When it comes to cloud, security is always a concern, and should be appropriately addressed by any organization (e.g., consumer) evaluating or using a cloud solution.
The following graphic illustrates the differences in security responsibilities between cloud consumers and Cloud Service Providers (CSPs) for each cloud service model (IaaS, PaaS, SaaS) in comparison to an organization owned and managed data center.
As indicated in the graphic, consumers and Cloud Service Providers (CSPs) security responsibilities are dependent on the cloud service model procured. Understanding this shared security responsibility model is fundamental to ensuring the appropriate allocation of security compliance responsibilities (i.e., impact level, security controls).
NIST SP 800-37 - Risk Management Framework for Information Systems and Organizations Revision 2 - provides the guidelines for applying the Risk Management Framework (RMF) to information systems and organizations. The RMF provides a disciplined, structured, and flexible process for managing security and privacy risk that includes information security categorization, control selection, implementation, and assessment, system and common control authorizations, and continuous monitoring.
NIST SP 800-53 - Security and Privacy Controls for Information Systems and Organizations Revision 5 defines the security control baselines that represent the starting point in determining the functional or operational requirements for securing low-impact, moderate-impact, and high-impact federal information systems.
NIST SP 800-53 defines security controls for following security control identifiers and families:
- Access Control (AC)
- Awareness and Training (AT)
- Audit and Accountability (AU)
- Security Assessment and Authorization (CA)
- Configuration Management (CM)
- Contingency Planning (CP)
- Identification and Authentication (IA)
- Incident Response (IR)
- Maintenance (MA)
- Media Protection (MP)
- Physical and Environmental Protection (PE)
- Planning (PL)
- Personnel Security (PS)
- Risk Assessment (RA)
- System and Services Acquisition (SA)
- System and Communications Protection (SC)
- System and Information Integrity (SI)
- Program Management (PM)
Federal Government Agency Security Responsibilities
The Federal Information Security Management Act (FISMA) identifies that federal government agencies are ultimately accountable for maintaining the security of their networks and Information Technology (IT) systems inclusive of IT systems leveraging or completely deployed using cloud solutions.
Federal government agencies are also responsible for ensuring that cloud products and services are operated and maintained at all times within the parameters of the agencies issued Authorizations to Operate (ATOs) and to conduct appropriate oversight of security operations and management.
What is an Authorization to Operate (ATO)?
It's an official management decision issued by a senior organizational official (e.g., Information System Security Officer (ISS)) that authorizes the operation of an information system (e.g., cloud infrastructure) and explicitly accepts security risks based on the implementation of an agreed-upon set of security controls.
Federal government agencies should familiarize themselves with and understand their Cloud Service Providers (CSPs) security tools (e.g., Identity Access Management (IAM)) in addition to ensuring that their existing suite of security tools are operational with, and extended as appropriate, to secure their cloud solutions.
How do federal agencies manage all this?
With both organizations and Cloud Service Providers (CSPs) being responsible for individual security controls, there needs to be a mechanism that manages, reviews, and audits the CSPs responsible security controls, allowing organizations to inherit the CSPs security controls to support the organization’s security review and authorization processes.
The federal government has identified and tasked individual agencies or programs with cybersecurity responsibilities to support the protection of federal government networks and information systems that in turn provide the mechanisms for the oversight of CSPs.
Federal Civilian Agency - Cloud Security Information
FedRAMP - (Federal Risk and Authorization Management Program)
The Federal Risk and Authorization Management Program (FedRAMP) is a federal government-wide program that provides a standardized approach to security assessment, authorization, and continuous monitoring of cloud products and services from Cloud Service Providers (CSPs).
Under FedRAMP, a cloud product or service undergoes a security assessment to identify the applicable security controls and control baselines. The scope of the security assessment is based on two factors:
- Impact Level - The identification (i.e., low-impact, moderate-impact, high-impact) is based on the federal government’s requirements for the Confidentially, Integrity, and Availability (CIA) of the information or information systems accessed or processed by the cloud product or service per the Federal Information Processing Standards Publication 199 (FIPS PUB 199) - Standards for Security Categorization of Federal Information and Information Systems.
- Cloud Service Model - The identification (i.e., IaaS, PaaS, SaaS) is used to identify the applicable security control identifiers and families for the cloud product or service per NIST SP 800-53 - Security and Privacy Controls for Information Systems and Organizations Revision 5.
Upon the successful completion of an assessment, a cloud product or service will be issued a FedRAMP authorization at the combination of assessed impact level and cloud service model. FedRAMP post-authorization conducts continuous monitoring, re-authorizations, and audits of authorized cloud products and services to ensure that Cloud Service Providers (CSPs) remain in compliance with authorizations and address emerging and evolving security threats.
FedRAMP publishes a listing of all authorized cloud products and services to the FedRAMP Marketplace.
FedRAMP uses a “do once, use many times” framework that reduces cost, time, and labor required for security assessments by maintaining a FedRAMP repository of authorizations for federal government agencies to review, leverage, and inherit the security controls for issuance of federal government agencies Authorizations to Operate (ATOs).
Is FedRAMP a requirement?
The Office of Management and Budget (OMB) Memorandum - Security Authorization of Information Systems in Cloud Computing Environments dated December 8, 2011 states that Executive department or agencies shall:
- "use FedRAMP when conducting risk assessments, security authorizations, and granting Authorities to Operate (ATO) for all Executive department or agency use of cloud services" and
- "use the FedRAMP PMO process and the JAB-approved FedRAMP security authorization requirements as a baseline when initiating, reviewing, granting and revoking security authorizations for cloud services”
Department of Homeland Security – Continuous Diagnostics and Mitigation Program (DHS-CDM)
The Department of Homeland Security-Continuous Diagnostics and Mitigation Program (DHS-CDM) provides capabilities to the federal government to support near-real time asset management, identity and access management, network security management, and data protection management of on premise data centers and cloud solutions. The DHS-CDM program is also available to support state and local governments and to the defense industrial base.
DHS-CDM has established and maintains the DHS-CDM Approved Products List (APL), which is the federal government’s authoritative products catalog, for products that meet DHS-CDM Supply Chain Risk Management (SCRM) and technical requirements.
Department of Homeland Security – Trusted Internet Connection Initiative
The Department of Homeland Security-Trusted Internet Connections (DHS-TIC) initiative, as outlined in the Office of Management and Budget (OMB) Memorandum M-19-26 Update to the Trusted Internet Connection (TIC) Initiative, date September 12, 2019, focuses on enhancing network and perimeter security across the federal government.
The DHS-TIC initiative emphasis agile and responsive security solutions that support the accelerated adoption of cloud, mobile, and other emerging technologies. The DHS-TIC initiative provides guidance to federal government agencies with the flexibility to secure distinctive computing scenarios in accordance with their unique risk tolerance levels. Federal government agencies are expected to reference the initiative’s Program Guidebook, Reference Architecture, and Security Capabilities Handbook to determine how to protect their environments to conform to their risk management strategy and the security considerations outlined in DHS-TIC Use Cases.
Department of Defense - Cloud Security Information
DoD Cloud Computing Security Requirements Guide (DoD CC SRG)
The Defense Information Systems Agency (DISA) published the Department of Defense Cloud Computing Security Requirements Guide (DoD CC SRG) that outlines the security model and requirements by which DoD will leverage cloud computing along with the security controls and requirements necessary for using cloud-based solutions.
The DoD CC SRG is based on the Federal Information Security Management Act (FISMA) and NIST Special Publication 800-37.
The DoD CC SRG applies a FedRAMP+ concept, leveraging the work done as part of the FedRAMP assessment and authorization processes, and adds specific security controls and requirements necessary to meet and assure DoD’s security considerations and requirements.
DISA publishes a listing of all authorized cloud products and services on the DISA Storefront – Cloud Service Support.
DoD Impact Levels
The DoD CC SRG defines the standards for categorizing DoD information and information systems and breaks them into 4 Impact Levels (DoD ILs):
- DoD IL 2 - Public or Non-Critical Mission Information - Cloud products or services that have been issued a FedRAMP authorization at the "Moderate Impact Level" are designated DoD IL 2 via reciprocity per DISA Memorandum August 15, 2019: Department of Defense (DoD) Memorandum of Reciprocity for FedRAMP Authorized Moderate Baseline Cloud Service Offerings (CSO) at Impact Level 2 (IL2)
- DoD IL 4 - Controlled Unclassified Information (CUI) or Non-CUI, Non-Critical Mission Information, Non-National Security Systems
- DoD IL 5 - Higher Sensitivity Controlled Unclassified Information (CUI), Mission Critical Information, National Security Systems
- DoD IL 6 - Classified SECRET, National Security Systems
The categorization is based on classification and the potential impact should the Confidentially, Integrity, or Availability (CIA) of the DoD information or information system be compromised.
DoD Risk Management Framework
Department of Defense Instruction (DoDI) 8510.01 Risk Management Framework (RMF), Incorporating Change 3, December 29, 2020 - is the implementing policy for the DoD Risk Management Framework (RMF) establishing associated cybersecurity policy and assigning responsibilities for executing and maintaining the RMF.
DoDI 8510.01 is consistent with:
- NIST SP 800-37 - Risk Management Framework for Information Systems and Organizations Revision 2
- NIST SP 800-53 - Security and Privacy Controls for Information Systems and Organizations Revision 5
- Committee on National Security Systems (CNSSI 1253) - Security Categorization and Control Selection for National Security Systems
DoDI 8510.01 "provides procedural guidance for the reciprocal acceptance of authorization decisions and artifacts within DoD, and between DoD and other federal agencies, for the authorization and connection of information systems (ISs)."