The need for compliance becomes more evident as issues become more sophisticated when your business grows. After all, failing to follow regulations impacts the reputation of the organization and those in charge.
In an era of evolving regulatory changes, organizations continue to reassess how to allocate their resources to meet imminent regulatory government changes effectively. Taking the required steps to fulfill legal obligations might like a management no-brainer, but there are still several organizations that ignore compliance laws.
The Electronic Evidence and Discovery Handbook revealed that roughly 10 percent of employers and workers ignore compliance laws. This is primarily because of the work, time, and resources that take to be compliant with government-mandated regulations related to information security.
Perhaps one of the most popular laws involving information security is the Federal Information Security Management Act (FISMA) of 2002, which tackles the need for federal agencies to create, document, and applies an all-encyclopedic program around security and protection. It was part of the giant E-Government Act of 2002, which was developed to enhance the supervision of electronic processes and government services.
FISMA was established to minimize the security threats to government information while managing federal spending on data security. The National Institute of Standards and Technology (NIST) is responsible for cultivating and updating compliance records as directed by FISMA.
More specifically, NIST establishes minimum requirements for data security plans and procedures as well as recommends types of security that organizations must implement. They also standardize the risk evaluation process by setting varying standards of data security based on agency risk assessments.
FISMA was created for federal agencies, but the law has evolved since then to cover state agencies that manage federal programs like unemployment insurance, Medicaid, and Medicare as well as agencies with contracts to work with governmental organizations. In other words, private sector organizations that do business with a federal agency should comply with FISMA requirements to ensure legitimacy.
Moreover, federal organizations should also provide real-time system data to FISMA auditor for continuous monitoring of FISMA-regulated data systems. Outlined in this guide is a FISMA compliance checklist that will help your organization stay ahead of emerging threats and ensure top-notch security in every business aspect.
Comply with NIST Guidelines
The initial step towards FISMA compliance is to adhere to NIST standards and requirements outlined in the NIST Special Publication (SP) 800-53. The NIST SP 800-53 requires federal organizations to come up with detailed privacy policies, processes, information security, procedures, and related internal controls.
The SP also contains a detailed list of control families and privacy controls that federal organizations need to become FISMA compliant. These NIST standards are responsible for creating the groundwork in ensuring security readiness and separation of Controlled Technical Information and Controlled Unclassified Information.
The process towards NIST compliance initially begins by searching organizational systems that have CTI or CUI and subsequently assessing all locations where these data might be housed. This includes evaluating central file shares, endpoints, or even mail servers where documents have been communicated, stored, and transferred.
Organizations are also required to limit access to CTI and CUI data to authorized personnel. This enables them to keep track of who opens their network and when to guarantee that information is not acquired through shared or non-attributed accounts. Taking these simple steps ensures NIST compliance and lets the organization move to the next phase of FISMA compliance.
List a Record of Information Systems
As defined in the cybersecurity framework for managing data security, FISMA requires agencies to establish and maintain an inventory of data systems. The organization should also recognize the integrations between these data systems and other circuits within its operational network. Through a catalog of information systems, organizations can have guidance on determining system boundaries and ensuring that their data circuits follow industry practices.
Organize Information and Systems Based on Risk Levels
FIPS 199 states how an organization classifies its security requirements and risks. Also known as the Standards for Security Categorization of Federal Information and Information Systems, FIPS 199 provides the definitions for security classifications.
By categorizing their data systems and information based on risk levels, federal agencies can ensure that confidential information and the data circuits that use it are given the highest level of security. Agencies should also define their information systems based on the following criteria:
- Low Impact Systems: These data circuits are designed to withstand cyberattacks and prevent massive consequences to the agency or its working individuals.
- Modern Impact Systems: Unlike low impact data circuits, these data systems cannot survive sophisticated hacking techniques. Attacks on these information systems usually result in a massive risk to the operations, individuals, and assets of the organization.
- High Impact Systems: Data breaches on these systems can lead to damages to property and individuals as well as significant financial losses that could put an organization on the pedestal of bankruptcy.
Designate Security Controls
NIST SP 800-53 outlines approximately 20 controls that each organization must apply to be FISMA compliant. The method of choosing the proper security controls and assurance requirements for organizational data systems to accomplish adequate security that is risk-based and involves management or operational personnel within the company.
Moreover, the organization is also flexible in implementing the baseline security controls under the tailoring guidance stated in SP 800-53. This empowers organizations to calibrate the security controls to ensure that they fit with their operational environment and mission requirements. The planned or chosen controls should be recorded in the system security plan for complete transparency during audits.
Establish a System Security Plan
Federal organizations should come up with policy during the system security planning process. The system security plan should also indicate the procedures and the individuals reviewing the plans to make sure that it is updated regularly.
The system security plan also has a significant input to the security accreditation and certification process for the system. During this process, the organization’s system security plan is assessed and updated to ensure that it is consistent with the FIPS 199 security category identified for the information system.
Perform Comprehensive Risk Assessments
The moment an agency modifies its systems, it is required to perform a three-tiered risk evaluation using the Risk Management Framework. The risk assessment is essential in validating the security controls set and finds out if any additional restrictions are required to protect the operations, individuals, and assets of the agency.
It is also critical to ensure that the information system is not a threat to other organizations or national security. A risk assessment begins by recognizing the potential dangers and vulnerabilities within the system and subsequently creating implemented controls to combat these individual risks.
A professional from RSI Security will then determine the threat by calculating the impact and likelihood that any given risk can be exploited. The risk assessment culminates by showing the estimated risk for all vulnerabilities and describes whether it should be accepted or mitigated.
When the organization decides to mitigate the implementation of the control, it is required to define the additional security controls that are needed to be added into the system. What is more, agencies can also use the Security Content Automation Protocol (SCAP) and the Information Security Automation Program (ISAP) as initiated by NIST to complement and support the approach for accomplishing a careful and consistent security control assessment.
Certification and Accreditation
FISMA requires an agency to perform annual security reviews once the risk assessment and system documentation have been completed. The agency should demonstrate that they can employ, maintain, or track the system and ensure proper function to be FISMA compliant.
Based on the results of the review, the information system is accredited based on the guidelines defined in NIST SP 800-37, which indicates all the requirements for security certification and accreditation of federal information systems.
Security accreditation is the official decision provided by a senior agency official to permit the operation of a data system and accept the risk to agency assets, processes, or individuals based on the application of a collection of security controls. By accrediting an information system, the organization official accepts all security responsibilities and is held fully accountable should any breaches occur during their watch.
The data and supporting evidence needed for security accreditation are established during a comprehensive security review of a data system, which is also known as the security certification. During this process, an official conducts a detailed evaluation of the operational, management, and technical security controls in a data circuit to determine proper implementation and operation.
The results collected from a security certification are adjacently used to reexamine the risks and update the system security plan. This provides an authorizing official a factual basis to make a security accreditation decision. Agencies can acquire FISMA Certification and Accreditation (C&A) through a four-step process, which includes planning and initiation, certification, accreditation, and constant monitoring.
Information systems accredited by FISMA are required to monitor a chosen set of security controls to remain compliant. The changes and modifications made by the organization to keep their systems compliant should all be recorded into the system documentation for transparency.
Substantial changes to system security profiles may require another risk assessment of modified controls for recertification. More often than not, constant monitoring activities involve the management of each configuration and control of data circuit components, continuous evaluation of security controls, status reporting, and all-encyclopedic security impact assessments of changes to the system.
The organization also needs to establish the selection criteria, and adjacently chooses a subset of the security controls applied within the data system for evaluation. They are also responsible for creating a schedule for control tracking to guarantee sufficient coverage is met.
Best Practices for FISMA Compliance
Achieving FISMA compliance helps agencies increase data security while simultaneously reducing IT-related costs. Enterprises operating in the private sector, particularly those who do business with federal agencies, can have an advantage in adding new business by meeting FISMA requirements.
On the flip side, government agencies and associated private enterprises that fail to comply with FISMA could end up suffering a range of potential penalties. This includes a censure by congress, damage in reputation, and a reduction of federal funding.
The loss of federal funding could be detrimental for an agency and could mean the end of business for federal contractors. Among the best practices to ensure FISMA compliance include the following:
- Classify Data Immediately: Classifying data based on its sensitivity upon development helps agencies prioritize controls and security policies that can be implemented to assure a sufficient level of security.
- Employ a Comprehensive Data Security Plan: A detailed security plan can help organizations track activities, group data, and, more importantly, detect risks to confidential information available at their disposal. Reevaluating the risks surrounding agency-level information that does not appear at a granular level is also necessary for identifying where additional security measures are required.
- Encrypt Every Information in your System: Make sure to encrypt sensitive data based on its risk level to avoid sophisticated data breaches and ensure complete privacy when communicating data over the cloud or internet.
- Keep Documentation of FISMA Compliance Efforts: No one likes audits, but it happens now and then. By keeping detailed documentation of the steps taken to achieve FISMA compliance, organizations can stay on top of FISMA audits.
Achieving FISMA compliance takes a lot of work, but the benefits that come with adhering to these regulations can keep the business competitive in a regulatory environment. One of the best ways to ensure compliance is to opt for an RSI Security auditor to perform an advanced audit on the information systems within your organization.
By performing an advanced audit, organizations can find out the strengths and weaknesses of their information systems and, more importantly, develop a plan of action to address any problems that could potentially result in failing to achieve FISMA compliance. Create comprehensive cybersecurity and remain compliant in the ever-changing digital landscape by talking to an expert at RSI Security today.