Security Assessment and Authorization (CA) Controls

 Today, I'll explain the CA controls for FedRAMP Moderate Rev 5 and provide examples.

 

CA-1: Security Assessment and Authorization Policy and Procedures


This control requires organizations to develop, document, and disseminate policies and procedures for security assessment and authorization.


Example: 

Create a comprehensive document outlining your organization's approach to security assessments, including frequency, scope, and responsible parties. Ensure this document is readily available to all relevant stakeholders and reviewed annually, at minimum, and when significant changes occur.


CA-2: Security Assessments


Organizations must conduct regular security assessments to evaluate the effectiveness of implemented security controls.


Example: 

Implement a quarterly vulnerability scanning program using tools like Nessus or Qualys, coupled with annual penetration testing by a third-party security firm. This can also be audits conducted annually (⅓ controls) by a third-party auditor.


CA-3: Information Exchange


This control focuses on establishing agreements and security measures for information exchange between systems.


Example: 

When integrating with a third-party payment processor, create a detailed interconnection security agreement (ISA) that outlines data protection measures, encryption standards, and incident response procedures. This needs to be reviewed annually or when significant changes occur. 


CA-5: Plan of Action and Milestones


Organizations must develop and maintain a plan to address any identified security weaknesses or deficiencies. FedRAMP has a specific template for POA&M.


Example: 

After a security assessment reveals several vulnerabilities, create a POA&M document listing each vulnerability, its risk level, proposed remediation steps, responsible team members, and target completion dates. This is a monthly, at minimum, activity to update each item.


 CA-6: Authorization


This control requires formal authorization before information systems are put into operation.


Example:

Implement a change management process where new systems or significant changes must go through a security review and receive formal approval from the CISO before being deployed to production. This can also be a formal authorization for the system provided by the authorizing official. 


 CA-7: Continuous Monitoring


Organizations must establish a continuous monitoring program to maintain ongoing awareness of information security vulnerabilities and threats.


Example: 

Deploy a Security Information and Event Management (SIEM) system like Splunk to collect and analyze logs from various sources in real time. Set up alerts for suspicious activities and conduct weekly security metric reviews.


 CA-8: Penetration Testing


This control requires organizations to conduct penetration testing at specified frequencies to identify exploitable vulnerabilities.


Example: 

Engage a reputable cybersecurity firm to conduct annual external and internal penetration tests, including web application testing, network infrastructure testing, and social engineering assessments.


 CA-9: Internal System Connections


Organizations must authorize, document, and monitor internal connections between information systems.


Example: 

Maintain an up-to-date network diagram showing all internal system connections. Implement network segmentation using VLANs and firewall rules to control traffic between different system components.


By implementing these CA controls effectively, organizations can significantly enhance their security posture and maintain compliance with FedRAMP Moderate Rev 5 requirements. Remember, security is an ongoing process, and these controls should be regularly reviewed and updated to address evolving threats and organizational changes.

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