Showing posts with label FISMA. Show all posts
Showing posts with label FISMA. Show all posts

FISMA, FedRAMP and the DoD CC SRG: A Review of the US Government Cloud Security Policy Landscape

The Federal Information System Management Act (FISMA), a US Law signed in 2002, defines the information protection requirements for US Government, "government", data and is applicable to all information systems that process any government data regardless of ownership or control of such systems. Systems Integrators (SI) under contract to perform work for the government are almost always provided some government furnished information (GFI) or government furnished equipment(GFE) and FISMA requirements extend to the systems owned and/or operated by these SIs if they store or process government data. Government data always remains under the ownership of the source agency with that agency holding sole responsibility for determining the data's sensitivity level. It is usually a contractual requirement for an SI, charged with management of government data, to ensure FISMA compliance and an SI is obligated to destroy or return all GFI and GFE at the end of contractual period of performance. Government data falls into a number of information sensitivity categories ranging from public information to the highest of classification and the compliance requirements imposed by FISMA increase in lockstep with that sensitivity.

A large portion of government data under the management or control of most SI's will fall in the public or controlled unclassified information (CUI) buckets. Public data is rather straightforward in that it is publicly releasable and if compromised would have little to no impact on the public image, trust, security or mission of the owning government agency and/or its personnel and as such, requires the least compliance overhead. CUI on the other hand is significantly more complex and nuanced. CUI data could compromise the public image, trust, security or mission of the owning government agency and/or its personnel. As such, CUI data has some restriction applied to its distribution [https://www.archives.gov/cui/registry/category-list.html]. With Department of Defense (DoD) data, there are additional types of distribution restrictions defined in DoD Directive (DoDD) 5200.01 v4 [http://www.dtic.mil/whs/directives/corres/pdf/520001_vol4.pdf] and a host of marking requirements [http://www.dtic.mil/whs/directives/corres/pdf/520001_vol2.pdf]. A common misunderstanding of CUI requirements is that, due to its unclassified nature, it does not require significant security consideration. This misunderstanding is something to be cognoscente of in any engagement with government agency or SI relationship and it is advisable to inquire about CUI data restrictions as this area comes with certain legal as well as contractual ramifications.