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The ultimate guide to FedRAMP
For small businesses and large corporations alike, US federal contracts are among the most profitable deals on the market. As the saying goes, nothing worth having comes easy, and that includes high-dollar contracts.
If you want to do business with federal entities, FedRAMP authorization is a mandatory checkpoint. Here’s everything you need to get started.
What is FedRAMP and what does FedRAMP stand for?
The Federal Risk and Authorization Management Program (FedRamp) is a standardized way for federal agencies to vet and approve cloud service providers before engaging in partnerships or business deals. Every US federal agency can only use cloud services that are FedRAMP authorized.
FedRAMP includes an extensive list of security controls and continuous monitoring requirements. If your cloud service is FedRAMP authorized, it gives the federal agency the reassurance that you have security best practices in place to keep their critical information safe.
This standard was created by the Joint Authorization Board or JAB. It was a collaborative effort between the JAB, the General Services Administration (GSA), the Department of Homeland Security (DHS), and the Department of Defense (DoD). While it is used by every federal agency, it’s overseen by the JAB.
What is the difference between FedRAMP and NIST?
The federal government has no shortage of security standards and requirements, so it’s easy to mix them up. In particular, what makes FedRAMP different from the NIST security standards?
NIST standards serve as the basis for FedRAMP, specifically NIST 800-53. FedRAMP adapts the security requirements of NIST 800-53 for cloud-based services and applies them to third-party cloud service providers. NIST compliance and FedRAMP authorization are two different processed and each one must be pursued separately.
What are the types of FedRAMP compliance or FedRAMP authorizations?
There are two types of FedRAMP authorization: a JAB P-ATO and an agency P-ATO. ATO stands for authority to operate; this is the language used for a FedRAMP authorization. That means you can either be FedRAMP authorized by JAB itself or by a specific federal agency.
When you’re FedRAMP authorized by a particular agency, you receive the right to provide your cloud service to that agency. With a JAB P-ATO, you can serve any federal agency.
While a JAB P-ATO opens more doors than an ATO for a specific agency, it’s much more difficult to attain. JAB only has the resources to review a certain number of applications for JAB P-ATOs each year. You need to be authorized to work with JAB, and you also need to go through an additional step of third-party readiness assessments.
Who needs to be FedRAMP compliant?
While FedRAMP is a government standard, it is not a law. No organization is legally required to be FedRAMP authorized. However, you can only provide services to federal agencies if you have FedRAMP authorization.
FedRAMP applies exclusively to cloud service providers—organizations that sell cloud-based services or SaaS services. If you offer a cloud service and would like to take on federal agencies as clients, FedRAMP compliance opens that door.
Benefits of FedRAMP certification
Is it worth your investment to become FedRAMP authorized? There are two primary benefits that this project will win for you.
Expanding your business opportunities
The most direct benefit of FedRAMP authorization is that it allows you to be eligible for federal contracts. Of course, it doesn’t guarantee those contracts, but you will not be in consideration without it. Depending on the circumstances and the service you provide, a single federal agency contract could be worth millions.
Achieving high levels of cloud security
Adhering to FedRAMP’s security requirements can be beneficial even if you don’t receive contracts with federal agencies. It can strengthen your cloud security and also make you a more desirable candidate for other clients.
Understandably, the federal government deals with extremely sensitive data. The standards for data security in cloud systems are very high. If a client sees that you are FedRAMP authorized, even if they’re simply a private business or NGO, they will know that you have highly sophisticated security—an incredibly powerful selling point.
How to get FedRAMP certified
Interested in becoming FedRAMP authorized? Here’s a quick overview of the process.
Conduct a preparatory assessment
Before you start working toward FedRAMP certification, you need to understand your current state of security and compliance. Whether you use an automated compliance system, or choose a manual path, you’ll need to go through the FedRAMP requirements one by one and determine which ones you satisfy and which ones you’re missing. From there, you can create a plan for achieving compliance.
Implement any missing aspects of FedRAMP
Now that you have a plan in place, it’s time to get into the legwork for FedRAMP compliance. Use your preparatory assessment as a guide and strategically implement each security control, policy, or safeguard in FedRAMP not yet in place.
Pursue a security assessment report
When you’re confident that you meet all the FedRAMP requirements, the next step is to get a security assessment report or SAR. You can receive this by hiring a third-party assessor to review your implementation of FedRAMP. They prepare the SAR to thoroughly document how you’ve met each of the requirements in this standard.
Submit for authorization
With your SAR in hand, you’ll put together your authorization package with the SAR and select other documentation and officially submit your application. You’ll submit this package to either the JAB (if you’re applying for a JAB P-ATO) or to the agency you want to work with iif you’re applying for an agency P-ATO.
The JAB or authorizing officer will do an initial review and either approve that they have all the materials they need or tell you what further testing they need. When all the documentation is in place, they’ll conduct a final review to determine your authorization. If you meet compliance, they’ll send you a signed P-ATO.
Maintain continuous monitoring
While a FedRAMP P-ATO doesn’t expire, it does require continuous security monitoring with specific tests, reports, and metrics. If you fall short of this continuous monitoring at any time, the issuing agency or JAB can revoke your ATO.
How to begin working toward FedRAMP compliance
Vanta’s automated compliance platform can guide you through FedRAMP with streamlined documentation, custom control creation, continuous monitoring, and instant alerts all in one place. Schedule a Vanta demo today to learn more.
Determine whether the GDPR applies to you and if so, if you are a processor or controller (or both)
Do you sell goods or service in the EU or UK?
Do you sell goods or services to EU businesses, consumers, or both?
Do you have employees in the EU or UK?
Do persons from the EU or UK visit your website?
Do you monitor the behavior of persons within the EU?
Create a Data Map by taking the following actions
Identify and document every system (i.e. database, application, or vendor) which stores or processes EU or UK based personally identifiable information (PII)
Document the retention periods for PII in each system
Determine whether you collect, store, or process “special categories” of data
Determine whether your Data Map meets the requirements for Records of Processing Activities (Art. 30)
Determine whether your Data Map includes the following information about processing activities carried out by vendors on your behalf
Determine your grounds for processing data
For each category of data and system/application have you determined the lawful basis for processing based on one of the following conditions?
Take inventory of current customer and vendor contracts to confirm new GDPR-required flow-down provisions are included
Review all customer contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Review all in-scope vendor contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Have you performed a risk assessment on vendors who are processing your PII?
Determine if you need to do a Data Protection Impact Assessment
Is your data processing taking into account the nature, scope, context, and purposes of the processing, likely to result in a high risk to the rights and freedoms of natural persons?
Review product and service design (including your website or app) to ensure privacy notice links, marketing consents, and other requirements are integrated
Does the notice to the data subject include the following items?
Does the notice also include the following items?
Do you have a mechanism for persons to change or withdraw consent?
Update internal privacy policies to comply with notification obligations
Update internal privacy notices for EU employees
Determine if you need to appoint a Data Protection Officer, and appoint one if needed
Have you determined whether or not you must designate a Data Protection Officer (DPO) based on one of the following conditions (Art. 37)?
If you export data from the EU, consider if you need a compliance mechanism to cover the data transfer, such as model clauses
If you transfer, store, or process data outside the EU or UK, have you identified your legal basis for the data transfer (note: most likely covered by the Standard Contractual Clauses)
Have you performed and documented a Transfer Impact Assessment (TIA)?
Confirm you are complying with other data subject rights (i.e. aside from notification)
Do you have a defined process for timely response to Data Subject Access Requests (DSAR) (i.e. requests for information, modification or deletion of PII)?
Are you able to provide the subject information in a concise, transparent, intelligible and easily accessible form, using clear and plain language?
Do you have a process for correcting or deleting data when requested?
Do you have an internal policy regarding a Compelled Disclosure from Law Enforcement?
Determine if you need to appoint an EU-based representative, and appoint one if needed
Have you appointed an EU Representative or determined that an EU Representative is not needed based on one of the following conditions?
If operating in more than one EU state, identify a lead Data Protection Authority (DPA)
Do you operate in more than one EU state?
If so, have you designated the Supervisory Authority of the main establishment to act as your Lead Supervisory Authority?
Implement Employee Trainings to Demonstrate Compliance with GDPR Principles and Data Subject Rights
Have you provided appropriate Security Awareness and Privacy training to your staff?
Update internal procedures and policies to ensure you can comply with data breach response requirements
Have you created and implemented an Incident Response Plan which included procedures for reporting a breach to EU and UK Data Subjects as well as appropriate Data Authorities?
Do breach reporting policies comply with all prescribed timelines and include all recipients i.e. authorities, controllers, and data subjects?
Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk
Have you implemented encryption of PII at rest and in transit?
Have you implemented pseudonymization?
Have you implemented appropriate physical security controls?
Have you implemented information security policies and procedures?
Can you access EU or UK PII data in the clear?
Do your technical and organizational measure ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed?
Develop a roadmap for successful implementation of an ISMS and ISO 27001 certification
Implement Plan, Do, Check, Act (PDCA) process to recognize challenges and identify gaps for remediation
Consider ISO 27001 certification costs relative to org size and number of employees
Clearly define scope of work to plan certification time to completion
Select an ISO 27001 auditor
Set the scope of your organization’s ISMS
Decide which business areas are covered by the ISMS and which are out of scope
Consider additional security controls for business processes that are required to pass ISMS-protected information across the trust boundary
Inform stakeholders regarding scope of the ISMS
Establish an ISMS governing body
Build a governance team with management oversight
Incorporate key members of top management, e.g. senior leadership and executive management with responsibility for strategy and resource allocation
Conduct an inventory of information assets
Consider all assets where information is stored, processed, and accessible
- Record information assets: data and people
- Record physical assets: laptops, servers, and physical building locations
- Record intangible assets: intellectual property, brand, and reputation
Assign to each asset a classification and owner responsible for ensuring the asset is appropriately inventoried, classified, protected, and handled
Execute a risk assessment
Establish and document a risk-management framework to ensure consistency
Identify scenarios in which information, systems, or services could be compromised
Determine likelihood or frequency with which these scenarios could occur
Evaluate potential impact of each scenario on confidentiality, integrity, or availability of information, systems, and services
Rank risk scenarios based on overall risk to the organization’s objectives
Develop a risk register
Record and manage your organization’s risks
Summarize each identified risk
Indicate the impact and likelihood of each risk
Document a risk treatment plan
Design a response for each risk (Risk Treatment)
Assign an accountable owner to each identified risk
Assign risk mitigation activity owners
Establish target dates for completion of risk treatment activities
Complete the Statement of Applicability worksheet
Review 114 controls of Annex A of ISO 27001 standard
Select controls to address identified risks
Complete the Statement of Applicability listing all Annex A controls, justifying inclusion or exclusion of each control in the ISMS implementation
Continuously assess and manage risk
Build a framework for establishing, implementing, maintaining, and continually improving the ISMS
Include information or references to supporting documentation regarding:
- Information Security Objectives
- Leadership and Commitment
- Roles, Responsibilities, and Authorities
- Approach to Assessing and Treating Risk
- Control of Documented Information
- Internal Audit
- Management Review
- Corrective Action and Continual Improvement
- Policy Violations
Assemble required documents and records
Review ISO 27001 Required Documents and Records list
Customize policy templates with organization-specific policies, process, and language
Establish employee training and awareness programs
Conduct regular trainings to ensure awareness of new policies and procedures
Define expectations for personnel regarding their role in ISMS maintenance
Train personnel on common threats facing your organization and how to respond
Establish disciplinary or sanctions policies or processes for personnel found out of compliance with information security requirements
Perform an internal audit
Allocate internal resources with necessary competencies who are independent of ISMS development and maintenance, or engage an independent third party
Verify conformance with requirements from Annex A deemed applicable in your ISMS's Statement of Applicability
Share internal audit results, including nonconformities, with the ISMS governing body and senior management
Address identified issues before proceeding with the external audit
Undergo external audit of ISMS to obtain ISO 27001 certification
Engage an independent ISO 27001 auditor
Conduct Stage 1 Audit consisting of an extensive documentation review; obtain feedback regarding readiness to move to Stage 2 Audit
Conduct Stage 2 Audit consisting of tests performed on the ISMS to ensure proper design, implementation, and ongoing functionality; evaluate fairness, suitability, and effective implementation and operation of controls
Address any nonconformities
Ensure that all requirements of the ISO 27001 standard are being addressed
Ensure org is following processes that it has specified and documented
Ensure org is upholding contractual requirements with third parties
Address specific nonconformities identified by the ISO 27001 auditor
Receive auditor’s formal validation following resolution of nonconformities
Conduct regular management reviews
Plan reviews at least once per year; consider a quarterly review cycle
Ensure the ISMS and its objectives continue to remain appropriate and effective
Ensure that senior management remains informed
Ensure adjustments to address risks or deficiencies can be promptly implemented
Calendar ISO 27001 audit schedule and surveillance audit schedules
Perform a full ISO 27001 audit once every three years
Prepare to perform surveillance audits in the second and third years of the Certification Cycle
Consider streamlining ISO 27001 certification with automation
Transform manual data collection and observation processes into automated and continuous system monitoring
Identify and close any gaps in ISMS implementation in a timely manner
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Determine which annual audits and assessments are required for your company
Perform a readiness assessment and evaluate your security against HIPAA requirements
Review the U.S. Dept of Health and Human Services Office for Civil Rights Audit Protocol
Conduct required HIPAA compliance audits and assessments
Perform and document ongoing technical and non-technical evaluations, internally or in partnership with a third-party security and compliance team like Vanta
Document your plans and put them into action
Document every step of building, implementing, and assessing your compliance program
Vanta’s automated compliance reporting can streamline planning and documentation
Appoint a security and compliance point person in your company
Designate an employee as your HIPAA Compliance Officer
Schedule annual HIPAA training for all employees
Distribute HIPAA policies and procedures and ensure staff read and attest to their review
Document employee trainings and other compliance activities
Thoroughly document employee training processes, activities, and attestations
Establish and communicate clear breach report processes
to all employees
Ensure that staff understand what constitutes a HIPAA breach, and how to report a breach
Implement systems to track security incidents, and to document and report all breaches
Institute an annual review process
Annually assess compliance activities against theHIPAA Rules and updates to HIPAA
Continuously assess and manage risk
Build a year-round risk management program and integrate continuous monitoring
Understand the ins and outs of HIPAA compliance— and the costs of noncompliance
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