NIST 800-53 Contingency Planning: Ensuring Business Continuity in the Face of Disruption

In today's digital landscape, organizations must be prepared for unforeseen events that could disrupt their operations. This is a big statement because you are trying to predict unforeseen events - - get out your magic 8 ball…


Let’s delve into the specifics of NIST 800-53 CP (Contingency Planning)  controls, offering detailed insights and implementation strategies.


1. CP-1: Contingency Planning Policy and Procedures


The foundation of any robust contingency plan is a well-defined policy. Think about writing policy as if you are writing it for a 5th grader. Policies should be understood by any employee - yes, it does not matter what their job is… 


CP-1 requires organizations to:


- Develop, document, and disseminate contingency planning policies

- Establish procedures to facilitate policy implementation - - this little detail here is where this control gets its bite. Procedures for the unforeseen…


Example Policy Statement:

"Our organization will maintain a comprehensive Contingency Plan that is reviewed annually and tested semi-annually. This plan will address all critical systems and business functions, ensuring minimal disruption in the event of an incident."


Key Procedures might include:

- Annual risk assessment to identify critical systems (this should also be done on an ongoing basis during the design phase of the SDLC)

- Quarterly review of roles and responsibilities

- Monthly backup and recovery tests (this is not a set timeframe, it should be about what works for your organization)


2. CP-2: Contingency Plan


This control focuses on developing and maintaining a comprehensive contingency plan. 


Key elements include:


a) Identifying essential missions and business functions - read this as what you REALLY need

b) Defining recovery objectives and restoration priorities - how do you get the things you REALLY need working

c) Addressing roles, responsibilities, and lines of communication - who is responsible for what and ensure you have pre-written templates for communication because it is way easier to edit in a crisis than start from scratch.


Specific Plan Components:

- Business Impact Analysis (BIA) results

- Alternate processing site details

- Data backup procedures and locations

- Emergency contact information (don’t forget to include outside counsel!)

- Step-by-step recovery procedures for each critical system (THIS RIGHT HERE)


Example Recovery Time Objective (RTO) Table:

```

| System         | RTO    | RPO    | Priority |

|----------------|--------|--------|----------|

| ERP           | 4 hrs  | 15 min | High     |

| Email         | 12 hrs | 1 hr    | Medium  |

| File Server | 24 hrs | 4 hrs  | Low      |

```


3. CP-3: Contingency Training


Organizations must provide contingency training to personnel with assigned roles. 


This control requires:


- Initial training for new personnel (ensure this matches your policy statement…” within 10 days of assuming the role and specific training within 60 days”...)

- Annual refresher training

- Simulations and tabletop exercises


Contingency Training Example:

1. Overview of the Contingency Plan

2. Individual roles and responsibilities

3. Communication protocols during an incident

4. Hands-on practice with recovery tools and procedures

5. Scenario-based exercises or live exercises depending on your requirements and the maturity of your organization


4. CP-4: Contingency Plan Testing


Regular testing of the contingency plan is crucial. 


CP-4 mandates:


- Annual testing of the plan

- Reviewing test results

- Updating the plan based on lessons learned


Test Types and Frequency:

- Tabletop Exercises: Quarterly

- Functional Exercises: Semi-annually

- Full-Scale Simulations: Annually


Example Test Scenario:

"Simulate a ransomware attack that encrypts critical data on the main file server. Initiate the contingency plan, including communication procedures, data recovery from backups, and failover to the alternate site."


5. CP-6: Alternate Storage Site


Organizations must identify an alternate storage site for system backups. 


Key requirements:


- Geographically distinct from the primary site (Cloud resources could be with a different provider or in a different region)

- Secure facility with appropriate environmental controls (Cloud users need to read the SSP and ensure it meets the requirements)

- Defined Service Level Agreements (SLAs) for data retrieval


Example SLA:

"The alternate storage provider guarantees data retrieval within 2 hours of request, 24/7/365, with 99.99% availability."


6. CP-7: Alternate Processing Site


This control requires establishing an alternate processing site capable of supporting essential operations. Considerations include:


- Equipment and supplies at the alternate site

- Telecommunications and information system connections

- Defined activation time for the alternate site


Alternate Site Specifications:

- Location: At least 100 miles from primary site

- Capacity: Able to support 80% of normal operations

- Activation Time: Fully operational within 24 hours


7. CP-9: System Backup


CP-9 focuses on regular system backups. 


Key requirements:


- Defined frequency and scope of backups

- Daily backups of incremental

- Weekly or based on recovery objectives

- Testing of backup information

- I have many stories of companies with backups that they did not test and could not use…

- Protection of backup information


Backup Strategy Example:

```

Daily: Incremental backups of all systems

Weekly: Full backups of all systems

Monthly: Full backups stored at alternate site

Quarterly: Backup restoration tests

```


8. CP-10: System Recovery and Reconstitution


This control ensures that systems can be recovered and reconstituted to a known secure state. 


Key aspects:


- Documented recovery procedures (that are understood easily)

- Automated tools for system recovery

- Integrity checks during reconstitution


Recovery Procedure Example:

1. Isolate affected systems

2. Verify integrity of backup data

3. Restore systems from clean backups

4. Apply all security patches

5. Perform integrity checks and vulnerability scans

6. Gradually reintroduce systems to the network


By developing comprehensive plans, conducting regular training and testing, and establishing robust backup and recovery procedures, organizations can minimize the impact of disruptions and quickly resume normal operations.


Remember, contingency planning is an ongoing process. Regularly review and update your plans to address new threats, technologies, and business requirements. By doing so, you'll build a resilient organization capable of weathering the unforeseen.​​​​​​​​​​​​​​​​

Comments

Post a Comment

Popular posts from this blog

Understanding Protection (SC)

Understanding Protection (SC) These controls focus on protecting system boundaries, communications, and preventing unauthorized data exposure. Let's break down the key SC controls with examples. SC-1: Policy and Procedures This foundational control requires documented policies and procedures for system and communications protection. Example: SYSTEM AND COMMUNICATIONS PROTECTION POLICY Version: 2.1 Last Updated: 2025-01-02 1. PURPOSE This policy establishes requirements for protecting the organization’s cloud infrastructure and communications. 2. SCOPE Applies to all cloud systems within the authorization boundary. 3. POLICIES 3.1 Encryption Requirements - All data in transit must use TLS 1.2 or higher - All data at rest must use FIPS 140-2 validated encryption - Key rotation required every 365 days 3.2 Network Security - All external connections must traverse a DMZ - Firewall rules follow deny-by-default principle - Monthly review of access control lists 4. PROCEDURES 4.1 Firewall ...
Read more

Security Assessment (SA) Controls

The Security Assessment (SA) family of controls, derived from NIST 800-53 Revision 5, plays a pivotal role in keeping systems secure over time. What Are the Security Assessment (SA) Controls? The SA family of controls focuses on ensuring that security controls are assessed for their effectiveness and are continuously monitored throughout the life of the system. This means checking whether the security measures in place are not only effective but remain effective and up-to-date as time progresses. For FedRAMP Moderate, these controls are crucial because: They ensure security controls are evaluated regularly. They support continuous monitoring for vulnerabilities or weaknesses. They establish corrective actions when necessary. SA-1: Security Assessment and Authorization Policies and Procedures Control Overview SA-1 requires the development of security assessment and authorization (A&A) policies and procedures. These procedures outline the process for conducting security assessm...
Read more

FedRAMP Moderate Rev 5 SI Controls

  In this post, I'll break down each SI control in FedRAMP Moderate Rev 5 and provide tips.   SI-1: System and Information Integrity Policy and Procedures The key to a strong base is well-documented policies and procedures.  For SI-1, organizations must: - Develop and maintain system and information integrity policies that address purpose, scope, roles, and responsibilities - Define procedures for implementing security controls - Review and update these documents at least annually Example:  Create a System and Information Integrity Policy document that includes: - Malware protection requirements with procedures - System monitoring procedures - Software and firmware update processes - Security alert handling processes and procedures - Error handling protocols  SI-2: Flaw Remediation Flaw remediation is key for maintaining system security.  Organizations must: - Identify, report, and correct system flaws promptly - Test software updates before deployment...
Read more