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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