Personnel Security in FedRAMP Moderate Revision 5

The Personnel Security (PS) control family in FedRAMP Moderate Revision 5 provides a comprehensive framework for managing the human element of cybersecurity— which is often the most vulnerable aspect of any security strategy.


 Understanding the PS Control Family


The Personnel Security control family ensures that individuals working with federal information systems are properly screened, trained, and managed throughout their organizational lifecycle. 


 PS-1: Personnel Security Policy and Procedures


Control Objective: Establish a robust policy and procedural framework for personnel security management.


- Develop a comprehensive personnel security policy that includes:

   Scope of personnel security measures

   Roles and responsibilities

   Screening requirements

   Training and awareness protocols

   Periodic review and update mechanisms


- Key Documentation Requirements:

   Formal policy document

   Detailed procedural guidelines

   Evidence of annual policy review


Practical Considerations:

- Ensure policy alignment with organizational mission and risk management strategy

- Obtain senior leadership approval

- Maintain clear audit trails of policy updates


 PS-2: Position Risk Designation


Control Objective: Systematically categorize organizational positions based on risk levels and associated security requirements.


Comprehensive Risk Designation Process:

1. Risk Assessment Criteria:

   - Access to sensitive systems

   - Potential for data exposure

   - Critical operational responsibilities

   - Level of system privileges


2. Position Risk Categorization:

   - Low-Risk Positions

   - Moderate-Risk Positions

   - High-Risk Positions


Example Risk Designation Matrix:


Position Type

Risk Level

Screening Requirements

Help Desk

Low Risk

Basic Background Check

Security Analyst

Moderate Risk

Enhanced Background Check

System Administrator

High Risk

Comprehensive Background Check and Periodic Reinvestigation




 PS-3: Personnel Screening


Control Objective: Conduct comprehensive background screenings before granting system access.


Screening Components:

- Criminal background checks

- Employment verification

- Education Confirmation

- Professional reference checks

- Citizenship verification


Screening Depth by Risk Level:



Risk Level

Screening Depth Level

Low Risk

Basic criminal background check

Moderate Risk

Enhanced background investigation

High Risk

A comprehensive background investigation and periodic reinvestigation (time depends on the type of data accessed should be between 2-7 years)



 PS-4: Personnel Termination


Control Objective: Establish a structured process for managing system access during employee departure.


Termination Checklist:

1. Immediate Access Revocation

   - Disable all system accounts

   - Revoke network and physical access credentials

   - Collect company-issued devices


2. Data Protection Measures

   - Preserve and transfer critical work-related data

   - Conduct exit interview focusing on confidentiality obligations


3. Documentation

   - Maintain formal termination records

   - Document access removal process


 PS-5: Personnel Transfer


Control Objective: Manage system access and privileges during internal role transitions.


Transfer Management Process:

- Conduct comprehensive access review

- Update role-based access controls

- Provide necessary security awareness training

- Document transfer-related security modifications


Example Transfer Scenario:


Employee Moving From: Database Administrator

Employee Moving To: Cloud Security Analyst


Transfer Actions:

- Revoke database system administrative privileges

- Grant new role-specific access

- Provide targeted security awareness training

- Update access control lists


 PS-6: Access Agreements


Control Objective: Develop and maintain formal access agreements defining user responsibilities.


Key Agreement Components:

- Acceptable use policies

- Confidentiality requirements

- Data handling protocols

- Consequences of policy violations


Sample Access Agreement:

1. User Identification and Authentication Responsibilities

2. Confidentiality and Non-Disclosure Obligations

3. Acceptable System Usage Guidelines

4. Monitoring and Auditing Consent

5. Disciplinary Action Provisions


 PS-7: Third-Party Personnel Security


Control Objective: Extend personnel security controls to contractors, vendors, and external personnel.


Implementation Strategies:

- Contractual security requirements

- Equivalent screening processes

- Ongoing monitoring

- Clear confidentiality agreements


By developing comprehensive policies, conducting thorough screenings, managing access meticulously, and maintaining robust transfer and termination processes, organizations can significantly mitigate human-related security risks.

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