Assessments for both StateRAMP and FedRAMP rely on the 3PAO’s understanding of the systems and people that will interact with a specific government agency. With this knowledge, it’s easier to determine where particular requirements begin and where they end. Across both of these frameworks, this concept is known as the “authorization boundary.”
The authorization boundary serves as a (sometimes physical, sometimes logical, sometimes administrative) fence that delineates the scope of a cloud system’s operations, setting clear boundaries for where assessment and regulatory requirements begin and end.
Whether you’re a cloud service provider or a government agency representative, this article will shed light on this essential concept and help you understand its impact on the landscape of cloud security.
What Is an Authorization Boundary?
In the context of FedRAMP and StateRAMP, the authorization boundary is a concept derived from information security. It delineates the boundary within which a system’s security controls are implemented and assessed.
An authorization boundary defines the scope of the system under evaluation, marking the operational limits and explicitly stating what is included in the system and what is not. More importantly, it delineates what components should be assessed and which shouldn’t. It can be considered an “imaginary line” that circumscribes all components of an information system (hardware, software, network connections, interfaces with other systems, etc.).
Both FedRAMP and StateRAMP use this concept to create an effective evaluation and authorization process for cloud service providers. It serves a few crucial purposes:
- Ensure all necessary system elements are included in the security assessment.
- Ensure that risk is evaluated in relation to the whole system.
- Define a clear scope for the implementation and evaluation of security controls.
For FedRAMP, the authorization boundary includes all hardware and software components, system connections, and system interfaces owned, managed, and controlled by the cloud service provider.
StateRAMP, which is modeled on FedRAMP but designed for state and local governments, also uses the concept of authorization boundary in the same way.
What Is an Authorization Boundary Diagram?
Creating an authorization boundary diagram is essential in documenting the system components and security protections. In the context of FedRAMP or StateRAMP, the diagram helps to illustrate the boundaries of a cloud offering.
There should be several essential components outlined in this diagram:
- Cloud Offering Components: Detail all major components of the offering, such as application servers, databases, web servers, and other significant elements. You should also include any relevant subsystems or sub-components to the offering. These components should be clearly labeled, whether within or outside of the boundary.
- External Connections: Identify and depict all the external systems that the CSO connects to. These could include third-party services, customer environments, and any other systems that interact with your offering. Defining these connections and identifying the data flow between systems is important.
- Data Flows: Data flows are, specifically, the movement of data across a boundary… and, more importantly, the movement of secure data from an agency into or out of a cloud platform. Accordingly, it’s imperative that they are mapped into authorization diagrams.
- Interfaces: This diagram is similar to the data flow diagrams, except focusing on connective functionality across interactive parts of the system (like user interfaces, APIs, etc.).
- Security Controls: Highlight how security controls are implemented within the system. This could involve showing the implementation of firewalls, intrusion detection systems, access control systems, etc.
- Physical Locations: Different locations containing cloud servers may fall under the same authorization boundary, regardless of their distance.
- Trust Levels: If there are different trust levels within the system, such as public and private zones, these should also be marked on the diagram.
The key is to make sure the diagram is clear, accurate, and comprehensive, providing an easy-to-understand visualization of the system and its security posture. It’s a fundamental part of the System Security Plan (SSP) and helps reviewers understand the scope and architecture of the system.
Data Flows
Data flows are some of the most important aspects to record when diagramming a cloud offering. That’s because sensitive information from a government agency will invariably cross the boundary (and, subsequently, in and out of the CSP’s area of responsibility).
Some important aspects of data flow diagrams include:
- Understanding System Functionality: Data flows illustrate how the system operates fundamentally. They show where data originates, where it goes, how it is processed, and where it ends up. This helps reviewers to understand the core functions of the system.
- Identifying Security Risks: Data flows can help identify potential security risks. For example, data moving between different trust zones (like from an internal network to the internet) may be at higher risk. By mapping these flows, you can identify where additional security controls may be necessary.
- Regulatory Compliance: Certain data types may have specific handling requirements due to regulatory compliance. For example, Personally Identifiable Information (PII) or Protected Health Information (PHI) may have strict requirements for storing, transmitting, and processing it. A clear understanding of the data flows can ensure these requirements are met.
- Defining Responsibilities: In a cloud environment, responsibility for security is often shared between the cloud service provider and the customer. Understanding data flows can help determine who is responsible for securing each part of the data’s journey.
- Intrusion Detection and Response: Knowing your expected data flows can help detect anomalies or potential intrusions. For example, if data suddenly starts flowing to an unusual destination, it could indicate a security breach.
- Data Loss Prevention: Understanding data flows can also aid in preventing data loss. For example, if sensitive data is moving outside the system’s boundaries, that might indicate a need for additional data loss prevention controls.
Interfaces
Another critical area to focus on is “Interfaces.” Interfaces, in an authorization boundary diagram, represent the points at which the system interacts with external entities. This can include network devices, applications, or code APIs–essentially, any place external forces engage with the cloud product.
Some common interfaces include:
- User Interfaces: This includes any point at which a user interacts with the system, like a web portal, a mobile application, or a desktop application. The interface could be for end users or system administrators.
- APIs: APIs allow different software components to interact with each other. This could be internal (within the system boundary) or external (across the system boundary). APIs can handle various interactions, including data exchange, triggering processes, or allowing different components to work together.
- Network Interfaces: These are the points at which your system connects to different networks. This could include connections to the internet, private networks, or other cloud services. Network interfaces involve hardware (routers, firewalls, or switches) or virtual (like a VPN gateway).
- Data Interfaces: These interfaces are concerned with exchanging, processing, or storing data. For example, a system might interface with a database, a data storage service, or a data processing component.
- Hardware Interfaces: This includes the interfaces between different hardware components—for example, servers, storage devices, or network devices.
- Third-party Services: If your system integrates with third-party services (like payment processors, email services, etc.), these would also be considered interfaces.
The purpose of documenting interfaces in an authorization boundary diagram is to identify where data enters clearly and exits the system, how components interact, and where potential vulnerabilities may exist. These interfaces often necessitate certain security controls to ensure the integrity, confidentiality, and availability of the data and the system.
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