fisma fedramp drupal
DESCRIPTION
Overview of FISMA and FedRAMP process and controls with a focus on Drupal layer controlsTRANSCRIPT
Agenda
• Review Current US Government Compliance landscape
• How to achieve FISMA Compliance
• International and Developing Compliance Standards
• How Acquia achieved a compliant ready hosting platform.
Drupal in the Federal Government• Governments are expanding use of Drupal
• Drupal is open source• Cost effective vs proprietary licensed software• Proven secure
• Drupal facilitates shared development between agencies
• Proven• www.whitehouse.gov• www.house.gov• www.ready.gov• www.investor.gov• www.teach.gov• www.ed.gov• www.energy.gov
Current US Government Compliance LandscapeFISMA, DIACAP and FedRAMP are standardized approaches to security assessment,
authorization, and continuous monitoring for information systems utilized by the Federal government.
FISMA - Federal Information Security Management Act of 2002. Applicable to non-DoD agencies.
DIACAP – Department of Defense Information Assurance Certification and Accreditation Process. Applicable to DoD related agencies.
With both FISMA and DIACAP each information system must be documented, reviewed by independent third party assessor and authorized by authorizing officials.
Time consuming, expensive
FedRAMP - Federal Risk and Authorization Management Program
• Establishes an “authorize once, use many times” framework for cloud computing products and services. FedRAMP is meant to supersede FISMA and DIACAP for cloud products.
• FedRAMP was established on Dec 8, 2011 via a memorandum produced by the Federal Chief Information Officer and is due to achieve Initial Operating Capacity in 2012.
• Based on the same NIST publications as FISMA with added controls pertinent to the cloud
• FedRAMP Concept of Operations – defines how the FedRAMP process will work
• http://www.gsa.gov/graphics/staffoffices/FedRAMP_CONOPS.pdf
Coming Soon - FedRAMP
FIPS 199 – Security categorization of the information system according to its Confidentiality, Availability and Integrity requirements
• What type of data?
• Importance to national security?
Determine “High water mark” (low, medium, high)
NIST 800-53 rev 3 – Security Controls documented in the SSP
All domains of security are covered and must be documented
Risk Assessment, Personnel, System Acquisition, Physical and Environmental, Contingency Planning, Configuration Management, Incident Response, Security Awareness Training, Authentication, Logging and Audit, Network Security and Encryption
Rev 4 now in draft – adds add’l mobile and cloud controls
NIST 800-30 – Risk Assessments
Defines process for assessing risk and how to apply the process to the organizational, mission and information system levels.
Important NIST Publications and Standards
FISMA, DIACAP and FedRAMP Process
Federal Compliance - High Level Process1. Categorize the System –
FIPS 199Confidentiality, Integrity,
Availability
2. Select the controls – NIST 800-53
3. Implement the controls and document them
-System Security Plan-Privacy Impact Assessment
4. Assess – Contract with Third Party Assessor
-3PAO reviews SSP and creates STE & POA&M
5. Authorize – This package of documents submitted to the
Authorizing Official who reviews, comments, asks for
revisions.-grants IATC and/or ATO
6.Monitor – Continuous update to SSP , continuous mitigation of items identified in STE and
POA&M
Step 1: Categorize the system –FIPS 199
Establish the “high water mark”- Low/Moderate or High
NIST 800-53 Revision 3
Annex 1 – Low “high water mark”
Annex 2 – moderate “high water mark”
Annex 3 – high “high water mark”
Step 2: Select the controls
Step 3: Implement and document the controlsThe System Security Plan (SSP) -a narrative description of the system
-define the “accreditation boundary” – what is it that is being authorized
-describes the system and the environment where it resides
.. And the controls, divided into control families:
Risk Assessment (RA)
Planning (PL)
System and Service Acquisition (SA) Access Control (AC)
Certification and Authorization (CA) Audit and Accountability (AU)
Personnel Security (PS) System and Communication Protection (SC)
Physical and Environmental Security (PE)
Continuity Planning (CP)
Configuration Management (CM)
Maintenance (MA)
System and Information Integrity (SI)
Media Protection (MP)
Incident Response (IR)
Awareness and Training (AT)
Identification and Authentication (IA)
Step 4: Assess The Controls (Audit)The assessment is a validation by an independent auditor that “you do what
you say you do”. Guided by NIST 800-53a
The third party assessor (3PAO) is tasked with reviewing the SSP and validating are those control in place.
3PAO creates Security Test & Evaluation Plan (ST&E) and the System Assessment Report (SAR) which documents the evidencing activities and results.
-What is non-compliant
Plan of Action Milestone (POA&M) – Lists controls which are not in place and the plan to implement those controls
Step 5: Authorize the SystemFinally the FISMA C&A Package is submitted to the Authorizing Official
The package:
• The SSP
• Relevant Policies and Procedures
• The FIPS 199 categorization
• The SAR and ST&E
• The POA&M
Authorizing Official once satisfied issues Authority to Operate (ATO)
Step 6: Monitor and Update
• Update the SSP as things change
• Resolve issues and follow plan per POA&M
• Continuous monitoring of risks
• Re-authorize system every 3 years
Accomplishing Federal Compliance in the Cloud
Cloud Service Providers may be responsible for the entire set of controls, or they may be shared in a Shared Responsibility ModelExamples:SaaS may be built on PaaS Ex: DrupalGardensPaaS may be built on IaaS Ex: Acquia Managed Cloud
Three primary layers in the shared responsibility model:•Application Layer (Drupal)•OS Stack Layer (Linux, Windows, Database, etc)•Infrastructure Layer (Datacenter, network)
*Each entity must document the controls for which they are responsible for.*
Example: Acquia Managed CloudAcquia Managed Cloud is a PaaS built on Amazon’s AWS IaaS
Example SSP control description:Control: (from 800-53)Control Type: Agency/Common/HybridControl Status: Implemented/Planned/Not Applicable
Application Layer:Responsibility: Customer (Agency)Implementation Detail: Describe how the control is the responsibility of the agency.
LAMP Stack Layer:Responsibility: AcquiaImplementation Detail: Describe how the control is implemented
Infrastructure:Responsibility: AmazonImplementation Detail: Refer to hosting provider’s SSP
Acquia documents its control responsibilities in its SSPAmazon documents its control responsibilities in its SSP
Example: Acquia Managed Cloud
FISMA Moderate Controls applicable to the Drupal layer
FISMA Moderate Controls applicable to the Drupal layer
FISMA Moderate Controls applicable to the Drupal layer
How to implement these controls:-OpenPublic distribution
-Drupal modules:Password Policy
http://drupal.org/project/password_policy
