CMMC Practice Number: RA.L2-3.11.1
CMMC Level: 2 CMMC Domain: Risk Management (RM)
Practice Summary:
Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI.
Contents:
CMMC Practice Implementation |
Assessment Objectives
Determine if:
[a] the frequency to assess risk to organizational operations, organizational assets, and individuals is defined; and
[b] risk to organizational operations, organizational assets, and individuals resulting from the operation of an organizational system that processes, stores, or transmits CUI is assessed with the defined frequency.
Practice Clarification (DOD, CMU)
Risk arises from anything that can reduce an organization’s assurance of mission/business success; cause harm to image or reputation; or harm individuals, other organizations, or the Nation.
Organizations assess the risk to their operations and assets at regular intervals [a]. Areas where weakness or vulnerabilities could lead to risk may include:
• poorly designed and executed business processes;
• inadvertent actions of people, such as disclosure or modification of information;
• intentional actions of people inside and outside the organization;
• failure of systems to perform as intended;
• failures of technology; and
• external events, such as natural disasters, public infrastructure and supply chain failures.
When conducting risk assessments use established criteria and procedures. The results of formal risk assessments are documented. It is important to note that risk assessments differ from vulnerability assessments (see RM.2.142). A vulnerability assessment provides input to a risk assessment along with other information such as results from likelihood analysis and analysis of potential threat sources.
Risk assessments should be performed at defined regular intervals [a]. Mission risks include anything that will keep an organization from meeting its mission. Function risk is anything that will prevent the performance of a function. Image and reputation risks refer to intangible risks that have value and could cause damage to potential or future trust relationships.
This practice, RA.L2-3.11.1, which requires periodically assessing the risk to organization systems, assets, and individuals, is a baseline Risk Assessment practice. RA.L2-3.11.1 enables other Risk Assessment practices (e.g., RA.L2-3.11.3, Vulnerability Remediation), as well as CA.L2-3.12.2, Plan of Action.
Example
You are a system administrator. You and your team members are working on a big government contract requiring you to store CUI. As part of your periodic (e.g., annual) risk assessment exercise, you evaluate the new risk involved with storing CUI [a,b]. When conducting the assessment you consider increased legal exposure, financial requirements of safeguarding CUI, potentially elevated attention from external attackers, and other factors. After determining how storing CUI affects your overall risk profile, you use that as a basis for a conversation on how that risk should be mitigated.
Potential Assessment Considerations
• Have initial and periodic risk assessments been conducted [b]?
• Are methods defined for assessing risk (e.g., reviewing security assessments, incident reports, and security advisories, identifying threat sources, threat events, and vulnerabilities, and determining likelihood, impact, and overall risk to the confidentiality of CUI) [b]?
Where To Look
- Risk assessment policy;
- security planning policy and procedures;
- procedures addressing organizational risk assessments;
- system security plan;
- risk assessment;
- risk assessment results;
- risk assessment reviews;
- risk assessment updates;
- other relevant documents or records.
Who To Talk To
- Personnel with risk assessment responsibilities;
- personnel with information security responsibilities.
Perform Test On
- Organizational processes for risk assessment;
- mechanisms supporting or for conducting, documenting, reviewing, disseminating, and updating the risk assessment.
Additional Information
Risk assessments play a critical role in the development and implementation of effective information security programs and help companies address a range of security-related issues from advanced persistent threats to supply chain concerns. The results of risk assessments are used to develop specific courses of action that can provide effective response measures to the identified risks as part of a broad-based risk management process.
There is no defined requirement, methodology, or period for the assessments, nor is a report required. These are dependent on the organization, its mission, changes to its systems and environment. This is a periodic assessment of how you operate to insure you understand your risk, which can change over time.
Any changes resulting from the assessment would be reflected in implementing plans of action and in the system security plan per NIST SP 800-171 requirements 3.12.2 and 3.12.4.
Additional information on conducting risk assessments can be found in NIST 800-30 Rev 1 “Guide for Conducting Risk Assessments”
http://nvlpubs.nist.gov/nistpubs/Legacy/SP/nistspecia lpublication800-30r1.pdf
CMMC Practice Background and References (DOD, CMU) |
Practice Discussion:
DISCUSSION FROM SOURCE: NIST SP 800-171 R2
Clearly defined system boundaries are a prerequisite for effective risk assessments. Such risk assessments consider threats, vulnerabilities, likelihood, and impact to organizational operations, organizational assets, and individuals based on the operation and use of organizational systems. Risk assessments also consider risk from external parties (e.g., service providers, contractor operating systems on behalf of the organization, individuals accessing organizational systems, outsourcing entities). Risk assessments, either formal or informal, can be conducted at the organization level, the mission or business process level, or the system level, and at any phase in the system development life cycle.
NIST SP 800-30 provides guidance on conducting risk assessments.
CMMC References:
· NIST SP 800-171 Rev 1 3.11.1
· NIST CSF v1.1 ID.RA-1, ID.RA-4, DE.AE-4, RS.MI-3
· CERT RMM v1.2 RISK:SG4
· NIST SP 800-53 Rev 4 RA-3