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Guidance for NIST 800-171 Assessment & Compliance

Navigation: CHAPTER TWO: THE FUNDAMENTALS

2.3   BUILDING AN EFFECTIVE ASSURANCE CASE

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Building an effective assurance case19 for security and privacy control effectiveness is a process that involves: (i) compiling evidence from a variety of activities conducted during the system development life cycle that the controls employed in the information system are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security and privacy requirements of the system and the organization; and (ii) presenting this evidence in a manner that decision makers are able to use effectively in making risk-based decisions about the operation or use of the system. The evidence described above comes from the implementation of the security and privacy controls in the information system and inherited by the system (i.e., common controls) and from the assessments of that implementation. Ideally, the assessor is building on previously developed materials that started with the specification of the organization’s information security and privacy needs and was further developed during the design, development, and implementation of the information system. These materials, developed while implementing security and privacy throughout the life cycle of the information system, provide the initial evidence for an assurance case.

Assessors obtain the required evidence during the assessment process to allow the appropriate organizational officials to make objective determinations about the effectiveness of the security and privacy controls and the overall security and privacy state of the information system. The assessment evidence needed to make such determinations can be obtained from a variety of sources including, for example, information technology product and system assessments and, in the case of privacy assessments, privacy compliance documentation such as Privacy Impact Assessments and Privacy Act System of Record Notices. Product assessments (also known as product testing, evaluation, and validation) are typically conducted by independent, third-party testing organizations. These assessments examine the security and privacy functions of products and established configuration settings. Assessments can be conducted to demonstrate compliance to industry, national, or international information security standards, privacy standards embodied in applicable laws and policies, and developer/vendor claims. Since many information technology products are assessed by commercial testing organizations and then subsequently deployed in millions of information systems, these types of assessments can be carried out at a greater level of depth and provide deeper insights into the security and privacy capabilities of the particular products.

System assessments are typically conducted by information systems developers, systems integrators, information system owners, common control providers, assessors, auditors, Inspectors General, and the information security and privacy staffs of organizations. The assessors or assessment teams bring together available information about the information system such as the results from individual component product assessments, if available, and conduct additional system-level assessments using a variety of methods and techniques. System assessments are used to compile and evaluate the evidence needed by organizational officials to determine how effective the security and privacy controls employed in the information system are likely to be in mitigating risks to organizational operations and assets, to individuals, to other organizations, and to the Nation. The results of assessments conducted using information system-specific and organization-specific assessment procedures derived from the guidelines in this publication contribute to compiling the necessary evidence to determine security and privacy control effectiveness in accordance with the assurance requirements documented in the security and privacy plans.

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