RSI Security

Preparing for a FISMA Audit : How to Get Started

Cybersecurity laws are becoming more critical than ever, with so much of business processes being conducted online nowadays. Marketing studies indicate that roughly 78 percent of business people use the internet to do product research.  

Related statistics further added that a cyberattack occurs every 39 seconds. In most cases, cyberattacks are perpetrated by ransomware, computer viruses, malware, phishing, or even carelessness of employees. 

According to the Ponemon Institute and IBM Security, the average total cost of a data breach has increased to $3.86 million over the previous year. Usually, 60 percent of these hacked small businesses fail or shut down because of massive reputation damage and financial losses. 

One of the essential cybersecurity laws that are designed to ensure security and safety of data is the Federal Information Security Management Act (FISMA). Unlike other cybersecurity laws, FISMA is geared towards reducing the security threat to federal data and information while managing federal spending on information security. 

FISMA was developed to require each federal agency and its contractors to establish, record, and employ all-encyclopedic information security to safeguard and support organizational operations. It is one article in a larger piece of legislation known as the E-Government Act, which sets the importance of information security to the national and economic interests of the United States.

The U.S. Congress amended FISMA in 2014 to make in line with information security concerns. Through FISMA, federal organizations are now encouraged to use more constant tracking and concentration on compliance compared to what was needed in the previous legislation. 

Originally, FISMA was designed to regulate federal agencies. However, the law has evolved to cover state agencies that operate federal programs as well as organizations with contracts to work with national companies. In other words, private sector organizations that do business with federal agencies should adhere to the information security standards set by FISMA. 

For compliance, FISMA has established a set of security guidelines and standards that federal agencies have to meet. FISMA has a framework for managing information security that must be adhered to by all information systems used or operated by an organization. This particular framework is further defined by the guidelines and standards set by the National Institute of Standards and Technology (NIST). 

NIST plays an essential role in the FISMA implementation project developed in 2003. The organization also must adhere to regulations indicated on special publications like FIPS 199, FIPS 200, and the NIST 800 series. While FISMA audit requirements may differ depending on the information systems, here are some of the top resources needed to start your road towards compliance. 

 

Assess your FISMA compliance

 

Perform an Inventory on Your Information Systems

FISMA requires federal organizations and its contractors to have an information systems inventory in place. The agency should also be able to determine the integration of these information systems and other systems within the network. 

 

Categorize Risks and Threats to the System

Organizations should also define their data and the information systems in order or risk to assure that sensitive data and the systems that use it are given the highest priority. Technically-speaking, organizations should be able to define their policies based on the following criteria: 

 

Create a System Security Plan

A comprehensive system security plan will indicate the procedures and the policies on security controls. Before creating a system security plan, organizations should be able to select the appropriate security controls and assurance requirements for agency information systems to ensure adequate security. 

Organizations are also given a choice in employing the baseline security controls in correspondence with the tailoring guidance provided by NIST SP 800-53. Through this process, federal agencies and organizations can adjust the security controls to ensure that it fits their operational environments and mission requirements. 

The moment the appropriate security controls are selected, and the requirements have been satisfied, organizations will need to document the chosen controls in their system security plan. The system security plan is a significant detail to the security certification and accreditation process for the System. 

 

Initiate Risk Assessments 

After the system security plan has been completed, organizations will subsequently evaluate the risks of their information systems. The risk assessment does not only verify the security controls set, but it also determines if any additional restrictions are needed to safeguard other aspects of the organization. 

Usually, a risk assessment begins by recognizing the potential vulnerabilities or threats to the System, and mapping implemented controls to these risks. An auditor from RSI Security will adjacently determine the risk by estimating the impact and likelihood that any given threat is exploited.  

The risk assessment ends by showing the organization with the estimated risk for all vulnerabilities. The auditor will also describe whether the risk should be accepted or mitigated depending on how the System needs security control. 

The security controls of the information system should be reevaluated and certified to ensure proper function after completing a risk assessment and system documentation. Every accredited information system is also required to monitor a chosen set of security controls and ensure that all changes and modifications to the System reflect in the documentation. 

Monitoring activities may include but are not only limited to continuous evaluation of security controls, reporting of system statuses, analyses of changes to the System, and management of configuration controls.

FISMA also requires organizations to establish a selection metric and subsequently chooses a subset of the security controls implemented within the information system for evaluation. The organization should set a schedule for control monitoring as well to guarantee that sufficient coverage is met.

 

How to Ace a FISMA Audit? 

No one likes to see auditors, but they are a fact of life, especially when working with massive amounts of federal information. While it is relatively difficult to believe that FISMA auditors are the good guys, having them perform an audit to your information systems will save your business a great deal of trouble in the long run. 

These auditors measure how well your agency complies with the public law and federal regulations, as well as your capacity to manage your security program. Rules have changed over the years, and having a checklist is necessary to increase the chances of being accredited. Here is a detailed FISMA audit checklist that every organization should review before starting their journey towards compliance. 

 

1. Perform an Advanced Audit 

Audits are usually performed on a schedule, so it should be easy to prepare in advance. One of the best ways to make a review is to opt for an RSI Security auditor to perform an in-house audit of the information systems within your organization. 

Usually, an auditor will examine the security controls implemented to make sure that it is under the standards and guidelines of FISMA. They will also document a plan of action that will display your strengths and weaknesses. The document will not only be used as a guide, but it also shows that you know your environment and have an idea to address the shortcomings of your information systems. 

During the advance audit, organizations should also make sure that the key people should be present during the meeting to discuss every detail about your information system. This is to ensure that all of the talented people within your organization can cooperate smoothly with FISMA auditors during the official auditing procedure. 

 

2. Don’t Let the Information Overwhelm You

Business leaders and federal contractors should develop frameworks to address risk and information security management within their organization. Leaders should also designate a responsible party to handle information security to avoid juggling too much information at the same time.  

Make sure that the person assigned to these tasks has the ultimate oversight over information security policies, maters, and risk management. Moreover, the personnel assigned should also emphasize safeguarding information rather than systems.  

While the systems and system security are both critical, it is the data on these systems that has the most value. In a nutshell, business leaders should examine the information that is critical to their organizations and the agencies they work with by ensuring that all segments and bases are covered. Through this process, organizations will not only better align themselves with FISMA but also have a cost-efficient yet risk-based security program. 

 

3. Create Written Reports and Documentation of IT Systems

Reports are essential in determining the weak points of your information systems. Implementing technologies that provide better insight and refine reporting metrics will help minimize the workload and ensure the increasing effectiveness of your security program.  

FISMA also requires continuous monitoring of specific controls within your information system, thus, making reports and documentation a necessity. Documentation and written reports will provide you with a broader view of the continuous assessments of your security controls and configuration management. 

This ensures that you can immediately address the inherent problems within your System, stay compliant, and, more importantly, avoid hefty penalties. The loss of federal funding is perhaps the most significant potential fines for FISMA compliance violations. Other penalties may also include loss of reputation due to security breaches and missed federal project bid opportunities. 

 

4. Test Controls and Have the Proof

An annual evaluation of information security controls is required by FISMA so that organizations can maintain compliance. Make sure to thoroughly examine the controls and retain the evidence of the valuation as well as implement a process to remediate the findings. 

Companies should also know that some risks are subtle. More often than not, a 100 percent clean assessment checklist indicates that the organization being assessed lied or the assessor missed something. Keep proper documentation and assign someone to lead the remediation project to make the process much smoother.

Besides the tips mentioned above, organizations are also encouraged to adhere to the following practices to ensure FISMA compliance

 Agencies that consistently flunk their FISMA audit tests often fail to provide verification documents to auditors that certify the presence and effectiveness of security controls.  Always maintain an audit trail that explicitly demonstrates the restrictions that are in place and how they were integrated into the routine security activities within the organization.

 The more an organization can display documentation of its work, the higher the chances of getting accredited and certified by FISMA. It is also in the best interest of the organization to initiate security awareness training to ensure that all the personnel, including contractors, are aware of the security risks related to their job requirements. 

 

In Conclusion

Compliance is often viewed as a required burden that diverts time from accomplishing business or operational objectives. Nevertheless, FISMA compliance should not be considered in this way. It creates a part of the business duties with respect to the community it belongs while building trust.

Instead, compliance with FISMA results in a myriad of essential benefits that ultimately leads to an amplified readiness for present and emerging cyber threats. Start your journey towards creating comprehensive cybersecurity by contacting an expert at RSI Security today for their auditing services.

 

 

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