Incident Response for NIST 800-53 and FedRAMP

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In the ever-evolving landscape of cybersecurity, staying ahead of persistent, rapid evolving, and increasingly sophisticated threats is of paramount importance. Government agencies and organizations handling sensitive data have stringent security requirements to protect their information systems and assets. Two key frameworks that play a pivotal role in this endeavor are the National Institute of Standards and Technology (NIST) 800-53 and the Federal Risk and Authorization Management Program (FedRAMP). A key focus of these frameworks is incident response, based on a strategy for businesses to not only survive but to thrive, regardless of the impact of incidents on critical organizational operations. 

Given the massive increase in breach volume surging toward a pace of nearly eight per day, organizations, whether a government, multinational corporation, or small startup, must accept that incidents will occur regardless of their defensive posture. Said another way, it’s a matter of when, not if. Incident response is a critical aspect of security programs, and it’s a matter that should be top of mind for security teams, security leaders, and business boards and executives. These two frameworks, NIST 800-53 and FedRAMP, shed light on how security teams can shift from a reactive, plan-based posture to one that creates a proactive incident response program focused on their entire business, ensuring they’re well-equipped to navigate the ever-shifting cybersecurity landscape and stay focused on their business.

NIST 800-53: Goals and Guidelines

NIST 800-53 is a comprehensive framework that provides a set of security and privacy controls specifically designed for information systems and organizations. It was initially released in early 2005 and has continued to evolve to help federal agencies implement the Federal Information Security Modernization Act of 2014 (known as FISMA) while protecting their information and systems. The framework’s purpose is to guide agencies through the Risk Management Framework, assisting in the selection and customization of security controls. Compliance with NIST 800-53 is mandatory for all US federal government agencies and contractors to safeguard critical data.

For its fifth revision published in September 2020, NIST 800-53 underwent a substantial transformation to meet the evolving landscape of cybersecurity and privacy controls. This effort aimed to enhance usability for a wide range of users, from enterprises to engineering organizations and industry partners. Key changes included the move towards more outcome-focused controls, integration of security and privacy controls into a consolidated catalog, and the introduction of a supply chain risk management control family. Moreover, control selection processes were separated from the controls, enabling their use by different communities of interest. This version also clarified the relationship between requirements and controls, integrated state-of-the-art controls supporting cyber resiliency, secure system design, and strengthened security and privacy governance based on the latest threat intelligence and cyber-attack data.

NIST 800-53 lays out a comprehensive set of objectives for effective incident response. At its core, the framework emphasizes the development of clear and concise incident response policies that cover multiple organizational levels. These policies call for addressing roles, responsibilities, management commitment, and compliance. Another key element highlighted in NIST 800-53 is role-based training, underscoring the importance of educating personnel based on their responsibilities. The framework recommends periodic reviews and updates of training content as well as regular testing to evaluate the effectiveness of incident response capabilities and drive continuous improvement.

Furthermore, as part of its criteria, 800-53 guides organizations to implement a structured approach to incident handling, using different phases such as preparation, detection, containment, eradication, and recovery as well as severity levels that scale with the criticality of the incident. It calls for effective coordination with contingency planning activities and encourages information correlation, dynamic response measures, and the use of automated mechanisms for tracking, reporting, and communication.

By developing a comprehensive approach to incident response, organizations that leverage NIST 800-53 will enhance their incident preparation and management process, within an umbrella of an incident response program, that strengthens their overall cybersecurity posture.

FedRAMP: A Closer Look at Key Components

FedRAMP is a US government-wide initiative focused on driving the adoption of secure cloud services throughout federal agencies. It achieves this by offering a standardized approach for assessing security and risks associated with cloud technologies. This program delivers a range of benefits, including reducing redundancy and costs, promoting innovation in secure IT solutions through public-private collaboration, and expediting cloud adoption with transparent security standards. Its core objectives involve expanding the use of secure cloud technologies, refining the government’s cloud security and authorization framework, and establishing strong partnerships between government and its providers. 

In addition to NIST 800-53 controls, FedRAMP incorporates its own set of comprehensive guidelines aimed at ensuring the security of cloud products and services in use by government entities. Of particular note is FedRAMP’s incident response framework, a robust guide to handling security incidents effectively to ensure organizations are well-prepared to respond to cyber threats. It emphasizes the importance of developing clear incident response policies that comprehensively address purpose, scope, roles, and responsibilities of business functions and team members. It calls for designated officials that oversee the development, documentation, and dissemination of these policies, including regular reviews and updates to ensure their continued relevance.

As part of its criteria, FedRAMP also mandates incident response training for personnel based on their roles and responsibilities, including regular updates to keep personnel well-prepared for incidents. For example, it distinguishes between training timelines for privileged users and incident response roles, rather than a single universal time for all types of users regardless of the risks associated with their job function, processes, and accesses. FedRAMP also encourages incorporating simulated events into training to ensure that personnel can effectively respond to crisis situations. 

Much like NIST 800-53, organizations are expected to implement incident handling capabilities consistent with the incident response plan, covering various phases like preparation, detection, containment, eradication, and recovery. Continuous improvement is encouraged, with lessons learned from ongoing incident handling activities being integrated into procedures, training, and testing. Dynamic updates, centralization and correlation of incident information, and addressing insider threats are other critical elements for FedRAMP. 

Organizations are encouraged to establish an incident response team capable of rapid deployment that can act on incidents promptly, particularly through automation to enhance efficiency and response time. The framework calls for sharing incident information with relevant internal stakeholders and external parties like law enforcement, regulators, customers, and partners. Many cybersecurity compliance frameworks lack depth in criteria related to this area, a true positive for FedRAMP.

Incorporating FedRAMP guidelines into your cybersecurity strategy is crucial for ensuring the security and compliance of cloud services, especially when serving government agencies and handling sensitive information. By adhering to these guidelines, organizations can enhance their incident response capabilities and bolster their overall cybersecurity posture.

FedRAMP & Its Relationship with NIST 800-53

FedRAMP and NIST 800-53 are inextricably intertwined. One of the key relationships between FedRAMP and NIST 800-53 is that FedRAMP leverages the controls from NIST 800-53 as the baseline for cloud service providers. FedRAMP takes those controls and adapts them to the cloud context, ensuring that cloud services meet the same high-security standards required by government agencies.

To that end, by aligning incident response strategies with either NIST 800-53 or FedRAMP, organizations can ensure that their response plans are not just well-developed, but also that they’re well-suited to the cloud. Further, initially adopting 800-53 will streamline the ability to acquire FedRAMP certification to make them more appealing to government clients. Bottom line, the synergy between NIST 800-53 and FedRAMP forms a robust framework for effective incident response, particularly in a government and cloud context.

Why Align Incident Response with These Frameworks?

Aligning your incident response strategies with NIST 800-53 and FedRAMP isn’t just about building stronger defenses; it’s about fostering a proactive, agile, and resilient security posture. This is crucial for several reasons:

1. Compliance: It ensures compliance with government regulations, other federal directives, and other security standards and cybersecurity compliance requirements, reducing the risk of non-compliance penalties and fostering trust with government clients.
2. Effective Incident Handling: These frameworks provide a structured approach to incident response, enabling organizations to handle incidents efficiently and effectively.
3. Consistency: Aligning with these frameworks ensures that incident response measures are consistent, predictable, and comparable across the organization.
4. Continuous Improvement: Regular testing, training, and updates encourage continuous improvement of incident response processes.

This approach empowers your organization to respond swiftly and effectively to incidents, safeguarding your operations, personnel, customers, and the trust they place in your organization.

A Proactive Approach to Incident Response

A forward-thinking approach to incident response is paramount given the perseverance of threat actors and their continued rate of success breaching organizations of all sizes globally. By shedding ad hoc approaches and aligning your incident response strategy with NIST 800-53 or FedRAMP, you’re not merely reactively responding to threats, you’re actively preparing for them. This proactive stance serves as the foundation of a robust security posture, reducing the likelihood and impact of security breaches and enabling swift recovery when incidents do occur.

While many might perceive the implementation of an effective incident response program as a daunting task, modern technology automation, such as the BreachRx incident response platform and Cyber RegScout™, empowers cybersecurity teams to ditch the single written incident response plan and effortlessly design tactical, operational and strategic approaches for dealing with incidents. Leveraging libraries of compliance tasks, regulatory requirements, and cybersecurity and privacy playbooks specific to common incidents, advanced technologies like these streamline incident response strategies and assessments, not only resulting in substantial cost savings but also ensuring a faster alignment with global cybersecurity frameworks. These platforms enhance team collaboration, reduce the consequences of incidents, and expedite the overall operational response process. In essence, automation enables teams to actively prepare and then decisively prioritize and resolve security incidents when they occur.

Ultimately, NIST 800-53 and FedRAMP offer organizations, and particularly those dealing with government data and services, a solid groundwork for enhanced cybersecurity and compliance. By embracing these frameworks and harmonizing incident response strategies with their principles, organization’s can evolve to adeptly manage the challenges presented by the constantly-shifting, wide range of attacks. And this isn’t just a reactive measure; it’s a strategic imperative that minimizes the fallout of cyberattacks while continually safeguarding sensitive information. Embracing these frameworks, combined with the power of technology automation, streamlines incident response and ensures a swift and coordinated reaction, resulting in the fortification of their organization’s cyber resilience.