Planning Controls in FedRAMP Moderate Revision 5

Planning (PL) Controls in FedRAMP Moderate Revision 5 Planning (PL) control family is often misunderstood yet critically important in the FedRAMP Moderate Revision 5 authorization process. 


The Planning (PL) control family focuses on developing, documenting, and maintaining system security and privacy plans that provide a comprehensive approach to security risk management. In FedRAMP Moderate Rev 5, these controls are designed to ensure that organizations take a proactive approach to security planning.


 PL-1: Security and Privacy Planning Policy and Procedures


Control Objective: Establish a comprehensive policy and procedural framework for security planning.


- Develop a formal, documented security planning policy

- Include:

   Purpose and scope of the security planning process

   Roles and responsibilities

   Management commitment to security

   Coordination among organizational entities

   Compliance requirements

- Review and update the policy at least annually



Key Considerations:

- Ensure the policy is approved by senior leadership

- Align the policy with the organizational risk management strategy

- Maintain clear documentation of policy updates and review processes


 PL-2: System Security and Privacy Plans


Control Objective: Create and maintain a comprehensive security plan that provides a holistic view of the system's security controls and risk management approach.


Detailed Implementation Strategy:

1. Plan Development:

   - Conduct thorough system categorization

   - Identify all security control requirements

   - Document system boundaries and interconnections

   

2. Content Requirements:

   - System architecture overview

   - Threat and risk assessment results

   - Detailed control implementation descriptions

   - Control inheritance information

   - Security control mapping


Example:

For a cloud service platform, the System Security Plan (SSP) would include:

- Detailed network architecture diagrams

- Cloud infrastructure component descriptions

- Specific implementation details for each NIST SP 800-53 control

- Identification of inherited controls from the cloud service provider

- Explanation of how additional controls are implemented at the application level


 PL-4: Rules of Behavior


Control Objective: Establish and enforce rules of behavior for system users, defining acceptable and prohibited actions.


Comprehensive Implementation Approach:

- Develop a detailed Rules of Behavior (RoB) document

- Include:

   Acceptable use of information systems

   Consequences for non-compliance

   User responsibilities for data protection

   Monitoring and enforcement mechanisms


Rules of Behavior Sections:


1. Data Handling Protocols

   - Classification and handling of sensitive information

   - Prohibition of unauthorized data sharing


2. System Access Guidelines

   - Password complexity requirements

   - Multi-factor authentication compliance

   - Restrictions on personal device usage


3. Incident Reporting

   - Mandatory reporting of security incidents

   - Timelines and communication channels for reporting



 PL-7: Security and Privacy Concepts of Operations


Control Objective: Develop a Concept of Operations (ConOps) that describes the system's operational context, mission/business processes, and security considerations.


Key Components:

- Operational environment description

- System functionality overview

- Security service requirements

- Operational scenarios and use cases

- Performance and resilience expectations


 PL-8: Information Security and Privacy Architect


Control Objective: Establish an organizational role responsible for information security and privacy architecture integration.


Recommended Implementation:

- Designate a senior-level Information Security Architect

- Responsibilities include:

   Developing enterprise-wide security architecture

   Ensuring security control consistency

   Providing guidance on security design principles

   Conducting architecture risk assessments



Implementing the PL control family effectively requires a strategic, comprehensive approach. By developing robust policies, detailed system security plans, clear rules of behavior, and maintaining a holistic view of security architecture, organizations can significantly enhance their security posture.


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