Risk Assessment (RA)¶
RA.L2-3.11.1 – RIsk Assessments¶
Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI.
Assessment Objectives¶
Source: NIST SP 800-171A, p. 49.
Determine if:
- [a] the frequency to assess risk to organizational operations, organizational assets, and individuals is defined; and
- [b] risk to organizational operations, organizational assets, and individuals resulting from the operation of an organizational system that processes, stores, or transmits CUI is assessed with the defined frequency.
Potential Assessment Methods and Objects¶
Source: NIST SP 800-171A, p. 49.
Examine: [SELECT FROM: Risk assessment policy; security planning policy and procedures; procedures addressing organizational risk assessments; system security plan; risk assessment; risk assessment results; risk assessment reviews; risk assessment updates; other relevant documents or records].
Interview: [SELECT FROM: Personnel with risk assessment responsibilities; personnel with information security responsibilities].
Test: [SELECT FROM: Organizational processes for risk assessment; mechanisms supporting or for conducting, documenting, reviewing, disseminating, and updating the risk assessment].
Discussion¶
Source: NIST SP 800-171 Rev. 2, p. 33.
Clearly defined system boundaries are a prerequisite for effective risk assessments. Such risk assessments consider threats, vulnerabilities, likelihood, and impact to organizational operations, organizational assets, and individuals based on the operation and use of organizational systems. Risk assessments also consider risk from external parties (e.g., service providers, contractor operating systems on behalf of the organization, individuals accessing organizational systems, outsourcing entities). Risk assessments, either formal or informal, can be conducted at the organization level, the mission or business process level, or the system level, and at any phase in the system development life cycle. NIST SP 800-30 provides guidance on conducting risk assessments.
Further Discussion¶
Risk arises from anything that can reduce an organization’s assurance of mission/business success; cause harm to image or reputation; or harm individuals, other organizations, or the Nation. Organizations assess the risk to their operations and assets at regular intervals. Areas where weakness or vulnerabilities could lead to risk may include:
- poorly designed and executed business processes;
- inadvertent actions of people, such as disclosure or modification of information;
- intentional actions of people inside and outside the organization;
- failure of systems to perform as intended;
- failures of technology; and
- external events, such as natural disasters, public infrastructure and supply chain failures.
When conducting risk assessments use established criteria and procedures. The results of formal risk assessments are documented. It is important to note that risk assessments differ from vulnerability assessments (see RA.L2-3.11.2). A vulnerability assessment provides input to a risk assessment along with other information such as results from likelihood analysis and analysis of potential treat sources. Risk assessments should be performed at defined regular intervals. Mission risks include anything that will keep an organization from meeting its mission. Function risk is anything that will prevent the performance of a function. Image and reputation risks refer to intangible risks that have value and could cause damage to potential or future trust relationships. 173 This requirement, RA.L2-3.11.1, which requires periodically assessing the risk to organization systems, assets, and individuals, is a baseline Risk Assessment requirement. RA.L2-3.11.1 enables other Risk Assessment requirements (e.g., RA.L2-3.11.3, Vulnerability Remediation), as well as CA.L2-3.12.2, Plan of Action.
Examples¶
- You are a system administrator. You and your team members are working on a big government contract requiring you to store CUI. As part of your periodic (e.g., annual) risk assessment exercise, you evaluate the new risk involved with storing CUI [a,b]. When conducting the assessment you consider increased legal exposure, financial requirements of safeguarding CUI, potentially elevated attention from external attackers, and other factors.
After determining how storing CUI affects your overall risk profile, you use that as a basis for a conversation on how that risk should be mitigated.
Potential Assessment Considerations¶
- Have initial and periodic risk assessments been conducted [b]?
- Are methods defined for assessing risk (e.g., reviewing security assessments, incident reports, and security advisories, identifying threat sources, threat events, and vulnerabilities, and determining likelihood, impact, and overall risk to the confidentiality of CUI) [b]?
Key References¶
- NIST SP 800-171 Rev. 2 3.11.1
RA.L2-3.11.2 – Vulnerability Scan¶
Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified.
Assessment Objectives¶
Source: NIST SP 800-171A, pp. 49-50.
Determine if:
- [a] the frequency to scan for vulnerabilities in organizational systems and applications is defined;
- [b] vulnerability scans are performed on organizational systems with the defined frequency;
- [c] vulnerability scans are performed on applications with the defined frequency;
- [d] vulnerability scans are performed on organizational systems when new vulnerabilities are identified; and
- [e] vulnerability scans are performed on applications when new vulnerabilities are identified.
Potential Assessment Methods and Objects¶
Source: NIST SP 800-171A, pp. 49-50.
Examine: [SELECT FROM: Risk assessment policy; procedures addressing vulnerability scanning; risk assessment; system security plan; security assessment report; vulnerability scanning tools and associated configuration documentation; vulnerability scanning results; patch and vulnerability management records; other relevant documents or records].
Interview: [SELECT FROM: Personnel with risk assessment, security assessment and vulnerability scanning responsibilities; personnel with vulnerability scan analysis and remediation responsibilities; personnel with information security responsibilities; system or network administrators].
Test: [SELECT FROM: Organizational processes for vulnerability scanning, analysis, remediation, and information sharing; mechanisms supporting or implementing vulnerability scanning, analysis, remediation, and information sharing].
Discussion¶
Source: NIST SP 800-171 Rev. 2, pp. 33-34.
Organizations determine the required vulnerability scanning for all system components, ensuring that potential sources of vulnerabilities such as networked printers, scanners, and copiers are not overlooked. The vulnerabilities to be scanned are readily updated as new vulnerabilities are discovered, announced, and scanning methods developed. This process ensures that potential vulnerabilities in the system are identified and addressed as quickly as possible. Vulnerability analyses for custom software applications may require additional approaches such as static analysis, dynamic analysis, binary analysis, or a hybrid of the three approaches. Organizations can employ these analysis approaches in source code reviews and in a variety of tools (e.g., static analysis tools, web-based application scanners, binary analyzers). Vulnerability scanning includes: scanning for patch levels; scanning for functions, ports, protocols, and services that should not be accessible to users or devices; and scanning for improperly configured or incorrectly operating information flow control mechanisms. To facilitate interoperability, organizations consider using products that are Security Content Automated Protocol (SCAP)-validated, scanning tools that express vulnerabilities in the Common Vulnerabilities and Exposures (CVE) naming convention, and that employ the Open Vulnerability Assessment Language (OVAL) to determine the presence of system vulnerabilities. Sources for vulnerability information include the Common Weakness Enumeration (CWE) listing and the National Vulnerability Database (NVD). Security assessments, such as red team exercises, provide additional sources of potential vulnerabilities for which to scan. Organizations also consider using scanning tools that express vulnerability impact by the Common Vulnerability Scoring System (CVSS). In certain situations, the nature of the vulnerability scanning may be more intrusive or the system component that is the subject of the scanning may contain highly sensitive information. Privileged access authorization to selected system components facilitates thorough vulnerability scanning and protects the sensitive nature of such scanning. NIST SP 800-40 provides guidance on vulnerability management.
Further Discussion¶
A vulnerability scanner is an application that identifies vulnerabilities in organizational assets. Most scanners can create a prioritized list of vulnerabilities ordered by their level of severity. Scan for vulnerabilities on all devices connected to the network including servers, desktops, laptops, virtual machines, containers, firewalls, switches, and printers. All assets that are within the scope of the CMMC assessment must be scanned, including assets such as laptop computers that may not routinely connect to an organization’s network. Perform reviews of your organization’s custom-developed software. Vulnerability analysis of a custom-made solution may require a penetration tester to properly test and validate findings. Automated vulnerability scanners may not be as thorough when scanning custom developed applications. Source code scanners can help identify weaknesses and vulnerabilities within code prior to compilation and use.
The vulnerability scanning process is a regular activity, not a single occurrence. Organizations put in place a vulnerability scanner that updates its database each time it performs a scan so it can identify the most current known vulnerabilities. Schedule scans with consideration of the potential for impact to normal operations and use caution when scanning critical assets. This requirement, RA.L2-3.11.2, which ensures scanning for vulnerabilities in organizational systems and application, is a baseline Risk Assessment requirement. RA.L2-3.11.2, contributes to performing risk assessments as described in RA.L2-3.11.1.
Examples¶
- You are a system administrator. Your organization has assessed its risk and determined that it needs to scan for vulnerabilities in systems and applications once each quarter [a]. You conduct some tests and decide that it is important to be able to schedule scans after standard business hours. You also realize that you have remote workers and that you will need to be sure to scan their remote computers as well [b]. After some final tests, you integrate the scans into normal IT operations, running as scheduled [b,c]. You verify that the scanner application receives the latest updates on vulnerabilities and that those are included in future scans [d,e].
Potential Assessment Considerations¶
- Is the frequency specified for vulnerability scans to be performed in organizational systems and applications (e.g., continuous passive scanning, scheduled active scans) [a]?
- Are vulnerability scans performed on a defined frequency or randomly in accordance with company policy [a,b,c]?
- Are systems periodically scanned for common and new vulnerabilities [d,e]?
- Is the list of scanned system vulnerabilities updated on a defined frequency or when new vulnerabilities are identified and reported [d,e]?
Key References¶
- NIST SP 800-171 Rev. 2 3.11.2
RA.L2-3.11.3 – Vulnerability Remediation¶
Remediate vulnerabilities in accordance with risk assessments.
Assessment Objectives¶
Source: NIST SP 800-171A, p. 50.
Determine if:
- [a] vulnerabilities are identified; and
- [b] vulnerabilities are remediated in accordance with risk assessments.
Potential Assessment Methods and Objects¶
Source: NIST SP 800-171A, p. 50.
Examine: [SELECT FROM: Risk assessment policy; procedures addressing vulnerability scanning; risk assessment; system security plan; security assessment report; vulnerability scanning tools and associated configuration documentation; vulnerability scanning results; patch and vulnerability management records; other relevant documents or records].
Interview: [SELECT FROM: Personnel with risk assessment, security assessment and vulnerability scanning responsibilities; personnel with vulnerability scan analysis responsibilities; personnel with vulnerability remediation responsibilities; personnel with information security responsibilities; system or network administrators].
Test: [SELECT FROM: Organizational processes for vulnerability scanning, analysis, remediation, and information sharing; mechanisms supporting or implementing vulnerability scanning, analysis, remediation, and information sharing].
Discussion¶
Source: NIST SP 800-171 Rev. 2, p. 34.
Vulnerabilities discovered, for example, via the scanning conducted in response to RA.L2-3.11.2, are remediated with consideration of the related assessment of risk. The consideration of risk influences the prioritization of remediation efforts and the level of effort to be expended in the remediation for specific vulnerabilities.
Further Discussion¶
Not all vulnerabilities captured in a vulnerability scanner may pose the same level of risk to an organization. Prioritize mitigation efforts to close the most critical vulnerabilities first.
Track all vulnerability remediation to ensure completion; also track vulnerabilities that you have determined not to remediate. This requirement, RA.L2-3.11.3, benefits from CA.L2-3.12.2. RA.L2-3.11.3 allows remediation of vulnerabilities to take place based on the developed plans of actions for vulnerabilities from CA.L2-3.12.2.
Examples¶
- You are a system administrator. Each quarter you receive a list of vulnerabilities generated by your company’s vulnerability scanner [a]. You prioritize that list and note which vulnerabilities should be targeted as soon as possible as well as which vulnerabilities you can safely defer addressing at this time. You document the reasoning behind accepting the risk of the unremediated flaws and note to continue to monitor these vulnerabilities in case you need to revise the decision at a later date [b].
Potential Assessment Considerations¶
- Are the results of risk assessments used to prioritize vulnerabilities for remediation [b]?
- For any given vulnerability is action taken for remediation, acceptance, avoidance, or transference of the vulnerability risk [b]?
- Are all high risk vulnerabilities prioritized [b]?
Key References¶
- NIST SP 800-171 Rev. 2 3.11.3