The Cloud Security Alliance Security, Trust, Assurance, and Risk (CSA STAR) program was established in 2012 as a way to verify and document the security and privacy controls implemented by cloud service providers (CSPs). CSA has seen mounting interest in their STAR certifications and attestations as adoption of cloud technologies continues to rise. Gartner predicts that nearly two-thirds (65.9%) of spending on application software will be directed toward cloud technologies by 2025.

Here’s everything you need to know about CSA STAR, how their certification program works, and why a growing number of CSPs are working toward certification.

What is CSA STAR?

The CSA, the governing body of the STAR program, is a nonprofit organization that is considered a worldwide authority in the area of cloud security research and the advocacy of best practices that support secure cloud computing. CSA designed the STAR program to help CSPs enhance their security assurance in the cloud through “the key principles of transparency, rigorous auditing, and harmonization of standards outlined in the Cloud Controls Matrix (CCM).”

CSA STAR leverages the CSA’s CCM, a framework used to test security and privacy controls (CSPs must adhere to the newest version, CCM v4). Once CSA STAR has been implemented, CSPs can apply to be listed on the official registry, allowing prospects and customers to confirm the security and compliance posture they adhere to.

Achieving a certification through the CSA STAR program effectively helps CSPs reduce the security risks inherent to cloud computing solutions and services, like Software as a Service (SaaS), Platform as a Service (PaaS), and Infrastructure as a Service (IaaS). As CSA Founder and Chairman Dave Cullinane said, “If you have an application exposed to the Internet that will allow people to make money, it will be probed.”

CSPs have two options to choose from when pursuing CSA STAR, each which has its own specific set of requirements.

What is CSA STAR Level 1?

CSA STAR Level 1 is a self-assessment intended for CSPs that operate in a low-risk environment and want to offer greater visibility into the security controls they have in place. Level 1 is a free assessment conducted internally and does not require a third-party firm to complete.

There are two variations of the Level 1 assessment:

• Security Self-Assessment: The CSP submits a completed Consensus Assessment Initiative Questionnaire (CAIQ) to document compliance with the CCM. The security self-assessment only covers security-related controls and must be updated annually.
• GDPR Self-Assessment: The CSP submits a completed Code of Conduct Statement of Adherence and Code of Practice to document compliance with GDPR. The GDPR self-assessment only covers privacy-related controls and must be updated annually.

Both of these self-assessments must also be updated any time there is a change to the CSP’s policies or practices related to the service being assessed. Depending on the CSP’s desire to highlight security and/or privacy controls, they may choose to complete one self-assessment or both.

What is CSA STAR Level 2?

CSA STAR Level 2 is a third-party audit intended for CSPs that operate in a medium- to high-risk environment and want to enhance the controls of another standard or certification the business already follows. Completing both the self-assessment and CAIQ mentioned above are prerequisites for Level 2.

Additionally, Level 2 is not a standalone assessment and there are costs associated. For the third-party audit, the organization must use a certified STAR auditor, such as A-LIGN, to perform one of the following assessments depending on the standard they have already adopted:

• AICPA SOC 2 + CSA STAR Attestation (Most Common) — This attestation includes the SOC 2 Trust Services Criteria and the CCM framework, and must be renewed annually. Type 1 SOC 2 is acceptable for companies undergoing the CSA STAR for the first time, but subsequent submissions must have a review period of no less than six months (12 months for Type 2).
• ISO 27001:2022 + CSA STAR Certification — This certification includes the ISO 27001:2022 requirements and the CCM framework. It must be conducted on an annual basis and submitted to CSA Star to update the registry upon recertification every three years.
• GB/T 22080-2008 + CSA C-STAR Assessment — Intended for CSPs that do business in China, this assessment includes the CCM framework and the Chinese national requirements of GB/T 22080-2008, plus additional controls from GB/T 22239-2008 and GB/Z 28828-2012. It must be completed every three years to maintain compliance.

If you are a CSP interested in pursuing CSA STAR Level 2, consider reading the CSA’s official Code of Practice to gain a better understanding of the steps required to earn a certification or attestation.

What are the benefits of certification?

Described as “the world’s largest and most consequential cloud provider security program,” CSA STAR allows CSPs to show that they take information security very seriously and are willing to take comprehensive measures to reduce the risk of a data breach. At its core, a CSA STAR certification or attestation (Level 2) demonstrates that companies needing to host their data within a cloud computing environment can do so knowing that it is protected using a world-class security framework specifically designed for cloud computing. The certification also:

• Reduces security risk for everyone involved with a CSP: the business, its customers, and other data owners.
• Allows CSPs and their customers to become better aligned on security practices. The transparency inherent to CSA STAR makes it easier for both parties to work together to keep data safe.
• Helps CSPs establish themselves as trusted cloud vendors. The certification is a valuable marketing tool and being listed in the CSA STAR Registry can bring in new business.
• Accelerates the sales cycle in some cases by reducing the work security teams might need to perform to sign new clients or establish new partnerships.

Navigating the Cloud Security Spotlight 

With the adoption of cloud-based technologies only becoming more prevalent, there will undoubtedly be a spotlight on cloud security for years to come. CSA STAR certification offers a tried-and-tested way for CSPs to take their security posture to the next level and reduce the risk of a breach for both themselves and their customers. It is a highly valuable addition to any CSP’s compliance arsenal; for example, we helped PROS achieve CSA STAR certification in addition to SOC 1, SOC 2, SOC 3, ISO 27001, and PCI DSS.

If you are a CSP interested in SOC 2 + CSA STAR Attestation or ISO 27001:2022 + CSA STAR Certification, A-LIGN is a certified CSA STAR auditor that can help your organization take the most efficient path to earning a spot on the official registry.

There are a number of steps that need to take place before an organization can embark on their ISO 27001 certification journey. Perhaps the most important is to determine which certification body to work with. A certification body (CB) is an organization that provides certifications around a chosen standard. They can either be an accredited CB or an unaccredited CB. Although there are admittedly minor differences between the two, the outcome of your ISO/IEC 27001 certification, and how you are able to leverage it, could vary drastically.

In this blog, we’ll explore the different certification bodies, and explain why choosing the right one matters.

What is ISO 27001?

ISO 27001 is a cybersecurity framework established by the International Organization for Standards (ISO), focused on building an information security management system (ISMS) within your organization. An ISMS helps organizations manage the security of all data, ranging from financial information to intellectual property (IP) or other confidential information.

ISO 27001, specifically, is a risk-driven standard that centers on data confidentiality, integrity and availability. Because it’s built around the process of monitoring and improving information security, its intent is to help organizations improve their approach to data security in a more holistic manner.

This is of particular importance for organizations looking to more efficiently reduce risk, optimize operations, and build a culture of information security. In fact, the standard also helps in implementing controls specific to an organization’s unique risks and assets, rather than applying general guidance in a one-size-fits-all approach.

Accredited certification body vs. unaccredited certification body

Accredited certification body

An accredited certification body (CB) must complete an extremely rigorous evaluation process through an accreditation body to ensure the certification audit it conducts is performed in accordance with the audit requirements. The evaluation process reviews the competence of the audit team, the audit methodology used by the certification body, and the quality control procedures in place to ensure both the audit and report are properly completed.

It’s worth noting organizations that use an accredited CB for certification will receive their ISO 27001 certifications with the accreditation body and IAF seal included. This illustrates that the certification body has an accreditation certificate and is  accepted worldwide.

Unaccredited certification body

Unlike an accredited CB, an unaccredited CB is not audited to confirm their compliance with IAF certification audit requirements.

In some cases, it will be critically important for organizations to determine their clients’ expectations. If an organization is pursuing an ISO 27001 certification to meet a client need, they should also confirm if the client requires an accredited certificate or if they will accept a certificate from an unaccredited CB.

The ISO 27001 certification process is a detailed and intensive assessment that requires organizations to illustrate conformance to the standard across seven mandatory clauses and 114 Annex A controls. No organization wants to needlessly go through the process twice by working with an unaccredited CB when a certificate from an accredited CB is required.

ISO 27001 Certification bodies

Certification bodies are accredited to issue ISO/IEC 27001certificates. That said, there are many national accreditation bodies that provide accreditation to CBs for ISO 27001.  Here is a deeper look into a few major players ANAB and UKAS.

ANAB

The ANSI National Accreditation Board (ANAB) is the largest accreditation body in North America, providing services to more than 75 countries. ANAB’s mission is to be a “leader in guiding the international development of accreditation processes that build confidence and value for stakeholders worldwide.” ANAB aims to do this by “providing high quality and reliable accreditation services with the most professional value-added services for customers and end users.”

Obtaining an ANAB accreditation for CBs has a number of benefits, including assurance of competence and reliability, and increased confidence from suppliers, partners and vendors. These result from the regular, impartial, and independent audits conducted by an internationally respected body.

UKAS

The United Kingdom Accreditation Service (UKAS) is the national accreditation body for the UK. Its mission is to instill trust and confidence in the products and services widely used each day.

The benefits for CBs obtaining UKAS accreditation is that UKAS demonstrates the competence, impartiality and performance capability of the evaluators. Basically, UKAS describes themselves as “checking the checkers,” essentially allowing certified organizations to establish a stronger sense of trust around data security with their customers.

Although there are many accreditation bodies located throughout the world, there is little difference among the primary three. This is because all accreditation bodies follow similar processes to identify CBs based on alignment with various checks-and-balances established by organizations like the IAF.

The IAF

The International Accreditation Forum (IAF) serves as the regulator for national accreditation bodies, including ANAB, RvA, and UKAS. Its primary function is to “develop a single worldwide program of conformity assessment which reduces risk for businesses and their customers by assuring them that accredited certificates and validation and verification statements may be relied upon.”

Basically, the IAF oversees the activities of the accreditation bodies to ensure they maintain the required standards when providing accreditation to CBs.

Most accreditation bodies are represented within the IAF and are committed to upholding the trust and validity of accreditation bodies in their efforts to provide certificates to CBs.

How certification bodies obtain and maintain accreditations

Certification bodies undergo a stringent process of annual office and witness audits. Many accreditation bodies will offer numerous training sessions for both individuals and organizations to not only stay educated on evolving standards, but to also maintain accreditations.

The ANAB, for example, offers a variety of training sessions focused on expanding knowledge of certain standards and mandatory documents.

Next steps

With an ISO 27001 certification, your organization can gain significant benefits, including building a culture of information security and diligence, and meeting additional security compliance requirements. And when you leverage an accredited certification body to help you achieve your ISO 27001 certification, your certification creates a stronger sense of trust and acceptance with customers worldwide.

A-LIGN is an ANAB accredited ISO/IEC 27001 certification body that helps organizations meet their ISO certification needs.

Get started by downloading our ISO 27001 checklist.

HIPAA (Health Insurance Portability and Accountability Act) is a federal law requiring organizations to keep patient data confidential and secure. If you are an organization that handles protected health information (PHI), a HIPAA compliance report will demonstrate you have the required safeguards in place to protect patient information.

There are three major components to HIPAA rules and regulations – the Security Rule, Privacy Rule, and Breach Notification Rule. This article will give background information on these three components and provide a checklist you can use when seeking HIPAA compliance.

What is HIPAA Compliance?

HIPAA compliance is a process for covered entities and business associates to protect and secure PHI in a way that complies with the established Privacy, Security, and Breach Notification Rules. Let’s review what information classifies as protected healthcare information and the professions bound by HIPAA regulations.

• PHI is protected healthcare information. This includes items such as paper documents, X-Rays, and prescription information. Electronic protected health information (ePHI) is PHI that includes digital medical records, electronic MRI scans, names, addresses, and dates (birthdays, hospital admission, discharge dates, etc.) stored or transmitted electronically.
• Covered entities are individuals and organizations working in healthcare who have access to PHI. These include doctors, surgeons, nurses, psychologists, dentists, chiropractors, hospitals, clinics, nursing homes, pharmacies, health plans, health insurance companies, HMOs, and company health plans. They frequently work with sensitive health information and are therefore bound by HIPAA regulations. 
• Business associates are individuals and entities that perform activities involving the use or disclosure of protected health information on behalf of, or provide services to, a covered entity. This could include, but is not limited to, lawyers, accountants, administrators, and IT professionals.

Compliance with the HIPAA Security Rule

The HIPAA Security Rule requires covered entities accessing or handling ePHI to follow appropriate technical, physical, and administrative safeguards designed to keep the healthcare data confidential and secure.

• Technical Safeguards refers to the following:
  • Access Controls. Only authorized persons may have access to ePHI.
  • Audit Controls. Records of those accessing ePHI must be kept for auditing.
  • Integrity Controls. Measures must be established to confirm ePHI has not been improperly altered or destroyed.
  • Transmission Security. Security measures must be established to guard against unauthorized access to ePHI transmitted electronically.
• Physical Safeguards refers to the following:
  • Facility Access and Control. Physical access to facilities must be limited to authorized personnel.
  • Workstation and Device Security. Policies and procedures must be established specifying the proper use of and access to workstations and electronic media.
• Administrative Safeguards refers to the following:
  • Security Management Process. Potential risks to ePHI must be identified and analyzed, and security measures implemented to reduce these risks.
  • Security Personnel. The entity must appoint someone from the organization as the designated security official responsible for developing and implementing its security policies and procedures to assure compliance with the Security Rule.
  • Information Access Management. Policies and procedures must be established authorizing access to ePHI only when necessary.
  • Workforce Training and Management. Workforce members handling ePHI must be trained on security policies and procedures, supervised, and sanctioned when they violate these policies and procedures.
  • Evaluation. Periodic assessment must be conducted to evaluate how well security policies and procedures meet the requirements of the Security Rule.

Compliance with the HIPAA Privacy Rule

The Privacy Rule addresses the use and disclosure of PHI by covered entities and outlines an individual’s privacy rights so they can understand their health information and control how it’s used. This rule covers all personal identifiers handled by a covered entity or its business associates in any media (electronic, paper, or spoken word).

With the exception of disclosure of PHI for treatment, payment, or healthcare operations, complying with the Privacy Rule means that PHI is only disclosed when authorization is given by the patient, patient’s legal representative, or decedents, or:

• When required by law
• When in the patient’s or the public’s interest
• To a third-party HIPAA covered entity where a relationship exists between that party

Additionally, the Privacy Rule limits disclosure of PHI to the minimum necessary for the stated purpose.

Compliance with the Breach Notification Rule

The HIPAA Breach Notification Rule requires covered entities and their business associates to provide notification following a breach, or the impermissible use or disclosure of PHI. Patients and the Department of Health and Human Services must be notified of breaches, as well as the media if the breach affects more than 500 patients. Notification must be reasonably prompt and no later than 60 days following discovery of the breach.

Breaches affecting fewer than 500 individuals must be reported to the Office for Civil Rights (OCR) web portal on an annual basis. Breach notifications should include:

• The nature of the PHI and the types of personal identifiers exposed
• The unauthorized person who accessed or used the PHI or, if known, to whom the disclosure was made
• Whether the PHI was acquired or viewed (if known)
• The extent to which the damage or risk of damage has been mitigated

HIPAA Compliance Checklist

Covered entities and business associates can use the following as a guide to help establish or remain in HIPAA compliance.

1. Identify gaps in audits and document deficiencies through a HIPAA gap analysis
2. Create and document remediation plans to address deficiencies found in audits
   • Update and review these remediation plans annually
   • Retain records of documented remediation plans for six years
3. Ensure staff completes HIPAA training
   • Document their training
   • Designate a staff member to be the HIPAA Compliance, Privacy, and/or Security Officer
4. Maintain policies and procedures relevant to the annual HIPAA Privacy, Security, and Breach Notification Rules
   • Ensure staff reads and legally attests to the policies and procedures
   • Maintain documentation of their legal attestation
   • Maintain documentation for annual reviews of the policies and procedures
5. Identify vendors and business associates who may handle PHI
   • Establish agreements with all business associates
   • Assess the HIPAA compliance of business associates
   • Track and review business associate agreements annually
   • Sign confidentiality agreements with non-business associate vendors
6. Define a process for incidents and breaches
   • Ensure you can track and manage the investigations of all incidents
   • Ensure you can provide the required reporting of all breaches or incidents
   • Ensure staff members can report incidents anonymously

A-LIGN Specializes in HIPAA Compliance

The fines for HIPAA violations are imposed per violation category and can be severe, reaching up to $1,500,000 per violation category, per calendar year. Authorities can even file criminal charges in the case of willful neglect.

To ensure your organization remains in good standing, it’s often best to have professional assistance. With over 850 healthcare assessments completed, A-LIGN helps organizations achieve HIPAA compliance from readiness to report. Click to explore our HIPAA services.

Download our HIPAA checklist now!

On February 15, 2022, the International Organization for Standardization (ISO) released an update to ISO/IEC (International Electrotechnical Commission) 27002:2013 under the name ISO/IEC 27002:2022. The release of this new standard has caused a lot of confusion and anxiety within companies, with many under the mistaken impression that they’ll have to undergo a new certification process in order to achieve compliance. This, however, is not true.

In this blog, I’ll shed light on the new standard and explain what ISO 27002:2022 means for your business.

What Is ISO 27002?

Let’s start by clarifying that ISO 27002 should be viewed as more of a manual as it offers extensive guidance on the Annex A controls and best practices an organization should implement to ensure the confidentiality, integrity, and availability (CIA) of assets.

ISO 27001, on the other hand, actually establishes the compliance requirements needed to become certified. This clarification is important, primarily because ISO 27001 has not been updated yet, only its supplemental guidebook ISO 27002 has changed. This is, however, a great time for organizations to implement the best practices found in the revamped guidebook as we expect ISO 27001 will also be updated fairly soon.

Why Was ISO 27002 Updated?

Updates to ISO standards occur periodically. ISO/IEC 27002 has origins that trace back to a 1990’s UK government initiative. It was first a standard developed by the oil company Shell Energy that was donated to the UK and became a British standard in the mid-1990s ISO 27002 was adopted as an ISO standard in the year 2000 and seems to undergo revisions on an eight/nine-year cycle with official updates to ISO 27002 occurring in 2005, 2013, and now in 2022.

This most recent update reimagines the terminology and format of ISO 27002 to make it easier for the layperson to understand. There’s also more focus on cybersecurity and privacy, better aligning the controls to the modern digital era. 

What Are the Major Changes?

While ISO 27002:2022 is an exhaustive guide with numerous changes, there are six changes in particular of which organizations should be aware.

1. Reduced Total Controls

There were previously 114 internal controls listed in ISO 27002:2013. Now, 57 of the controls have been consolidated, leaving just 24 controls to eliminate redundancies. It’s worth noting that while the number of controls has decreased, no controls were excluded, only merged for simplicity. And with the addition of some new controls, the total number now stands at 93.

2. 11 New Controls

The 93 total controls include 11 brand new controls that address:

• Information security for use of cloud services
• ICT readiness for business continuity
• Physical security monitoring
• Configuration management
• Information deletion
• Data masking
• Data leakage prevention
• Monitoring activities
• Web filtering
• Secure coding
• Threat Intelligence

3. Domains Have Become Categories      

Say goodbye to confusing domains and hello to categories. Now, instead of 14 domains, each of the internal controls fall under one or more of the following four categories:

• Organization
• People
• Physical
• Technological

4. “Objectives” Have Become “Purpose”

Don’t expect to find the word “objective” as you would have in previous versions of the standard. Instead, you’ll find each of the controls have an intended “purpose.” This new framing was done intentionally to help organizations better understand the point of the control and its impact on your assets. 

5. New Attributes Tables

ISO created a table of attributes that correspond with each control. The five categories of attributes are as followed:

6. Two New Annexes

Although there’s been a lot of consolidations, additions, and renaming of controls, ISO has made it easy to map the controls back to the 2013 version. With Annex B, users can find a 2022 control and then see with which 2013 control it corresponds. The reverse is true with Annex A, which allows users to first select a 2013 control and find the 2022 control with which it corresponds.

Get Ready for Certification

Although no action needs to be taken today, the updates to ISO 27002:2022 present a great opportunity for organizations to start reviewing and updating their internal controls. Doing so now, ahead of the anticipated ISO 27001 update, will enable organizations to more efficiently implement best practices to achieve compliance in the future. Certification bodies will require a shift once ISO 27001 has been updated but as always, being prepared is key to cybersecurity compliance success!

To expand your knowledge on how to achieve compliance, check out what it takes to get certified in 5 Steps to ISO Certification.

Federal supply chain risk management has garnered considerable attention in recent years following the 2020 SolarWinds cyberattack. Similar threats still loom large — cyber-enabled supply chain attacks are increasingly being used as a hybrid warfare tactic against the United States. While the concepts of supply chain risk management (SCRM), cyber SCRM (C-SCRM), and federal SCRM are closely related, it’s important to note that federal SCRM is a matter of national security. As a result, it has more serious implications when compared to commercial SCRM.

To understand current efforts being made to improve federal supply chain risk management, you first need to learn how supply chain risk management is defined in the context of cybersecurity. 

What is cyber supply chain risk management?

Cyber supply chain risk management is the ongoing process of maintaining the integrity of an organization’s cyber supply chain by identifying, evaluating, and mitigating the risks associated with IT and software service supply chains. However, much like cybersecurity, C-SCRM is not entirely dependent on the IT department — it must be an organization-wide effort to protect critical systems that fits into the overarching risk management framework.

The National Institute of Standards and Technology (NIST) has been at the forefront of researching C-SCRM and presenting their findings to benefit both the public and private sectors. They note that many of the factors that enable rapid, cost-effective technological innovation are also increasing supply chain risk. Last year, NIST released a comprehensive guide of C-SCRM best practices that includes eight recommendations organizations (across industries) should prioritize:

1. Integrate C-SCRM across your organization.
2. Establish a formal C-SCRM program that is evaluated and updated in real-time.
3. Know your critical suppliers and how to manage them.
4. Understand your organization’s supply chain.
5. Collaborate with your key suppliers and incorporate them in your supplier risk management program.
6. Include key suppliers in your resilience and improvement activities; for instance, include as part of your vendor risk assessment process.
7. Constantly and vigorously provide continuous monitoring of your C-SCRM.
8. Have a plan for all business operations, not just for what appears to be the most critical parts of your organization’s various functions.

C-SCRM is similar to other categories of risk management in that there is a significant focus on increasing information visibility and awareness. After all, you can’t manage what you don’t know. As you can see in several of the NIST best practices outlined above, maintaining trustful and transparent relationships with your suppliers and vendors is essential — your C-SCRM program is only as strong as its weakest link. 

According to research from Ponemon Institute, breaches caused by third parties increase the cost of a data breach by over $370,000. This also includes “fourth parties,” or the third parties of third parties.

To navigate these frequently overlooked challenges, here are a few additional tips for effective C-SCRM:

• Adopt an “assume breach” mentality (see: zero trust) in which you expect all of your networks, systems, and applications are already, or will soon be, compromised.
• Make a thorough inventory of all assets (hardware, software, personnel, contracts, etc.) and where they interact with third parties.
• Clearly define security requirements in contracts and RFPs, and ask suppliers/vendors for evidence (e.g., their security policy, pen test reports, compliance certifications).
• Beyond initial verification, practice continuous monitoring of your vendors’ security controls to ensure that they remain effective over time.

What is federal supply chain risk management?

Federal supply chain risk management focuses on mitigating supply chain risks in the context of national security. The Cybersecurity and Infrastructure Security Agency (CISA) sometimes refers to federal SCRM as “National Industrial Base Security” because it has historically fallen under the purview of the Department of Defense (DoD).

However, the U.S. government is now making a major effort to relate the importance of cybersecurity and SCRM to all businesses and industries, not just those that are part of the Defense Industrial Base (DIB). In fact, in the cybersecurity Executive Order that was released last year, there is an entire section dedicated to enhancing the software supply chain security of the federal government, which includes thousands of technology companies. The Department of Homeland Security (DHS) also recently launched the Cyber Safety Review Board (CSRB) which will investigate national cyber incidents.

Federal SCRM is vital to U.S. security because our nation’s adversaries have become extremely sophisticated in their ability to exploit supply chain vulnerabilities to infiltrate systems, steal intellectual property, corrupt software, surveil critical infrastructure, and more.

NIST 800-171 and supply chain risk management

In 2015, NIST published special publication 800-171 to help shore up federal supply chain security. NIST 800-171 sets standards that federal contractors and subcontractors that handle, transmit, or store federal contract information (FCI) and/or controlled unclassified information (CUI) must follow to ensure that data is protected.

In September 2020, the DoD issued the Defense Federal Acquisition Regulation Supplement (DFARS) Interim Rule which states that all federal contractors and subcontractors must upload their NIST 800-171 self-assessment results to the Supplier Performance Risk System (SPRS) as a requirement to do business with the government.

CMMC and supply chain risk management

The self-attestation approach that is currently in place has proven to be unreliable for SCRM — many organizations involved in the federal supply chain still do not fully adhere to NIST 800-171. That’s why the DoD is in the process of creating the Cybersecurity Maturity Model Certification (CMMC) program to protect Controlled Unclassified Information (CUI).

When the program is officially launched, certification will require an independent assessment conducted by a CMMC Third-Party Assessment Organization (C3PAO).

CMMC 2.0: The future of federal supply chain risk management

CMMC 1.0 vs. CMMC 2.0

In November 2021, the DoD announced several updates and changes to the initially proposed CMMC framework, resulting in an enhanced “CMMC 2.0.” You can read my CMMC 2.0 recap here, but the most significant changes from CMMC 1.0 include:

• Two levels of the original five-level framework have been removed for a total of three levels (Level 1: Foundational, Level 2: Advanced, and Level 3: Expert).
• Certain third-party assessment requirements have been reduced. For Level 1, annual self-assessments will be accepted without third-party validation. For Level 2, for some organizations, depending on the CUI sensitivity, may only require an annual self-assessment without independent validation.
• Level 2 (formerly CMMC 1.0 Level 3) now includes only the 110 practices from NIST SP 800-171 Rev. 2; the additional 20 practices from other frameworks have been removed for now.
• Level 3 (CMMC 1.0 Level 5) is currently under development but will include a subset of NIST SP 800-172 requirements to be assessed by DoD directly.

How to prepare for CMMC 2.0

If your organization is one of the 300,000+ companies that are part of the DIB supply chain and will be required to obtain CMMC, now is the time to lay the foundation for future success. Here are a few tips to prepare for CMMC 2.0:

• Implement NIST 800-171 in its entirety (this is perhaps the most important thing you can do right now).
• Identify where critical data is stored — CMMC only considers the parts of your organization that touch FCI and CUI and relate to the protection of FCI and CUI to be in-scope.
• Determine what level of the CMMC model you will have to achieve depending on the critical data being handled. If you fall under one of the first two levels (as most organizations will), review the DoD self-assessment scope for Level 1 or Level 2.
• Begin to educate your subcontractors about the CMMC requirements they will have to fulfill so they can begin laying the groundwork, as well.

CMMC 2.0 will not become a contractual requirement until the DoD completes the rulemaking process, which is estimated to take 9 to 24 months from the start of 2022. Given this time frame, it is expected that there will be one to two new interim rules published before the program is officially launched.

Work with a top FedRAMP assessor

Federal SCRM will be vital in the coming years as the global cyberattack volume continues to increase. Companies that previously didn’t consider C-SCRM a high priority are now tasked with enhancing their defenses and increasing visibility into their entire supply chain to identify weak points. Third-party risk is a significant threat because many organizations don’t realize they are working with suppliers or vendors that have poor cybersecurity hygiene.

If you’re looking for guidance through the NIST 800-171 self-assessment process, or would like assistance preparing for CMMC so you can take the most efficient path to certification once the program launches, A-LIGN can help. We have completed hundreds of successful federal assessments and our firm is a candidate C3PAO that will be authorized to complete CMMC certification.

Since late 2016, organizations have faced a stricter certification process to be granted access to the Death Master File (DMF), a computer database created by the United States’ Social Security Administration from 1962 to present day. The DMF is a protected file that includes information regarding the deceased such as their name, date of birth, date of death, social security number, last known zip code, if their death certification was observed, and other personal identifiable information (PII). For organizations who need to access to the PII of deceased individuals, they will need to certify with the DMF. Generally, in the three-year period following an individual’s death, sensitive information is unable to be released.

There are many challenges organizations can face when seeking DMF certification. Let’s review the certification process, what your organization should prepare for, and the standards against which you can certify.  

What is the DMF certification process?

To access the DMF, an individual or entity must have a legitimate fraud prevention interest or have a legitimate business purpose to a law, government rule, regulation, or fiduciary duty. If an organization qualifies for DMF certification, they will be required to follow the steps below during their assessment process.

Step 1: Testing is conducted against SOC 2 or NIST 800 series standards.

Step 2: Organizations must go to the National Technical Information Service (NTIS) website to pay the required fees and will receive a processing number. Please note, these fees are in addition to those paid to the Accredited Conformity Assessment Body (ACAB) for attestation.

Step 3: Organizations must obtain the FM100A attestation form from the NTIS website and provide your auditing firm with the processing number to complete the attestation.

Step 4: Your auditor files the attestation documentation with NTIS. Your auditor will notify you that your form has been submitted and reaches out only if an issue arises. If all information is correct, NTIS communicates directly with your organization on approval/certification status.

What should my organization prepare for?

Once you achieve DMF certification, it doesn’t stop there. Your organization will need to be prepared for recertifications, unscheduled audits and more. Below is a list of what you can expect in the next several years following your initial DMF certification.

• Annual recertification by the organization seeking access
• Third-party conformity attestation every three years
• Agreement to scheduled and unscheduled audits, conducted by National Technical Information Service (NTIS) or the ACAB at the request of NTIS
• Fines up to $250,000 per year for noncompliance

The entity wishing to access the DMF must submit written attestation from an ACAB to prove that the appropriate systems, facilities and procedures are in place to safeguard information and maintain the confidentiality, security, and appropriate use of the information.

Subscriber certification must be completed annually. The LADMF Systems Safeguards Attestation Form must be completed every three years.

The U.S. Department of Commerce’s National Technical Information Service (NTIS), the governing body behind the DMF, can conduct both scheduled and unscheduled compliance audits and fine organizations up to $250,000 for noncompliance, with even higher penalties for willful violations. Due to the potential for substantial fines, it is important that entities be able to implement the appropriate systems’ facilities and procedures to safeguard the information.

What standards can organizations certify against?

Organizations can achieve certification by testing against standards such as SOC 2, and NIST 800 series publications.

What is SOC 2?

SOC 2 is a reporting standard that provides clients assurance regarding a service organization’s controls that do not affect the clients’ internal controls over financial reporting. This report is intended for use by stakeholders (customers, regulators, business partners, suppliers, directors) of the service organization to have a thorough understanding of the service organization and its internal controls.

What is NIST 800-53?

Published by the National Institute of Standards and Technology (NIST), NIST 800-53 covers the steps in the Risk Management Framework (RMF) that address security control selection for federal information systems in accordance with the security requirements in the Federal Information Processing Standard (FIPS) 200.

Helping You Achieve DMF Certification

A-LIGN is an ACAB that can attest to organizations’ systems and procedures in place. A-LIGN utilizes various published information security standards, mainly the AICPA SOC 2, to satisfy the rule’s audit requirements.

Since 2015, A-LIGN has been working to help our clients meet their DMF audit requirements and has successfully submitted the appropriate attestation forms to NTIS, resulting in certification for our clients. We have extensive experience testing the controls required by LADMF and can guide your organization through the certification process with ease.

Any organization seeking to provide cloud products or solutions to a federal agency will need to go through a FedRAMP Readiness Assessment and then a full FedRAMP assessment to receive an Authorization to Operate (ATO) which ensures the security of its hosted information meets FedRAMP requirements. The Federal Risk and Authorization Management Program (FedRAMP) is a government-developed standardized approach to security assessment, authorization, and continuous monitoring of Cloud Service Providers (CSPs). Only Third Party Assessment Organizations (3PAO) may perform FedRAMP assessments.

Rather than needing multiple assessments, FedRAMP is an integrative standardized audit designed to be a common one-stop-shop for CSPs. FedRAMP follows the “do once, use many” methodology. FedRAMP’s myriad of benefits includes efficiency of resources, both cost effective and time-saving.

The goal of FedRAMP is to increase confidence in the security of cloud solutions through continuous monitoring and consistent use of best information security practices and procedures.

As organizations explore their federal audit options, A-LIGN’s experienced assessors have compiled and answered five frequently asked questions to help organizations better understand the assessment process.

1. Does FedRAMP apply to me?

Any Cloud Service Provider (CSP) that is currently or looking to become a third-party vendor for federal agencies must become FedRAMP certified. State government agencies may also require third-party CSPs to become FedRAMP certified. There is also the StateRAMP program for CSPs working with State governments.

2. Do CSPs need an agency sponsor to become FedRAMP certified?

Yes, there are two processes in which CSPs can become FedRAMP certified. The first is through an agency sponsorship when a government entity vouches for a CSP streamlining their approval process. The other option is for CSPs to go through the Joint Authorization Board (JAB) that includes a readiness assessment which reviews controls and upon passing provides joint provisional security authorization.

3. What are the key processes of FedRAMP?

The key processes of FedRAMP include a security assessment, leveraging and authorization, and ongoing assessment and authorization. The security assessment involves a set of requirements from the NIST 800-53 Rev. 4* controls to test security authorizations. In the FedRAMP repository, federal agencies view security authorization packages and leverage these packages to grant authorization. Once granted, continuous assessment and authorization, or continuous monitoring, activities must be in place to uphold authorization.

*FedRAMP will be transitioning to NIST SP 800-53 Rev. 5.

4. Is penetration testing mandatory for a FedRAMP ATO?

Yes, a penetration test is a mandatory part of the assessment process if the CSP is moderate or high-risk level impact. Third-Party Assessment Organization (3PAO) must perform mandated penetration testing.

5. How do I start the process of becoming FedRAMP certified?

The process is dependent on an organization’s current level of compliance with NIST SP 800-53 Rev. 4. If an organization has never written a System Security Plan (SSP), evaluating current security controls against the controls in the NIST SP 800-53 Rev. 4 is recommended.

Becoming FedRAMP Compliant

If you are a Cloud Service Provider (CSP) currently providing, or seeking to provide, services to federal agencies, A-LIGN can make your FedRAMP process seamless. We will support you during your entire FedRAMP journey, from readiness to authorization.

You may have noticed the United States’ Federal Risk and Authorization Management Program (FedRAMP) is now gaining traction in other parts of the world. It begs the question, “Does my business need a FedRAMP assessment?”

FedRAMP was originally launched in 2011 as a way for the U.S. government to manage security risks as they adopt products and services that store, process, and transmit federal information in the cloud. Although FedRAMP is usually leveraged as a way for cloud service providers (CSPs) to meet Federal Information Security Modernization Act (FISMA) requirements, a growing number of organizations are using this risk-based standard to not only enhance their security, but to also stand out from the competition and win new business.

Let’s take a look at why a European business would want to pursue FedRAMP authorization and the many benefits to their organisation.

Why would a European business pursue FedRAMP Authorization?

There’s one main factor that most often motivates European businesses to pursue FedRAMP Authorization to Operate (ATO) status: They would like to sell a cloud service offering (CSO) to the U.S. government.

FedRAMP was specifically designed to ensure that CSPs with a software as a service (SaaS), platform as a service (PaaS), or infrastructure as a service (IaaS) CSO have adequate information security to do business with a U.S. federal agency. The specific requirements that a CSO must fulfil are dictated by FISMA and its subsequent memorandums.

In other words: If your business is a CSP that would like to sell a cloud-based solution to the U.S. government, you must obtain FedRAMP. Bonus- FedRAMP’s “do once, use many approach” means that when you achieve FedRAMP ATO status, your security package can be reused by any federal agency. You will also be listed in the FedRAMP Marketplace, which is often the first place federal agencies look when sourcing a new CSO.

What are the benefits of FedRAMP for European businesses?

Before we dive into the benefits, it’s worth noting that FedRAMP is not a quick and easy process that your business can sail through without much effort. It is a serious undertaking that requires patience as you work to fill your existing security gaps.

That being said, achieving FedRAMP ATO status comes with several advantages that make the effort required more than worth it. Here are a few to consider:

• The ability to re-use FedRAMP across multiple U.S. government agencies
• More robust security and risk mitigation for your CSO
• Enhanced real-time security visibility
• Improved trust among customers, prospects, and partners
• A marketing proof point that can be used in the private sector

Additionally, the new FedRAMP control baselines using NIST 800-53 Rev 5v uses an evolving, threat-based approach that allows CSPs to keep their information security efforts up to date against new and emerging threats.

How can my business get started with FedRAMP?

There are two options to choose from when looking to authorize a CSO through FedRAMP: a Joint Authorization Board (JAB) provisional authorization (P-ATO) or an ATO issued by an individual U.S. government agency. For more guidance on selecting your authorization strategy, I highly recommend reading through the FedRAMP CSP Authorization Playbook.

Below are the four high-level steps involved in the FedRAMP authorization process:

1. Document

Your business must categorize the CSO being considered for FedRAMP in accordance with NIST FIPS-199. The category (Low, Moderate, or High impact) that applies to your CSO depends on how much harm would be caused by a security breach. See our guide Understanding Federal Compliance for more details about these impact levels.

2. Assess

A federally-accredited third-party assessment organization (3PAO) conducts a security assessment to determine if your CSO meets the baseline controls required for FedRAMP. If they do meet the baseline controls, the 3PAO will submit an assessment package attesting to your compliance.

3. Authorize

The government agency will review the security package and either approve to organization as FedRAMP authorized or request additional testing. A final review is then conducted by the government agency and FedRAMP Program Management Office (PMO) to decide if they will accept the risk associated with the use of the CSO. If approved and accepted, Authorizing Officials will issue an ATO letter.

*For the P-ATO route, this review process will also include the FedRAMP JAB.

4. Continuously monitor

After authorization is granted, you must provide monthly deliverables to the agency (or agencies) using your CSO to demonstrate that your cloud security controls are continuing to operate effectively. You must also have a 3PAO complete an annual security assessment to ensure the system’s risk posture remains acceptable.

Work with a top FedRAMP assessor

While FedRAMP was created to assist the U.S. government to rapidly, rigorously, and consistently assess the security of cloud solutions, it also benefits CSPs. From earning more U.S. federal work to increasing trust among customers and prospects in the private sector, there are several reasons why your European business may want to pursue FedRAMP authorization.

Looking to firm up your plan for FedRAMP? As an accredited 3PAO that is one of the top five FedRAMP assessors in the world, A-LIGN is ready to perform your security assessment. In fact, we are currently a FedRAMP 3PAO for a growing number of European CSPs. If you have already chosen a 3PAO, but could use some guidance throughout the preparation process, our independent team of advisors can help you with control implementation, process documentation, and everything in between. Learn more about our comprehensive FedRAMP services.

As more customers ask for demonstrated SOC 2 compliance, independent cybersecurity control validation and attestation are becoming necessary to compete for high-priority contracts. Beyond customer demand, SOC 2 reports ensure that controls are properly implemented and used within your organization, greatly reducing potential security threats.

For organizations seeking a SOC 2 report, there are two attestation options available: Type 1 and Type 2. What type is best for your organization to prove compliance? Our experienced assessors break down the options so the path to SOC 2 compliance is clear.

What is a SOC 2 report?

A SOC 2 report highlights the controls in place that protect and secure an organization’s system or services used by its customers. The scope of a SOC 2 examination extends beyond the systems that have a financial impact, reaching all systems and tools used in support of the organization’s system or services. The security of your environment is based on the requirements within a SOC 2 examination, known as the Trust Services Criteria (TSC):

• Common Criteria/Security (required)
• Availability (optional)
• Processing Integrity (optional)
• Confidentiality (optional)
• Privacy (optional)

The difference between Type 1 and Type 2 reports

Which SOC 2 report should your organization choose? Read on to learn the difference.

SOC 2 Type 1 Report 

Organizations that select a SOC 2 Type 1 report will evaluate the design and implementation of an organization’s system of internal controls as they relate to the in-scope TSCs. The report will include the management’s assertion, auditor’s opinion on the design and implementation of controls, a description of the in-scope system, and the controls that were independently tested by the auditor. This serves as a snapshot of an organization’s environment to determine if controls are suitably designed and in place. 

SOC 2 Type 2 Report 

SOC 2 Type 2 reports will evaluate the design, implementation and operating effectiveness of an organization’s system of internal control as they relate to the in-scope TSCs over a defined period of time, typically six to twelve months. The report will include the management’s assertion, auditor’s opinion on the design and operating effectiveness of controls, a description of the in-scope system, and the controls and test results that were independently tested by the auditor A SOC 2 Type 2 report provides a historical view of an organization’s environment to determine if the organization’s internal controls are designed and operating effectively. 

What is a readiness assessment?

Now that you understand the difference between a Type 1 and Type 2 report, how can you best prepare for your SOC 2 examination? Consider these options from A-LIGN’s expert auditors: 

• Traditional approach: A-LIGN will perform a formal Readiness Assessment that simulates a Type 1 or Type 2 audit and results in a report with recommendations from the auditor. This option is recommended for companies that don’t have many formal procedures or have never been through an audit before. 
• Belay approach: This hybrid two-step approach has a smaller high-level gap assessment of key controls prior to the Type 1 SOC 2 examination. This approach saves time and costs and is designed for more mature organizations with formally established and implemented procedures who still have concerns or questions about their readiness for a SOC 2 audit.  

Why A-LIGN? 

A-LIGN is the leading provider of high-quality, efficient cybersecurity compliance programs. Combining experienced auditors and audit management technology, A-LIGN provides the widest breadth and depth of services including SOC 2, ISO 27001, HITRUST, FedRAMP, and PCI. A-LIGN is the number one issuer of SOC 2 and a leading HITRUST and FedRAMP assessor. The A-LIGN difference is: 

• 17.5k+ SOC assessments completed 

• #1 SOC 2 issuer in the world 

• 200+ SOC auditors globally 

Next steps

Ready to begin your compliance journey? Contact A-LIGN today to get started.