CMMC Practice Number: CM.L2-3.4.3
CMMC Level: 2 CMMC Domain: Configuration Management (CM)
Practice Summary:
Track, review, approve, or disapprove, and log changes to organizational systems.
Contents:
CMMC Practice Implementation |
Assessment Objectives
Determine if:
[a] changes to the system are tracked;
[b] changes to the system are reviewed;
[c] changes to the system are approved or disapproved; and
[d] changes to the system are logged.
Practice Clarification (DOD, CMU)
You must track, review, and approve configuration changes before committing to production. Changes to computing environments can create unintended and unforeseen issues that can affect the security and availability of the systems. Relevant experts and stakeholders must review and approve proposed changes [c]. They should discuss potential impacts before the organization puts the changes in place [b]. Relevant items include changes to the physical environment and to the systems hosted within it.
Example
Once a month, the management and technical team leads join a change control board meeting. During this meeting, everyone reviews all proposed changes to the environment [b,c]. This includes changes to the physical and computing environments. The meeting ensures that relevant subject-matter experts review changes and propose alternatives where needed.
Potential Assessment Considerations
• Are changes to the system authorized by company management and documented [a,b,c,d]?
• Are changes documented and tracked (e.g., manually written down or included in a tracking service such as a ticketing system) [d]?
Where To Look
- Configuration management policy;
- procedures addressing system configuration change control;
- configuration management plan;
- system architecture and configuration documentation;
- system security plan;
- change control records;
- system audit logs and records;
- change control audit and review reports;
- agenda/minutes from configuration change control oversight meetings;
- other relevant documents or records.
Who To Talk To
- Personnel with configuration change control responsibilities;
- personnel with information security responsibilities;
- system or network administrators;
- members of change control board or similar.
Perform Test On
- Organizational processes for configuration change control;
- mechanisms that implement configuration change control.
Additional Information
Changes to information systems include modifications to hardware, software, or firmware components and configuration settings. Companies ensure that testing does not interfere with information system operations. Individuals/groups conducting tests understand company security policies and procedures, information system security policies and procedures, and the specific health, safety, and environmental risks associated with facilities/processes.
Operational systems may need to be taken off-line, or replicated to the extent feasible, before testing can be conducted. If information systems must be taken off- line for testing, the tests are scheduled to occur during planned system outages whenever possible. If testing cannot be conducted on operational systems, organizations employ compensating controls (e.g., testing on replicated systems).
Changes to information systems should be reviewed and approved by company management prior to implementation.
CMMC Practice Background and References (DOD, CMU) |
Practice Discussion:
DISCUSSION FROM SOURCE: DRAFT NIST SP 800-171 R2
Tracking, reviewing, approving/disapproving, and logging changes is called configuration change control. Configuration change control for organizational systems involves the systematic proposal, justification, implementation, testing, review, and disposition of changes to the systems, including system upgrades and modifications. Configuration change control includes changes to baseline configurations for components and configuration items of systems, changes to configuration settings for information technology products (e.g., operating systems, applications, firewalls, routers, and mobile devices), unscheduled and unauthorized changes, and changes to remediate vulnerabilities.
Processes for managing configuration changes to systems include Configuration Control Boards or Change Advisory Boards that review and approve proposed changes to systems. For new development systems or systems undergoing major upgrades, organizations consider including representatives from development organizations on the Configuration Control Boards or Change Advisory Boards. Audit logs of changes include activities before and after changes are made to organizational systems and the activities required to implement such changes.
NIST SP 800-128 provides guidance on configuration change control.
CMMC References:
· NIST SP 800-171 Rev 1 3.4.3
· NIST CSF v1.1 PR.IP-1, PR.IP-3
· CERT RMM v1.2 KIM:SG5.SP2
· NIST SP 800-53 Rev 4 CM-3
· AU ACSC Essential Eight