It’s widely acknowledged that NIST SP 800-53 cyber security guidelines are confusing and overwhelming — it’s universally challenging to make heads or tails of the guidelines stemming from the Federal Information Security Management Act (FISMA) regulations. If managing the mountain of FIPS 200 and NIST standards have you gasping for air, it’s time to take a breath. Here’s how you earn the confidence of your NIST SP 800-53 access certification compliance auditor:
Plan for Remediation Projects
During the compliance certification process it’s critically important to anticipate and proactively plan for problems. There must be resources set aside as a reserve for remediation to effectively maintain compliance.
Draft and Implement a Data Security Plan and Budget
NIST SP 800-53 requires the appointment of a specific person within the organization to take charge of information security, though of course, accountability ultimately rolls up to the CIO. This appointee is responsible for oversight of data security matters and must be free of undue distractions from other duties and obligations. To empower the representative in charge, there must be a formalized plan and resources specifically allocated to data security. If funds for data security are dumped in a “miscellaneous” bucket, an outside compliance auditor may be concerned that the organization lacks foresight and commitment to keeping records safe.
Automate Reports
Reports are a pain. However, the compliance audit process requires them. Assessors aren’t trying to make trouble — they want their reports because FISMA compliance requires them. It’s their job to ask for them, and the organization’s job to be prepared. The best way to simplify this process is to automate. Investment in identity and access management software with user provisioning NIST cyber security tools built-in makes fulfilling compliance auditor requests a painless, routine exercise.
Accept that Monitoring is Mandatory
FISMA compliance requires perpetual monitoring of specific audit controls, including system changes, configuration management, ongoing assessments of security controls and reporting activities. Monitoring can be costly, time consuming and a serious drain on limited resources. However, with the right compliance management software tool in place, the solution takes care of the monitoring. Through unmanned administration, compliance auditor software can send automated alerts to keep the organization on top of irregularities and problems. If implementing an automated identity management and access governance solution seems too expensive, consider what it’s costing in people hours to manually fulfill FISMA requirements.
Test Controls and Protocols
Organizations are required to evaluate their cyber security audit controls at regular intervals, in theory perpetually, and at least annually. Outside compliance auditors know that this is an area in which many agencies fall flat. So, the organization needs to not only adhere to the testing requirement but also retain proof that the examination was conducted, that the findings were documented and that a process was implemented to address deficiencies. The devil is in the documentation — spell out record keeping methods in advance of conducting the tests and assign an individual to take ownership of compliance and remediation projects.
Finessing NIST 800-53 isn’t rocket science‐ it’s about thinking like a compliance auditor. Once the organization has familiarized itself with the requirements and the potential pitfalls, it becomes clear that automating NIST 800-53 guidelines to meet FISMA compliance just makes sense. It reduces resource drain, compliance risk and headaches — and makes life a whole lot easier.
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