Overview
  1. 03.01: Access Control
  2. 03.02: Awareness and Training
  3. 03.03: Audit and Accountability
  4. 03.04: Configuration Management
  5. 03.05: Identification and Authentication
  6. 03.06: Incident Response
  7. 03.07: Maintenance
  8. 03.08: Media Protection
  9. 03.09: Personnel Security
  10. 03.10: Physical Protection
  11. 03.11: Risk Assessment
  12. 03.12: Security Assessment
  13. 03.13: System and Communications Protection
  14. 03.14: System and Information Integrity

Security Requirements for 03.04.04 Security Impact Analysis

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.[SP 800-128] provides guidance on configuration change control and security impact analysis.

Assessment GuidanceExamine 0/9

How an assessor determines this requirement is met. Source: CMMC Assessment Guide – Level 2, Version 2.13 (NIST SP 800-171 Rev. 2).

Discussion

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. This can uncover and mitigate potential problems before they occur.

Examples

  1. Example 1

    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].

Assessment Methods

Examine
The process of reviewing, inspecting, observing, studying, or analyzing assessment objects (e.g., policies, procedures, plans, system designs, mechanisms) to facilitate understanding, achieve clarification, or obtain evidence.Example: An assessor reads the access control policy and inspects system configuration settings to confirm they match.

Not all of the evidence listed is required to meet this requirement — check the items your organization has collected.

Interview
The process of holding discussions with individuals or groups within an organization to facilitate understanding, achieve clarification, or identify the location of evidence.Example: An assessor asks a system administrator to describe how user accounts are approved, reviewed, and disabled.
  • Personnel with responsibility for conducting security impact analysis
  • Personnel with information security responsibilities
  • System or network administrators
Test
The process of exercising assessment objects (e.g., activities, mechanisms) under specified conditions to compare actual behavior with expected behavior.Example: An assessor attempts to sign in with a disabled account to confirm that access is denied.
  • Organizational processes for security impact analysis

Potential Assessment Considerations

  • Are configuration changes tested, validated, and documented before installing them on the operational system [a]?

Key References

NIST SP 800-171 Rev. 2 3.4.4

Evidence

  1. 03.04.04.a

    The security impact of changes to the system is analyzed prior to implementation