03.12.03: Security Control Monitoring

Beyond CMMC Level 1

The free web app covers the 17 CMMC Level 1 practices. This requirement is part of the full NIST 800-171 set — get the desktop app to work on all 110 requirements with SPRS scoring. Previously saved data is shown read-only below, and your data always remains exportable in full.

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Security Requirements for 03.12.03 Security Control Monitoring

Continuous monitoring programs facilitate ongoing awareness of threats, vulnerabilities, and information security to support organizational risk management decisions. The terms continuous and ongoing imply that organizations assess and analyze security controls and information security-related risks at a frequency sufficient to support risk-based decisions. The results of continuous monitoring programs generate appropriate risk response actions by organizations. Providing access to security information on a continuing basis through reports or dashboards gives organizational officials the capability to make effective and timely risk management decisions.Automation supports more frequent updates to hardware, software, firmware inventories, and other system information. Effectiveness is further enhanced when continuous monitoring outputs are formatted to provide information that is specific, measurable, actionable, relevant, and timely. Monitoring requirements, including the need for specific monitoring, may also be referenced in other requirements.[SP 800-137] provides guidance on continuous monitoring.

Assessment GuidanceExamine 0/7

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

Discussion

Provide a plan for monitoring the state of security controls on a recurring basis that occurs more frequently than the periodic assessments discussed in CA.L2-3.12.1. This process provides a mechanism to assess the overall security posture of your organization, which directly relates to activities discussed in CA.L2-3.12.4. As a result, the process not only maintains awareness of vulnerabilities and threats, but it also informs management of the effectiveness of the security controls in determining if security controls are current and for management to make an acceptable risk decision.

Examples

Example 1
You are responsible for ensuring your company fulfills all cybersecurity requirements for its DoD contracts. You review those requirements and the security controls your company has put in place to meet them. You then create a plan to evaluate each control regularly over the next year. You mark several controls to be evaluated by a third-party security assessor. You assign other IT resources in the organization to evaluate controls within their area of responsibility. To ensure progress you establish recurring meetings with the accountable IT staff to assess continuous monitoring progress, review security information, evaluate risks from gaps in continuous monitoring, and produce reports for your management [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.

Security planning policy
Organizational procedures addressing system security plan development and implementation
Procedures addressing system security plan reviews and updates
Enterprise architecture documentation
System security plan
Records of system security plan reviews and updates
Other relevant documents or records

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 security planning and system security plan implementation responsibilities
Personnel with information security responsibilities

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 system security plan development, review, update, and approval
Mechanisms supporting the system security plan

Potential Assessment Considerations

Are the security controls that need to be continuously monitored identified [a]?
Is the timeframe for continuous monitoring activities to support risk-based decision making defined [a]?
Is the output of continuous monitoring activities provided to stakeholders [a]?

Key References

NIST SP 800-171 Rev. 2 3.12.3

Overview