1 1 00:00:00,000 --> 00:00:02,460 Now that your controls are implemented, 2 2 00:00:02,460 --> 00:00:03,660 you'll have to assess them 3 3 00:00:03,660 --> 00:00:06,090 to make sure they're correctly configured, 4 4 00:00:06,090 --> 00:00:08,280 operating as you intended, 5 5 00:00:08,280 --> 00:00:11,970 and producing the needed outcomes for your system. 6 6 00:00:11,970 --> 00:00:15,660 There are six tasks in step number five, 7 7 00:00:15,660 --> 00:00:18,360 and this step is called assess. 8 8 00:00:18,360 --> 00:00:21,360 Now, let's go through the tasks together. 9 9 00:00:21,360 --> 00:00:23,670 When you complete task A-1, 10 10 00:00:23,670 --> 00:00:26,790 you'll have an assessor or an assessment team 11 11 00:00:26,790 --> 00:00:29,670 selected to evaluate your controls. 12 12 00:00:29,670 --> 00:00:31,440 No matter who does step number five, 13 13 00:00:31,440 --> 00:00:34,770 your senior security and privacy officers 14 14 00:00:34,770 --> 00:00:37,440 will be responsible for making sure the assessments 15 15 00:00:37,440 --> 00:00:40,050 are complete and documented. 16 16 00:00:40,050 --> 00:00:42,360 As you select your assessors, 17 17 00:00:42,360 --> 00:00:43,860 keep in mind that they must have 18 18 00:00:43,860 --> 00:00:46,050 enough feelings of independence 19 19 00:00:46,050 --> 00:00:48,840 to be able to make truthful judgements. 20 20 00:00:48,840 --> 00:00:50,760 Among other factors in play, 21 21 00:00:50,760 --> 00:00:52,620 their level of independence will be affected 22 22 00:00:52,620 --> 00:00:57,620 by whether your assessors are in-house versus contracted. 23 23 00:00:57,810 --> 00:01:00,420 Now, when you complete task A-2, 24 24 00:01:00,420 --> 00:01:04,290 you'll have developed, reviewed, and approved the plans 25 25 00:01:04,290 --> 00:01:07,620 that you'll follow to assess your controls. 26 26 00:01:07,620 --> 00:01:10,860 Now, these plans should be created by the assessors 27 27 00:01:10,860 --> 00:01:13,920 that you selected in task A-1. 28 28 00:01:13,920 --> 00:01:15,660 They can make a plan for the assessment 29 29 00:01:15,660 --> 00:01:18,150 that is either a single integrated plan 30 30 00:01:18,150 --> 00:01:21,420 for both security and privacy controls, 31 31 00:01:21,420 --> 00:01:25,770 or they can be two plans, one for each category. 32 32 00:01:25,770 --> 00:01:28,140 Assessment plans should also include an evaluation 33 33 00:01:28,140 --> 00:01:29,820 of the control objectives 34 34 00:01:29,820 --> 00:01:33,870 and the assessment procedures for each control. 35 35 00:01:33,870 --> 00:01:36,450 Once the assessment plans are created, 36 36 00:01:36,450 --> 00:01:38,700 they should be reviewed and approved 37 37 00:01:38,700 --> 00:01:40,980 by the authorizing official. 38 38 00:01:40,980 --> 00:01:43,950 Your next task is A-3. 39 39 00:01:43,950 --> 00:01:45,120 When it's finished, 40 40 00:01:45,120 --> 00:01:47,760 your controls assessment will be complete, 41 41 00:01:47,760 --> 00:01:51,270 and you'll have evidence that the assessments happened. 42 42 00:01:51,270 --> 00:01:53,760 It might be appropriate to apply and assess controls 43 43 00:01:53,760 --> 00:01:56,190 throughout your system development life cycle 44 44 00:01:56,190 --> 00:01:59,340 if you have an iterative development process. 45 45 00:01:59,340 --> 00:02:02,550 Something similar is done when assessing controls 46 46 00:02:02,550 --> 00:02:04,890 in commercial IT products. 47 47 00:02:04,890 --> 00:02:07,110 You'll also have the option to begin assessing controls 48 48 00:02:07,110 --> 00:02:09,240 prior to finishing the implementation 49 49 00:02:09,240 --> 00:02:12,960 of all the controls in your security and privacy plans. 50 50 00:02:12,960 --> 00:02:14,910 This type of incremental assessment 51 51 00:02:14,910 --> 00:02:19,170 might be more cost efficient or cost effective for you. 52 52 00:02:19,170 --> 00:02:21,330 When you finish task A-4, 53 53 00:02:21,330 --> 00:02:24,210 you'll have security and privacy assessment reports 54 54 00:02:24,210 --> 00:02:29,210 that detail all the assessor's findings and recommendations. 55 55 00:02:29,250 --> 00:02:32,100 The amount of detail in the report should be appropriate 56 56 00:02:32,100 --> 00:02:35,100 to the type of control assessment that was conducted. 57 57 00:02:35,100 --> 00:02:39,300 Superficial assessment reports may be questioned or rejected 58 58 00:02:39,300 --> 00:02:41,670 by the authorizing official. 59 59 00:02:41,670 --> 00:02:44,310 Control assessment results can be documented 60 60 00:02:44,310 --> 00:02:46,440 in interim reports. 61 61 00:02:46,440 --> 00:02:49,380 Having interim reports for different assessments 62 62 00:02:49,380 --> 00:02:52,140 during phases of the SDLC, 63 63 00:02:52,140 --> 00:02:54,900 reinforces the fact that assessment reports 64 64 00:02:54,900 --> 00:02:58,560 are in fact evolving documents. 65 65 00:02:58,560 --> 00:03:01,290 Your interim reports then inform 66 66 00:03:01,290 --> 00:03:04,050 the final assessment report. 67 67 00:03:04,050 --> 00:03:09,050 Your next task, A-5, begins the remediation actions. 68 68 00:03:09,300 --> 00:03:10,950 By the end of task A-5, 69 69 00:03:10,950 --> 00:03:14,100 you'll have completed your initial remediations 70 70 00:03:14,100 --> 00:03:17,880 based on your security and privacy assessment reports. 71 71 00:03:17,880 --> 00:03:19,890 Then, you'll update your original reports 72 72 00:03:19,890 --> 00:03:22,500 to include any changes that you made 73 73 00:03:22,500 --> 00:03:25,170 to the control implementations. 74 74 00:03:25,170 --> 00:03:27,990 If significant security or privacy risks 75 75 00:03:27,990 --> 00:03:30,030 are discovered during the assessment, 76 76 00:03:30,030 --> 00:03:32,940 then those should be mitigated as soon as possible. 77 77 00:03:32,940 --> 00:03:36,270 Less severe risks that are quick and easy to mitigate 78 78 00:03:36,270 --> 00:03:37,620 can be done later. 79 79 00:03:37,620 --> 00:03:39,720 However, it may be more practical 80 80 00:03:39,720 --> 00:03:42,750 to conduct initial mitigations for assessment findings 81 81 00:03:42,750 --> 00:03:46,053 that are easy to fix with existing resources. 82 82 00:03:46,980 --> 00:03:49,050 Your organization can prepare an addendum 83 83 00:03:49,050 --> 00:03:52,260 to your security and privacy assessment reports 84 84 00:03:52,260 --> 00:03:53,400 that provides an opportunity 85 85 00:03:53,400 --> 00:03:56,310 for system owners and control providers 86 86 00:03:56,310 --> 00:03:58,410 to respond to your assessment. 87 87 00:03:58,410 --> 00:04:00,390 This addendum could have information 88 88 00:04:00,390 --> 00:04:02,580 about initial mitigation actions 89 89 00:04:02,580 --> 00:04:05,730 and additional details about the findings. 90 90 00:04:05,730 --> 00:04:08,130 Findings from control assessments may lead 91 91 00:04:08,130 --> 00:04:11,730 to needing an update to your system risk assessment 92 92 00:04:11,730 --> 00:04:15,210 and your organization risk assessment as well. 93 93 00:04:15,210 --> 00:04:17,880 Your next task is A-6, 94 94 00:04:17,880 --> 00:04:19,170 and when you finish it, 95 95 00:04:19,170 --> 00:04:21,990 you'll have a plan of action and milestones 96 96 00:04:21,990 --> 00:04:24,810 that's also known as a POAM, 97 97 00:04:24,810 --> 00:04:27,870 and it'll show you how to mitigate the deficiencies 98 98 00:04:27,870 --> 00:04:30,000 that are contained in the security 99 99 00:04:30,000 --> 00:04:32,820 and privacy assessment reports. 100 100 00:04:32,820 --> 00:04:34,710 Your POAM will describe the actions 101 101 00:04:34,710 --> 00:04:37,020 that are planned to correct the deficiencies 102 102 00:04:37,020 --> 00:04:38,310 in your controls 103 103 00:04:38,310 --> 00:04:41,190 that were discovered during the assessment of the controls, 104 104 00:04:41,190 --> 00:04:44,340 as well as during continuous monitoring. 105 105 00:04:44,340 --> 00:04:48,270 A POAM also includes the tasks to be accomplished, 106 106 00:04:48,270 --> 00:04:49,950 recommendations for completion 107 107 00:04:49,950 --> 00:04:53,280 before or after system authorization, 108 108 00:04:53,280 --> 00:04:56,400 the resources required to accomplish the tasks, 109 109 00:04:56,400 --> 00:04:59,460 milestones established to meet the task, 110 110 00:04:59,460 --> 00:05:01,350 and scheduled completion dates 111 111 00:05:01,350 --> 00:05:04,260 for the milestones and the tasks. 112 112 00:05:04,260 --> 00:05:08,550 All right, that's all the tasks in step number five 113 113 00:05:08,550 --> 00:05:10,871 which is called assess.