The best way to convey the complexity and difficulty of achieving FedRAMP compliance is to compare it to the challenges of climbing a very steep mountain. It requires careful planning, extensive preparation, and a lot of hard work. Just as climbers face obstacles like treacherous terrain and unpredictable weather conditions, organizations aiming for FedRAMP compliance must navigate through a maze of security requirements, documentation, and audits. It's not a task for the faint-hearted but reaching the summit – achieving FedRAMP authorization – brings a sense of accomplishment and opens up new opportunities in the federal market.
Over the next several weeks we will be breaking down the 6 key phases to achieving FedRAMP compliance in a series of articles, Preparing Your Organization for FedRAMP Authority to Operate (ATO). These phases represent the overarching process of achieving and maintaining FedRAMP compliance, with each phase building upon the previous one to ensure the security and integrity of systems and data.
1.1 Prepare Phase: Resource Review and Allocation
In the above analogy it first states the careful planning and extensive preparation that is required to safely and successfully reach the summit. When preparing for a FedRAMP ATO there are several crucial steps on the front end that will help ensure your organization's cloud services meet the rigorous security standards required by the Federal government.
First, you must assess whether your organization has staff with expertise and experience in cloud security, compliance, and project management. FedRAMP compliance requires a deep understanding of security controls, risk management, and regulatory requirements. Then, evaluate the availability of staff members to dedicate time and effort to the FedRAMP process. Achieving FedRAMP compliance is a significant undertaking that requires ongoing attention and commitment over an extended period.
Take some dedicated to time identify answers to the below questions:
- Do you have developers who can enhance the application to meet FedRAMP requirements?
- Do you have a compliance team in place who can work on documentation and implement new processes?
- Do you have team members who can architect and configure cloud infrastructure?
- Do you need to hire staff members with FedRAMP experience?
- Will you need an advisory firm to help guide the process?
- Will you need to augment your team with an engineering firm?
Ensuring you have the right support and team from top down is critical in the pursuit of FedRAMP compliance. Be sure to obtain buy-in from key decision-makers; this will help create a smooth process in securing the right resources.
1.2 Prepare Phase: Understand Your Offer
Take a moment to consider your product offering in the Federal space. Understanding the intended user, the type of data, and the use cases of the solution will help your organization map out the time and investment required to achieve and maintain compliance.
- Are you going to offer the same exact solution to the government as you do to your commercial customers.
- Does your government customer only care about a subset of the offering, or will you be offering something unique to them?
- Will you be developing a separate instance for government only?
1.3 Prepare Phase: Categorize Your System
Understanding data types is crucial for FedRAMP preparation because it enables organizations to assess the sensitivity and criticality of the data they handle, which in turn informs the implementation of appropriate security controls.
The different data types can be found in a NIST SP, specifically 800-60, which has a catalog of all the data types. Once you identify the applicable data types, you’ll be able to determine the baseline (Low, Moderate, High). At this point, if you have an agency sponsor, it might be a good idea to get them involved, and obtain approvals on the categorization (baseline).
1.4 Prepare Phase: Define Your System Boundary
The system boundary defines the extent of the information system that is subject to FedRAMP compliance requirements. It delineates the boundaries within which security controls are applied and where the protection of government data is enforced. The system boundary encompasses all components, processes, and interfaces that are relevant to the security of the information system.
CSPs tend to believe they can draw their boundary around a handful of virtual servers and some databases; however, you don’t get to pick the boundary, the boundary really picks you. What does this mean? To help you understand why that is, imagine a packet of data leaving an agency and sent to your system. Anywhere that packet travels through your network and system is in scope. The reason why it’s so important for a CSP to understand their boundary well and define it appropriately earlier on in the process, is because you need to apply all applicable security controls across all components in the boundary where those controls apply. It’s very likely that this boundary will change as you make your way through the next two phases, but this gives you a really good starting point.
Final Thoughts:
As you embark on your FedRAMP journey it’s important to understand that preparation is not just about checking boxes. In order to develop a clear and realistic roadmap for achieving FedRAMP compliance your organization needs to start with a deep analysis of resources, key stakeholders, impact levels, competitive landscape, market position, and boundaries.