Practice CA.L2-3.12.3 Details

Source of Reference: The official CMMC Level 2 Assessment Guide from the Office of the Under Secretary of Defense Acquisition & Sustainment.

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CA.L2-3.12.3 – SECURITY CONTROL MONITORING

SECURITY REQUIREMENT

Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls.

ASSESSMENT OBJECTIVES

Determine if:

[a] security controls are monitored on an ongoing basis to ensure the continued effectiveness of those controls.

POTENTIAL ASSESSMENT METHODS AND OBJECTS

Examine

[SELECT FROM: Security planning policy; organizational procedures addressing system security plan development and implementation; procedures addressing system security plan reviews and updates; enterprise architecture documentation; system security plan;records of system security plan reviews and updates; other relevant documents or records].

Interview

[SELECT FROM: Personnel with security planning and system security plan implementation responsibilities; personnel with information security responsibilities].

Test

[SELECT FROM: Organizational processes for system security plan development, review, update, and approval; mechanisms supporting the system security plan].

DISCUSSION

Continuous monitoring programs facilitate ongoing awareness of threats, vulnerabilities, and information security to support organizational risk management decisions. The terms continuous and ongoing imply that organizations assess and analyze security controls and information security-related risks at a frequency sufficient to support risk-based decisions.The results of continuous monitoring programs generate appropriate risk response actions by organizations. Providing access to security information on a continuing basis through reports or dashboards gives organizational officials the capability to make effective and timely risk management decisions.Automation supports more frequent updates to hardware, software, firmware inventories, and other system information. Effectiveness is further enhanced when continuous monitoring outputs are formatted to provide information that is specific, measurable, actionable, relevant, and timely.Monitoring requirements, including the need for specific monitoring, may also be referenced in other requirements.

NIST SP 800-137 provides guidance on continuous monitoring.

FURTHER DISCUSSION

Provide a plan for monitoring the state of security controls on a recurring basis that occurs more frequently than the periodic assessments discussed in CA.L2-3.12.1. This process provides a mechanism to assess the overall security posture of your organization, which directly relates to activities discussed in CA.L2-3.12.4. As a result, the process not only maintains awareness of vulnerabilities and threats, but it also informs management of the effectiveness of the security controls in determining if security controls are current and for management to make an acceptable risk decision.

Example

You are responsible for ensuring your company fulfills all cybersecurity requirements for its DoD contracts. You review those requirements and the security controls your company has put in place to meet them. You then create a plan to evaluate each control regularly over the next year. You mark several controls to be evaluated by a third-party security assessor. You assign other IT resources in the organization to evaluate controls within their area of responsibility. To ensure progress you establish recurring meetings with the accountable IT staff to assess continuous monitoring progress, review security information, evaluate risks from gaps in continuous monitoring, and produce reports for your management [a].

Potential Assessment Considerations

• Are the security controls that need to be continuously monitored identified [a]?
• Is the timeframe for continuous monitoring activities to support risk-based decision making defined [a]?
• Is the output of continuous monitoring activities provided to stakeholders [a]?

KEY REFERENCES

• NIST SP 800-171 Rev 2 3.12.3