Fisma FedRAMP Drupal

Fisma FedRAMP Drupal

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  Presenter Michael Lemire Director of Information Security michael.lemire@acquia.com
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  Agenda • Review CurrentUS Government Compliance landscape • How to achieve FISMA Compliance • International and Developing Compliance Standards • How Acquia achieved a compliant ready hosting platform.
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  Drupal in theFederal Government • Governments are expanding use of Drupal • Drupal is open source • Cost effective vs proprietary licensed software • Proven secure • Drupal facilitates shared development between agencies • Proven • www.whitehouse.gov • www.house.gov • www.ready.gov • www.investor.gov • www.teach.gov • www.ed.gov • www.energy.gov
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  Current US GovernmentCompliance Landscape FISMA, DIACAP and FedRAMP are standardized approaches to security assessment, authorization, and continuous monitoring for information systems utilized by the Federal government. FISMA - Federal Information Security Management Act of 2002. Applicable to non- DoD agencies. DIACAP – Department of Defense Information Assurance Certification and Accreditation Process. Applicable to DoD related agencies. With both FISMA and DIACAP each information system must be documented, reviewed by independent third party assessor and authorized by authorizing officials. Time consuming, expensive
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  Coming Soon -FedRAMP FedRAMP - Federal Risk and Authorization Management Program • Establishes an “authorize once, use many times” framework for cloud computing products and services. FedRAMP is meant to supersede FISMA and DIACAP for cloud products. • FedRAMP was established on Dec 8, 2011 via a memorandum produced by the Federal Chief Information Officer and is due to achieve Initial Operating Capacity in 2012. • Based on the same NIST publications as FISMA with added controls pertinent to the cloud • FedRAMP Concept of Operations – defines how the FedRAMP process will work • http://www.gsa.gov/graphics/staffoffices/FedRAMP_CONOPS.pdf
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  Important NIST Publicationsand Standards FIPS 199 – Security categorization of the information system according to its Confidentiality, Availability and Integrity requirements • What type of data? • Importance to national security? Determine “High water mark” (low, medium, high) NIST 800-53 rev 3 – Security Controls documented in the SSP All domains of security are covered and must be documented Risk Assessment, Personnel, System Acquisition, Physical and Environmental, Contingency Planning, Configuration Management, Incident Response, Security Awareness Training, Authentication, Logging and Audit, Network Security and Encryption Rev 4 now in draft – adds add’l mobile and cloud controls NIST 800-30 – Risk Assessments Defines process for assessing risk and how to apply the process to the organizational, mission and information system levels.
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  Federal Compliance -High Level Process 1. Categorize the System – FIPS 199 FISMA, DIACAP and FedRAMP Process Confidentiality, Integrity, Availability 2. Select the controls – NIST 800-53 3. Implement the controls and document them -System Security Plan -Privacy Impact Assessment 4. Assess – Contract with Third Party Assessor -3PAO reviews SSP and creates STE & POA&M 5. Authorize – This package of documents submitted to the Authorizing Official who reviews, comments, asks for revisions. -grants IATC and/or ATO 6.Monitor – Continuous update to SSP , continuous mitigation of items identified in STE and POA&M
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  Step 1: Categorizethe system –FIPS 199 Establish the “high water mark”- Low/Moderate or High
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  Step 2: Selectthe controls NIST 800-53 Revision 3 Annex 1 – Low “high water mark” Annex 2 – moderate “high water mark” Annex 3 – high “high water mark”
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  Step 3: Implementand document the controls The System Security Plan (SSP) -a narrative description of the system -define the “accreditation boundary” – what is it that is being authorized -describes the system and the environment where it resides .. And the controls, divided into control families: Risk Assessment (RA) Planning (PL) System and Service Acquisition (SA) Access Control (AC) Certification and Authorization (CA) Audit and Accountability (AU) Personnel Security (PS) System and Communication Protection (SC) Physical and Environmental Security (PE) Continuity Planning (CP) Configuration Management (CM) Maintenance (MA) System and Information Integrity (SI) Media Protection (MP) Incident Response (IR) Awareness and Training (AT) Identification and Authentication (IA)
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  Step 4: AssessThe Controls (Audit) The assessment is a validation by an independent auditor that “you do what you say you do”. Guided by NIST 800-53a The third party assessor (3PAO) is tasked with reviewing the SSP and validating are those control in place. 3PAO creates Security Test & Evaluation Plan (ST&E) and the System Assessment Report (SAR) which documents the evidencing activities and results. -What is non-compliant Plan of Action Milestone (POA&M) – Lists controls which are not in place and the plan to implement those controls
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  Step 5: Authorizethe System Finally the FISMA C&A Package is submitted to the Authorizing Official The package: • The SSP • Relevant Policies and Procedures • The FIPS 199 categorization • The SAR and ST&E • The POA&M Authorizing Official once satisfied issues Authority to Operate (ATO)
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  Step 6: Monitorand Update • Update the SSP as things change • Resolve issues and follow plan per POA&M • Continuous monitoring of risks • Re-authorize system every 3 years
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  Accomplishing Federal Compliancein the Cloud Cloud Service Providers may be responsible for the entire set of controls, or they may be shared in a Shared Responsibility Model Examples: SaaS may be built on PaaS Ex: DrupalGardens PaaS may be built on IaaS Ex: Acquia Managed Cloud Three primary layers in the shared responsibility model: •Application Layer (Drupal) •OS Stack Layer (Linux, Windows, Database, etc) •Infrastructure Layer (Datacenter, network) *Each entity must document the controls for which they are responsible for.*
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  Example: Acquia ManagedCloud Acquia Managed Cloud is a PaaS built on Amazon’s AWS IaaS
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  Example: Acquia ManagedCloud Example SSP control description: Control: (from 800-53) Control Type: Agency/Common/Hybrid Control Status: Implemented/Planned/Not Applicable Application Layer: Responsibility: Customer (Agency) Implementation Detail: Describe how the control is the responsibility of the agency. LAMP Stack Layer: Responsibility: Acquia Implementation Detail: Describe how the control is implemented Infrastructure: Responsibility: Amazon Implementation Detail: Refer to hosting provider’s SSP Acquia documents its control responsibilities in its SSP Amazon documents its control responsibilities in its SSP
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  FISMA Moderate Controlsapplicable to the Drupal layer
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  FISMA Moderate Controlsapplicable to the Drupal layer
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  FISMA Moderate Controlsapplicable to the Drupal layer How to implement these controls: -OpenPublic distribution -Drupal modules: Password Policy http://drupal.org/project/password_policy