Risk Management Framework Rev. 5

Access control policy and procedures address the controls in the AC family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of access control policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies reflecting the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to access control policy and procedures include assessment or audit findings, security incidents or breaches, or changes in laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.

Examples of system account types include individual, shared, group, system, guest, anonymous, emergency, developer, temporary, and service. Identification of authorized system users and the specification of access privileges reflect the requirements in other controls in the security plan. Users requiring administrative privileges on system accounts receive additional scrutiny by organizational personnel responsible for approving such accounts and privileged access, including system owner, mission or business owner, senior agency information security officer, or senior agency official for privacy. Types of accounts that organizations may wish to prohibit due to increased risk include shared, group, emergency, anonymous, temporary, and guest accounts. Where access involves personally identifiable information, security programs collaborate with the senior agency official for privacy to establish the specific conditions for group and role membership; specify authorized users, group and role membership, and access authorizations for each account; and create, adjust, or remove system accounts in accordance with organizational policies. Policies can include such information as account expiration dates or other factors that trigger the disabling of accounts. Organizations may choose to define access privileges or other attributes by account, type of account, or a combination of the two. Examples of other attributes required for authorizing access include restrictions on time of day, day of week, and point of origin. In defining other system account attributes, organizations consider system-related requirements and mission/business requirements. Failure to consider these factors could affect system availability. Temporary and emergency accounts are intended for short-term use. Organizations establish temporary accounts as part of normal account activation procedures when there is a need for short-term accounts without the demand for immediacy in account activation. Organizations establish emergency accounts in response to crisis situations and with the need for rapid account activation. Therefore, emergency account activation may bypass normal account authorization processes. Emergency and temporary accounts are not to be confused with infrequently used accounts, including local logon accounts used for special tasks or when network resources are unavailable (may also be known as accounts of last resort). Such accounts remain available and are not subject to automatic disabling or removal dates. Conditions for disabling or deactivating accounts include when shared/group, emergency, or temporary accounts are no longer required and when individuals are transferred or terminated. Changing shared/group authenticators when members leave the group is intended to ensure that former group members do not retain access to the shared or group account. Some types of system accounts may require specialized training.

Access control policies control access between active entities or subjects (i.e., users or processes acting on behalf of users) and passive entities or objects (i.e., devices, files, records, domains) in organizational systems. In addition to enforcing authorized access at the system level and recognizing that systems can host many applications and services in support of mission and business functions, access enforcement mechanisms can also be employed at the application and service level to provide increased information security and privacy. In contrast to logical access controls that are implemented within the system, physical access controls are addressed by the controls in the Physical and Environmental Protection (PE) family.

Information flow control regulates where information can travel within a system and between systems (in contrast to who is allowed to access the information) and without regard to subsequent accesses to that information. Flow control restrictions include blocking external traffic that claims to be from within the organization, keeping export-controlled information from being transmitted in the clear to the Internet, restricting web requests that are not from the internal web proxy server, and limiting information transfers between organizations based on data structures and content. Transferring information between organizations may require an agreement specifying how the information flow is enforced (see CA-3). Transferring information between systems in different security or privacy domains with different security or privacy policies introduces the risk that such transfers violate one or more domain security or privacy policies. In such situations, information owners/stewards provide guidance at designated policy enforcement points between connected systems. Organizations consider mandating specific architectural solutions to enforce specific security and privacy policies. Enforcement includes prohibiting information transfers between connected systems (i.e., allowing access only), verifying write permissions before accepting information from another security or privacy domain or connected system, employing hardware mechanisms to enforce one-way information flows, and implementing trustworthy regrading mechanisms to reassign security or privacy attributes and labels. Organizations commonly employ information flow control policies and enforcement mechanisms to control the flow of information between designated sources and destinations within systems and between connected systems. Flow control is based on the characteristics of the information and/or the information path. Enforcement occurs, for example, in boundary protection devices that employ rule sets or establish configuration settings that restrict system services, provide a packet-filtering capability based on header information, or provide a message-filtering capability based on message content. Organizations also consider the trustworthiness of filtering and/or inspection mechanisms (i.e., hardware, firmware, and software components) that are critical to information flow enforcement. Control enhancements 3 through 32 primarily address cross-domain solution needs that focus on more advanced filtering techniques, in-depth analysis, and stronger flow enforcement mechanisms implemented in cross-domain products, such as high-assurance guards. Such capabilities are generally not available in commercial off-the-shelf products. Information flow enforcement also applies to control plane traffic (e.g., routing and DNS).

Separation of duties addresses the potential for abuse of authorized privileges and helps to reduce the risk of malevolent activity without collusion. Separation of duties includes dividing mission or business functions and support functions among different individuals or roles, conducting system support functions with different individuals, and ensuring that security personnel who administer access control functions do not also administer audit functions. Because separation of duty violations can span systems and application domains, organizations consider the entirety of systems and system components when developing policy on separation of duties. Separation of duties is enforced through the account management activities in AC-2, access control mechanisms in AC-3, and identity management activities in IA-2, IA-4, and IA-12.

Organizations employ least privilege for specific duties and systems. The principle of least privilege is also applied to system processes, ensuring that the processes have access to systems and operate at privilege levels no higher than necessary to accomplish organizational missions or business functions. Organizations consider the creation of additional processes, roles, and accounts as necessary to achieve least privilege. Organizations apply least privilege to the development, implementation, and operation of organizational systems.

The need to limit unsuccessful logon attempts and take subsequent action when the maximum number of attempts is exceeded applies regardless of whether the logon occurs via a local or network connection. Due to the potential for denial of service, automatic lockouts initiated by systems are usually temporary and automatically release after a predetermined, organization-defined time period. If a delay algorithm is selected, organizations may employ different algorithms for different components of the system based on the capabilities of those components. Responses to unsuccessful logon attempts may be implemented at the operating system and the application levels. Organization-defined actions that may be taken when the number of allowed consecutive invalid logon attempts is exceeded include prompting the user to answer a secret question in addition to the username and password, invoking a lockdown mode with limited user capabilities (instead of full lockout), allowing users to only logon from specified Internet Protocol (IP) addresses, requiring a CAPTCHA to prevent automated attacks, or applying user profiles such as location, time of day, IP address, device, or Media Access Control (MAC) address. If automatic system lockout or execution of a delay algorithm is not implemented in support of the availability objective, organizations consider a combination of other actions to help prevent brute force attacks. In addition to the above, organizations can prompt users to respond to a secret question before the number of allowed unsuccessful logon attempts is exceeded. Automatically unlocking an account after a specified period of time is generally not permitted. However, exceptions may be required based on operational mission or need.

System use notifications can be implemented using messages or warning banners displayed before individuals log in to systems. System use notifications are used only for access via logon interfaces with human users. Notifications are not required when human interfaces do not exist. Based on an assessment of risk, organizations consider whether or not a secondary system use notification is needed to access applications or other system resources after the initial network logon. Organizations consider system use notification messages or banners displayed in multiple languages based on organizational needs and the demographics of system users. Organizations consult with the privacy office for input regarding privacy messaging and the Office of the General Counsel or organizational equivalent for legal review and approval of warning banner content.

Previous logon notification is applicable to system access via human user interfaces and access to systems that occurs in other types of architectures. Information about the last successful logon allows the user to recognize if the date and time provided is not consistent with the user’s last access.

Organizations may define the maximum number of concurrent sessions for system accounts globally, by account type, by account, or any combination thereof. For example, organizations may limit the number of concurrent sessions for system administrators or other individuals working in particularly sensitive domains or mission-critical applications. Concurrent session control addresses concurrent sessions for system accounts. It does not, however, address concurrent sessions by single users via multiple system accounts.

Device locks are temporary actions taken to prevent logical access to organizational systems when users stop work and move away from the immediate vicinity of those systems but do not want to log out because of the temporary nature of their absences. Device locks can be implemented at the operating system level or at the application level. A proximity lock may be used to initiate the device lock (e.g., via a Bluetooth-enabled device or dongle). User-initiated device locking is behavior or policy-based and, as such, requires users to take physical action to initiate the device lock. Device locks are not an acceptable substitute for logging out of systems, such as when organizations require users to log out at the end of workdays.

Session termination addresses the termination of user-initiated logical sessions (in contrast to SC-10, which addresses the termination of network connections associated with communications sessions (i.e., network disconnect)). A logical session (for local, network, and remote access) is initiated whenever a user (or process acting on behalf of a user) accesses an organizational system. Such user sessions can be terminated without terminating network sessions. Session termination ends all processes associated with a user’s logical session except for those processes that are specifically created by the user (i.e., session owner) to continue after the session is terminated. Conditions or trigger events that require automatic termination of the session include organization-defined periods of user inactivity, targeted responses to certain types of incidents, or time-of-day restrictions on system use.

Specific user actions may be permitted without identification or authentication if organizations determine that identification and authentication are not required for the specified user actions. Organizations may allow a limited number of user actions without identification or authentication, including when individuals access public websites or other publicly accessible federal systems, when individuals use mobile phones to receive calls, or when facsimiles are received. Organizations identify actions that normally require identification or authentication but may, under certain circumstances, allow identification or authentication mechanisms to be bypassed. Such bypasses may occur, for example, via a software-readable physical switch that commands bypass of the logon functionality and is protected from accidental or unmonitored use. Permitting actions without identification or authentication does not apply to situations where identification and authentication have already occurred and are not repeated but rather to situations where identification and authentication have not yet occurred. Organizations may decide that there are no user actions that can be performed on organizational systems without identification and authentication, and therefore, the value for the assignment operation can be none.

Information is represented internally within systems using abstractions known as data structures. Internal data structures can represent different types of entities, both active and passive. Active entities, also known as subjects, are typically associated with individuals, devices, or processes acting on behalf of individuals. Passive entities, also known as objects, are typically associated with data structures, such as records, buffers, tables, files, inter-process pipes, and communications ports. Security attributes, a form of metadata, are abstractions that represent the basic properties or characteristics of active and passive entities with respect to safeguarding information. Privacy attributes, which may be used independently or in conjunction with security attributes, represent the basic properties or characteristics of active or passive entities with respect to the management of personally identifiable information. Attributes can be either explicitly or implicitly associated with the information contained in organizational systems or system components. Attributes may be associated with active entities (i.e., subjects) that have the potential to send or receive information, cause information to flow among objects, or change the system state. These attributes may also be associated with passive entities (i.e., objects) that contain or receive information. The association of attributes to subjects and objects by a system is referred to as binding and is inclusive of setting the attribute value and the attribute type. Attributes, when bound to data or information, permit the enforcement of security and privacy policies for access control and information flow control, including data retention limits, permitted uses of personally identifiable information, and identification of personal information within data objects. Such enforcement occurs through organizational processes or system functions or mechanisms. The binding techniques implemented by systems affect the strength of attribute binding to information. Binding strength and the assurance associated with binding techniques play important parts in the trust that organizations have in the information flow enforcement process. The binding techniques affect the number and degree of additional reviews required by organizations. The content or assigned values of attributes can directly affect the ability of individuals to access organizational information. Organizations can define the types of attributes needed for systems to support missions or business functions. There are many values that can be assigned to a security attribute. By specifying the permitted attribute ranges and values, organizations ensure that attribute values are meaningful and relevant. Labeling refers to the association of attributes with the subjects and objects represented by the internal data structures within systems. This facilitates system-based enforcement of information security and privacy policies. Labels include classification of information in accordance with legal and compliance requirements (e.g., top secret, secret, confidential, controlled unclassified), information impact level; high value asset information, access authorizations, nationality; data life cycle protection (i.e., encryption and data expiration), personally identifiable information processing permissions, including individual consent to personally identifiable information processing, and contractor affiliation. A related term to labeling is marking. Marking refers to the association of attributes with objects in a human-readable form and displayed on system media. Marking enables manual, procedural, or process-based enforcement of information security and privacy policies. Security and privacy labels may have the same value as media markings (e.g., top secret, secret, confidential). See MP-3 (Media Marking).

Remote access is access to organizational systems (or processes acting on behalf of users) that communicate through external networks such as the Internet. Types of remote access include dial-up, broadband, and wireless. Organizations use encrypted virtual private networks (VPNs) to enhance confidentiality and integrity for remote connections. The use of encrypted VPNs provides sufficient assurance to the organization that it can effectively treat such connections as internal networks if the cryptographic mechanisms used are implemented in accordance with applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Still, VPN connections traverse external networks, and the encrypted VPN does not enhance the availability of remote connections. VPNs with encrypted tunnels can also affect the ability to adequately monitor network communications traffic for malicious code. Remote access controls apply to systems other than public web servers or systems designed for public access. Authorization of each remote access type addresses authorization prior to allowing remote access without specifying the specific formats for such authorization. While organizations may use information exchange and system connection security agreements to manage remote access connections to other systems, such agreements are addressed as part of CA-3. Enforcing access restrictions for remote access is addressed via AC-3.

Wireless technologies include microwave, packet radio (ultra-high frequency or very high frequency), 802.11x, and Bluetooth. Wireless networks use authentication protocols that provide authenticator protection and mutual authentication.

A mobile device is a computing device that has a small form factor such that it can easily be carried by a single individual; is designed to operate without a physical connection; possesses local, non-removable or removable data storage; and includes a self-contained power source. Mobile device functionality may also include voice communication capabilities, on-board sensors that allow the device to capture information, and/or built-in features for synchronizing local data with remote locations. Examples include smart phones and tablets. Mobile devices are typically associated with a single individual. The processing, storage, and transmission capability of the mobile device may be comparable to or merely a subset of notebook/desktop systems, depending on the nature and intended purpose of the device. Protection and control of mobile devices is behavior or policy-based and requires users to take physical action to protect and control such devices when outside of controlled areas. Controlled areas are spaces for which organizations provide physical or procedural controls to meet the requirements established for protecting information and systems. Due to the large variety of mobile devices with different characteristics and capabilities, organizational restrictions may vary for the different classes or types of such devices. Usage restrictions and specific implementation guidance for mobile devices include configuration management, device identification and authentication, implementation of mandatory protective software, scanning devices for malicious code, updating virus protection software, scanning for critical software updates and patches, conducting primary operating system (and possibly other resident software) integrity checks, and disabling unnecessary hardware. Usage restrictions and authorization to connect may vary among organizational systems. For example, the organization may authorize the connection of mobile devices to its network and impose a set of usage restrictions, while a system owner may withhold authorization for mobile device connection to specific applications or impose additional usage restrictions before allowing mobile device connections to a system. Adequate security for mobile devices goes beyond the requirements specified in AC-19. Many safeguards for mobile devices are reflected in other controls. AC-20 addresses mobile devices that are not organization-controlled.

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

Information sharing applies to information that may be restricted in some manner based on some formal or administrative determination. Examples of such information include, contract-sensitive information, classified information related to special access programs or compartments, privileged information, proprietary information, and personally identifiable information. Security and privacy risk assessments as well as applicable laws, regulations, and policies can provide useful inputs to these determinations. Depending on the circumstances, sharing partners may be defined at the individual, group, or organizational level. Information may be defined by content, type, security category, or special access program or compartment. Access restrictions may include non-disclosure agreements (NDA). Information flow techniques and security attributes may be used to provide automated assistance to users making sharing and collaboration decisions.

In accordance with applicable laws, executive orders, directives, policies, regulations, standards, and guidelines, the public is not authorized to have access to nonpublic information, including information protected under the PRIVACT and proprietary information. Publicly accessible content addresses systems that are controlled by the organization and accessible to the public, typically without identification or authentication. Posting information on non-organizational systems (e.g., non-organizational public websites, forums, and social media) is covered by organizational policy. While organizations may have individuals who are responsible for developing and implementing policies about the information that can be made publicly accessible, publicly accessible content addresses the management of the individuals who make such information publicly accessible.

Data mining is an analytical process that attempts to find correlations or patterns in large data sets for the purpose of data or knowledge discovery. Data storage objects include database records and database fields. Sensitive information can be extracted from data mining operations. When information is personally identifiable information, it may lead to unanticipated revelations about individuals and give rise to privacy risks. Prior to performing data mining activities, organizations determine whether such activities are authorized. Organizations may be subject to applicable laws, executive orders, directives, regulations, or policies that address data mining requirements. Organizational personnel consult with the senior agency official for privacy and legal counsel regarding such requirements. Data mining prevention and detection techniques include limiting the number and frequency of database queries to increase the work factor needed to determine the contents of databases, limiting types of responses provided to database queries, applying differential privacy techniques or homomorphic encryption, and notifying personnel when atypical database queries or accesses occur. Data mining protection focuses on protecting information from data mining while such information resides in organizational data stores. In contrast, AU-13 focuses on monitoring for organizational information that may have been mined or otherwise obtained from data stores and is available as open-source information residing on external sites, such as social networking or social media websites. EO 13587 requires the establishment of an insider threat program for deterring, detecting, and mitigating insider threats, including the safeguarding of sensitive information from exploitation, compromise, or other unauthorized disclosure. Data mining protection requires organizations to identify appropriate techniques to prevent and detect unnecessary or unauthorized data mining. Data mining can be used by an insider to collect organizational information for the purpose of exfiltration.

Access control decisions (also known as authorization decisions) occur when authorization information is applied to specific accesses. In contrast, access enforcement occurs when systems enforce access control decisions. While it is common to have access control decisions and access enforcement implemented by the same entity, it is not required, and it is not always an optimal implementation choice. For some architectures and distributed systems, different entities may make access control decisions and enforce access.

A reference monitor is a set of design requirements on a reference validation mechanism that, as a key component of an operating system, enforces an access control policy over all subjects and objects. A reference validation mechanism is always invoked, tamper-proof, and small enough to be subject to analysis and tests, the completeness of which can be assured (i.e., verifiable). Information is represented internally within systems using abstractions known as data structures. Internal data structures can represent different types of entities, both active and passive. Active entities, also known as subjects, are associated with individuals, devices, or processes acting on behalf of individuals. Passive entities, also known as objects, are associated with data structures, such as records, buffers, communications ports, tables, files, and inter-process pipes. Reference monitors enforce access control policies that restrict access to objects based on the identity of subjects or groups to which the subjects belong. The system enforces the access control policy based on the rule set established by the policy. The tamper-proof property of the reference monitor prevents determined adversaries from compromising the functioning of the reference validation mechanism. The always invoked property prevents adversaries from bypassing the mechanism and violating the security policy. The smallness property helps to ensure completeness in the analysis and testing of the mechanism to detect any weaknesses or deficiencies (i.e., latent flaws) that would prevent the enforcement of the security policy.

Awareness and training policy and procedures address the controls in the AT family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of awareness and training policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to awareness and training policy and procedures include assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.

Organizations provide basic and advanced levels of literacy training to system users, including measures to test the knowledge level of users. Organizations determine the content of literacy training and awareness based on specific organizational requirements, the systems to which personnel have authorized access, and work environments (e.g., telework). The content includes an understanding of the need for security and privacy as well as actions by users to maintain security and personal privacy and to respond to suspected incidents. The content addresses the need for operations security and the handling of personally identifiable information. Awareness techniques include displaying posters, offering supplies inscribed with security and privacy reminders, displaying logon screen messages, generating email advisories or notices from organizational officials, and conducting awareness events. Literacy training after the initial training described in AT-2a.1 is conducted at a minimum frequency consistent with applicable laws, directives, regulations, and policies. Subsequent literacy training may be satisfied by one or more short ad hoc sessions and include topical information on recent attack schemes, changes to organizational security and privacy policies, revised security and privacy expectations, or a subset of topics from the initial training. Updating literacy training and awareness content on a regular basis helps to ensure that the content remains relevant. Events that may precipitate an update to literacy training and awareness content include, but are not limited to, assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines.

Organizations determine the content of training based on the assigned roles and responsibilities of individuals as well as the security and privacy requirements of organizations and the systems to which personnel have authorized access, including technical training specifically tailored for assigned duties. Roles that may require role-based training include senior leaders or management officials (e.g., head of agency/chief executive officer, chief information officer, senior accountable official for risk management, senior agency information security officer, senior agency official for privacy), system owners; authorizing officials; system security officers; privacy officers; acquisition and procurement officials; enterprise architects; systems engineers; software developers; systems security engineers; privacy engineers; system, network, and database administrators; auditors; personnel conducting configuration management activities; personnel performing verification and validation activities; personnel with access to system-level software; control assessors; personnel with contingency planning and incident response duties; personnel with privacy management responsibilities; and personnel with access to personally identifiable information. Comprehensive role-based training addresses management, operational, and technical roles and responsibilities covering physical, personnel, and technical controls. Role-based training also includes policies, procedures, tools, methods, and artifacts for the security and privacy roles defined. Organizations provide the training necessary for individuals to fulfill their responsibilities related to operations and supply chain risk management within the context of organizational security and privacy programs. Role-based training also applies to contractors who provide services to federal agencies. Types of training include web-based and computer-based training, classroom-style training, and hands-on training (including micro-training). Updating role-based training on a regular basis helps to ensure that the content remains relevant and effective. Events that may precipitate an update to role-based training content include, but are not limited to, assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines.

Documentation for specialized training may be maintained by individual supervisors at the discretion of the organization. The National Archives and Records Administration provides guidance on records retention for federal agencies.

Training feedback includes awareness training results and role-based training results. Training results, especially failures of personnel in critical roles, can be indicative of a potentially serious problem. Therefore, it is important that senior managers are made aware of such situations so that they can take appropriate response actions. Training feedback supports the evaluation and update of organizational training described in AT-2b and AT-3b.

Audit and accountability policy and procedures address the controls in the AU family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of audit and accountability policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to audit and accountability policy and procedures include assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.

An event is an observable occurrence in a system. The types of events that require logging are those events that are significant and relevant to the security of systems and the privacy of individuals. Event logging also supports specific monitoring and auditing needs. Event types include password changes, failed logons or failed accesses related to systems, security or privacy attribute changes, administrative privilege usage, PIV credential usage, data action changes, query parameters, or external credential usage. In determining the set of event types that require logging, organizations consider the monitoring and auditing appropriate for each of the controls to be implemented. For completeness, event logging includes all protocols that are operational and supported by the system. To balance monitoring and auditing requirements with other system needs, event logging requires identifying the subset of event types that are logged at a given point in time. For example, organizations may determine that systems need the capability to log every file access successful and unsuccessful, but not activate that capability except for specific circumstances due to the potential burden on system performance. The types of events that organizations desire to be logged may change. Reviewing and updating the set of logged events is necessary to help ensure that the events remain relevant and continue to support the needs of the organization. Organizations consider how the types of logging events can reveal information about individuals that may give rise to privacy risk and how best to mitigate such risks. For example, there is the potential to reveal personally identifiable information in the audit trail, especially if the logging event is based on patterns or time of usage. Event logging requirements, including the need to log specific event types, may be referenced in other controls and control enhancements. These include AC-2(4), AC-3(10), AC-6(9), AC-17(1), CM-3f, CM-5(1), IA-3(3)(b), MA-4(1), MP-4(2), PE-3, PM-21, PT-7, RA-8, SC-7(9), SC-7(15), SI-3(8), SI-4(22), SI-7(8), and SI-10(1). Organizations include event types that are required by applicable laws, executive orders, directives, policies, regulations, standards, and guidelines. Audit records can be generated at various levels, including at the packet level as information traverses the network. Selecting the appropriate level of event logging is an important part of a monitoring and auditing capability and can identify the root causes of problems. When defining event types, organizations consider the logging necessary to cover related event types, such as the steps in distributed, transaction-based processes and the actions that occur in service-oriented architectures.

Audit record content that may be necessary to support the auditing function includes event descriptions (item a), time stamps (item b), source and destination addresses (item c), user or process identifiers (items d and f), success or fail indications (item e), and filenames involved (items a, c, e, and f) . Event outcomes include indicators of event success or failure and event-specific results, such as the system security and privacy posture after the event occurred. Organizations consider how audit records can reveal information about individuals that may give rise to privacy risks and how best to mitigate such risks. For example, there is the potential to reveal personally identifiable information in the audit trail, especially if the trail records inputs or is based on patterns or time of usage.

Organizations consider the types of audit logging to be performed and the audit log processing requirements when allocating audit log storage capacity. Allocating sufficient audit log storage capacity reduces the likelihood of such capacity being exceeded and resulting in the potential loss or reduction of audit logging capability.

Audit logging process failures include software and hardware errors, failures in audit log capturing mechanisms, and reaching or exceeding audit log storage capacity. Organization-defined actions include overwriting oldest audit records, shutting down the system, and stopping the generation of audit records. Organizations may choose to define additional actions for audit logging process failures based on the type of failure, the location of the failure, the severity of the failure, or a combination of such factors. When the audit logging process failure is related to storage, the response is carried out for the audit log storage repository (i.e., the distinct system component where the audit logs are stored), the system on which the audit logs reside, the total audit log storage capacity of the organization (i.e., all audit log storage repositories combined), or all three. Organizations may decide to take no additional actions after alerting designated roles or personnel.

Audit record review, analysis, and reporting covers information security- and privacy-related logging performed by organizations, including logging that results from the monitoring of account usage, remote access, wireless connectivity, mobile device connection, configuration settings, system component inventory, use of maintenance tools and non-local maintenance, physical access, temperature and humidity, equipment delivery and removal, communications at system interfaces, and use of mobile code or Voice over Internet Protocol (VoIP). Findings can be reported to organizational entities that include the incident response team, help desk, and security or privacy offices. If organizations are prohibited from reviewing and analyzing audit records or unable to conduct such activities, the review or analysis may be carried out by other organizations granted such authority. The frequency, scope, and/or depth of the audit record review, analysis, and reporting may be adjusted to meet organizational needs based on new information received.

Audit record reduction is a process that manipulates collected audit log information and organizes it into a summary format that is more meaningful to analysts. Audit record reduction and report generation capabilities do not always emanate from the same system or from the same organizational entities that conduct audit logging activities. The audit record reduction capability includes modern data mining techniques with advanced data filters to identify anomalous behavior in audit records. The report generation capability provided by the system can generate customizable reports. Time ordering of audit records can be an issue if the granularity of the timestamp in the record is insufficient.

Time stamps generated by the system include date and time. Time is commonly expressed in Coordinated Universal Time (UTC), a modern continuation of Greenwich Mean Time (GMT), or local time with an offset from UTC. Granularity of time measurements refers to the degree of synchronization between system clocks and reference clocks (e.g., clocks synchronizing within hundreds of milliseconds or tens of milliseconds). Organizations may define different time granularities for different system components. Time service can be critical to other security capabilities such as access control and identification and authentication, depending on the nature of the mechanisms used to support those capabilities.

Audit information includes all information needed to successfully audit system activity, such as audit records, audit log settings, audit reports, and personally identifiable information. Audit logging tools are those programs and devices used to conduct system audit and logging activities. Protection of audit information focuses on technical protection and limits the ability to access and execute audit logging tools to authorized individuals. Physical protection of audit information is addressed by both media protection controls and physical and environmental protection controls.

Types of individual actions covered by non-repudiation include creating information, sending and receiving messages, and approving information. Non-repudiation protects against claims by authors of not having authored certain documents, senders of not having transmitted messages, receivers of not having received messages, and signatories of not having signed documents. Non-repudiation services can be used to determine if information originated from an individual or if an individual took specific actions (e.g., sending an email, signing a contract, approving a procurement request, or receiving specific information). Organizations obtain non-repudiation services by employing various techniques or mechanisms, including digital signatures and digital message receipts.

Organizations retain audit records until it is determined that the records are no longer needed for administrative, legal, audit, or other operational purposes. This includes the retention and availability of audit records relative to Freedom of Information Act (FOIA) requests, subpoenas, and law enforcement actions. Organizations develop standard categories of audit records relative to such types of actions and standard response processes for each type of action. The National Archives and Records Administration (NARA) General Records Schedules provide federal policy on records retention.

Audit records can be generated from many different system components. The event types specified in AU-2d are the event types for which audit logs are to be generated and are a subset of all event types for which the system can generate audit records.

Unauthorized disclosure of information is a form of data leakage. Open-source information includes social networking sites and code-sharing platforms and repositories. Examples of organizational information include personally identifiable information retained by the organization or proprietary information generated by the organization.

Session audits can include monitoring keystrokes, tracking websites visited, and recording information and/or file transfers. Session audit capability is implemented in addition to event logging and may involve implementation of specialized session capture technology. Organizations consider how session auditing can reveal information about individuals that may give rise to privacy risk as well as how to mitigate those risks. Because session auditing can impact system and network performance, organizations activate the capability under well-defined situations (e.g., the organization is suspicious of a specific individual). Organizations consult with legal counsel, civil liberties officials, and privacy officials to ensure that any legal, privacy, civil rights, or civil liberties issues, including the use of personally identifiable information, are appropriately addressed.

When organizations use systems or services of external organizations, the audit logging capability necessitates a coordinated, cross-organization approach. For example, maintaining the identity of individuals who request specific services across organizational boundaries may often be difficult, and doing so may prove to have significant performance and privacy ramifications. Therefore, it is often the case that cross-organizational audit logging simply captures the identity of individuals who issue requests at the initial system, and subsequent systems record that the requests originated from authorized individuals. Organizations consider including processes for coordinating audit information requirements and protection of audit information in information exchange agreements.

Assessment, authorization, and monitoring policy and procedures address the controls in the CA family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of assessment, authorization, and monitoring policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to assessment, authorization, and monitoring policy and procedures include assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.

Organizations ensure that control assessors possess the required skills and technical expertise to develop effective assessment plans and to conduct assessments of system-specific, hybrid, common, and program management controls, as appropriate. The required skills include general knowledge of risk management concepts and approaches as well as comprehensive knowledge of and experience with the hardware, software, and firmware system components implemented. Organizations assess controls in systems and the environments in which those systems operate as part of initial and ongoing authorizations, continuous monitoring, FISMA annual assessments, system design and development, systems security engineering, privacy engineering, and the system development life cycle. Assessments help to ensure that organizations meet information security and privacy requirements, identify weaknesses and deficiencies in the system design and development process, provide essential information needed to make risk-based decisions as part of authorization processes, and comply with vulnerability mitigation procedures. Organizations conduct assessments on the implemented controls as documented in security and privacy plans. Assessments can also be conducted throughout the system development life cycle as part of systems engineering and systems security engineering processes. The design for controls can be assessed as RFPs are developed, responses assessed, and design reviews conducted. If a design to implement controls and subsequent implementation in accordance with the design are assessed during development, the final control testing can be a simple confirmation utilizing previously completed control assessment and aggregating the outcomes. Organizations may develop a single, consolidated security and privacy assessment plan for the system or maintain separate plans. A consolidated assessment plan clearly delineates the roles and responsibilities for control assessment. If multiple organizations participate in assessing a system, a coordinated approach can reduce redundancies and associated costs. Organizations can use other types of assessment activities, such as vulnerability scanning and system monitoring, to maintain the security and privacy posture of systems during the system life cycle. Assessment reports document assessment results in sufficient detail, as deemed necessary by organizations, to determine the accuracy and completeness of the reports and whether the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting requirements. Assessment results are provided to the individuals or roles appropriate for the types of assessments being conducted. For example, assessments conducted in support of authorization decisions are provided to authorizing officials, senior agency officials for privacy, senior agency information security officers, and authorizing official designated representatives. To satisfy annual assessment requirements, organizations can use assessment results from the following sources: initial or ongoing system authorizations, continuous monitoring, systems engineering processes, or system development life cycle activities. Organizations ensure that assessment results are current, relevant to the determination of control effectiveness, and obtained with the appropriate level of assessor independence. Existing control assessment results can be reused to the extent that the results are still valid and can also be supplemented with additional assessments as needed. After the initial authorizations, organizations assess controls during continuous monitoring. Organizations also establish the frequency for ongoing assessments in accordance with organizational continuous monitoring strategies. External audits, including audits by external entities such as regulatory agencies, are outside of the scope of CA-2.

System information exchange requirements apply to information exchanges between two or more systems. System information exchanges include connections via leased lines or virtual private networks, connections to internet service providers, database sharing or exchanges of database transaction information, connections and exchanges with cloud services, exchanges via web-based services, or exchanges of files via file transfer protocols, network protocols (e.g., IPv4, IPv6), email, or other organization-to-organization communications. Organizations consider the risk related to new or increased threats that may be introduced when systems exchange information with other systems that may have different security and privacy requirements and controls. This includes systems within the same organization and systems that are external to the organization. A joint authorization of the systems exchanging information, as described in CA-6(1) or CA-6(2), may help to communicate and reduce risk. Authorizing officials determine the risk associated with system information exchange and the controls needed for appropriate risk mitigation. The types of agreements selected are based on factors such as the impact level of the information being exchanged, the relationship between the organizations exchanging information (e.g., government to government, government to business, business to business, government or business to service provider, government or business to individual), or the level of access to the organizational system by users of the other system. If systems that exchange information have the same authorizing official, organizations need not develop agreements. Instead, the interface characteristics between the systems (e.g., how the information is being exchanged. how the information is protected) are described in the respective security and privacy plans. If the systems that exchange information have different authorizing officials within the same organization, the organizations can develop agreements or provide the same information that would be provided in the appropriate agreement type from CA-3a in the respective security and privacy plans for the systems. Organizations may incorporate agreement information into formal contracts, especially for information exchanges established between federal agencies and nonfederal organizations (including service providers, contractors, system developers, and system integrators). Risk considerations include systems that share the same networks.

Plans of action and milestones are useful for any type of organization to track planned remedial actions. Plans of action and milestones are required in authorization packages and subject to federal reporting requirements established by OMB.

Authorizations are official management decisions by senior officials to authorize operation of systems, authorize the use of common controls for inheritance by organizational systems, and explicitly accept the risk to organizational operations and assets, individuals, other organizations, and the Nation based on the implementation of agreed-upon controls. Authorizing officials provide budgetary oversight for organizational systems and common controls or assume responsibility for the mission and business functions supported by those systems or common controls. The authorization process is a federal responsibility, and therefore, authorizing officials must be federal employees. Authorizing officials are both responsible and accountable for security and privacy risks associated with the operation and use of organizational systems. Nonfederal organizations may have similar processes to authorize systems and senior officials that assume the authorization role and associated responsibilities. Authorizing officials issue ongoing authorizations of systems based on evidence produced from implemented continuous monitoring programs. Robust continuous monitoring programs reduce the need for separate reauthorization processes. Through the employment of comprehensive continuous monitoring processes, the information contained in authorization packages (i.e., security and privacy plans, assessment reports, and plans of action and milestones) is updated on an ongoing basis. This provides authorizing officials, common control providers, and system owners with an up-to-date status of the security and privacy posture of their systems, controls, and operating environments. To reduce the cost of reauthorization, authorizing officials can leverage the results of continuous monitoring processes to the maximum extent possible as the basis for rendering reauthorization decisions.

Continuous monitoring at the system level facilitates ongoing awareness of the system security and privacy posture to support organizational risk management decisions. The terms continuous and ongoing imply that organizations assess and monitor their controls and risks at a frequency sufficient to support risk-based decisions. Different types of controls may require different monitoring frequencies. The results of continuous monitoring generate risk response actions by organizations. When monitoring the effectiveness of multiple controls that have been grouped into capabilities, a root-cause analysis may be needed to determine the specific control that has failed. Continuous monitoring programs allow organizations to maintain the authorizations of systems and common controls in highly dynamic environments of operation with changing mission and business needs, threats, vulnerabilities, and technologies. Having access to security and privacy information on a continuing basis through reports and dashboards gives organizational officials the ability to make effective and timely risk management decisions, including ongoing authorization decisions. Automation supports more frequent updates to hardware, software, and firmware inventories, authorization packages, and other system information. Effectiveness is further enhanced when continuous monitoring outputs are formatted to provide information that is specific, measurable, actionable, relevant, and timely. Continuous monitoring activities are scaled in accordance with the security categories of systems. Monitoring requirements, including the need for specific monitoring, may be referenced in other controls and control enhancements, such as AC-2g, AC-2(7), AC-2(12)(a), AC-2(7)(b), AC-2(7)(c), AC-17(1), AT-4a, AU-13, AU-13(1), AU-13(2), CM-3f, CM-6d, CM-11c, IR-5, MA-2b, MA-3a, MA-4a, PE-3d, PE-6, PE-14b, PE-16, PE-20, PM-6, PM-23, PM-31, PS-7e, SA-9c, SR-4, SC-5(3)(b), SC-7a, SC-7(24)(b), SC-18b, SC-43b, and SI-4.

Penetration testing is a specialized type of assessment conducted on systems or individual system components to identify vulnerabilities that could be exploited by adversaries. Penetration testing goes beyond automated vulnerability scanning and is conducted by agents and teams with demonstrable skills and experience that include technical expertise in network, operating system, and/or application level security. Penetration testing can be used to validate vulnerabilities or determine the degree of penetration resistance of systems to adversaries within specified constraints. Such constraints include time, resources, and skills. Penetration testing attempts to duplicate the actions of adversaries and provides a more in-depth analysis of security- and privacy-related weaknesses or deficiencies. Penetration testing is especially important when organizations are transitioning from older technologies to newer technologies (e.g., transitioning from IPv4 to IPv6 network protocols). Organizations can use the results of vulnerability analyses to support penetration testing activities. Penetration testing can be conducted internally or externally on the hardware, software, or firmware components of a system and can exercise both physical and technical controls. A standard method for penetration testing includes a pretest analysis based on full knowledge of the system, pretest identification of potential vulnerabilities based on the pretest analysis, and testing designed to determine the exploitability of vulnerabilities. All parties agree to the rules of engagement before commencing penetration testing scenarios. Organizations correlate the rules of engagement for the penetration tests with the tools, techniques, and procedures that are anticipated to be employed by adversaries. Penetration testing may result in the exposure of information that is protected by laws or regulations, to individuals conducting the testing. Rules of engagement, contracts, or other appropriate mechanisms can be used to communicate expectations for how to protect this information. Risk assessments guide the decisions on the level of independence required for the personnel conducting penetration testing.

Internal system connections are connections between organizational systems and separate constituent system components (i.e., connections between components that are part of the same system) including components used for system development. Intra-system connections include connections with mobile devices, notebook and desktop computers, tablets, printers, copiers, facsimile machines, scanners, sensors, and servers. Instead of authorizing each internal system connection individually, organizations can authorize internal connections for a class of system components with common characteristics and/or configurations, including printers, scanners, and copiers with a specified processing, transmission, and storage capability or smart phones and tablets with a specific baseline configuration. The continued need for an internal system connection is reviewed from the perspective of whether it provides support for organizational missions or business functions.

Configuration management policy and procedures address the controls in the CM family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of configuration management policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission/business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to configuration management policy and procedures include, but are not limited to, assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.

Baseline configurations for systems and system components include connectivity, operational, and communications aspects of systems. Baseline configurations are documented, formally reviewed, and agreed-upon specifications for systems or configuration items within those systems. Baseline configurations serve as a basis for future builds, releases, or changes to systems and include security and privacy control implementations, operational procedures, information about system components, network topology, and logical placement of components in the system architecture. Maintaining baseline configurations requires creating new baselines as organizational systems change over time. Baseline configurations of systems reflect the current enterprise architecture.

Configuration change control for organizational systems involves the systematic proposal, justification, implementation, testing, review, and disposition of system changes, including system upgrades and modifications. Configuration change control includes changes to baseline configurations, configuration items of systems, operational procedures, configuration settings for system components, remediate vulnerabilities, and unscheduled or unauthorized changes. Processes for managing configuration changes to systems include Configuration Control Boards or Change Advisory Boards that review and approve proposed changes. For changes that impact privacy risk, the senior agency official for privacy updates privacy impact assessments and system of records notices. For new systems or major upgrades, organizations consider including representatives from the development organizations on the Configuration Control Boards or Change Advisory Boards. Auditing of changes includes activities before and after changes are made to systems and the auditing activities required to implement such changes. See also SA-10.

Organizational personnel with security or privacy responsibilities conduct impact analyses. Individuals conducting impact analyses possess the necessary skills and technical expertise to analyze the changes to systems as well as the security or privacy ramifications. Impact analyses include reviewing security and privacy plans, policies, and procedures to understand control requirements; reviewing system design documentation and operational procedures to understand control implementation and how specific system changes might affect the controls; reviewing the impact of changes on organizational supply chain partners with stakeholders; and determining how potential changes to a system create new risks to the privacy of individuals and the ability of implemented controls to mitigate those risks. Impact analyses also include risk assessments to understand the impact of the changes and determine if additional controls are required.

Changes to the hardware, software, or firmware components of systems or the operational procedures related to the system can potentially have significant effects on the security of the systems or individuals’ privacy. Therefore, organizations permit only qualified and authorized individuals to access systems for purposes of initiating changes. Access restrictions include physical and logical access controls (see AC-3 and PE-3), software libraries, workflow automation, media libraries, abstract layers (i.e., changes implemented into external interfaces rather than directly into systems), and change windows (i.e., changes occur only during specified times).

Configuration settings are the parameters that can be changed in the hardware, software, or firmware components of the system that affect the security and privacy posture or functionality of the system. Information technology products for which configuration settings can be defined include mainframe computers, servers, workstations, operating systems, mobile devices, input/output devices, protocols, and applications. Parameters that impact the security posture of systems include registry settings; account, file, or directory permission settings; and settings for functions, protocols, ports, services, and remote connections. Privacy parameters are parameters impacting the privacy posture of systems, including the parameters required to satisfy other privacy controls. Privacy parameters include settings for access controls, data processing preferences, and processing and retention permissions. Organizations establish organization-wide configuration settings and subsequently derive specific configuration settings for systems. The established settings become part of the configuration baseline for the system. Common secure configurations (also known as security configuration checklists, lockdown and hardening guides, and security reference guides) provide recognized, standardized, and established benchmarks that stipulate secure configuration settings for information technology products and platforms as well as instructions for configuring those products or platforms to meet operational requirements. Common secure configurations can be developed by a variety of organizations, including information technology product developers, manufacturers, vendors, federal agencies, consortia, academia, industry, and other organizations in the public and private sectors. Implementation of a common secure configuration may be mandated at the organization level, mission and business process level, system level, or at a higher level, including by a regulatory agency. Common secure configurations include the United States Government Configuration Baseline USGCB and security technical implementation guides (STIGs), which affect the implementation of CM-6 and other controls such as AC-19 and CM-7. The Security Content Automation Protocol (SCAP) and the defined standards within the protocol provide an effective method to uniquely identify, track, and control configuration settings.

Systems provide a wide variety of functions and services. Some of the functions and services routinely provided by default may not be necessary to support essential organizational missions, functions, or operations. Additionally, it is sometimes convenient to provide multiple services from a single system component, but doing so increases risk over limiting the services provided by that single component. Where feasible, organizations limit component functionality to a single function per component. Organizations consider removing unused or unnecessary software and disabling unused or unnecessary physical and logical ports and protocols to prevent unauthorized connection of components, transfer of information, and tunneling. Organizations employ network scanning tools, intrusion detection and prevention systems, and end-point protection technologies, such as firewalls and host-based intrusion detection systems, to identify and prevent the use of prohibited functions, protocols, ports, and services. Least functionality can also be achieved as part of the fundamental design and development of the system (see SA-8, SC-2, and SC-3).

System components are discrete, identifiable information technology assets that include hardware, software, and firmware. Organizations may choose to implement centralized system component inventories that include components from all organizational systems. In such situations, organizations ensure that the inventories include system-specific information required for component accountability. The information necessary for effective accountability of system components includes the system name, software owners, software version numbers, hardware inventory specifications, software license information, and for networked components, the machine names and network addresses across all implemented protocols (e.g., IPv4, IPv6). Inventory specifications include date of receipt, cost, model, serial number, manufacturer, supplier information, component type, and physical location. Preventing duplicate accounting of system components addresses the lack of accountability that occurs when component ownership and system association is not known, especially in large or complex connected systems. Effective prevention of duplicate accounting of system components necessitates use of a unique identifier for each component. For software inventory, centrally managed software that is accessed via other systems is addressed as a component of the system on which it is installed and managed. Software installed on multiple organizational systems and managed at the system level is addressed for each individual system and may appear more than once in a centralized component inventory, necessitating a system association for each software instance in the centralized inventory to avoid duplicate accounting of components. Scanning systems implementing multiple network protocols (e.g., IPv4 and IPv6) can result in duplicate components being identified in different address spaces. The implementation of CM-8(7) can help to eliminate duplicate accounting of components.

Configuration management activities occur throughout the system development life cycle. As such, there are developmental configuration management activities (e.g., the control of code and software libraries) and operational configuration management activities (e.g., control of installed components and how the components are configured). Configuration management plans satisfy the requirements in configuration management policies while being tailored to individual systems. Configuration management plans define processes and procedures for how configuration management is used to support system development life cycle activities. Configuration management plans are generated during the development and acquisition stage of the system development life cycle. The plans describe how to advance changes through change management processes; update configuration settings and baselines; maintain component inventories; control development, test, and operational environments; and develop, release, and update key documents. Organizations can employ templates to help ensure the consistent and timely development and implementation of configuration management plans. Templates can represent a configuration management plan for the organization with subsets of the plan implemented on a system by system basis. Configuration management approval processes include the designation of key stakeholders responsible for reviewing and approving proposed changes to systems, and personnel who conduct security and privacy impact analyses prior to the implementation of changes to the systems. Configuration items are the system components, such as the hardware, software, firmware, and documentation to be configuration-managed. As systems continue through the system development life cycle, new configuration items may be identified, and some existing configuration items may no longer need to be under configuration control.

Software license tracking can be accomplished by manual or automated methods, depending on organizational needs. Examples of contract agreements include software license agreements and non-disclosure agreements.

If provided the necessary privileges, users can install software in organizational systems. To maintain control over the software installed, organizations identify permitted and prohibited actions regarding software installation. Permitted software installations include updates and security patches to existing software and downloading new applications from organization-approved app stores. Prohibited software installations include software with unknown or suspect pedigrees or software that organizations consider potentially malicious. Policies selected for governing user-installed software are organization-developed or provided by some external entity. Policy enforcement methods can include procedural methods and automated methods.

Information location addresses the need to understand where information is being processed and stored. Information location includes identifying where specific information types and information reside in system components and how information is being processed so that information flow can be understood and adequate protection and policy management provided for such information and system components. The security category of the information is also a factor in determining the controls necessary to protect the information and the system component where the information resides (see FIPS 199). The location of the information and system components is also a factor in the architecture and design of the system (see SA-4, SA-8, SA-17).

Data actions are system operations that process personally identifiable information. The processing of such information encompasses the full information life cycle, which includes collection, generation, transformation, use, disclosure, retention, and disposal. A map of system data actions includes discrete data actions, elements of personally identifiable information being processed in the data actions, system components involved in the data actions, and the owners or operators of the system components. Understanding what personally identifiable information is being processed (e.g., the sensitivity of the personally identifiable information), how personally identifiable information is being processed (e.g., if the data action is visible to the individual or is processed in another part of the system), and by whom (e.g., individuals may have different privacy perceptions based on the entity that is processing the personally identifiable information) provides a number of contextual factors that are important to assessing the degree of privacy risk created by the system. Data maps can be illustrated in different ways, and the level of detail may vary based on the mission and business needs of the organization. The data map may be an overlay of any system design artifact that the organization is using. The development of this map may necessitate coordination between the privacy and security programs regarding the covered data actions and the components that are identified as part of the system.

Software and firmware components prevented from installation unless signed with recognized and approved certificates include software and firmware version updates, patches, service packs, device drivers, and basic input/output system updates. Organizations can identify applicable software and firmware components by type, by specific items, or a combination of both. Digital signatures and organizational verification of such signatures is a method of code authentication.

Contingency planning policy and procedures address the controls in the CP family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of contingency planning policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to contingency planning policy and procedures include assessment or audit findings, security incidents or breaches, or changes in laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.