LLMPrompt CM.L2-3.4.4

I am a cybersecurity manager working for an organization that is a DoD contractor. I need to implement various security practices that conform to DoD's CMMC program at level 2. The CMMC program stipulates security practices that are based on NIST Special Publication 800-171 R2. For each security practice of CMMC Level 2, I need to show evidence that my organization is in compliance with CMMC. Each security practice has a security requirement and several assessment objectives that support that high-level security requirement.

I am assessing one of the assessment objectives within the practice CM.L2-3.4.4 – SECURITY IMPACT ANALYSIS. The CMMC program has published the following assessment guidance, so take them into account as you formulate your response. Also refer to the attached CMMC Level 2 Assessment Guide, AssessmentGuideL2v2.pdf, for more context and information about the practice.

A. SECURITY REQUIREMENT: Analyze the security impact of changes prior to implementation.

B. ASSESSMENT OBJECTIVES: Determine if: [a] the security impact of changes to the system is analyzed prior to implementation.

C. ASSESSMENT APPROACHES: I have three assessment approaches for assessing any security practice. They are listed as follows:

C1. Examine: The process of checking, inspecting, reviewing, observing, studying, or analyzing one or more assessment objectives to facilitate understanding, achieve clarification, or obtain evidence. The results are used to support the determination of security safeguard existence, functionality, correctness, completeness, and potential for improvement over time.

C2. Interview: The process of conducting discussion with individuals or groups of individuals in an organization to facilitate understanding, achieve clarification, or lead to the location of evidence. The results are used to support the determination of security safeguard existence, functionality, correctness, completeness, and potential for improvement over time.

C3. Test: The process of exercising one or more assessment objects under specified conditions to compare actual with expected behavior. The results are used to support the determination of security safeguard existence, functionality, correctness, completeness, and potential for improvement over time.

D. ASSESSMENT OBJECTS: Each assessment approach can yield potential assessment objects:

D1. Examine: [SELECT FROM: Configuration management policy; procedures addressing security impact analysis for system changes; configuration management plan; security impact analysis documentation; system security plan; analysis tools and associated outputs; change control records; system audit logs and records; other relevant documents or records].

D2. Interview: [SELECT FROM: Personnel with responsibility for conducting security impact analysis; personnel with information security responsibilities; system or network administrators].

D3. Test: [SELECT FROM: Organizational processes for security impact analysis].

E. DISCUSSION: Organizational personnel with information security responsibilities (e.g., system administrators, system security officers, system security managers, and systems security engineers) conduct security impact analyses. Individuals conducting security impact analyses possess the necessary skills and technical expertise to analyze the changes to systems and the associated security ramifications. Security impact analysis may include reviewing security plans to understand security requirements and reviewing system design documentation to understand the implementation of controls and how specific changes might affect the controls. Security impact analyses may also include risk assessments to better understand the impact of the changes and to determine if additional controls are required. NIST SP 800-128 provides guidance on configuration change control and security impact analysis.

F. FURTHER DISCUSSION: Changes to complex environments are reviewed for potential security impact before implemented. Changes to IT systems can cause unforeseen problems and have unintended consequences for both users and the security of the operating environment. Analyze the security impact of changes prior to implementing them. This can uncover and mitigate potential problems before they occur.

G. Example: You have been asked to deploy a new web browser plug-in. Your standard change management process requires that you produce a detailed plan for the change, including a review of its potential security impact. A subject-matter expert who did not submit the change reviews the plan and tests the new plug-in for functionality and security. You update the change plan based on the expert’s findings and submit it to the change control board for final approval [a].

H. Potential Assessment Considerations: Are configuration changes tested, validated, and documented before installing them on the operational system [a]?

I. EVIDENCE TYPES: Finally, I have four evidence types that I can collect. The definitions of the evidence types are as follows:

I1. Artifacts: Tangible and reviewable records that are the direct outcome of a practice or process being performed by a system, person, or persons performing a role in that practice, control, or process. (See CAP Glossary for additional details.)

I2. Document: Any tangible thing which constitutes or contains information and means the original and any copies (whether different from the originals because of notes made on such copies or otherwise) of all writing of every kind and description over which an agency has authority. (See CAP Glossary for additional details.)

I3. Physical Review: An on-premise observation of Evidence.

I4. Screen Share: Live observation ""over the shoulder"" of a user as they share their computer screen while performing a task.

J. KEY REFERENCES: NIST SP 800-171 Rev 2 3.4.4