Every federal information system must go through NIST’s Risk Management Framework before it can be used to process federal information. This process culminates in a signed Authority to Operate (ATO) being issued. Because the ATO process is a complex, multi-step process which will constrain the design and implementation of your system, you should start thinking about how it applies to your system before you begin designing and implementing it.
- Assessment: The step of the ATO process (and RMF) where the system and package are reviewed by a third party.
- ATO package: The SSP and other documentation needed to get an ATO.
- Authority to Operate (ATO): The approval for a government system to be run in production, and the compliance process for getting there.
- Compliance: Ensuring that a system meets minimum security requirements.
- Information system means a discrete set of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information (44 U.S.C. § 3502).
- POAM: Plan of Action and Milestones. They are the TODOs following an assessment, which are usually low-risk security findings that need to be addressed.
- RMF: The NIST Risk Management Framework (RMF), which is what most ATO processes are based on.
- Security: The sum of processes and features safeguarding systems and data.
- System Security Plan (SSP): The primary document in an ATO package, the bulk of which contains the NIST 800-53 security controls. “The purpose…is to provide an overview of the security requirements of the system and describe the controls in place or planned for meeting those requirements.” (NIST SP 800-18)
For a full list, see the NIST Glossary.
Roles in ATO processes typically include:
- Assessor: Responsible for checking the compliance of systems; sit in an agency’s Security team. Validates and verifies that the documented controls (see Step 3) actually work, using the assessment cases (see Step 4).
- Authorizing Official (AO): Responsible for overall impact categorization and risk acceptance. The AO is ultimately responsible for determining if the risk of operating the system is acceptable, and if so, issuing an Authority to Operate (ATO) for that system. They often Designate this responsibility to one or more other people.
- Information System Security Officer (ISSO): Supports the information security system, consults on control selection, organizes scanning process. Reports to the Information System Security Manager (ISSM).
- Penetration tester(s): Conducts the penetration test after terms are agreed to as documented in the Rules of Engagement (RoE).
- Program team : Those who are trying to build/launch the system.
- System Owner The system owner is usually the product lead or tech lead of the project team. They will be named in the ATO documents and are the main contact during the evaluation process that leads up to an ATO.
The long version: NIST SP 800-37 Appendix D
In the Federal government, the principal law governing the security of information systems is the Federal Information Security Management Act (FISMA). For more information on FISMA, check out the FISMA Ready introduction.
One of the goals of the Federal Information Security Management Act of 2002 (FISMA) is to “provide a comprehensive framework for ensuring the effectiveness of information security controls over information resources that support Federal operations and assets.” The National Institute of Standards and Technology (NIST) was tasked with designing and implementing this framework: the result is NIST’s Risk Management Framework (RMF). All federal information and information systems (except classified information and national security systems) are subject to NIST’s RMF. There’s an introduction to the RMF on NIST’s website. A more comprehensive guide, including how to apply the framework, references to the various relevant publications, and definitions of roles and responsibilities, is found in NIST’s Special Publication 800-37.
Your system may need to be reassessed and re-authorized if your application team is planning to make substantive changes, such as changes to:
- Encryption methodologies
- Administrative functionality within the application
- The kinds of information you store (for example, personally identifiable information (PII))
- The external services used or how/what data flows to/from them
- Anything that will requires an update to the System Security Plan, system diagram, etc.
Example changes that do not require re-authorization, as long as they don’t include the above:
- Bug fixes
- Interface changes
- Documentation updates
The Authorizing Official determines whether a system needs re-authorization. If you’re planning a change that you think may require re-authorization, contact them.
If it needs re-authorization, follow the usual steps for getting an ATO. You should be able to reuse most of your existing ATO materials, assuming they have been kept up-to-date.
Many ATOs are issued with a time limit, often this expiration is between one and three years. When an ATO nears expiration, you’ll need the ATO to be renewed. Follow the usual steps for getting an ATO. You should be able to reuse most of your existing ATO materials, assuming they have been kept up-to-date.