By Lon J. Berman, CISSP
As DoD begins its transition from DIACAP to Risk Management Framework for DoD IT, everyone is naturally focused on all the things that will be changing—everything from terminology to documentation to security controls.
Thankfully, not everything is changing!
We thought it would be interesting to take a look at some of the things that will not be changing with the advent of RMF in DoD.
1. DoDI 8510.01. DoD Instruction 8510.01 will remain the governing document for the security life cycle process. It is currently being revised to reflect RMF rather than DIACAP as the “official” DoD process.
2. DIACAP Knowledge Service. The DIACAP Knowledge Service will remain the authoritative source for security-related information and guidance. RMF-oriented content is currently being added.
3. Major Change. Systems will still need to be reauthorized (reaccredited) when a “major change” to the system takes place. The individual who signed the Authority to Operate (ATO) will still have the final say on whether or not a proposed change is “major”.
4. Contractor owned/Operated Systems. IT-based processes “outsourced” to contractor-owned systems will still require ATO.
5. Independent Assessment. DoD systems will still require independent assessment (in accordance with DoD Component policies and procedures) in order to receive ATO.
6. System Registration. Information systems will be still need to be registered with the IA program, in accordance with DoD Component policies and procedures.
7. Plan of Action and Milestones (POA&M). POA&Ms will continue to be used to report and track security weaknesses of information systems, and to manage corrective actions.
8. Configuration Standards. DISA Security Technical Implementation Guides (STIGs) will continue to be the official DoD standards for configuring operating systems, databases, web servers, network devices, etc..
9. Training and Certification. DoD Instruction 8570.1 (or its planned successor) will still be in force. DoD employees and contractors having any sort of IA responsibility will still be required to hold appropriate professional certification.
10. Approval to Operate (ATO). All information systems owned by DoD, or operated on behalf of DoD, will still need ATO from a senior DoD official.The process leading to ATO will be changing (RMF rather than DIACAP). Even the title of the person signing it will change (Authorizing Official rather than DAA), but the fundamental concept of risk-based decision (“balancing” or residual risk against mission need) will be unchanged.