Advice for writing a successful FedRAMP SSP
A FedRAMP SSP (System Security Plan) is the bedrock of a FedRAMP assessment and the primary document of the security package in which a cloud service provider (CSP) details their system architecture, data flows and authorization boundaries, and all security controls and their implementation.
Keep in mind that to prevent conflicts of interest, 3PAO’s are prohibited by regulation from helping a CSP put together a FedRAMP SSP and also conducting that CSP’s FedRAMP assessment.
A FedRAMP SSP is a highly detailed document that must be readable, relevant, consistent, and complete. Even tiny mistakes can cause lengthy delays in the FedRAMP certification process. Here are some tips for writing a successful FedRAMP SSP.
Allocate sufficient time and resources to writing your FedRAMP SSP
Expect your FedRAMP SSP to be several hundred pages long. Putting together an SSP is never an overnight project, and it’s rarely a one-person job. Organizations generally require the input of several subject matter experts with deep technical knowledge of the systems they are documenting, as well as NIST and FedRAMP security controls.
Make sure the FedRAMP SSP is clear, concise, consistent, and complete
Although an SSP is a group project, it shouldn’t “look” like one when it is finished. FedRAMP PMO’s don’t expect System Security Plans to read like Pulitzer Prize-worthy literature, but they do expect that CSP’s to turn in a logically organized document that describes systems and controls clearly and completely, and that is not riddled with spelling and grammar errors. When reviewing an SSP, a FedRAMP PMO looks for the 4 C’s:
- Do not write meandering, convoluted, or overly long descriptions. Avoid the use of passive voice, as it could cause confusion. Do not include text that is not directly relevant to the specific control being described.
- Describe each system and control completely, but use as few words as possible. Make each word count.
- All system names and abbreviations, hardware and software elements, and citations referenced in the SSP should be referenced in exactly the same way throughout the entire document. The presentation style and level of detail should also be consistent throughout.
- Use the correct FedRAMP SSP template, and do not modify or remove sections. However, sections can be added if necessary. Address all required controls. If a control has multiple requirements, you must address all of them. If a control is inherited or does not apply, use a risk-based justification to explain why. You must describe how each control is addressed in your system; you cannot simply copy/paste or rephrase the control requirements.
Identify all people and places relevant to your controls
All people who are responsible for implementing/enforcing a security control must be identified, by role. All roles defined for a control should also be included in the SSP’s Roles and Privileges table.
The SSP must also describe all possible places where a control is implemented; for example:
- Access for both privileged and non-privileged users
- Access control, audit logging, maintenance, flaw remediation, and configuration management for all platforms
- Physical controls at all facilities
Be sure to select the correct Implementation Status for each control
A common SSP error is checking the wrong Implementation Status; for example, a control is marked Planned but does not identify a planned date. FedRAMP offers the following general guidance:
- If all or part of the control is an alternative implementation, check both “Partially Implemented” and “Alternative Implementation.”
- If all or part of the control is planned, check both “Partially Implemented” and “Planned.”
- If selecting a status of Planned, Alternative Implementation, and/or Not Applicable, clearly explain the aspects of the control that are Planned, Alternative, and/or Not Applicable in the implementation description.
- If the control is solely a customer responsibility, and the CSP has no responsibility for the implementation of the control, check “Implemented,” along with the appropriate customer-related control origination.
Use an automation solution such as Continuum GRC’s ITAM
Traditionally, creating a FedRAMP SSP has been an arduous, manual, and chaotic process involving dozens of text documents and spreadsheets. Updating and maintaining it over time was extremely difficult and prone to error, and it wasn’t integrated with any of the technologies 3PAO’s use to carry out FedRAMP assessments.
Now, CSP’s have access to automation solutions, such as the IT Audit Machine (ITAM) FedRAMP SSP module from Continuum GRC. ITAM is a cloud-based solution that uses pre-loaded, drag-and-drop modules to walk CSP’s through the process of preparing their SSP, ensuring completeness and accuracy. CSP’s not only save time and money upfront, while preparing their SSP, but later on, when they are ready to work with their 3PAO.
The cyber security experts at Continuum GRC have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting your organization from security breaches. Continuum GRC offers full-service and in-house risk assessment and risk management subscriptions, and we help companies all around the world sustain proactive cyber security programs.
FedRAMP Mindset for SSP Development
FedRAMP authorization requires submitting a System Security Plan (SSP). This is a clear but detailed outline of how a cloud service provider ensures security across the organization. This is the most important document when seeking FedRAMP authorization, and it needs to be thorough with a clear picture of system security.
Going in, know that the document will likely be several hundred pages long and require the expertise and input of several people. Give your group plenty of time to create it, but ensure that the language is unfussy. Use clear terms in describing security controls, both internal and external. Be conscious of detail, because leaving something out or calling a piece of equipment by the wrong name may slow the process
Document Requirement & Acceptance Criteria
Outlining your CSP’s security posture and plan requires clear documentation (and lots of it) for a successful, delay-free submission. These documents for the FedRAMP assessment will provide a thorough picture and show that your organization meets FedRAMP security requirements at every step.
Among the dozen-plus documents you will need is one detailing your CSP’s information security policies and procedures, your contingency plan and incident response plan, a separation of duties matrix, and a continuous monitoring strategy.
Ensure that each of these documents contains clear and straightforward descriptions of each part of your security program, both internal and external. Equipment and systems must be properly identified, as well as the key players involved.
Improper or missing documentation will greatly slow down the process.
Importance of SSP to a FedRAMP Assessment?
An appropriate Security System Plan is absolutely essential to achieve a FedRAMP assessment. Being able to clearly demonstrate that your CSP addresses the many elements to assure data security and integrity in today’s hostile cyber environment is a must.
Carve out the time to create the Plan. Prepare your documentation carefully. Work regularly with your team to craft it. Set goals and deadlines for deliverables. Double-check for clunkiness in the verbiage (use fewer words whenever possible) and ensure that all technical names and details are consistent throughout the document.
If your organization wants to partner with any federal agency, a well-crafted SSP is a critical step to achieving it. It may take anywhere from a year to 18 months to be awarded the certification. Overlooking details or sloppy presentation can greatly slow the process down. Invest the time in doing it right.
Common Challenges in Creating the SSP
Creating the SSP is a detailed process that takes time and successful collaboration with your team. Understand these common challenges before starting.
- Understanding the hundreds of security controls required for continuous monitoring (ConMon).
- Cross-team collaboration. It’s critical that each member of the SSP team understands the expectations around cybersecurity and the increased vigilance needed for compliance.
- The right tools. All scanning tools that are needed for Continuous Monitoring must comply with federal regulations.
- Implementing and maintaining monthly scans and related assets. A thorough monthly scan to identify any vulnerabilities is a must.
- Managing Plan of Action & Milestones (POA & M). This is a monthly inventory of active vulnerabilities and pathways to remedy them. This can be a tedious process.
Conclusion
The System Security Plan is an opportunity to do a deep dive into your cloud infrastructure to spot potential threats and vulnerabilities and get ahead of them. More importantly, this process is essential for working with any federal agency. Being able to demonstrate your ongoing compliance with important security protocols around sensitive data boosts trust and confidence among all clients.
There are a lot of moving parts to the SSP, some of which must be done on your end, but some that Continuum GRC can help you with. We offer a variety of risk management and compliance solutions to establish a more robust security plan and make putting the document together simpler.
Continuum GRC is proactive cyber security®. Call 1-888-896-6207 to discuss your organization’s cyber security needs and find out how we can help your organization protect its systems and ensure compliance.