AC-1 Access Control Policy and Procedures (L) (M) (H)

NIST 800-53 (r4) Control:

The organization:

a. Develops, documents, and disseminates to [Assignment: organization-defined personnel or roles]:

1. An access control policy that addresses purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance; and

2. Procedures to facilitate the implementation of the access control policy and associated access controls; and

b. Reviews and updates the current:

1. Access control policy [FedRAMP Assignment: (L)(M) at least every 3 years; (H) at least annually]; and

2. Access control procedures [FedRAMP Assignment: (L)(M) at least annually; (H) at least annually or whenever a significant change occurs].

NIST 800-53 (r4) Supplemental Guidance:

This control addresses the establishment of policy and procedures for the effective implementation of selected security controls and control enhancements in the AC family. Policy and procedures reflect applicable federal laws, Executive Orders, directives, regulations, policies, standards, and guidance. Security program policies and procedures at the organization level may make the need for system-specific policies and procedures unnecessary. The policy can be included as part of the general information security policy for organizations or conversely, can be represented by multiple policies reflecting the complex nature of certain organizations. The procedures can be established for the security program in general and for particular information systems, if needed.

The organizational risk management strategy is a key factor in establishing policy and procedures. Related control: PM-9.

References: NIST Special Publications 800-12, 800-100.

NIST 800-53 (r5) Discussion:

Access control policy and procedures address the controls in the AC family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance. Therefore, it is important that security and privacy programs collaborate on the development of access control policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies reflecting the complex nature of organizations. Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents. Events that may precipitate an update to access control policy and procedures include assessment or audit findings, security incidents or breaches, or changes in laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.

38North Guidance:

Meets Minimum Requirement:

• Develop, document, and disseminate AC policies and procedures.

• AC policies and procedures must address:

• All AC controls contained in the AC family including guidelines and processes for account creations, transfers, & termination of accounts. Access Control for identifying and authenticating privileged and non-privileged accounts including break glass accounts. Access & Information Flow Enforcement as well as Separation of Duties, and least privilege for all accounts within the boundary. Session Lock, Termination & Concurrent Session Control should be addressed.

• Policy must include: purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance.

• Review, approve, and update (when a review indicates updates are required) documented AC policies (at least every three (3) years for FedRAMP Moderate and at least annually for FedRAMP High) and procedures at least annually or if there is a major change in the environment.

Best Practice:

• Disseminate policies and procedures to only personnel with AC roles or responsibilities.

• Ensure that the responsible party reviews, approves, and signs the AC policy and procedures.

• Quarterly reviews of who has access based on their roles and responsibilities.

Unofficial FedRAMP Guidance:

Assessment Evidence:

• Versioned AC policies and procedures documents with last update, last approval date, and approver.

• Approval by management within the last year or as a result of a major change in the environment, whichever occurred most recently.

• Group permissions in SharePoint, Confluence, etc. for how the policies and procedures are disseminated.

CSP Implementation Tips:

• Amazon Web Services (AWS): TBD

• Microsoft Azure: TBD

• Google Cloud Platform: TBD