Moving beyond periodic certification of information systems to the Risk Management Framework requires standardizing and automating the assessment process.
Making decisions based on outdated information is a recipe for failure. No matter how good the data at the time it is collected, if it cannot be used quickly it loses its value for making critical cybersecurity decisions.
This has been demonstrated by federal agencies struggling to secure their information systems using Certification and Accreditation (C&A) schemes that call for periodic certification of static security controls. Government now is moving beyond C&A to continuous assessment of security status under a Risk Management Framework (RMF). But challenges remain in automating the processes needed to use the framework.
The Risk Management Framework
The Risk Management Framework is a risk-based approach to cybersecurity intended to enable continuous response to threats.
Under the Federal Information Security Management Act (FISMA)—now the Federal Information Security Modernization Act—IT systems were certified and accredited for operation every three years. Each agency or department had its own C&A process. Information was maintained in data silos and there was no standardization and no reciprocity. The results were time consuming and labor intensive, security controls were rarely up-to-date, and the lack of reciprocity required basic work to be duplicated by each agency.
The Risk Management Framework is a risk-based approach to cybersecurity intended to enable continuous response to threats
RMF is a unified framework for assessing organizational risk posed by IT systems, and managing that risk by selecting the appropriate security controls. The framework supports continuous assessment of security as the security status changes throughout the system lifecycle.
RMF includes six steps:
- Step 1: Categorize the system and the information using impact analysis.
- Step 2: Select an appropriate set of baseline security controls based on the potential impact and tailored to the assessment of risk.
- Step 3: Implement those controls and document their deployment.
- Step 4: Assess whether security controls are implemented correctly, operating as intended, and producing the desired outcome.
- Step 5: Authorize the system’s operation based on a determination that its risk is acceptable.
- Step 6: Monitor security controls on an ongoing basis to assess effectiveness, document changes to the system and environment, conduct security impact analyses of the changes, and report the security state.
Where the process falls short
Carrying out these steps requires access to near-real-time data on which to base decisions. Strides have been made in automating data collection to support the RMF. The Security Content Automation Protocol (SCAP) is a set of specifications assembled by the National Institute of Standards and Technology that lets commercial security tools interoperate and automate information gathering.
The process of accessing and using the data remains time consuming and labor intensive
But the process of accessing and using the data remains time consuming and labor intensive, with many manual steps. Data must be reviewed, standardized, moved to an authorization database, analyzed, and reports generated to support selection of controls and authorization to operate.
This can take months to complete. While this is an improvement over the static three-year certification timeline under the original C&A scheme, it remains inadequate in today’s rapidly evolving cyberthreat landscape. John Chirhart, federal technology director for Tenable, likens this to going to a dentist and waiting three months to get your X-rays back. No matter how good the data when it was gathered, it is outdated by then.
Automating the process
The key to effective risk management is automation and open standards to provide visibility and flexibility
The key to effective risk management is automation and open standards to provide visibility and flexibility to not only see data but to put it into context. Automating workflows gives stakeholders access to the information they need when they need it.
ASSESS (Automated Scalable Solution for Enterprise Systems Security), a cloud-based big data enterprise solution from Secure Innovations, provides access and visualization of data across disparate systems. IT and security officials can be confident in the security posture of their IT systems. ASSESS is product agnostic, leveraging industry standards to work with tools from industry-leading vendors, including SecurityCenter Continuous View™ from Tenable Network Security.
It coordinates and standardizes data from assessment and reporting tools, automates workflow and supports role-based access so that only those who need it have access to what they need. ASSESS is customizable to support compliance with any government or industry regulations. The result is a flexible and scalable solution that shortens the time for system authorization under the RMF from months to days, reducing costs while improving situational awareness and security.