CMMC Practice Number: CM.L2-3.4.4
CMMC Level: 2 CMMC Domain: Configuration Management (CM)
Practice Summary:
Analyze the security impact of changes prior to implementation.
Contents:
CMMC Practice Implementation |
Assessment Objectives
Determine if:
[a] the security impact of changes to the system is analyzed prior to implementation.
Practice Clarification (DOD, CMU)
Changes to complex environments are reviewed for potential security impact before implemented. Changes to IT systems can cause unforeseen problems and have unintended consequences for both users and the security of the operating environment. Analyze the
security impact of changes prior to implementing them [a]. This can uncover and mitigate potential problems before they occur.
Example
You have been asked to deploy a new web browser plug-in. Your standard change management process requires that you produce a detailed plan for the change, including a review of its potential security impact. A subject-matter expert who did not submit the change reviews the plan and tests the new plug-in for functionality and security. You update the change plan based on the expert’s findings and submit it to the change control board for final approval [a].
Potential Assessment Considerations
• Are configuration changes tested, validated, and documented before installing them on the operational system [a]?
Where To Look
- Configuration management policy;
- procedures addressing security impact analysis for system changes;
- configuration management plan;
- security impact analysis documentation;
- system security plan;
- analysis tools and associated outputs;
- change control records;
- system audit logs and records;
- other relevant documents or records.
Who To Talk To
- Personnel with responsibility for conducting security impact analysis;
- personnel with information security responsibilities;
- system or network administrators.
Perform Test On
- Organizational processes for security impact analysis.
Additional Information
Employees with information security responsibilities (e.g., Information System Administrators, Information System Security Officers, Information System Security Managers, and Information System Security Engineers) conduct security impact analyses. Individuals conducting security impact analyses possess the necessary skills/ technical expertise to analyze the changes to information systems and the associated security ramifications.
Security impact analysis may include, for example, reviewing security plans to understand security control requirements and reviewing system design documentation to understand requirement implementation and how specific changes might affect the requirements. Security impact analyses may also include assessments of risk to better understand the impact of the changes and to determine if additional security requirements are required. Security impact analyses are scaled in accordance with the security categories of the information systems.
CMMC Practice Background and References (DOD, CMU) |
Practice Discussion:
DISCUSSION FROM SOURCE: DRAFT NIST SP 800-171 R2
Organizational personnel with information security responsibilities (e.g., system administrators, system security officers, system security managers, and systems security engineers) conduct security impact analyses. Individuals conducting security impact analyses possess the necessary skills and technical expertise to analyze the changes to systems and the associated security ramifications. Security impact analysis may include reviewing security plans to understand security requirements and reviewing system design documentation to understand the implementation of controls and how specific changes might affect the controls. Security impact analyses may also include risk assessments to better understand the impact of the changes and to determine if additional controls are required.
NIST SP 800-128 provides guidance on configuration change control and security impact analysis.
CMMC References:
• NIST SP 800-171 Rev 1 3.4.4
• NIST CSF v1.1 PR.IP-3
• NIST SP 800-53 Rev 4 CM-4