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This is an overview of NIST 800-37 Revision 2. I discuss the changes, the sources and Cybersecurity Framework.
NIST Special Publication 800-37, Revision 2
Risk Management Framework for Security and Privacy
Initial Public Draft: May 2018
Final Public Draft: July 2018
Final Publication: October 2018
Source of Changes:
President’s Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure
Office of Management and Budget Memorandum M-17-25 – next-generation Risk Management Framework (RMF) for systems and organizations
NIST SP 800-53 Revision 5 Coordination
Tier 1: Organization level
Tier 2: Mission/Business Process level
Tier 3: Information System level
Tier 1: Organization Level risk management
Tier one addresses security from the organizations perspective. The activities include the implementation of the first component of risk management, risk framing. Risk framing provides context of all the risk activities within an organization, which affects the risk activities of tier 1 & 2. The output of risk framing is Risk Management Strategy. In tier 1 the organization establishes and implements governance structure that are in compliance with laws, regulations and policies. Tier 1 activities include establishment of the Risk Executive Function, establishment of the risk management strategy and determination of the risk tolerance.
Tier 2: Mission/Business Process Level risk management
Tier 2 risk management activities include: 1) defining the mission/business processes to support the organization. 2) Prioritize the mission/business process with respect to the long term goals of the organization. 3) Define the type of information needed to successfully execute the mission/business processes, criticality/sensitivity of the information and the information flows both internal and external of the information.
Having a risk-aware process is an important part of tier 2. To be risk-aware senior leaders/executives need to know: 1) types of threat sources and threat events that could have an adverse affect the ability of the organizations 2) the potential adverse impacts on the organizational operations and assets, individuals, the Nation if confidentiality, integrity, availability is compromised 3) the organization�s resilience to such an attack that can be achieved with a given mission/business process
Tier 3: Information System risk management
From the information system perspective, tier 3 addresses the following tasks:
1) Categorization of the information system
2) Allocating the organizational security control
3) Selection, implementation, assessment, authorization, and ongoing
Chapter 3 focuses on the step to have a comprehensive risk management program. The tasks discussed include:
Risk Framing
Risk Assessing
Risk Response
Risk Monitoring
With the move from certification and accreditation (C&A) to risk management framework, comes a few new terms. “C&A†will be replaced with assessment and authorization. Even though “information assurance (IA) controls” will be call “security controls”, the definition and work is still the same, but the hope is that its done continuously and more cost-effective.
Certification (NIST Assessment) – Comprehensive evaluation of an information system assessment of IA Controls/Security Controls to determine the extent to which the controls are implemented correctly and operating as intended. That means when evaluated, they produce the desired outcome. An assessment is about gathering information to providing the factual basis for an authorizing official (Designated Accrediting Authority) to render a security accreditation decision
Accreditation (NIST Authorization) – Security accreditation is the official management decision to operate (DAA – Formal approval of the system). Authorization is given by a senior agency official (upper-management/higher head quarters/combat commander). The official should have the authority to oversee the budget and business operations of the information system explicitly accept the risk to operations, assets, individuals. They accept responsibility for the security of the system and are fully accountable for the security of the system.
“The official management decision given by a senior organization“The official management decision given by a senior organizational official to authorize operation of an information system and to explicitly accept the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, individuals, other organizations, and the Nation based on the implementation of an agreed-upon set of security controls.â€
On the DIACAP Knowledge Service goto “C&A Transformation”. This page introduces some of the coming changes from Certification & Accreditation changes to the Risk Management Framework seen in NIST SP 800-37.
DIACAP has “Risk Management Framework Transformation Initiative†underway that provides information on use of NIST SP 800-53, NIST SP 800-37, CNSS Instruction 1253.
The site introduces changes being made to DoDD 8500.01, DoDI 8500.2, DoDI 8510.01 and other documents that will be aligned with NIST 800 and FISMA 2013. They will feature an attempt to keep up with new arising cyberthreats, vulnerabilites and security incidence using real-time, “continuous monitoring†technologies such as HP ArcSight, McAfee ESM, ePO, NSP, Retina, Nessuss and other near real-time active monitoring systems.
road to diarmf
Why DIACAP to DIARMF?
Federal government has gotten more serious about security. They realize that enterprise level security and process is a continuous and expensive business. The old certification & accreditation process is not only long and expensive but so slow that it cannot keep up with the constant changes of information technology.
Risk based/cost effective security means creating security systems and policies that focus on “adequate securityâ€. The Executive Branch Office of Management and Budget (OMB) defines as adequate security, or security commensurate with risk, to include the magnitude of harm resulting from the unauthorized access, use, disclosure, disruption, modification, or destruction of information. The feds are also attempting to make the process of implementing and evaluating security controls by creating as much paper-less automation as possible.
note IMHO: Since technology is changing at a rate of what Ray Kurzweil calls “accelerating returns” I think for governments and organizations stuck in “static policy” based systems there is no way they can ever keep up with information technology without revolutionary shift in thinking. Google is probably the closest to understanding what is actually happening. The best any of us can do is observe.
 Source documents for all U.S. Federal information security:
OMB A-130 – Management of Federal Information Resources
FISMA – Federal Information Security Management Act of 2002
Required for all government agencies to develop, document, and implement an agency-wide information security program to provide information security for the information and systems that support the operations and assets of the agency Applies to contractors and other sources.
The federal government has created various acts/laws to implement to changes to the C&A process to a more risk management approach and emphasize a risk-based policy for cost-effective security. These acts include (but are not limited to):
 Federal Information Security Management Act of 2002 (amended as of 2013 April)
The Paperwork Reduction Act of 1995
The Information Technology Management Reform Act of 1996 (Clinger-Cohen Act) supported by Office of Management and Budget (OMB) through Circular A-130, Appendix III, Security of Federal Automated Information Resources
This NIST 800 is a well thought out set of federal security standards that DoD and the Intel world is moving too. It aligns with International Organization for Standardization (ISO) and International Electotechnical Commissions (IEC) 27001:2005, Information Security Management System (ISMS).
who-created-manages-nist-800
NIST 800 is updated and revised by the following organizations:
Joint Task Force Transformation Initiative Interagency (JTFTI) Working Group National Institute of Standards and Technology (NIST)
JTFTI is made up of from the Civil, Defense, and Intelligence Communities. This working group reviews and updates the following documents
    NIST Special Publication 800-37, Revision 1 Guide for Applying the Risk Management Framework to Federal Information Systems: A Security Life Cycle Approach
   NIST Special Publication 800-39, Enterprise-Wide Risk Management: Organization, Mission, and Information Systems View
   NIST Special Publication 800-53, Revision 3 Recommended Security Controls for Federal Information Systems and Organizations
   NIST Special Publication 800-53A, Revision 1 Guide for Assessing the Security Controls in Federal Information Systems and Organizations: Building Effective Assessment Plans
These core documents are a standard on how to implement FISMA. The organization has done a good job of keeping NIST 800 inline with international standards of ISO 27001. The JTFTI is made up of ODNI, DoD, CNSS. This document is also publicly vetted.
Office of the Director of National Intelligence (ODNI)
The DNI is a position required by Intelligence Reform and Terrorism Prevention Act of 2004. This office serves as adviser to the president, Homeland Security and National Security Counsil as well and director of National Intelligence.
Department of Defense (DoD)
DoD is composed of (but not limited to) the USAF, US Army, DON and Marines. It is the most powerful military organization in recorded history.
Committee on National Security Systems (CNSS)
This committee was created to satisfy National Security Directive 42, “National Policy for the Security of National Security Telecommunications and Information Systems“,
the group has represtatives from NSA, CIA, FBI, DOD, DOJ, DIA and is focused on protecting the US crititcal infrastructure.
DIACAP is transitioning from a Certification and Accreditation to a Risk Management Framework. Most of the new Risk Manager Framework is in the NIST Special Publication 800-37. The old NIST SP 800-37 was also based on Certification and Accreditation. After FISMA 2002, it adjusted to a Risk Management Framework in NIST SP 800-37 Rev 1, Guide for Applying the Risk Management Framework to Federal Information Systems.
diacap-to-diarmf-ca-vs-rmf
NIST SP 800-37 to SP 800-37 rev 1 transformed from a Certification and Accreditation (C&A) process into the six-step Risk Management Framework (RMF). The changes included:
Revised process emphasizes
Building information security capabilities into federal information systems through the application of state-of-the-practice management, operational, and technical security controls
Maintaining awareness of the security state of information systems on an ongoing basis though enhanced monitoring processes
Providing essential information to senior leaders to facilitate decisions regarding the acceptance of risk to organizational operations and assets, individuals, other organizations, and the Nation arising from the operation and use of information systems
The Federal Information Security Amendments Act, H.R. 1163, Amends the Federal Information Security Management Act of 2002 (FISMA).
Main Points of FISMA 2002:
Cost-effectively reduce information technology security risks
Vulnerability Database System
Maintain an inventory of major information systems
Security Categorization of Federal IS by risk levels
Minimum security requirements
System Security planning process
Annual review of assigned IS compliance
Risk Management
The amendment has a few big changes to the previous 2002 version that will affect federal agencies. But two main ones the stood out for me is the emphasis on automation and the CISO position.
The FISMA Amendment was passed by the House of Representatives (4 April 2013) but must still pass the Senate and be signed into law by the President.
1 – Continuous monitoring / automation of Everything -FISMA 2013, requires continuous monitoring (automation) and regular cyberthreat assessments for better oversight to federal organizations.
Security Incidents - Security incidents are automatically detected with tools like McAfee Network Security Platform (IPS), Source Fire SNORT (IDS), McAfee ePO and Cisco IDS. With the right people to manage the signatures and the configuration, theses are great products. Once they are detected you can then do incident handling with something like Remedy. FISMA 2013: “with a frequency sufficient to support risk-based security decisions, automated and continuous monitoring, when possible, for detecting, reporting, and responding to security incidents, consistent with standards and guidelines issued by the National Institute of Standards and Technology”
Information Systems Security – Vulnerability scanners such as Retina and Tenable’s Nessuss are great with automatically detecting security controls and policies within an agency. Change Auditor and other tools can detect changes the GPO’s within a domain. FISMA 2013: “with a frequency sufficient to support risk-based security decisions, automated and continuous monitoring, when possible, for testing and evaluation of the effectiveness and compliance of information security policies, procedures, and practices, including…” Security controls
Risk Level & Impact of Harm – McAfee ESM and ArcSight are good and pulling in the data from security tools that detect security events, evaluating the risk level and giving an measurement of the possible harm of and asset. FISMA 2013: “automated and continuous monitoring, when possible, of the risk and magnitude of the harm that could result from the disruption or unauthorized access, use, disclosure, modification, or destruction of information and information systems that support the operations and assets of the agency;
Detection/Correlation – this one could be grouped in with Security Incident, but Security Incident gets more into incident handling. Also, ArcSight, McAfee, LogRythm, LogLogic, AlienVault and other Security Incident Event Managers do Correlation automatically. FISMA 2013: “efficiently detect, correlate, respond to, contain, mitigate, and remediate incidents that impair the adequate security of the information systems of more than one agency. To the extent practicable, the capability shall be continuous and technically automated.”
2 – CISO positions and responsibilities backed by Law – The amendment requires each department head to be held accountable for IT. In DoD Information Assurance Risk Management Framework (DIARMF) this department director is known as the Authorizing Official (aka Designated Authorizing Authority in DIACAP). FISMA 2013 require the AO to have an Chief Information Security Officer. This is a position that is already assigned under Risk Management Framework. The DoD has referred to this position as Senior Information Assurance Officer in DIACAP. Under FISMA 2013, CISO/SIAO must have must have qualifications to implement agency-wide security programs for which they are responsible
and report directly to the AO.
The CISCO/SIAO will also have responsibility of Automated Security systems. The CISO will be responsible for development, maintaining and overseeing these automated systems.
FISMA 2013 is targeted to minimize the risk of cyberattacks by conducting pentesting.
Overall, they made automation a requirement, which is the direction the field of information security has already been following and put some more emphasis on the CISO. The amendments highlight the changes from DIACAP to DIARMF as many of the changes are already in the NIST 800 series that DIARMF is based on.
Information Assurance is based on obtaining a high level of confidence on information’s confidentiality, integrity, and availability. Â Some organizations that deal with “critical information”. Â Critical information included things like banking transactions, classified data, information that is evidence in an ongoing investigation. Â Companies, unions and government that handle this kind of information usually have a lot of exposure because they are handling public data, share holder data, employee data and are doing a lot of translation across the un-trusted networks such as the Internet. Â With critical information and high exposure these organizations MUST have “approved processes” for vetting, testing and validating “approved software” and “approved systems”.
For example, in the Department of Defense there are many lists that have approved software. Â These lists are per command within larger organizations. Â One over arching process/list is the Common Criteria:
Common Criteria is an international standard for validating technical security built in to security feature of information systems. Â The international standard is known as ISO/IEC 15408.
This standard is used by many large organizations all over the world that serve the public:
www.commoncriteriaportal.org
www.commoncriteria.com
Each organization has there own specific security needs so most of the time they have many levels of application approval and process:
NSA / DOD / US Gov - www.niap-ccevs.org - National Information Assurance Partnership (NIAP) uses Common Criteria Evaluation and Validation Scheme (CCEVS) to ensure that only approved Information Assurance (IA)  and IA-Enabled Information Technology (IT) products are used
Canadian Trusted Computer Product Evaluation Criteria UK – www.cesg.gov.uk/servicecatalogue/ccitsec‎
Commercial organizations that want their products used by organization processing and storing critical information must submit to common criteria as well:
Apple – https://ssl.apple.com/support/security/commoncriteria/‎
Microsoft – www.microsoft.com/en-us/sqlserver/common-criteria.aspx‎
2014 Update: Â DIACAP has been replaced by RMF for DoD IT. Â The RMF for DoD IT is almost completely derived from the NIST SP 800-37.
NIST roles and responsibilities are addressed throughout the special publication 800 series. The definition of the roles & responsibilities are as follows:
Head of Agency
The Head of Agency is also known as the Chief Executive Officer. This role is the highest level executive senior officer within an organization. They have ultimate responsible for the providing information security protection. The level of protection must be at the same level as the importance of the information. The Department of Defense equivanent is a DoD Head of component (i.e. Secretary of the Army).
image of secretary army john mchugh
Risk Executive Function
The Risk Executive Function’s main focus is the overall risk to the entire organization. They create a risk strategy for the organization that guides mission/business process and system-level risk assessments. The Risk Executive Function is and important role for Tier 1 activities of managing risk of information systems IAW NIST SP 800-39.
CIO
Chief Information Officer is an organizational official responsible for (1) designating a senior information security officer; (2) developing and maintaining information security policies; (3) ensure that those with responsibilities in system security have proper training.
Information Owner/Steward
“The information owner/steward is an organizational official with statutory, management, or operational authority for specified information and the responsibility for establishing the policies and procedures governing its generation, collection, processing, dissemination, and disposal.” NIST SP 800-37 The Information Owner must coodinate with the Information System Owner (DoD PM equivalent) for decisions involving the overall system.
Senior Information Security Officer
The SISO is directly responsible to the CIO. They’re focus is the information security of the organization’s data. They act as a liaison between CIO and the Authorizing Official. The DoD equivalent (circa 2010) is known as the Senior Information Assurance Officer (SIAO).
Authorizing Official
AO formally accepts the risk of a system in the Implementation/Assessment phase of the System Development Lifecycle and Step 5, Authorization step of the Risk Management Framework.
Common Control Provider
“The common control provider is an individual, group, or organization responsible for the development, implementation, assessment, and monitoring of common controls.” NIST SP 800-37. A common control is a security controls that covers multiple information systems within and organization. Examples of common controls: Incident Response, Network boundary protection (firewalls, IDS/IPS).
Information System Owner
“The information system owner is an organizational official responsible for the procurement, development, integration, modification, operation, maintenance, and disposal of an information system.” NIST SP 800-37
Information System Security Engineer
“The information system security engineer is an individual, group, or organization responsible for conducting information system security engineering activities.” NIST SP 800-37 The ISSE implements security into the design of systems. The ISSE is often a consultant or Subject Matter Expert who focus is applying information assurance frameworks and regulations in an information system.
Information System Security Officer
This role is initiated at the Initial phase of the System Development Lifecycle (SDLC). “The information system security officer
is an individual responsible for ensuring that the appropriate operational security posture is maintained for an information system and as such, works in close collaboration with the information system owner” NIST SP 800-37. This role has been called and Information Assurance Officer (IAO) within the Department of Defense. Within the DoD this role is appointed by the Information Assurance Manager (IAM). Also known as the Information System Security Manager (ISSM). The ISSM is often responsible to over site and being a supervisor of ISSO positions.
Security Control Assessor
“The security control assessor is an individual, group, or organization responsible for conducting a comprehensive assessment of the management, operational, and technical security controls employed within or inherited by an information system to determine the overall effectiveness of the controls” NIST SP 800-37.
The NIST & DoD have very similar roles with different names:
DoDI 8510.01 DIACAP
NIST SP 800-37 Security Authorization
Heads of the DoD Components
Head of Agency (CEO)
Designated Accrediting Authority (DAA)/
Authorizing Official
Program Manager (PM)/ Systems Manager (SM)
Information System Owner
Information Assurance Manager (IAM)
Information System Security Officer
Information Assurance Officer (IAO)
Information System Security Officer/ Information System
Security Engineer
Understand the Risk Management Approach to Security Authorization
The concept of management of information security risks across an enterprise is discussed in 800-39. An organization takes a multitier approach to the risk management at the organizational, mission, and system levels. Risk management framework is a process that is broken down in NIST 800-37, Risk Management Framework. The CAP addresses the following:
Distinguish between applying risk management principles and satisfying compliance requirements
Identify and maintain information systems inventory
Understand the criticality of securing information
Understand organizational operations
Distinguish between applying risk management principles and satisfying compliance
Risk management includes satisfying compliance. Even though some controls may not be able to be made fully compliant due to limited resources, residual risk to the organization can still be mitigated and managed. – Concepts of NIST SP 800-37, Guide of RMF
Identifying and maintaining information system (IS) inventory is addressed in NIST 800-37, Risk Management Framework, 800-18, System Security Plan & 800-64, System Development Life Cycle. 800-37 addresses inventory of the IS in RMF Step 1 – Categorization of IS. Of the tasks of categorization includes information system registration which begins with by identifying the information system in the system inventory. This is documented in the security plan. NIST SP 800-18 discusses how the inventory is documents, and logically separates the system authorization boundary. That inventory is maintained and monitored throughout the life cycle of the IS (from imitation to disposal and from categorization to monitoring of the system).
A CAP candidate can understand the criticality of security information from reading FIPS 199, categorization of federal information systems.
Understanding the organizational operations of the system is imperative to a CAP candidate for the purpose of scope guidance described in NIST SP 800-53.
