boundary (i.e., system) information; organization- and system-level risk assessment results; information types processed, stored, or transmitted by the system; list of security and privacy requirements allocated to the system, system elements, and environment of operation; organizational authority or purpose for operating the system; business impact analyses or criticality analyses; information about missions, business functions, and mission/business processes supported by the system.

Expected Outputs: Impact levels determined for each information type and for each security objective (confidentiality, integrity, availability); security categorization based on high-water mark of information type impact levels.

Primary Responsibility: System Owner; Information Owner or Steward.

Supporting Roles: Senior Accountable Official for Risk Management or Risk Executive (Function); Chief Information Officer; Senior Agency Information Security Officer; Senior Agency Official for Privacy; Authorizing Official or Authorizing Official Designated Representative; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: Security categorization determinations consider potential adverse impacts to organizational operations, organizational assets, individuals, other organizations, and the Nation resulting from the loss of confidentiality, integrity, or availability of information. Organizations have flexibility in conducting a security categorization using either [FIPS 200] to establish a single impact level for a system based on the high-water mark concept (for other than national security systems), or [CNSSI 1253] to establish three impact values that may vary for each of the security objectives of confidentiality, integrity, and availability (for national security systems). The security categorization process is carried out by the system owner and the information owner or steward in cooperation and collaboration with senior leaders and executives with mission, business function, or risk management responsibilities. Cooperation and collaboration helps to ensure that individual systems are categorized based on the mission and business objectives of the organization. The system owner and information owner or steward consider the results from the security risk assessment (and the privacy risk assessment when the system processes PII) as a part of the security categorization decision. The decision is consistent with the risk management strategy. The results of the categorization process influence the selection of security controls for the system. Security categorization information is documented in the system security plan or included as an attachment to the plan and can be cross-referenced in a privacy plan when the system processes PII.

The security categorization results for the system can be further refined by the organization to facilitate an impact-level prioritization of systems with the same impact level (see Task P-6). Results from the impact-level prioritization conducted by the organization can be used to help system owners in control selection and tailoring decisions.

References: [FIPS 199]; [FIPS 200]; [SP 800-30]; [SP 800-39] (System Level); [SP 800-59]; [SP 800-60 v1]; [SP 800-60 v2]; [SP 800-160 v1] (Stakeholder Needs and Requirements Definition and System Requirements Definition Processes); [IR 8179]; [CNSSI 1253]; [NIST CSF] (Core [Identify Function]).

TASK C-3 Review and approve the security categorization results and decision.

Potential Inputs: Impact levels determined for each information type and for each security objective (confidentiality, integrity, availability); security categorization based on high-water mark of information type impact levels; list of high value assets for the organization.

Expected Outputs: Approval of security categorization for the system.

Primary Responsibility: Authorizing Official or Authorizing Official Designated Representative; Senior Agency Official for Privacy.⁷⁵

Supporting Roles: Senior Accountable Official for Risk Management or Risk Executive (Function); Chief Information Officer; Senior Agency Information Security Officer.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: For information systems that process PII, the senior agency official for privacy reviews and approves the security categorization results and decision prior to the authorizing official’s review.⁷⁶ Security categorization results and decisions are reviewed by the authorizing official or a designated representative to ensure that the security category selected for the information system is consistent with the mission and business functions of the organization and the need to adequately protect those missions and functions. The authorizing official or designated representative reviews the categorization results and decision from an organization-wide perspective, including how the decision aligns with the categorization decisions for all other organizational systems. The authorizing official collaborates with the senior accountable official for risk management or the risk executive (function) to ensure that the categorization decision for the system is consistent with the organizational risk management strategy and satisfies requirements for high value assets. As part of the approval process, the authorizing official can provide specific guidance to the system owner with respect to any limitations on baseline tailoring activities for the system that occur at the RMF Select step (see Task S-2). If the security categorization decision is not approved, the system owner initiates steps to repeat the categorization process and resubmits the adjusted results to the authorizing official or designated representative. System registration information is subsequently updated with the approved security categorization information (see Task P-18).

References: [FIPS 199]; [SP 800-30]; [SP 800-39] (Organization Level); [SP 800-160 v1] (Stakeholder Needs and Requirements Definition Process); [CNSSI 1253]; [NIST CSF] (Core [Identify Function]).

The purpose of the Select step is to select, tailor, and document the controls necessary to protect the information system and organization commensurate with risk to organizational operations and assets, individuals, other organizations, and the Nation.

Table 4 provides a summary of tasks and expected outcomes for the RMF Select step. Applicable Cybersecurity Framework constructs are also provided.

TABLE 4: SELECT TASKS AND OUTCOMES

Quick link to summary table for RMF tasks, responsibilities, and supporting roles.

TASK S-1 Select the controls for the system and the environment of operation.

Potential Inputs: Security categorization; organization- and system-level risk assessment results; system element information; system component inventory; list of security and privacy requirements allocated to the system, system elements, and environment of operation; list of contractual requirements allocated to external providers of the system or system element; business impact analysis or criticality analysis; risk management strategy; organizational security and privacy policy; federal or organization-approved or mandated baselines or overlays; Cybersecurity Framework Profiles.

Expected Outputs: Controls selected for the system and the environment of operation.

Primary Responsibility: System Owner; Common Control Provider.

Supporting Roles: Authorizing Official or Authorizing Official Designated Representative; Information Owner or Steward; Systems Security Engineer; Privacy Engineer; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Development/Acquisition.

Existing – Operations/Maintenance.

Discussion: There are two approaches that can be used for the initial selection of controls: a baseline control selection approach, or an organization-generated control selection approach. The baseline control selection approach uses control baselines, which are pre-defined sets of controls specifically assembled to address the protection needs of a group, organization, or community of interest. Control baselines serve as a starting point for the protection of individuals’ privacy, information, and information systems. Federal control baselines are provided in [SP 800-53B]. The system security categorization (see Task C-2) and the security requirements derived from stakeholder protection needs, laws, executive orders, regulations, policies, directives, instructions, and standards (see Task P-15) can help inform the selection of security control baselines. A privacy risk assessment (see Task P-14) and privacy requirements derived from stakeholder protection needs, laws, executive orders, regulations, policies, directives, instructions, and standards (see Task P-15) can help inform the selection of privacy control baselines. Privacy programs use security and privacy control baselines to manage the privacy risks arising from both unauthorized system activity or behavior, as well as from authorized activities. After the pre-defined control baseline is selected, organizations tailor the baseline in accordance with the guidance provided (see Task S-2). The baseline control selection approach can provide consistency across a broad community of interest.

The organization-generated control selection approach differs from the baseline selection approach because the organization does not start with a pre-defined set of controls. Rather, the organization uses its own selection process to select controls. This may be necessary when the system is highly specialized (e.g., a weapons system or a medical device) or has limited purpose or scope (e.g., a smart meter). In these situations, it may be more efficient and cost-effective for an organization to select a specific set of controls for the system (i.e., a bottom-up approach) instead of starting with a pre-defined set of controls from a broad-based control baseline and subsequently eliminating controls through the tailoring process (i.e., top-down approach).

In both the baseline control selection approach and organization-generated control selection approach, organizations develop a well-defined set of security and privacy requirements using a life cycle-based systems engineering process (e.g., [ISO 15288] and [SP 800-160 v1] as described in the RMF Prepare-System Level step, Task P-15. This process generates a set of requirements that can be used to guide and inform the selection of a set of controls to satisfy the requirements (whether the organization starts with a control baseline or generates the set of controls from its own selection process). Similarly, organizations can use the [NIST CSF] to develop Cybersecurity Framework Profiles representing a set of organization-specific security and privacy requirements—and thus, guiding and informing control selection from [SP 800-53]. Tailoring may also be required in the organization-generated control selection approach (see Task S-2). Organizations do not need to choose one approach for the selection of controls for each of their systems, but instead, may use different approaches as circumstances dictate.

References: [FIPS 199]; [FIPS 200]; [SP 800-30]; [SP 800-53]; [SP 800-53B]; [SP 800-160 v1] (System Requirements Definition, Architecture Definition, and Design Definition Processes); [SP 800-161] (Respond and Chapter 3); [IR 8062]; [IR 8179]; [CNSSI 1253]; [NIST CSF] (Core [Identify, Protect, Detect, Respond, Recover Functions]; Profiles).

TASK S-2 Tailor the controls selected for the system and the environment of operation.

Potential Inputs: Initial control baselines; organization- and system-level risk assessment results; system element information; system component inventory; list of security and privacy requirements allocated to the system, system elements, and environment of operation; business impact analysis or criticality analysis; risk management strategy; organizational security and privacy policies; federal or organization-approved or mandated overlays.

Expected Outputs: List of tailored controls for the system and environment of operation (i.e., tailored control baselines).

Primary Responsibility: System Owner; Common Control Provider.

Supporting Roles: Authorizing Official or Authorizing Official Designated Representative; Information Owner or Steward; Systems Security Engineer; Privacy Engineer; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Development/Acquisition.

Existing – Operations/Maintenance.

Discussion: After selecting the applicable control baselines, organizations tailor the controls based on various factors (e.g., missions or business functions, threats, security and privacy risks (including supply chain risks), type of system, or risk tolerance). The tailoring process includes identifying and designating common controls in the control baselines (see Task P-5); applying scoping considerations to the remaining baseline controls; selecting compensating controls, if needed; assigning values to organization-defined control parameters using either assignment or selection statements; supplementing baselines with additional controls; and providing specification information for control implementation.⁷⁷ Organizations determine the amount of detail to include in justifications or supporting rationale required for tailoring decisions. For example, the justification or supporting rationale for scoping decisions related to a high-impact system or high value asset⁷⁸ may necessitate greater specificity than similar decisions for a low-impact system. Such determinations are consistent with the organization’s missions and business functions; stakeholder needs; and any relevant laws, executive orders, regulations, directives, or policies. Controls related to the SDLC and SCRM provide the basis for determining whether an information system is fit-for-purpose⁷⁹ and need to be tailored accordingly.

Organizations use risk assessments to inform and guide the tailoring process. Threat information from security risk assessments provides information on adversary capabilities, intent, and targeting that may affect organizational decisions regarding the selection of security controls, including the associated costs and benefits. Privacy risk assessments, including the contextual factors therein, will also influence tailoring when an information system processes PII.⁸⁰ Risk assessment results are also leveraged when identifying common controls to determine if the controls available for inheritance meet the security and privacy requirements for the system and its environment of operation. When common controls provided by the organization do not provide adequate protection for the systems inheriting the controls, system owners can either supplement the common controls with system-specific or hybrid controls to achieve the required level of protection or recommend a greater acceptance of risk to the authorizing official. Organizations may also consider federally or organizationally directed or approved overlays, tailored baselines, or Cybersecurity Framework Profiles when tailoring controls (see Task P-4).

References: [FIPS 199]; [FIPS 200]; [SP 800-30]; [SP 800-53]; [SP 800-53B]; [SP 800-160 v1] (System Requirements Definition, Architecture Definition, and Design Definition Processes); [SP 800-161] (Respond and Chapter 3); [IR 8179]; [CNSSI 1253]; [NIST CSF] (Core [Identify, Protect, Detect, Respond, Recover Functions]; Profiles).

TASK S-3 Allocate security and privacy controls to the system and to the environment of operation.

Potential Inputs: Security categorization; organization- and system-level risk assessment results; organizational policy on system registration; enterprise architecture; security and privacy architectures; security and privacy requirements; list of security and privacy requirements allocated to the system, system elements, and the environment of operation; list of common control providers and common controls available for inheritance; system description; system element information; system component inventory; relevant laws, executive orders, directives, regulations, and policies.

Expected Outputs: List of security and privacy controls allocated to the system, system elements, and the environment of operation.

Primary Responsibility: Security Architect; Privacy Architect; System Security Officer; System Privacy Officer.

Supporting Roles: Chief Information Officer; Authorizing Official or Authorizing Official Designated Representative; Mission or Business Owner; Senior Agency Information Security Officer; Senior Agency Official for Privacy; System Owner.

System Development Life Cycle Phase: New – Initiation (concept/requirements definition).

Existing – Operations/Maintenance.

Discussion: The organization designates controls as system-specific, hybrid, or common, and allocates the controls to the system elements (i.e, machine, physical, or human elements) responsible for providing a security or privacy capability. Controls are allocated to a system or an organization consistent with the organization’s enterprise architecture and security or privacy architecture and the allocated security and privacy requirements. Not all controls need to be allocated to every system element. Controls providing a specific security or privacy capability are only allocated to system elements that require that capability. The security categorization, privacy risk assessment, security and privacy architectures, and the allocation of controls work together to help achieve a suitable balance between security and privacy protections and the mission-based function of the system.

Security and privacy requirements allocated to the system, system elements, and the environment of operation (see Task P-17) guide and inform control allocation to system elements. Common controls that are made available by the organization during the RMF Prepare-Organization Level step (see Task P-5), are selected for inheritance; hybrid controls are also selected. Common controls satisfy security and privacy requirements allocated to the organization and provide a protection capability that is inherited by one or more systems. Hybrid controls satisfy security and privacy requirements allocated to the system and to the organization and provide a protection capability that is partially inherited by one or more systems. And finally, system-specific controls satisfy security and privacy requirements allocated to the system and provide a protection capability for that system. Controls can be allocated to specific system elements rather than to every element within a system. For example, system-specific controls associated with management of audit logs may be allocated to a log management server and need not be implemented on every system element.

References: [SP 800-39] (Organization, Mission/Business Process, and System Levels); [SP 800-64]; [SP 800-160 v1] (System Requirements Definition, Architecture Definition, and Design Definition Processes); [NIST CSF] (Core [Identify Function]; Profiles); [OMB FEA].

TASK S-4 Document the controls for the system and environment of operation in security and privacy plans.

Potential Inputs: Security categorization; organization- and system-level risk assessment results (security, privacy, and/or supply chain); system element information; system component inventory; business impact or criticality analysis; list of security and privacy requirements allocated to the system, system elements, and environment of operation; risk management strategy; list of selected controls for the system and environment of operation; organizational security, privacy, and SCRM policies.

Expected Outputs: Security and privacy plans for the system.

Primary Responsibility: System Owner; Common Control Provider.

Supporting Roles: Authorizing Official or Authorizing Official Designated Representative; Information Owner or Steward; Systems Security Engineer; Privacy Engineer; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Development/Acquisition.

Existing – Operations/Maintenance.

Discussion: Security and privacy plans contain an overview of the security and privacy requirements for the system and the controls selected to satisfy the requirements. The plans describe the intended application of each selected control in the context of the system with a sufficient level of detail to correctly implement the control and to subsequently assess the effectiveness of the control. The control documentation describes how system-specific and hybrid controls are implemented and the plans and expectations regarding the functionality of the system. The description includes planned inputs, expected behavior, and expected outputs where appropriate, typically for those controls implemented in the hardware, software, or firmware components of the system. Common controls are also identified in the plans. There is no requirement to provide implementation details for inherited common controls. Rather, those details are provided in the plans for common control providers and are made available to system owners. For hybrid controls, the organization specifies in the system-level plans the parts of the control that are provided by the common control provider and the parts of the control that are implemented at the system level.

Organizations may develop a consolidated plan that incorporates security and privacy plans or maintain separate plans. If developing a consolidated plan, privacy programs collaborate with security programs to ensure that the plan reflects the selection of controls that provide protections with respect to managing the confidentiality, integrity, and availability of PII; and delineates roles and responsibilities for control implementation, assessment, and monitoring. For separate system security plans and privacy plans, organizations cross-reference the controls in all plans to help maintain accountability and awareness. The senior agency official for privacy reviews and approves the privacy plan (or integrated plan) before the plan is provided to the authorizing official or designated representative for review (see Task S-6). Organizations may document the control selection and tailoring information in documents equivalent to security and privacy plans, for example, in systems engineering or system life cycle artifacts or documents.

Documentation of planned control implementations allows for traceability of decisions prior to and after the deployment of the system. To the extent possible, organizations reference existing documentation (either by vendors or other organizations that have employed the same or similar systems or system elements), use automated support tools, and coordinate across the organization to reduce redundancy and increase the efficiency and cost-effectiveness of control documentation. The documentation also addresses platform dependencies and includes any additional information necessary to describe how the capability required is to be achieved at the level of detail sufficient to support control implementation and assessment. Documentation for control implementations follows best practices for hardware and software development and for systems security and privacy engineering disciplines and is also consistent with established policies and procedures for documenting activities in the SDLC. In certain situations, security controls can be implemented in ways that create privacy risks. The privacy program supports documentation of privacy risk considerations and the implementations intended to mitigate them.

For controls that are mechanism-based, organizations take advantage of the functional specifications provided by or obtainable from manufacturers, vendors, and systems integrators. This includes any documentation that may assist the organization during the development, implementation, assessment, and monitoring of controls. For certain controls, organizations obtain control implementation information from the appropriate organizational entities (e.g., physical security offices, facilities offices, records management offices, and human resource offices). Since the enterprise architecture and the security and privacy architectures established by the organization guide and inform the organizational approach used to plan for and implement controls, documenting the process helps to ensure traceability in meeting the security and privacy requirements.

References: [FIPS 199]; [FIPS 200]; [SP 800-18]; [SP 800-30]; [SP 800-53]; [SP 800-64]; [SP 800-160 v1] (System Requirements Definition, Architecture Definition, and Design Definition Processes); [SP 800-161] (Respond and Chapter 3); [IR 8179]; [CNSSI 1253]; [NIST CSF] (Core [Identify, Protect, Detect, Respond, Recover Functions]; Profiles).

TASK S-5 Develop and implement a system-level strategy for monitoring control effectiveness that is consistent with and supplements the organizational continuous monitoring strategy.

Potential Inputs: Organizational risk management strategy; organizational continuous monitoring strategy; organization- and system-level risk assessment results; security and privacy plans; organizational security and privacy policies.

Expected Outputs: Continuous monitoring strategy for the system including time-based trigger for ongoing authorization.

Primary Responsibility: System Owner; Common Control Provider.

Supporting Roles: Senior Accountable Official for Risk Management or Risk Executive (Function); Chief Information Officer; Senior Agency Information Security Officer; Senior Agency Official for Privacy; Authorizing Official or Authorizing Official Designated Representative; Information Owner or Steward; Security Architect; Privacy Architect; Systems Security Engineer; Privacy Engineer; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Development/Acquisition.

Existing – Operations/Maintenance.

Discussion: An important aspect of risk management is the ongoing monitoring of controls implemented within or inherited by an information system. An effective continuous monitoring strategy at the system level is developed and implemented in coordination with the organizational continuous monitoring strategy early in the SDLC (i.e., during initial system design or procurement decision). The system-level continuous monitoring strategy is consistent with and supplements the continuous monitoring strategy for the organization. The system-level strategy addresses monitoring those controls for which monitoring is not provided as part of the continuous monitoring strategy and implementation for the organization. The system-level strategy identifies the frequency of monitoring for controls not addressed by the organization-level strategy and defines the approach to be used for assessing those controls. The system-level continuous monitoring strategy, consistent with the organizational monitoring strategy, defines how changes to the system and the environment of operation⁸¹ are to be monitored; how risk assessments are to be conducted; and the security and privacy posture reporting requirements including recipients of the reports. The system-level continuous monitoring strategy can be included in security and privacy plans.⁸²

For controls that are not addressed by the organizational continuous monitoring strategy, the system-level continuous monitoring strategy identifies the criteria for determining the frequency with which controls are monitored post-implementation and the plan for the ongoing assessment of those controls. The criteria are established by the system owner or common control provider in collaboration with other organizational officials (e.g., the authorizing official or designated representative; senior accountable official for risk management or risk executive [function]; senior agency information security officer; senior agency official for privacy; and chief information officer). The frequency criteria at the system level reflect organizational priorities and the importance of the system to the organization’s operations and assets, individuals, other organizations, and the Nation. Controls that are volatile (i.e., where the control or the control implementation is most likely to change over time),⁸³ critical to certain aspects of the protection needs for the organization, or identified in plans of action and milestones, may require more frequent assessment. The approach to control assessments during continuous monitoring may include reuse of assessment procedures and results that supported the initial authorization decision; detection of the status of system elements; and analysis of historical and operational data.

The authorizing official or designated representative approves the continuous monitoring strategy and the minimum frequency with which each control is to be monitored. The approval of the strategy can be obtained in conjunction with the security and privacy plan approval. The monitoring of controls begins at the start of the operational phase of the SDLC and continues through the disposal phase.

References: [SP 800-30]; [SP 800-39] (Organization, Mission or Business Process, System Levels); [SP 800-53]; [SP 800-53A]; [SP 800-137]; [SP 800-161]; [IR 8011 v1]; [CNSSI 1253]; [NIST CSF] (Core [Detect Function]).

TASK S-6 Review and approve the security and privacy plans for the system and the environment of operation.

Potential Inputs: Security and privacy plans; organization- and system-level risk assessment results.

Expected Outputs: Security and privacy plans approved by the authorizing official.

Primary Responsibility: Authorizing Official or Authorizing Official Designated Representative.

Supporting Roles: Senior Accountable Official for Risk Management or Risk Executive (Function); Chief Information Officer; Chief Acquisition Officer; Senior Agency Information Security Officer; Senior Agency Official for Privacy.

System Development Life Cycle Phase: New – Development/Acquisition.

Existing – Operations/Maintenance.

Discussion: The security and privacy plan review by the authorizing official or designated representative with support from the senior accountable official for risk management or risk executive (function), chief information officer, senior agency information security officer, and senior agency official for privacy, determines if the plans are complete, consistent, and satisfy the stated security and privacy requirements for the system. Based on the results from this review, the authorizing official or designated representative may recommend changes to the security and privacy plans. If the plans are unacceptable, the system owner or common control provider make appropriate changes to the plans. If the plans are acceptable, the authorizing official or designated representative approves the plans.

The acceptance of the security and privacy plans represents an important milestone in the SDLC and risk management process. The authorizing official or designated representative, by approving the plans, agrees to the set of controls (i.e., system-specific, hybrid, or common controls) and the description of the proposed implementation of the controls to meet the security and privacy requirements for the system and the environment in which the system operates.⁸⁴ The approval of the plans allows the risk management process to proceed to the RMF Implement step. The approval of the plans also establishes the level of effort required to successfully complete the remainder of the RMF steps and provides the basis of the security and privacy specifications for the acquisition of the system or individual system elements.

References: [SP 800-30]; [SP 800-53]; [SP 800-160 v1] (System Requirements Definition, Architecture Definition, and Design Definition Processes).

Purpose

The purpose of the Implement step is to implement the controls in the security and privacy plans for the system and for the organization and to document in a baseline configuration, the specific details of the control implementation.

Table 5 provides a summary of tasks and expected outcomes for the RMF Implement step. Applicable Cybersecurity Framework constructs are also provided.

TABLE 5: IMPLEMENT TASKS AND OUTCOMES

Quick link to summary table for RMF tasks, responsibilities, and supporting roles.

TASK I-1 Implement the controls in the security and privacy plans.

Potential Inputs: Approved security and privacy plans; system design documents; organizational security and privacy policies and procedures; business impact or criticality analyses; enterprise architecture information; security architecture information; privacy architecture information; list of security and privacy requirements allocated to the system, system elements; and environment of operation; system element information; system component inventory; organization- and system-level risk assessment results.

Expected Outputs: Implemented controls.

Primary Responsibility: System Owner; Common Control Provider.

Supporting Roles: Information Owner or Steward; Security Architect; Privacy Architect; Systems Security Engineer; Privacy Engineer; System Security Officer; System Privacy Officer; Enterprise Architect; System Administrator.

System Development Life Cycle Phase: New – Development/Acquisition; Implementation/Assessment. Existing – Operations/Maintenance.

Discussion: Organizations implement the controls as described in the security and privacy plans. The control implementation is consistent with the organization’s enterprise architecture and associated security and privacy architectures. Organizations use best practices when implementing controls, including systems security and privacy engineering methodologies, concepts, and principles. Risk assessments guide and inform decisions regarding the cost, benefit, and risk trade-offs in using different technologies or policies for control implementation. Organizations also ensure that mandatory configuration settings are established and implemented on system elements in accordance with federal and organizational policies. When organizations have no direct control over what controls are implemented in a system element, for example, in commercial off-the-shelf products, organizations consider the use of system elements that have been tested, evaluated, or validated by approved, independent, third-party assessment facilities (e.g., NIST Cryptographic Module Validation Program Testing Laboratories, National Information Assurance Partnership Common Criteria Testing Laboratories). The tests, evaluations, and validations consider products in specific configurations and in isolation; control implementation addresses how the product is integrated into the system while preserving security functionality and assurance.

Organizations also address, where applicable, assurance requirements when implementing controls. Assurance requirements are directed at the activities that control developers and implementers carry out to increase the level of confidence that the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security and privacy requirements for the system. The assurance requirements address quality of the design, development, and implementation of the controls.⁸⁵

For the common controls inherited by the system, systems security and privacy engineers with support from system security and privacy officers, coordinate with the common control provider to determine the most appropriate way to implement common controls. System owners can refer to the authorization packages prepared by common control providers when making determinations regarding the adequacy of common controls inherited by their systems. During implementation, it may be determined that common controls previously selected to be inherited by the system do not meet the specified security or privacy requirements for the system. For common controls that do not meet the requirements for the system inheriting the controls or when common controls have unacceptable deficiencies, the system owners identify compensating or supplementary controls to be implemented. System owners can supplement the common controls with system-specific or hybrid controls to achieve the required protection for their systems or they can accept greater risk with the acknowledgement and approval of the organization. Risk assessments may determine how gaps in security or privacy requirements between systems and common controls affect the risk associated with the system, and how to prioritize the need for compensating or supplementary controls to mitigate specific risks.

Consistent with the flexibility allowed in applying the tasks in the RMF, organizations conduct initial control assessments during system development and implementation. Conducting such assessments in parallel with the development and implementation phases of the SDLC facilitates early identification of deficiencies and provides a cost-effective method for initiating corrective actions. Issues discovered during these assessments can be referred to authorizing officials for resolution. The results of the initial control assessments can also be used during the authorize step to avoid delays or costly repetition of assessments. Assessment results that are subsequently reused in other phases of the SDLC meet the reuse requirements established by the organization.⁸⁶

References: [FIPS 200]; [SP 800-30]; [SP 800-53]; [SP 800-53A]; [SP 800-160 v1] (Implementation, Integration, Verification, and Transition Processes); [SP 800-161]; [IR 8062]; [IR 8179].

TASK I-2 Document changes to planned control implementations based on the “as-implemented” state of controls.

Potential Inputs: Security and privacy plans; information from control implementation efforts.

Expected Outputs: Security and privacy plans updated with implementation detail sufficient for use by assessors; system configuration baseline.

Primary Responsibility: System Owner; Common Control Provider.

Supporting Roles: Information Owner or Steward; Security Architect; Privacy Architect; Systems Security Engineer; Privacy Engineer; System Security Officer; System Privacy Officer; Enterprise Architect; System Administrator.

System Development Life Cycle Phase: New – Development/Acquisition; Implementation/Assessment. Existing – Operations/Maintenance.

Discussion: Despite the control implementation details in the security and privacy plans and the system design documents, it is not always feasible to implement controls as planned. Therefore, as control implementations are carried out, the security and privacy plans are updated with as-implemented control implementation details. The updates include revised descriptions of implemented controls including changes to planned inputs, expected behavior, and expected outputs with sufficient detail to support control assessments. Documenting the “as implemented” control information is essential to providing the capability to determine when there are changes to the controls, whether those changes are authorized, and the impact of the changes on the security and privacy posture of the system and the organization.

References: [SP 800-53]; [SP 800-128]; [SP 800-160 v1] (Implementation, Integration, Verification, and Transition, Configuration Management Processes).

Purpose

The purpose of the Assess step is to determine if the controls selected for implementation are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security and privacy requirements for the system and the organization.

Table 6 provides a summary of tasks and expected outcomes for the RMF Assess step. Applicable Cybersecurity Framework constructs are also provided.

TABLE 6: ASSESS TASKS AND OUTCOMES

Quick link to summary table for RMF tasks, responsibilities, and supporting roles.

TASK A-1 Select the appropriate assessor or assessment team for the type of control assessment to be conducted.

Potential Inputs: Security, privacy, and SCRM plans; program management control information; common control documentation; organizational security and privacy program plans; SCRM strategy; system design documentation; enterprise, security, and privacy architecture information; security, privacy, and SCRM policies and procedures applicable to the system.

Expected Outputs: Selection of assessor or assessment team responsible for conducting the control assessment.

Primary Responsibility: Authorizing Official or Authorizing Official Designated Representative.

Supporting Roles: Chief Information Officer; Senior Agency Information Security Officer; Senior Agency Official for Privacy.

System Development Life Cycle Phase: New – Development/Acquisition; Implementation/Assessment. Existing – Operations/Maintenance.

Discussion: Organizations consider both the technical expertise and level of independence⁸⁷ required in selecting control assessors.⁸⁸ Organizations ensure that control assessors possess the required skills and technical expertise to develop effective assessment plans and to conduct assessments of program management, system-specific, hybrid, and common controls, as appropriate. This includes general knowledge of risk management concepts and approaches as well as comprehensive knowledge of and experience with the hardware, software, and firmware components implemented. In organizations where the assessment capability is centrally managed, the senior agency information security officer may have the responsibility of selecting and managing the security control assessors or assessment teams for organizational systems. As controls may be implemented to achieve security and privacy objectives, organizations consider the degree of collaboration between security control and privacy control assessors that is necessary.

Organizations can conduct self-assessments of controls or obtain the services of an independent control assessor. An independent assessor is an individual or group that can conduct an impartial assessment. Impartiality means that assessors are free from perceived or actual conflicts of interest with respect to the determination of control effectiveness or the development, operation, or management of the system, common controls, or program management controls. The authorizing official determines the level of assessor independence based on applicable laws, executive orders, directives, regulations, policies, or standards. The authorizing official consults with the Office of the Inspector General, chief information officer, senior agency official for privacy, and senior agency information security officer to help guide and inform decisions regarding assessor independence.

The system privacy officer is responsible for identifying assessment methodologies and metrics to determine if privacy controls are implemented correctly, operating as intended, and sufficient to ensure compliance with applicable privacy requirements and manage privacy risks. The senior agency official for privacy is responsible for conducting assessments of privacy controls and documenting the results of the assessments. At the discretion of the organization, privacy controls may be assessed by an independent assessor. However, in all cases, the senior agency official for privacy is responsible and accountable for the organization’s privacy program, including any privacy functions performed by independent assessors. The senior agency official for privacy is responsible for providing privacy information to the authorizing official.

References: [FIPS 199]; [SP 800-30]; [SP 800-53A]; [SP 800-55].

TASK A-2 Develop, review, and approve plans to assess implemented controls.

Potential Inputs: Security, privacy, and SCRM plans; program management control information; common control documentation; organizational security and privacy program plans; SCRM strategy; system design documentation; supply chain information; enterprise, security, and privacy architecture information; security, privacy, and SCRM policies and procedures applicable to the system.

Expected Outputs: Security and privacy assessment plans approved by the authorizing official.

Primary Responsibility: Authorizing Official or Authorizing Official Designated Representative; Control Assessor.

Supporting Roles: Senior Agency Information Security Officer; Senior Agency Official for Privacy; System Owner; Common Control Provider; Information Owner or Steward; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Development/Acquisition; Implementation/Assessment. Existing – Operations/Maintenance.

Discussion: Security and privacy assessment plans are developed by control assessors based on the implementation information contained in security and privacy plans, program management control documentation, and common control documentation. Organizations may choose to develop a single, integrated security and privacy assessment plan for the system or the organization. An integrated assessment plan delineates roles and responsibilities for control assessment. Assessment plans also provide the objectives for control assessments and specific assessment procedures for each control. Assessment plans reflect the type of assessment the organization is conducting, including for example: developmental testing and evaluation; independent verification and validation; audits, including supply chain; assessments supporting system and common control authorization or reauthorization; program management control assessments; continuous monitoring; and assessments conducted after remediation actions.

Assessment plans are reviewed and approved by the authorizing official or the designated representative of the authorizing official to help ensure that the plans are consistent with the security and privacy objectives of the organization; employ procedures, methods, techniques, tools, and automation to support continuous monitoring and near real-time risk management; and are cost-effective. Approved assessment plans establish expectations for the control assessments and the level of effort for the assessment. Approved assessment plans help to ensure that appropriate resources are applied toward determining control effectiveness while providing the necessary level of assurance in making such determinations. When controls are provided by an external provider through contracts, interagency agreements, lines of business arrangements, licensing agreements, or supply chain arrangements, the organization can request security and privacy assessment plans and assessments results or evidence from the provider.

References: [SP 800-53A]; [SP 800-160 v1] (Verification and Validation Processes); [SP 800-161]; [IR 8011 v1].

TASK A-3 Assess the controls in accordance with the assessment procedures described in assessment plans.

Potential Inputs: Security and privacy assessment plans; security and privacy plans; external assessment or audit results (if applicable).

Expected Outputs: Completed control assessments and associated assessment evidence.

Primary Responsibility: Control Assessor.

Supporting Roles: Authorizing Official or Authorizing Official Designated Representative; System Owner; Common Control Provider; Information Owner or Steward; Senior Agency Information Security Officer; Senior Agency Official for Privacy; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Development/Acquisition; Implementation/Assessment. Existing – Operations/Maintenance.

Discussion: Control assessments determine the extent to which the selected controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting security and privacy requirements for the system and the organization. The system owner, common control provider, and/or organization rely on the technical skills and expertise of assessors to assess implemented controls using the assessment procedures specified in assessment plans and provide recommendations on how to respond to control deficiencies to reduce or eliminate identified vulnerabilities or unacceptable risks. The senior agency official for privacy serves as the control assessor for the privacy controls and is responsible for conducting an initial assessment of the privacy controls prior to system operation, and for assessing the controls periodically thereafter at a frequency sufficient to ensure compliance with privacy requirements and to manage privacy risks.⁸⁹ Controls implemented to achieve both security and privacy objectives may require a degree of collaboration between security and privacy control assessors. The assessor findings are a factual reporting of whether the controls are operating as intended and whether any deficiencies⁹⁰ in the controls are discovered during the assessment.

Control assessments occur as early as practicable in the SDLC, preferably during the development phase. These types of assessments are referred to as developmental testing and evaluation, and validate that the controls are implemented correctly and are consistent with the established information security and privacy architectures. Developmental testing and evaluation activities include, for example, design and code reviews, regression testing, and application scanning. Deficiencies identified early in the SDLC can be resolved in a more cost-effective manner. Assessments may be needed prior to source selection during the procurement process to assess potential suppliers or providers before the organization enters into agreements or contracts to begin the development phase. The results of control assessments conducted during the SDLC can also be used (consistent with reuse criteria established by the organization) during the authorization process to avoid unnecessary delays or costly repetition of assessments. Organizations can maximize the use of automation to conduct control assessments to increase the speed, effectiveness, and efficiency of the assessments, and to support continuous monitoring of the security and privacy posture of organizational systems.

Applying and assessing controls throughout the development process may be appropriate for iterative development processes. When iterative development processes (e.g., agile development) are employed, an iterative assessment may be conducted as each cycle is completed. A similar process is employed for assessing controls in commercial IT products that are used in the system. Organizations may choose to begin assessing controls prior to the complete implementation of all controls in the security and privacy plans. This type of incremental assessment is appropriate if it is more efficient or cost-effective to do so.

Common controls (i.e., controls that are inherited by the system) are assessed separately (by assessors chosen by common control providers or the organization) and need not be assessed as part of a system-level assessment.

Organizations ensure that assessors have access to the information system and environment of operation where the controls are implemented and to the documentation, records, artifacts, test results, and other materials needed to assess the controls. This includes the controls implemented by external providers through contracts, interagency agreements, lines of business arrangements, licensing agreements, or supply chain arrangements. Assessors have the required degree of independence as determined by the authorizing official.⁹¹ Assessor independence during the continuous monitoring process facilitates reuse of assessment results to support ongoing authorization and reauthorization.

To make the risk management process more efficient and cost-effective, organizations may choose to establish reasonable and appropriate criteria for reusing assessment results as part of organization-wide assessment policy or in the security and privacy program plans. For example, a recent audit of a system may have produced information about the effectiveness of selected controls. Another opportunity to reuse previous assessment results may come from external programs that test and evaluate security and privacy features of commercial information technology products (e.g., Common Criteria Evaluation and Validation Program and NIST Cryptographic Module Validation Program,). If prior assessment results from the system developer or vendor are available, the control assessor, under appropriate circumstances, may incorporate those results into the assessment. In addition, if a control implementation was assessed during other forms of assessment at previous stages of the SDLC (e.g., unit testing, functional testing, acceptance testing), organizations may consider potential reuse of those results to reduce duplication of efforts. And finally, assessment results can be reused to support reciprocity, for example, assessment results supporting an authorization to use (see Appendix F). Additional information on assessment result reuse is available in [SP 800-53A].

References: [SP 800-53A]; [SP 800-160 v1] (Verification and Validation Processes); [IR 8011 v1].

TASK A-4 Prepare the assessment reports documenting the findings and recommendations from the control assessments.

Potential Inputs: Completed control assessments and associated assessment evidence.

Expected Outputs: Completed security and privacy assessment reports detailing the assessor findings and recommendations.

Primary Responsibility: Control Assessor.

Supporting Roles: System Owner; Common Control Provider; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Development/Acquisition; Implementation/Assessment. Existing – Operations/Maintenance.

Discussion: The results of the security and privacy control assessments, including recommendations for correcting deficiencies in the implemented controls, are documented in the assessment reports⁹² by control assessors. Organizations may develop a single, integrated security and privacy assessment report. Assessment reports are key documents in the system or common control authorization package that is developed for authorizing officials. The assessment reports include information based on assessor findings, necessary to determine the effectiveness of the controls implemented within or inherited by the information system. Assessment reports are an important factor in a determining risk to organizational operations and assets, individuals, other organizations, and the Nation by the authorizing official. The format and the level of detail provided in assessment reports are appropriate for the type of control assessment conducted, for example, developmental testing and evaluation; independent verification and validation; independent assessments supporting information system or common control authorizations or reauthorizations; self-assessments; assessments after remediation actions; independent evaluations or audits; and assessments during continuous monitoring. The reporting format may also be prescribed by the organization.

Control assessment results obtained during the system development lifecycle are documented in an interim report and included in the final security and privacy assessment reports. Development of interim reports that document assessment results from relevant phases of the SDLC reinforces the concept that assessment reports are evolving documents. Interim reports are used, as appropriate, to inform the final assessment report. Organizations may choose to develop an executive summary from the control assessment findings. The executive summary provides authorizing officials and other interested individuals in the organization with an abbreviated version of the assessment reports that includes a synopsis of the assessment, findings, and the recommendations for addressing deficiencies in the controls.

References: [SP 800-53A]; [SP 800-160 v1] (Verification and Validation Processes).

TASK A-5 Conduct initial remediation actions on the controls and reassess remediated controls.

Potential Inputs: Completed security and privacy assessment reports with findings and recommendations; security and privacy plans; security and privacy assessment plans; organization- and system-level risk assessment results.

Expected Outputs: Completed initial remediation actions based on the security and privacy assessment reports; changes to implementations reassessed by the assessment team; updated security and privacy assessment reports; updated security and privacy plans including changes to the control implementations.

Primary Responsibility: System Owner; Common Control Provider; Control Assessor.

Supporting Roles: Authorizing Official or Authorizing Official Designated Representative; Senior Agency Information Security Officer; Senior Agency Official for Privacy; Senior Accountable Official for Risk Management or Risk Executive (Function); Information Owner or Steward; Systems Security Engineer; Privacy Engineer; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Development/Acquisition; Implementation/Assessment. Existing – Operations/Maintenance.

Discussion: The security and privacy assessment reports describe deficiencies in the controls that could not be resolved during the development of the system or that are discovered post-development. Such control deficiencies may result in security and privacy risks (including supply chain risks). The findings generated during control assessments, provide information that facilitates risk responses based on organizational risk tolerance and priorities. The authorizing official, in consultation and coordination with system owners and other organizational officials, may decide that certain findings represent significant, unacceptable risk and require immediate remediation actions. Additionally, it may be possible and practical to conduct initial remediation actions for assessment findings that can be quickly and easily remediated with existing resources.

If initial remediation actions are taken, assessors reassess the controls. The control reassessments determine the extent to which remediated controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security and privacy requirements for the system and the organization. The assessors update the assessment reports with the findings from the reassessment, but do not change the original assessment results. The security and privacy plans are updated based on the findings of the control assessments and any remediation actions taken. The updated plans reflect the state of the controls after the initial assessment and any modifications by the system owner or common control provider in addressing recommendations for corrective actions. At the completion of the control assessments, security and privacy plans contain an accurate description of implemented controls, including compensating controls.

Organizations can prepare an addendum to the security and privacy assessment reports that provides an opportunity for system owners and common control providers to respond to initial assessment findings. The addendum may include, for example, information regarding initial remediation actions taken by system owners or common control providers in response to assessor findings. The addendum can also provide the system owner or common control provider perspective on the findings. This may include providing additional explanatory material, rebutting certain findings, and correcting the record. The addendum does not change or influence the initial assessor findings provided in the reports. Information provided in the addendum is considered by authorizing officials when making risk-based authorization decisions. Organizations implement a process to determine the initial actions to take regarding the control deficiencies identified during the assessment. This process can address vulnerabilities and risks, false positives, and other factors that provide useful information to authorizing officials regarding the security and privacy posture of the system and organization including the ongoing effectiveness of system-specific, hybrid, and common controls. The issue resolution process can also ensure that only substantive items are identified and transferred to the plan of actions and milestones.

Findings from a system-level control assessment may necessitate an update to the system risk assessment and the organizational risk assessment.⁹³ The updated risk assessments and any inputs from the senior accountable official for risk management or risk executive (function) determines the initial remediation actions and the prioritization of those actions. System owners and common control providers may decide, based on a system or organizational risk assessment, that certain findings are inconsequential and present no significant security or privacy risk. Such findings are retained in the security and privacy assessment reports and monitored during the monitoring step. The authorizing official is responsible for reviewing and understanding the assessor findings and for accepting the security and privacy risks (including any supply chain risks) that result from the operation the system or the use of common controls.

In all cases, organizations review assessor findings to determine the significance of the findings and whether the findings warrant any further investigation or remediation. Senior leadership involvement in the mitigation process is necessary to ensure that the organization’s resources are effectively allocated in accordance with organizational priorities—providing resources to the systems that are supporting the most critical missions and business functions or correcting the deficiencies that pose the greatest risk.

References: [SP 800-53A]; [SP 800-160 v1] (Verification and Validation Processes).

TASK A-6 Prepare the plan of action and milestones based on the findings and recommendations of the assessment reports.

Potential Inputs: Updated security and privacy assessment reports; updated security and privacy plans; organization- and system-level risk assessment results; organizational risk management strategy and risk tolerance.

Expected Outputs: A plan of action and milestones detailing the findings from the security and privacy assessment reports that are to be remediated.

Primary Responsibility: System Owner; Common Control Provider.

Supporting Roles: Information Owner or Steward; System Security Officer; System Privacy Officer; Senior Agency Information Security Officer; Senior Agency Official for Privacy; Control Assessor; Chief Acquisition Officer.

System Development Life Cycle Phase: New – Implementation/Assessment.

Existing – Operations/Maintenance.

Discussion: The plan of action and milestones is included as part of the authorization package. The plan of action and milestones describes the actions that are planned to correct deficiencies in the controls identified during the assessment of the controls and during continuous monitoring. The plan of action and milestones includes tasks to be accomplished with a recommendation for completion before or after system authorization; resources required to accomplish the tasks; milestones established to meet the tasks; and the scheduled completion dates for the milestones and tasks. The plan of action and milestones is reviewed by the authorizing official to ensure there is agreement with the remediation actions planned to correct the identified deficiencies. It is subsequently used to monitor progress in completing the actions. Deficiencies are accepted by the authorizing official as residual risk or are remediated during the assessment or prior to submission of the authorization package to the authorizing official. Plan of action and milestones entries are not necessary when deficiencies are accepted by the authorizing official as residual risk. However, deficiencies identified during assessment and monitoring are documented in the assessment reports, which can be retained within an automated security/privacy management and reporting tool to maintain an effective audit trail. Organizations develop plans of action and milestones based on assessment results obtained from control assessments, audits, and continuous monitoring and in accordance with applicable laws, executive orders, directives, policies, regulations, standards, or guidance.

Organizations implement a consistent process for developing plans of action and milestones that uses a prioritized approach to risk mitigation that is uniform across the organization. A risk assessment guides the prioritization process for items included in the plan of action and milestones. The process ensures that plans of action and milestones are informed by the security categorization of the system and security, privacy, and supply chain risk assessments; the specific deficiencies in the controls; the criticality of the identified control deficiencies (i.e., the direct or indirect effect that the deficiencies may have on the security and privacy posture of the system, and therefore, on the risk exposure of the organization; or the ability of the organization to perform its mission or business functions); and the proposed risk mitigation approach to address the identified deficiencies in the controls (e.g., prioritization of risk mitigation actions and allocation of risk mitigation resources). Risk mitigation resources include, for example, personnel, new hardware or software, and tools.

References: [SP 800-30]; [SP 800-53A]; [SP 800-160 v1] (Verification and Validation Processes); [IR 8062].

The purpose of the Authorize step is to provide organizational accountability by requiring a senior management official to determine if the security and privacy risk (including supply chain risk) to organizational operations and assets, individuals, other organizations, or the Nation based on the operation of a system or the use of common controls, is acceptable.

Table 7 provides a summary of tasks and expected outcomes for the RMF Authorize step. Applicable Cybersecurity Framework constructs are also provided.

TABLE 7: AUTHORIZE TASKS AND OUTCOMES

Quick link to summary table for RMF tasks, responsibilities, and supporting roles.

TASK R-1 Assemble the authorization package and submit the package to the authorizing official for an authorization decision.

Potential Inputs: Security and privacy plans; security and privacy assessment reports; plan of action and milestones; supporting assessment evidence or other documentation, as required.

Expected Outputs: Authorization package (with an executive summary), which may be generated from a security or privacy management tool⁹⁴ for submission to the authorizing official.

Primary Responsibility: System Owner; Common Control Provider; Senior Agency Official for Privacy.⁹⁵

Supporting Roles: System Security Officer; System Privacy Officer; Senior Agency Information Security Officer; Control Assessor.

System Development Life Cycle Phase: New – Implementation/Assessment.

Existing – Operations/Maintenance.

Discussion: Authorization packages⁹⁶ include security and privacy plans, security and privacy assessment reports, plans of action and milestones, and an executive summary. Additional information can be included in the authorization package at the request of the authorizing official. Organizations maintain version and change control as the information in the authorization package is updated. Providing timely updates to the plans, assessment reports, and plans of action and milestones on an ongoing basis supports the concept of near real-time risk management and ongoing authorization, and can be used for reauthorization actions, if required.

The senior agency official for privacy reviews the authorization package for systems that process PII to ensure compliance with applicable privacy requirements and to manage privacy risks, prior to authorizing officials making risk determination and acceptance decisions.

The information in the authorization package is used by authorizing officials to make informed, risk-based decisions. When controls are implemented by an external provider through contracts, interagency agreements, lines of business arrangements, licensing agreements, or supply chain arrangements, the organization ensures that the information needed to make risk-based decisions is made available by the provider.

The authorization package may be provided to the authorizing official in hard copy or electronically or may be generated using an automated security/privacy management and reporting tool. Organizations can use automated support tools in preparing and managing the content of the authorization package. Automated support tools provide an effective vehicle for maintaining and updating information for authorizing officials regarding the ongoing security and privacy posture of information systems within the organization.

When an information system is under ongoing authorization, the authorization package is presented to the authorizing official via automated reports to provide information in the most efficient and timely manner possible.⁹⁷ Information to be presented to the authorizing official in assessment reports is generated in the format and with the frequency determined by the organization using information from the information security and privacy continuous monitoring programs.

The assessment reports presented to the authorizing official include information about deficiencies in system-specific, hybrid, and common controls (i.e., other than satisfied findings determined by assessors). The authorizing official uses automated security/privacy management and reporting tools or other automated methods, whenever practicable, to access the security and privacy plans and the plans of action and milestones. The authorization documents are updated at an organization-defined frequency using automated or manual processes in accordance with the risk management objectives of the organization.⁹⁸

References: [OMB A-130]; [SP 800-18]; [SP 800-160 v1] (Risk Management Process); [SP 800-161] (SCRM Plans).

TASK R-2 Analyze and determine the risk from the operation or use of the system or the provision of common controls.

Potential Inputs: Authorization package; supporting assessment evidence or other documentation as required; information provided by the senior accountable official for risk management or risk executive (function); organizational risk management strategy and risk tolerance; organization- and system-level risk assessment results.

Expected Outputs: Risk determination.

Primary Responsibility: Authorizing Official or Authorizing Official Designated Representative.

Supporting Roles: Senior Accountable Official for Risk Management or Risk Executive (Function); Senior Agency Information Security Officer; Senior Agency Official for Privacy.

System Development Life Cycle Phase: New – Implementation/Assessment.

Existing – Operations/Maintenance.

Discussion: The authorizing official or designated representative, in collaboration with the senior agency information security officer and the senior agency official for privacy (for information systems processing PII), analyzes the information in the authorization package provided by the control assessor, system owner, or common control provider, and finalizes the determination of risk. Further discussion with the control assessor, system owner, or common control provider may be necessary to help ensure a thorough understanding of risk by the authorizing official.

Risk assessments are employed to provide information⁹⁹ that may influence the risk analysis and determination. The senior accountable official for risk management or risk executive (function) may provide additional information to the authorizing official that is considered in the final determination of risk to organizational operations and assets, individuals, other organizations, and the Nation resulting from either the operation or use of the system or the provision of common controls. The additional information may include, for example, organizational risk tolerance, dependencies among systems and controls, mission and business requirements, the criticality of the missions or business functions supported by the system, or the risk management strategy.

The authorizing official analyzes the information provided by the senior accountable official for risk management or risk executive (function) and information provided by the system owner or common control provider in the authorization package when making a risk determination. Any additional information provided by the senior accountable official for risk management or risk executive (function) is documented and included, to the extent it is relevant, as part of the authorization decision (see Task R-4). The authorizing official may also use an automated security/privacy management and reporting tool to annotate senior accountable official for risk management or risk executive (function) input.

When the system is operating under an ongoing authorization, the risk determination task is effectively unchanged. The authorizing official analyzes the relevant security and privacy information provided by the automated security/privacy management and reporting tool to determine the current security and privacy posture of the system.

References: [OMB A-130]; [SP 800-30]; [SP 800-39] (Organization, Mission/Business Process, and System Levels); [SP 800-137]; [SP 800-160 v1] (Risk Management Process); [IR 8062].

TASK R-3 Identify and implement a preferred course of action in response to the risk determined.

Potential Inputs: Authorization package; risk determination; organization- and system-level risk assessment results.

Expected Outputs: Risk responses for determined risks.

Primary Responsibility: Authorizing Official or Authorizing Official Designated Representative.

Supporting Roles: Senior Accountable Official for Risk Management or Risk Executive (Function); Senior Agency Information Security Officer; Senior Agency Official for Privacy; System Owner or Common Control Provider; Information Owner or Steward; Systems Security Engineer; Privacy Engineer; System Security Officer; System Privacy Officer.

System Development Life Cycle Phase: New – Implementation/Assessment.

Existing – Operations/Maintenance.

Discussion: After risk is analyzed and determined, organizations can respond to risk in a variety of ways, including acceptance of risk and mitigation of risk. Existing risk assessment results and risk assessment techniques may be used to help determine the preferred course of action for the risk response.¹⁰⁰ When the response to risk is mitigation, the planned mitigation actions are included in and tracked using the plan of action and milestones. Once mitigated, assessors reassess the controls. Control reassessments determine the extent to which remediated controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security and privacy requirements for the system and the organization. The assessors update the assessment reports with the findings from the reassessment, but do not change the original assessment results. The security and privacy plans are updated based on the findings of the control assessments and any remediation actions taken. The updated plans reflect the state of the controls after the initial assessment and any modifications by the system owner or common control provider in addressing recommendations for corrective actions.

At the completion of the control reassessments, security and privacy plans contain an accurate description of implemented controls, including compensating controls. When the response to risk is acceptance, the deficiencies found during the assessment process remain documented in the security and privacy assessment reports and are monitored for changes to the risk factors.¹⁰¹ Because the authorizing official is the only person who can accept risk, the authorizing official is responsible for reviewing the assessment reports and plans of action and milestones and determining whether the identified risks need to be mitigated prior to authorization. Decisions on the most appropriate course of action for responding to risk may include some form of prioritization. Some risks may be of greater concern to organizations than other risks. In that case, more resources may need to be directed at addressing higher-priority risks versus lower-priority risks. Prioritizing risk response does not necessarily mean that the lower-priority risks are ignored. Rather, it could mean that fewer resources are directed at addressing the lower-priority risks, or that the lower-priority risks are addressed later. A key part of the risk-based decision process is the recognition that regardless of the risk response, there remains a degree of residual risk. Organizations determine acceptable degrees of residual risk based on organizational risk tolerance.

References: [SP 800-30]; [SP 800-39] (Organization, Mission/Business Process, and System Levels); [SP 800-160 v1] (Risk Management Process); [IR 8062]; [IR 8179]; [NIST CSF] (Core [Identify Function]).

TASK R-4 Determine if the risk from the operation or use of the information system or the provision or use of common controls is acceptable.

Potential Inputs: Risk responses for determined risks.