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SI.1.210 System Integrity/Patching (CMMC Level 1)

2021-03-15/0 Comments/in CMMC, Compliance, General Security/by Kellep Charles

Identify, report, and correct information and information system flaws in a timely manner.

CA.2.158 Ongoing Security Assessment (CMMC Level 2)

2021-03-11/0 Comments/in CMMC, Compliance, General Security/by Kellep Charles

Periodically assess the security controls in organizational systems to determine if the controls are effective in their application.

SI.1.210 System Integrity/Patching (CMMC Level 1)

2021-03-15/0 Comments/in CMMC, Compliance, General Security/by Kellep Charles

Identify, report, and correct information and information system flaws in a timely manner.

CA.2.158 Ongoing Security Assessment (CMMC Level 2)

2021-03-11/0 Comments/in CMMC, Compliance, General Security/by Kellep Charles

Periodically assess the security controls in organizational systems to determine if the controls are effective in their application.

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SI.1.210 System Integrity/Patching (CMMC Level 1)

2021-03-15/0 Comments/in CMMC, Compliance, General Security/by Kellep Charles

Identify, report, and correct information and information system flaws in a timely manner.

Source Discussion

Organizations identify systems that are affected by announced software and firmware flaws including potential vulnerabilities resulting from those flaws and report this information to designated personnel with information security responsibilities. Security-relevant updates include patches, service packs, hotfixes, and anti-virus signatures. Organizations address flaws discovered during security assessments, continuous monitoring, incident response activities, and system error handling. Organizations can take advantage of available resources such as the Common Weakness Enumeration (CWE) database or Common Vulnerabilities and Exposures (CVE) database in remediating flaws discovered in organizational systems.

Organization-defined time periods for updating security-relevant software and firmware may vary based on a variety of factors including the criticality of the update (i.e., the severity of the vulnerability related to the discovered flaw). Some types of flaw remediation may require more testing than other types of remediation. NIST SP 800-40 provides guidance on patch management technologies.

CMMC Clarification

All software and firmware have potential flaws. Many vendors work to reduce those flaws by releasing vulnerability information and updates to their software and firmware. Organizations should have a process to review relevant vendor newsletters with updates about common problems or weaknesses. After reviewing the information the organization should execute a process called patch management that allows for systems to be updated without adversely affecting the organization. Organizations should also purchase support from their vendors to ensure timely access to updates.

CMMC GUIDE FURTHER DISCUSSION

All software and firmware have potential flaws. Many vendors work to remedy those flaws by releasing vulnerability information and updates to their software and firmware. Contractors must have a process to review relevant vendor notifications and updates about problems or weaknesses [a]. After reviewing the information, the contractor must implement a patch management process that allows for software and firmware flaws to be fixed without adversely affecting the system functionality [e,f]. Contractors must define the time frames within which flaws are identified, reported, and corrected for all systems. Contractors should consider purchasing support from their vendors to ensure timely access to updates [a].

Examples

You have many responsibilities at your company, including IT. You know that malware, ransomware, and viruses can be big problems for companies. You make sure to enable all security updates for your software, including the operating system and applications, and purchase the maintenance packages for new hardware and operating systems.

References

FAR Clause 52.204-21 b.1.xii

NIST SP 800-171 Rev 1 3.14.1

NIST CSF v1.1 RS.CO-2, RS.MI-3

CERT RMM v1.2 VAR:SG2.SP2

NIST SP 800-53 Rev 4 SI-2

UK NCSC Cyber Essentials

AU ACSC Essential Eight

CA.2.158 Ongoing Security Assessment (CMMC Level 2)

2021-03-11/0 Comments/in CMMC, Compliance, General Security/by Kellep Charles

Periodically assess the security controls in organizational systems to determine if the controls are effective in their application.

Source Discussion

Organizations assess security controls in organizational systems and the environments in which those systems operate as part of the system development life cycle. Security controls are the safeguards or countermeasures organizations implement to satisfy security requirements. By assessing the implemented security controls, organizations determine if the security safeguards or countermeasures are in place and operating as intended. Security control assessments ensure that information security is built into organizational systems; identify weaknesses and deficiencies early in the development process; provide essential information needed to make risk-based decisions; and ensure compliance to vulnerability mitigation procedures. Assessments are conducted on the implemented security controls as documented in system security plans.

Security 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 security controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting security requirements. Security assessment results are provided to the individuals or roles appropriate for the types of assessments being conducted.

Organizations ensure that security assessment results are current, relevant to the determination of security control effectiveness, and obtained with the appropriate level of assessor independence. Organizations can choose to use other types of assessment activities such as vulnerability scanning and system monitoring to maintain the security posture of systems during the system life cycle.

NIST SP 800-53 provides guidance on security and privacy controls for systems and organizations. SP 800-53A provides guidance on developing security assessment plans and conducting assessments.

CMMC Clarification

As organizations implement security controls, they should avoid a “set it and forget it” mentality. The security landscape is constantly changing. Reassess existing controls at periodic intervals in order to validate their usefulness in organizational systems. This will let you determine if the control is still meeting the needs of the organization. Set the assessment schedule according to organizational needs. Consider regulatory obligations and internal policies when assessing the controls.

Typical outputs of the practice include:

documented assessment results;
proposed new controls, or updates to existing controls;
remediation plans; and
newly identified risks.

CMMC GUIDE FURTHER DISCUSSION

Avoid a “set it and forget it” mentality when implementing security controls. The security landscape is constantly changing. Reassess existing controls at periodic intervals in order to validate their effectiveness in your environment. Set the assessment schedule according to organizational needs. Consider regulatory obligations and internal policies when assessing the controls.

Outputs from security control assessments typically include:

documented assessment results;
proposed new controls, or updates to existing controls;
remediation plans; and
newly identified risks.

This practice, CA.2.158, which ensures determining security controls are implemented properly, promotes effective security assessments for organizational systems required by CA.3.161.

Examples

You are in charge of IT operations in your company. You ensure that security controls are achieving their objectives. After you implement the controls, you monitor their performance. You should perform this review as often as necessary to meet:

your organization’s risk planning needs; and
any regulations or policies you must follow. When you assess the controls, document what you find. When you find your controls are not meeting your requirements, you should act and make changes. You can:
propose updated or new controls;
develop a plan to improve the control; and
document new risks that you find. You should also document these actions.

References

NIST SP 800-171 Rev 1 3.12.1

NIST CSF v1.1 DE.DP-3

NIST SP 800-53 Rev 4 CA-2