DIACAP Activity #4 Maintain Authorization to Operate and Conduct Review

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Maintain Situational AwarenessIncluded in the IA controls assigned to all DoD ISs are IA controls related to configuration and vulnerability management, performance monitoring, and periodic independent evaluations (e.g., penetration testing). The IAM continuously monitors the system or information environment for security-relevant events and configuration changes that negatively impact IA posture and periodically assesses the quality of IA controls implementation against performance indicators such as security incidents, feedback from external inspection agencies (e.g., IG DoD, Government Accountability Office (GAO)), exercises, and operational evaluations. In addition the IAM may, independently or at the direction of the CA or DAA, schedule a revalidation of any or all IA controls at any time. Reference (a) requires revalidation of a select number of IA controls at least annually. (DoD 8510.01, 6.3.4.1)

Knowing what is going on with the system is the job of the Information Assurance Manager (IAM). This can be delegated to the Information Assurance Officer (IAO) or the IAM and IAO may be the same person, but keep in mind that these permission require training, a technical and security certification (IAW DoD 8570).

Maintain IA Posture

Ensuring that there are no changes to the IA posture falls on the shoulders of the IAM.  This includes making sure that the establish baseline of the system has no signifigant changes.  Most patches (even involving security) will have a minimal impact on the system.  Applicable patches should always be tested before being put on a system.  Major patches are usually service packs that may actually change the IA posture.  The DIACAP Team should be involved with any major changes to the IA posture.  They will also decide which modifications, upgrades and additions should be considered changes to the IA posture of the system.  As a minimum, the Program Manager, IAM, subject matter experts (software/system security engineers) and information system owner/user representative should be appart of that decision. 

What will likely be considered a change to the IA Posture:

Adding IA products (firewalls, intrusion detection systems, ect)

Some internetworking devices such as Routers and Switches

New operating systems

Major upgrades to software or operating systems (not including support applications)

Newly discover major vulnerabilities

*Basically any major changes that will affect the security, supportability, usability, and interoperability of the system.  It is important to have who, what when and where of sustainability, new risks, and usability requirements in writing.  Information Assurance includes all these things, not just security.

What are usually not changes to the IA Posture: 

Most NOTAM/IAVAS/TCNOs (such as Office patches, browser upgrades, ect)

Re-positioning equipment within the office (as long as the IAM has readable documentation on the data connections)

Adding passive periferal devices such as stand-alone printers, scanners and new monitors (devices with connectivity to external sources such as faxes, share external network printers should go before the DIACAP Team)

Devices such as DVD, CD and hard drives with more capacity may not affect the IA Posture but it is best to have some formalized method of tracking upgrades to hardware  especially on mission systems as some changes could have some unpredictable affects

Annual FISMA Reviews

DIACAP includes the task of performing reviews annually on the system.  This is one of the key features of the Federal Information System Management Act of 2002.  What ever command or branch of the DoD you reside, your system has the potential of being audited annually to make sure it is in compliance with federal regulations.  The eMASS IT Portfolio management systems (EITDR, DITPR-DON, APMS) also has this feature intergrated into its key functions.  All data on each systems IA posture is collect annually.   This is done by the IAMs and/or the DIACAP Team.

Additionally, each system must be re-accredited every three years:

6.3.4.4. Initiate Reaccreditation. In accordance with OMB Circular A-130 (Reference (s)), an IS must be recertified and reaccredited once every 3 years. The results of an annual review or a major change in the IA posture at any time may also indicate the need for recertification and reaccreditation of the IS.  DoD 8510.01, 6.3.4.4

From DoD 8510.01, DIACAP: 

6.3.4.1.1. DoD ISs with a current ATO that are found to be operating in an unacceptable IA posture through GAO audits, IG DoD audits, or other reviews or events such as an annual security review or compliance validation shall have the newly identified weakness added to an existing or newly created IT Security POA&M.

6.3.4.1.2. If a newly discovered CAT I weakness on a DoD IS operating with an ATO cannot be corrected within 30 days, the system can only continue operation under the terms prescribed in subparagraph 6.3.3.2.6.1.2.

6.3.4.1.3. If a newly discovered CAT II weakness on a DoD IS operating with a current ATO cannot be corrected or satisfactorily mitigated within 90 days, the system can only continue operation under the terms prescribed in subparagraph 6.3.3.2.6.2.5.

6.3.4.2. Maintain IA Posture. The IAM may recommend changes or improvement to the implementation of assigned IA controls, the assignment of additional IA controls, or changes or improvements to the design of the IS itself.

6.3.4.3. Perform Reviews. The IAM shall annually provide a written or DoD PKI-certified digitally signed statement to the DAA and the CA that indicates the results of the security review of all IA controls and the testing of selected IA controls as required by Reference (a). The review will either confirm the effectiveness of assigned IA controls and their implementation, or it will recommend: changes such as those described in subparagraph 6.3.4.2.; a change in accreditation status (e.g., accreditation status is downgraded to IATO or DATO); or development of an IT Security POA&M. The CA and DAA shall review the IAM statement in light of mission and information environment indicators and determine a course of action that will be provided to the concerned CIO or SIAO for reporting requirements described in Reference (a). The date of the annual security review will be recorded in the SIP. A DAA may downgrade or revoke an accreditation decision at any time if risk conditions or concerns so warrant.

6.3.4.4. Initiate Reaccreditation. In accordance with OMB Circular A-130 (Reference (s)), an IS must be recertified and reaccredited once every 3 years. The results of an annual review or a major change in the IA posture at any time may also indicate the need for recertification and reaccreditation of the IS.

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