ATTACHMENT A Security_and_Privacy_Requirements_for_IT_Acquisition_Efforts_CIO_IT_Security.pdf

Office of the Chief Information Security Officer

IT Security Procedural Guide:

Security and Privacy Requirements for IT Acquisition Efforts

CIO-IT Security-09-48

Revision 4

January 25, 2018

CIO-IT Security-09-48, Revision 4 Security and Privacy Requirements for IT Acquisition Efforts

U.S. General Services Administration

IMPORTANT!

This guide defines security and privacy requirements for GSA IT acquisition contracts involving externally hosted contractor information systems that do not connect to the GSA network;

information systems hosted in GSA facilities that directly connect to the GSA network; cloud information systems; or mobile applications. The security and privacy requirements are appropriately formatted to allow the respective security and privacy contract requirements to be placed in-line within a statement of work for each system type. Alternatively, this entire document can be incorporated into the statement of work or contract.

NOTE: Throughout this guide there are highlighted SELECT statements. The requirements office, in coordination with the contracting officer, will complete the selections prior to their incorporation into a contract or statement of work.

VERSION HISTORY/CHANGE RECORD

Change Number

Person Posting Change

Change Reason for Change Page Number of Change

Revision 1 – November 6, 2009 1 Bo Berlas Minor Changes to GSA 800-53

R3 Control Tailoring workbook in Appendix A

GSA 800-53 Control Tailoring Workbook Update

Revision 2 – November 7, 2014 1 John Sitcharing/

Blanche Heard Minor changes to verbiage regarding Penetration Testing

Update Penetration Testing verbiage

2 John Sitcharing/ Blanche Heard

CISO mandated change in Penetration Testing requirement/ naming conventions based on consolidation efforts

CISO Mandate Entire document

Revision 3 – February 2, 2017 1 Bo Berlas Added Essential Security controls to Section 2 Security Controls Update 9

2 Bo Berlas Added sections 3-5 Updated to Provide Requirements for Internal Systems, Cloud Systems, and Mobile Applications

22-55

Revision 4 – January 25, 2018 1 Bryon Feliksa/

John Klemens Incorporated security references from MV 16-01 and additional references. Added a section on LiSaaS, Privacy controls, and updated Privacy and other sections to align with GSA policy and procedures.

Incorporate MV 16-01 and consolidate GSA Cybersecurity and Privacy Guidance.

Throughout

APPROVAL

IT Security Procedural Guide 09-48, “Security and Privacy Requirements for IT Acquisition Efforts,” Revision 4, is hereby approved for distribution.

Invalid signature

X Kurt Garbars Kurt Garbars

CISO

Signed by: KURT GARBARS

This guide will be available on the OCIO Webpage and GSA.gov when revised.

https://www.gsa.gov/about-us/organization/office-of-the-chief-information-officer/chief-information-security-officer-ciso/it-security-procedural-guides

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Table of Contents

1 Introduction

1.1 Scope

1.2 Purpose

2 External Information Systems – IT Security and Privacy Requirements

2.1 Required Policies and Regulations for GSA Contracts

2.2 GSA Security Compliance Requirements

2.3 Essential Security Controls

2.4 Assessment and Authorization (A&A) Activities

2.5 Reporting and Continuous Monitoring

2.6 GSA Privacy Requirements

2.7 Additional Stipulations

3 Internal Information Systems - IT Security and Privacy Requirements

3.1 Required Policies and Regulations for GSA Contracts

3.2 GSA Security Compliance Requirements

3.3 Essential Security Controls

3.4 Assessment and Authorization (A&A) Activities

3.5 Reporting and Continuous Monitoring

3.6 GSA Privacy Requirements

3.7 Additional Stipulations

4 Low Impact Software as a Service (LiSaaS) – IT Security and Privacy Requirements

4.1 Assessment of the System

4.2 Authorization of the System

4.3 Reporting and Continuous Monitoring

4.4 Protection of Information

4.5 Data Ownership and Unrestricted Rights to Data

4.6 Personally Identifiable Information

4.7 Data Availability

4.8 Data Release

4.9 Confidentiality and Nondisclosure

4.10 Section 508 Compliancy

4.11 Additional Stipulations

4.12 Terms of Service

4.13 References

5 Cloud Information Systems – IT Security and Privacy Requirements

5.1 Assessment and Authorization

5.2 Assessment of the System

5.3 Authorization of the System

5.4 Reporting and Continuous Monitoring

5.5 Personnel Security Requirements

5.6 Sensitive Information Storage

5.7 Protection of Information

5.7.1 Unrestricted Rights to Data

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5.7.2 Personally Identifiable Information

5.7.3 Data Availability

5.7.4 Data Release

5.8 Data Ownership

5.9 Confidentiality and Nondisclosure

5.10 GSA Non-Disclosure Agreement

5.11 Additional Stipulations

5.12 References

6 Mobile Application - IT Security and Privacy Requirements

6.1 General Mobile Application Guidelines

6.2 Mobile Device Security

6.3 Application Sources

6.4 Terms of Service (ToS)

6.5 GSA Privacy Requirements

6.6 GSA App Development, Assessment, Authorization and Deployment

6.7 Intellectual Property

6.8 Confidentiality and Nondisclosure

6.9 GSA Non-Disclosure Agreement

6.10 Personnel Security Requirements

6.11 Additional Stipulations

Appendix A: GSA Tailoring of NIST 800-53 Controls

U.S. General Services Administration 1

1 Introduction

The U.S. General Services Administration (GSA) must provide information security for the information systems that support the operations and assets of the agency, including those provided or managed by GSA, another agency, contractor, or other source. The Federal Information Security Modernization Act of 2014 (FISMA of 2014) describes Federal agency security and privacy responsibilities as including “information systems used or operated by an agency or by a contractor of an agency or other organization on behalf of an agency.” This includes services which are either fully or partially provided; including other agency hosted, outsourced, and cloud computing solutions. Agency information security programs apply to all organizations (sources) which possess or use Federal information – or which operate, use, or have access to Federal information systems (whether automated or manual) – on behalf of a Federal agency, information systems used or operated by an agency or other organization on behalf of an agency.

Office of Management and Budget (OMB) Memorandum M-14-04 asserts that agencies are responsible for ensuring information technology acquisitions comply with the information technology security requirements in FISMA of 2014, OMB’s implementing policies including OMB Circular A-130 and guidance and standards from the National Institute of Standards and Technology (NIST).

1.1 Scope

This guide provides security and privacy requirements for the GSA information system types outlined below:

• External Information Systems. External information systems reside in contractor facilities and typically do not connect to the GSA network. External information systems may be government owned and contractor operated or contractor owned and operated on behalf of GSA or the Federal Government (when GSA is the managing agency).

• Internal Information Systems. Internal information systems reside on premise in GSA facilities AND directly connect to the GSA network. Internal systems are operated on behalf of GSA or the Federal Government (when GSA is the managing agency).

• Low Impact Software as a Service (LiSaaS) Systems. LiSaaS systems must adhere to GSA IT Security Procedural Guide 17-75, “Security Reviews for Low Impact Software as a Service (SaaS) Solutions.” LiSaaS systems are cloud applications that are implemented for a limited duration, considered low impact and would cause limited harm to GSA, and cost less than $100,000 to deploy.

• Cloud Information Systems. Includes Infrastructure as a Service (IaaS), Platform as a Service (PaaS), or SaaS. Requires FedRAMP.

• Mobile Application. A mobile application, most commonly referred to as an app, is a type of application software designed to run on a mobile device, such as a smartphone or tablet computer.

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1.2 Purpose

The purpose of this document is to define and establish consistent security and privacy requirements for GSA IT acquisition contracts involving externally hosted information systems that do not connect to the GSA network; information systems hosted in GSA facilities that directly connect to the GSA network; LiSaaS systems, cloud information systems; or mobile applications. The security and privacy requirements are appropriately formatted to allow the respective security and privacy contract language to be placed in-line within a statement of work for each system type. The security and privacy requirements identified in this guide will ensure compliance with the appropriate provisions of FISMA of 2014, OMB Circular A-130, and NIST Special Publication (SP) 800-53, Revision 4.

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2 External Information Systems – IT Security and Privacy Requirements

2.1 Required Policies and Regulations for GSA Contracts

Federal Laws and Regulations:

The contractor shall comply with all applicable Federal Laws and Regulations.

• 40 U.S.C. 11331, “Responsibilities for Federal Information Systems Standards”

• FISMA of 2014, “The Federal Information Security Modernization Act of 2014”

• HSPD 12, “Homeland Security Presidential Directive 12 – Policy for a Common

Identification Standard for Federal Employees and Contractors”

• OMB Circular No. A-130, “Managing Information as a Strategic Resource”

• OMB M-08-23, “Securing the Federal Government’s Domain Name System Infrastructure

(Submission of Draft Agency Plans Due by September 5, 2008)”

• OMB M 14-03, “Enhancing the Security of Federal Information and Information Systems”

• OMB M-10-23, “Guidance for Agency Use of Third-Party Websites and Applications”

• OMB M-15-13, “Policy to Require Secure Connections across Federal Websites and Web

Services”

• OMB M-17-12, “Preparing for and Responding to a Breach of Personally Identifiable

Information”

• Privacy Act of 1974, “5 USC, § 552a”

• OMB Memoranda, location of current fiscal year guidance on Federal Information

Security and Privacy Management Requirements, including FISMA reporting

Federal Standards and Guidance:

The contractor shall comply with all applicable Federal Information Processing Standards (FIPS).

NIST Special Publications (800 Series) are guidance, unless required by a FIPS publication, in which case usage is mandatory.

• FIPS PUB 199, “Standards for Security Categorization of Federal Information and Information Systems”

• FIPS PUB 200, “Minimum Security Requirements for Federal Information and Information Systems”

• FIPS PUB 140-2, “Security Requirements for Cryptographic Modules”

• NIST SP 800-18, Revision 1, “Guide for Developing Security Plans for Federal Information

Systems”

• NIST SP 800-30, Revision 1, “Guide for Conducting Risk Assessments”

• NIST SP 800-34, Revision 1, “Contingency Planning Guide for Federal Information

Systems”

• NIST SP 800-37, Revision 1, “Guide for Applying the Risk Management Framework to

Federal Information Systems: A Security Lifecycle Approach”

• NIST SP 800-47, “Security Guide for Interconnecting Information Technology Systems”

• NIST SP 800-53, Revision 4, “Security and Privacy Controls for Federal Information

Systems and Organizations” https://www.gpo.gov/fdsys/pkg/USCODE-2009-title40/pdf/USCODE-2009-title40-subtitleIII-chap113-subchapIII-sec11331.pdf https://www.congress.gov/113/plaws/publ283/PLAW-113publ283.pdf https://www.dhs.gov/homeland-security-presidential-directive-12 https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A130/a130revised.pdf https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/memoranda/2008/m08-23.pdf https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/memoranda/2014/m-14-03.pdf https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/memoranda/2010/m10-23.pdf https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/memoranda/2015/m-15-13.pdf https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/memoranda/2017/m-17-12_0.pdf https://www.justice.gov/opcl/privacy-act-1974 https://www.whitehouse.gov/omb/information-for-agencies/memoranda http://nvlpubs.nist.gov/nistpubs/FIPS/NIST.FIPS.199.pdf http://nvlpubs.nist.gov/nistpubs/FIPS/NIST.FIPS.200.pdf http://nvlpubs.nist.gov/nistpubs/FIPS/NIST.FIPS.140-2.pdf http://nvlpubs.nist.gov/nistpubs/Legacy/SP/nistspecialpublication800-18r1.pdf http://nvlpubs.nist.gov/nistpubs/Legacy/SP/nistspecialpublication800-30r1.pdf http://nvlpubs.nist.gov/nistpubs/Legacy/SP/nistspecialpublication800-34r1.pdf http://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-37r1.pdf http://csrc.nist.gov/publications/nistpubs/800-47/sp800-47.pdf http://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-53r4.pdf

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• NIST SP 800-53A, Revision 4, “Assessing Security and Privacy Controls in Federal Information Systems and Organizations: Building Effective Assessment Plans”

• NIST SP 800-63-3, “Digital Identity Guidelines”

• NIST SP 800-122, “Guide to Protecting the Confidentiality of Personally Identifiable

Information (PII)”

• NIST SP 800-137, “Information Security Continuous Monitoring (ISCM) for Federal

Information Systems and Organizations”

GSA Policies:

The contractor shall comply with the following GSA Directives/Policies.

• GSA Order CIO 1878.1, “GSA Privacy Act Program”

• GSA Order CIO 1878.2, “Conducting Privacy Impact Assessments (PIAs) in GSA”

• GSA Order CIO 2100.1, “GSA Information Technology (IT) Security Policy”

• GSA Order CIO 9297.2, “GSA Information Breach Notification Policy”

The GSA policies listed in this paragraph must be followed, if applicable.

• GSA Order CIO 2103.1, “Controlled Unclassified Information (CUI) Policy”

• GSA Order CIO 2104.1, “GSA Information Technology (IT) General Rules of Behavior”

• GSA Order CIO 2182.2, “Mandatory Use of Personal Identity Verification (PIV)

Credentials”

GSA Procedural Guides:

GSA IT Procedural Guides are guidance, unless required by a GSA Directive/Policy, in which case usage is mandatory.

Note: GSA’s Procedural Guides are updated frequently; to make sure you have the most recent version of publicly available procedural guides, visit GSA.gov. If a non-publicly available guide is needed, contact the contracting officer who will coordinate with the GSA Office of the Chief Information Security Officer to determine if it can be made available.

2.2 GSA Security Compliance Requirements

FIPS PUB 200, “Minimum Security Requirements for Federal Information and Information Systems,” is a mandatory federal standard that defines the minimum security requirements for federal information and information systems in seventeen security-related areas. Information systems supporting GSA must meet the minimum security and privacy requirements through the use of security controls in accordance with NIST Special Publication 800-53, Revision 4 (hereafter described as NIST 800-53), “Security and Privacy Controls for Federal Information Systems and Organizations.”

To comply with the Federal standard, GSA must determine the security category of the information and information system in accordance with FIPS PUB 199, “Standards for Security Categorization of Federal Information and Information Systems,” and then the contractor shall http://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-53Ar4.pdf http://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-63-3.pdf http://nvlpubs.nist.gov/nistpubs/Legacy/SP/nistspecialpublication800-122.pdf http://nvlpubs.nist.gov/nistpubs/Legacy/SP/nistspecialpublication800-137.pdf https://www.gsa.gov/directives-library/ https://www.gsa.gov/directives-library/ https://www.gsa.gov/directives-library/ https://www.gsa.gov/directives-library/ https://www.gsa.gov/directives-library/ https://www.gsa.gov/directives-library/ https://www.gsa.gov/directives-library/ https://www.gsa.gov/about-us/organization/office-of-the-chief-information-officer/chief-information-security-officer-ciso/it-security-procedural-guides

U.S. General Services Administration 5 apply the appropriately tailored set of Low, Moderate, or High impact baseline security controls in NIST 800-53, as determined by GSA. NIST 800-53 controls requiring organization-defined parameters (i.e., password change frequency) shall be consistent with GSA specifications. The GSA-specified control parameters and supplemental guidance defining more specifically the requirements per FIPS PUB 199 impact level are available in the GSA Control Tailoring Workbook referenced in Appendix A of this document.

The Contractor shall use GSA technical guidelines, NIST guidelines, Center for Internet Security (CIS) guidelines (Level 1), or industry best practice guidelines in hardening their systems.

2.3 Essential Security Controls

All NIST 800-53 controls must be implemented as per the applicable FIPS PUB 199 Low, Moderate, or High baseline. The following table identifies essential security controls from the respective baselines to highlight their importance and ensure they are implemented. The Contractor shall make the proposed system and security architecture of the information system available to the Security Engineering Division, in the Office of the Chief Information Security Officer for review and approval before commencement of system build (architecture, infrastructure, and code).

Control ID Control Title Baseline GSA Implementation Guidance

AC-2 Account Management L, M, H

AC-17 (3)

Remote Access | Managed Access Control Points

M, H

All remote accesses from internal users/systems to the external information system must be routed through GSA’s managed network access control points, subjecting them to security monitoring.

AU-2 Audit Events L, M, H

Information systems shall implement audit configuration requirements as documented in applicable GSA IT Security Technical Hardening Guides (i.e., hardening and technology implementation guides); for web applications see GSA IT Security Procedural Guide 07-35, Section 2.8.10, What to Log.

For technologies where a Technical Guide and Standard does not exist, events from an industry source such as vendor guidance or Center for Internet Security benchmark, recommended by the GSA S/SO or Contractor to be approved and accepted by the GSA AO shall be used.

CM-6 Configuration Settings L, M, H

Information systems, including vendor owned/operated systems on behalf of GSA, shall configure their systems in agreement with GSA technical guidelines, NIST guidelines, Center for Internet Security guidelines (Level 1), or industry best practice guidelines, as deemed appropriate.

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Control ID Control Title Baseline GSA Implementation Guidance

CP-7 Alternative Processing Site M, H

FIPS PUB 199 Moderate and High impact systems must implement processing across geographically-disparate locations to ensure fault tolerance. Amazon Web Services based architectures must implement a multi-region strategy (multiple availability zones in a single region are not sufficient).

CP-8 Telecom Services M, H

FIP PUB 199 Moderate and High impact information systems must implement alternate telecom services to support resumption when the primary telecommunications capabilities are unavailable at either the primary or alternate processing or storage sites.

IA-2 (1)

Identification and Authentication (Organizational Users) | Network Access to Privileged Accounts

L, M, H

All information systems shall implement multi-factor authentication for privileged accounts.

IA-2 (2)

Identification and Authentication (Organizational Users) | Network Access to Non- Privileged Accounts

M, H

FIPS PUB 199 Moderate and High impact information systems must implement multi-factor authentication for non-privileged accounts.

IA-7

Cryptographic Module Authentication

L, M, H

The information system shall implement FIPS PUB 140-2 compliant encryption modules for authentication functions.

Reference:

https://csrc.nist.gov/Projects/Cryptographic-Module- Validation-Program/Validated-Modules

MP-4 Media Storage M, H

Digital media including magnetic tapes, external/removable hard drives, flash/thumb drives, diskettes, compact disks and digital video disks shall be encrypted using a FIPS PUB 140-2 certified encryption module.

MP-5 Media Transport M, H

Digital media including magnetic tapes, external/removable hard drives, flash/thumb drives and digital video disks shall be encrypted using a FIPS PUB 140-2 certified encryption module during transport outside of controlled areas.

https://csrc.nist.gov/Projects/Cryptographic-Module-Validation-Program/Validated-Modules

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Control ID Control Title Baseline GSA Implementation Guidance

PL-8

Information Security Architecture

M, H

All information system security architectures must be formally reviewed and approved by the Office of the Chief Information Security Officer, Security Engineering Division during the system develop/design stages of the SDLC and prior to Security Assessment and Authorization.

RA-5 Vulnerability Scanning L, M, H

All systems must complete weekly operating system (OS) and monthly web application vulnerability scans.

The most recent vulnerability scanning results shall be provided to GSA together with the quarterly POA&M submission.

SA-22

Unsupported System Components

GSA

Required

All systems must be comprised of software and hardware components that are fully supported in terms of security patching for the anticipated life of the system; software must be on GSA’s Enterprise Architecture IT Standards List.

SC-8 / SC-

8(1)

Transmission Confidentiality and Integrity / Transmission Confidentiality and Integrity | Cryptographic or Alternate Physical Protection

M, H

Implemented encryption algorithms and cryptographic modules shall be FIPS-approved and FIPS PUB 140-2 validated, respectively.

o Digital signature encryption algorithms - Reference:

https://csrc.nist.gov/Projects/Cryptographic-Algorithm- Validation-Program/Validation/Validation-List/DSA o Block cypher encryption algorithms - Reference:

https://csrc.nist.gov/Projects/Cryptographic-Algorithm- Validation-Program/Block-Ciphers o Secure hashing algorithms – Reference:

https://csrc.nist.gov/Projects/Cryptographic-Algorithm- Validation-Program/Secure-Hashing

Internet accessible Websites shall implement HTTPS Only and HTTP Strict Transport Security (HSTS), reference OMB Memorandum M-15-13.

SSL/TLS implementations shall align with GSA IT Security Procedural Guide 14-69, “SSL/TLS Implementation.”

SC-13 Cryptographic Protection L, M, H

Implemented encryption algorithms and cryptographic modules shall be FIPS-approved and FIPS PUB 140-2 validated, respectively.

o Digital signature encryption algorithms - Reference:

https://csrc.nist.gov/Projects/Cryptographic-Algorithm- Validation-Program/Validation/Validation-List/DSA o Block cypher encryption algorithms - Reference:

https://csrc.nist.gov/Projects/Cryptographic-Algorithm- Validation-Program/Block-Ciphers o Secure hashing algorithms – Reference:

https://csrc.nist.gov/Projects/Cryptographic-Algorithm- Validation-Program/Secure-Hashing https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Validation/Validation-List/DSA https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Validation/Validation-List/DSA https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Block-Ciphers https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Block-Ciphers https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Secure-Hashing https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Secure-Hashing https://https.cio.gov/hsts/ https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Validation/Validation-List/DSA https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Validation/Validation-List/DSA https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Block-Ciphers https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Block-Ciphers https://csrc.nist.gov/Projects/Cryptographic-Algorithm-Validation-Program/Secure-Hashing

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Control ID Control Title Baseline GSA Implementation Guidance

SC-17 PKI Certificates M, H

Implement appropriate creation, use, and signing of crypto certs in agreement with GSA IT Security Procedural Guide 14- 69, “SSL/TLS Implementation,” and NIST Special Publications

800-32, NIST 800-63.

SC-18 Mobile Code M, H

SC-22

Architecture and Provisioning for Name / Address Resolution Service

L, M, H

Information systems shall be Domain Name System Security Extensions (DNSSEC) compliant. Reference OMB Memorandum M-08-23, which requires all Federal Government departments and agencies that have registered and are operating second level .gov to be DNSSEC.

SC-28 (1)

Protection of Information at Rest | Cryptographic Protection

GSA Required

– For systems with Personally Identifiable Information

Only

Systems bearing PII must implement protect information at rest. At a minimum, fields bearing PII data must be encrypted with field level encryption. Encryption algorithms shall be FIPS-approved; implemented encryption modules shall be FIPS PUB 140-2 validated.

SI-2 Flaw Remediation L, M, H

All projects and systems must be adequately tested for flaws;

all Critical, High, and Moderate risk findings must be remediated prior to go-live. Post go-live, all critical and high vulnerabilities identified must be mitigated within 30 days and all moderate vulnerabilities mitigated within 90 days.

SI-3 Malicious Code Protection L, M, H

SI-4

Information System Monitoring

L, M, H

SI-10 Information Input Validation M, H

All system accepting input from end users must validate the input in accordance to industry best practices and published guidelines, including GSA IT Security Procedural Guide 07-35, “Web Application Security,” and OWASP Top 10 Web Application Security Vulnerabilities.

AR-2

Privacy Impact and Risk Assessment

See note below

The contractor shall conduct a Privacy Threshold Analysis (PTA) and, if applicable, a Privacy Impact Assessment (PIA) identifying the categories of information and addressing potential risks to PII. The contractor also shall coordinate with the GSA Privacy Office concerning these documents.

AR-8 Accounting of Disclosures

See note below

The contractor shall keep an accurate accounting of disclosures of information held in any system of records under its control.

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Control ID Control Title Baseline GSA Implementation Guidance

TR-2

System of Records Notices and Privacy Act Statements

See note below.

The contractor shall coordinate with the GSA Privacy Office to ensure System of Records Notices (SORNs) and Privacy Act notices on forms that collect Personally Identifiable Information (PII) are established and kept current.

UL-1 Internal Use See note below

The contractor shall ensure that PII is shared internally only for the authorized purpose(s) identified in the Privacy Act and/or in public notices.

UL-2

Information Sharing with Third Parties

See note below

The contractor shall coordinate with the GSA Privacy Office to ensure PII is shared in accordance with GSA requirements and agreements with third parties.

Note: Privacy controls are not associated with a baseline. Controls are applicable/not applicable based on PII data being collected, stored, or transmitted.

2.4 Assessment and Authorization (A&A) Activities

The implementation of a new Federal Government IT system requires a formal approval process known as Assessment and Authorization (A&A). NIST Special Publication 800-37, Revision 1 (hereafter described as NIST 800-37) and GSA IT Security Procedural Guide 06-30, “Managing Enterprise Risk,” provide guidelines for performing the A&A process. The Contractor system/application must have a valid assessment and authorization, known as an Authority to Operate (ATO) (signed by the Federal government) before going into operation and processing GSA information. The failure to obtain and maintain a valid ATO will result in the termination of the contract. The system must have a new A&A conducted (signed by the Federal government) at least every three (3) years or at the discretion of the Authorizing Official when there is a significant change to the system’s security posture or via continuous monitoring based on GSA CIO IT Security 12-66, “Information Security Continuous Monitoring Strategy” that is reviewed and accepted by the GSA CISO.

Assessing the System

1. The Contractor shall comply with Assessment and Authorization (A&A) requirements as mandated by Federal laws and policies, including making available any documentation, physical access, and logical access needed to support this requirement. The Level of Effort for the A&A is based on the System’s NIST Federal Information Processing Standard (FIPS) Publication 199 categorization. The contractor shall create, maintain and update the following A&A documentation:

• System Security Plan (SSP) completed in agreement with NIST Special Publication 800-18, Revision 1, “Guide for Developing Security Plans for Federal Information Systems.” The SSP shall include as appendices required policies and procedures across 17 control families mandated per FIPS PUB 200, Rules of Behavior, and Interconnection Agreements (in agreement with NIST Special Publication 800-47, U.S. General Services Administration 10

“Security Guide for Interconnecting Information Technology Systems”). The SSP shall include; as an appendix, a completed GSA Control Tailoring Workbook identified in Appendix A of this guide. The column in the workbook titled “GSA Defined Values,” shall be used to document all contractor implemented settings that are different from the GSA defined setting and where the GSA defined setting allows a contractor determined setting.

• Contingency Plan (including Disaster Recovery Plan) completed in agreement with NIST Special Publication 800-34.

• Contingency Plan Test Report completed in agreement with GSA IT Security Procedural Guide 06-29, “Contingency Planning.”

• Incident Response Plan completed in agreement with NIST Special Publication 800-61, “Computer Security Incident Handling Guide” and GSA IT Security Procedural Guide 01-02, “Incident Response.”

• Incident Response Test Report completed in agreement NIST Special Publication 800-61, “Computer Security Incident Handling Guide” and GSA IT Security Procedural Guide 01-02, “Incident Response.”

• Configuration Management Plan completed in agreement with GSA IT Security Procedural Guide 01-05, “Configuration Management.”

• Plan of Actions & Milestones completed in agreement with GSA IT Security Procedural Guide 09-44, “Plan of Action and Milestones (POA&M).”

• Penetration Test Reports documenting the results of vulnerability analysis and exploitability of identified vulnerabilities. Note: Penetration testing is required for all FIPS PUB 199 Low impact and Moderate impact Internet accessible information systems, and all FIPS PUB 199 High impact information systems are required to complete an independent penetration test and provide an Independent Penetration Test Report documenting the results of the exercise as part of the A&A package. Reference GSA IT Security Procedural Guide 06-30, “Managing Enterprise Risk” and GSA IT Security Procedural Guide 11-51, “Conducting Penetration Test Exercises” for penetration testing guidance.

2. Information systems must be assessed and authorized every three (3) years or whenever there is a significant change to the system's security posture in accordance with NIST Special Publication 800-37, Revision 1, "Guide for the Security Certification and Accreditation of Federal Information Systems," and CIO IT Security 06-30, "Managing Enterprise Risk" or via continuous monitoring based on GSA CIO IT Security 12-66, "Information Security Continuous Monitoring Strategy" that is reviewed and accepted by the GSA CISO.

3. At the Moderate impact level and higher, the <SELECT: contractor or Government> is responsible for providing an independent Security Assessment/Risk Assessment in accordance with GSA IT Security Procedural Guide 06-30, “Managing Enterprise Risk.”

4. If the Government is responsible for providing a Security Assessment/Risk Assessment and Penetration Test, the Contractor shall allow GSA employees (or GSA designated third party contractors) to conduct A&A activities to include control reviews in

U.S. General Services Administration 11 accordance with NIST 800-53/NIST 800-53A and GSA IT Security Procedural Guide 06-30, “Managing Enterprise Risk.” Review activities include but are not limited to operating system vulnerability scanning, web application scanning, and database scanning of applicable systems that support the processing, transportation, storage, or security of GSA information. This includes the general support system infrastructure.

5. Identified gaps between required NIST 800-53 controls and the contractor’s implementation as documented in the Security Assessment/Risk Assessment report shall be tracked for mitigation in a Plan of Action and Milestones (POA&M) document completed in accordance with GSA IT Security Procedural Guide 09-44, “Plan of Action and Milestones (POA&M).” Depending on the severity of the gaps, the Government may require them to be remediated before an Authorization to Operate is issued.

6. The Contractor is responsible for mitigating all security risks found during the A&A and continuous monitoring activities. All high-risk vulnerabilities must be mitigated within 30 days and all moderate risk vulnerabilities must be mitigated within 90 days from the date vulnerabilities are formally identified. The Government will determine the risk rating of vulnerabilities.

Authorization of the System

1. Upon receipt of the documentation (Security Authorization Package (SAP)) described in GSA IT Security Procedural Guide 06-30, “Managing Enterprise Risk” and NIST Special Publication 800-37 as documented above, the GSA Authorizing Official (AO) for the system (in coordination with the GSA Chief Information Security Officer (CISO), system Program Manager (PM), Information System Security Manager (ISSM), and Information System Security Officer (ISSO) will render an authorization decision to:

• Authorize system operation w/out any restrictions or limitations on its operation;

• Authorize system operation w/restriction or limitation on its operation, or;

• Not authorize for operation.

2. The Contractor shall provide access to the Federal Government, or their designee acting as their agent, when requested, in order to verify compliance with the requirements for an Information Technology security program. At its option, the Government may choose to conduct on site surveys. The Contractor shall make appropriate personnel available for interviews and documentation during this review. If documentation is considered proprietary or sensitive, these documents may be reviewed on-site under the hosting Contractor’s supervision.

2.5 Reporting and Continuous Monitoring

Maintenance of the security authorization to operate will be through continuous monitoring of security controls of the external system and its environment of operation to determine if the security controls in the information system continue to be effective over time in light of changes that occur in the system and environment. Through continuous monitoring, security

U.S. General Services Administration 12 controls and supporting deliverables are updated and submitted to GSA per the schedules below. The submitted deliverables (or lack thereof) provide a current understanding of the security state and risk posture of the information systems. They allow GSA AOs to make credible risk-based decisions regarding the continued operations of the information systems and initiate appropriate responses as needed when changes occur.

Deliverables to be provided to the GSA COR/ISSO/ISSM Quarterly

1. Vulnerability Scanning Reference: NIST 800-53 control RA-5 Provide the most recent Web Application and Operating System vulnerability scan reports.

2. Plan of Action & Milestones (POA&M) Update Reference: NIST 800-53 control CA-5 Provide POA&M updates in accordance with requirements and the schedule set forth in GSA CIO IT Security Procedural Guide 09-44, “Plan of Action and Milestones

(POA&M).”

Deliverables to be provided to the GSA COR/ISSO/ISSM Annually

1. Updated A&A documentation including the System Security Plan and Contingency Plan

a. System Security Plan Reference: NIST 800-53 control PL-2 Review and update the System Security Plan annually to ensure the plan is current and accurately describes implemented system controls and reflects changes to the contractor system and its environment of operation. The System Security Plan must be in accordance with NIST 800-18, Revision 1, “Guide for Developing Security Plans.”

b. Contingency Plan Reference: NIST 800-53 control CP-2 Provide an annual update to the contingency plan completed in accordance with NIST 800-34, “Contingency Planning Guide.”

2. User Certification/Authorization Review Documents Reference: NIST 800-53 control AC-2 Provide the results of the annual review and validation of system users’ accounts to ensure the continued need for system access. The user certification and authorization documents will illustrate the organization establishes, activates, modifies, reviews, disables, and removes information system accounts in accordance with documented account management procedures.

3. Separation of Duties Matrix Reference: NIST 800-53 control AC-5

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Develop and furnish a separation of duties matrix reflecting proper segregation of duties for IT system maintenance, management, and development processes. The separation of duties matrix will be updated or reviewed on an annual basis.

4. Information Security Awareness and Training Records Reference: NIST 800-53 control AT-4 Provide the results of security awareness (AT-2) and role-based information security technical training (AT-3). AT-2 requires basic security awareness training for employees and contractors that support the operation of the contractor system.

AT-3 requires information security technical training to information system security roles. Training shall be consistent with the requirements contained in C.F.R. Part 5 Subpart C (5 C.F.R 930.301) and conducted at least annually.

5. Annual FISMA Self-Assessment Reference: NIST 800-53 control CA-2 Deliver the results of the annual FISMA self-assessment conducted per GSA IT Security Procedural Guide 04-26, “Federal Information Security Modernization Act (FISMA) Implementation.” Based on the controls selected for self-assessment, the GSA OCISO will provide the appropriate test cases for completion.

6. System(s) Baseline Configuration Standard Document Reference: NIST 800-53 control CM-2/CM-2(1) Provide a well-defined, documented, and up-to-date specification to which the information system is built.

7. System Configuration Settings Verification Reference: NIST 800-53 control CM-6/CM-6(1) Establish and document mandatory configuration settings for information technology products employed within the information system that reflect the most restrictive mode consistent with operational requirements. Configuration settings are the configurable security-related parameters of information technology products that compose the information system. Systems should be configured in agreement with GSA technical guidelines, NIST guidelines, Center for Internet Security guidelines (Level 1), or industry best practice guidelines in hardening their systems, as deemed appropriate by the Authorizing Official.

Provide the most recent operating system Configuration Settings Compliance scan report.

8. Configuration Management Plan Reference: NIST 800-53 control CM-9 Provide an annual update to the Configuration Management Plan for the information system.

9. Contingency Plan Test Report Reference: NIST 800-53 control CP-4 Provide a contingency plan test report completed in accordance with GSA IT Security Procedural Guide 06-29, “Contingency Planning.” A continuity test shall be

U.S. General Services Administration 14 conducted annually prior to mid-July of each year. The continuity test can be a table top test while the system is at the FIPS PUB 199 Low Impact level. The table top test must include Federal and hosting Contractor representatives. Functional exercises must be completed once every three years for FIPS PUB 199 Moderate impact systems and annually for FIPS PUB 199 High impact systems.

10. Incident Response Test Report Reference: NIST 800-53 control IR-3 Provide an incident response plan test report documenting results of incident reporting process per GSA IT Security Procedural Guide 01-02, “Incident Response.”

11. Information System Interconnection Agreements Reference: NIST 800-53 control CA-3 Provide Interconnection Security Agreements (ISA) and supporting Memoranda of Agreement/Understanding (MOA/U), completed in accordance with NIST 800-47, “Security Guide for Connecting Information Technology Systems,” for existing and new interconnections. Per NIST 800-47, an interconnection is the direct connection of two or more IT systems for the purpose of sharing data and other information resources through a pipe, such as ISDN, T1, T3, DS3, VPN, etc. ISAs shall be submitted as appendices as part of the annual System Security Plan submission. ISAs shall include, if applicable, any changes since the last submission; updated ISAs are required at least every three years.

12. Rules of Behavior Reference: NIST 800-53 control PL-4 Define and establish Rules of Behavior for information system users. Rules of Behavior shall be submitted as an appendix to the System Security Plan.

13. Penetration Testing Report Reference: NIST 800-53 control CA-8 All Internet accessible systems, and all FIPS PUB 199 High impact systems are required to complete an independent penetration test and provide a Penetration Test Report documenting the results of the exercise as part of their A&A package.

Annual penetration tests are required for these same systems in accordance with GSA Order CIO 2100.1 and CIO-IT Security-11-51, “Conducting Penetration Test Exercises.”

14. Personnel Screening and Security Reference: NIST 800-53 control PS-3, NIST 800-53 control PS-7 Furnish documentation reflecting favorable adjudication of background investigations for all personnel (including subcontractors) supporting the system.

Contractors shall comply with GSA Order CIO 2100.1, “GSA Information Technology (IT) Security Policy” and GSA Order, CIO P 2181.1, “Homeland Security Presidential Directive-12 (HSPD-12) Personal Identity Verification and Credentialing Handbook.”

GSA separates the risk levels for personnel working on Federal computer systems into three categories: Low Risk, Moderate Risk, and High Risk.

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• Those contract personnel (hereafter known as “Applicant”) determined to be in a Low Risk position will require a National Agency Check with Written Inquiries (NACI) investigation.

• Those Applicants determined to be in a Moderate Risk position will require either a Limited Background Investigation (LBI) or a Minimum Background Investigation (MBI) based on the Contracting Officer’s (CO) determination.

• Those Applicants determined to be in a High Risk position will require a Background Investigation (BI).

Applicants will not be reinvestigated if a prior favorable adjudication is on file with FPS or GSA, there has been less than a one year break in service, and the position is identified at the same or lower risk level.

Once a favorable FBI Criminal History Check (Fingerprint Check) has been returned, Applicants may receive a GSA identity credential (if required) and initial access to GSA information systems. The HSPD-12 Handbook contains procedures for obtaining identity credentials and access to GSA information systems as well as procedures to be followed in case of unfavorable adjudications.

Deliverables to be provided to the GSA COR/ISSO/ISSM Biennially

1. Policies and Procedures Develop and maintain current the following policies and procedures:

a. Access Control Policy and Procedures (NIST 800-53 AC-1)

b. Security Awareness and Training Policy and Procedures (NIST 800-53 AT-1)

c. Audit and Accountability Policy and Procedures (NIST 800-53 AU-1)

d. Identification and Authentication Policy and Procedures (NIST 800-53 IA-1)

e. Incident Response Policy and Procedures (NIST 800-53 IR-1, reporting timeframes are documented in GSA IT Security Procedural Guide 01-02, “Incident Response”

f. System Maintenance Policy and Procedures (NIST 800-53 MA-1)

g. Media Protection Policy and Procedures (NIST 800-53 MP-1)

h. Physical and Environmental Policy and Procedures (NIST 800-53 PE-1)

i. Personnel Security Policy and Procedures (NIST 800-53 PS-1)

j. System and Information Integrity Policy and Procedures (NIST 800-53 SI-1)

k. System and Communication Protection Policy and Procedures (NIST 800-53 SC-1)

l. Key Management Policy (NIST 800-53 SC-12)

2.6 GSA Privacy Requirements

Personally identifiable information (PII) <SELECT: is or is not> in the scope of the acquisition and PII <SELECT: is or is not> expected to be stored, processed, or transmitted in the vendor's information system. The collection, maintenance or dissemination of any PII that is subject to the Privacy Act and/or the E-Government Act will be handled in full accordance with all GSA rules of conduct and in accordance with GSA Privacy Program requirements.

https://www.gsa.gov/portal/content/104256

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The contractor shall prepare a Privacy Threshold Analysis (PTA) to confirm and document PII is not in scope, or to determine which categories of information will be stored, processed, or transmitted by the system. The PTA must be completed before development begins and whenever a change with a privacy impact (e.g., a new category of information is collected) is made to an existing system. PTAs are required as part of GSA’s process to determine whether a Privacy Impact Assessment (PIA) and/or a System of Records Notice (SORN) is required, and if any other privacy requirements apply to the information system. Instructions for the PTA and PIA forms can be found at https://www.gsa.gov/reference/gsa-privacy-program/privacy-impact-assessments-pia.

PII (should it come into scope) will require the following guidelines be adhered to.

• The vendor’s information system must be authorized at least at the FIPS PUB 199 Moderate level.

• For any system that collects, maintains or disseminates PII, a PIA must be completed by the contractor and provided to the GSA Privacy Office for review along with the other authorization to operate (ATO) documents.

• If the system retrieves information using PII, the Privacy Act applies and it must have a system of records notice (SORN) published in the Federal Register.

• If PII is collected from individuals by the system, a Privacy Act Statement (i.e., Privacy Notice) must be provided to users prior to their use of the application on what data is being collected and why, as well as the authority for the collection and the impact of not providing some or all of it. The Privacy Act Statement must be available to the individual directly on the form used to collect the information. Providing a link back to the Statement from the form is acceptable.

Provided below is a template for an acceptable Privacy Act Statement, when bracketed sections are completed. A completed example is available at https://www.gsa.gov/reference/gsa-privacy-program/privacy-act-statement-for-design-research.

Privacy Act Statement

This (insert voluntary or mandatory) collection of personal information in authorized by (insert legal authority). We collect (developer insert categories of PII collected, e.g., name, email, etc.).

Your personal information is collected so we can (developer insert purpose of collection and what effect on the individual, if any, not providing any or all of the information may have). Your personal information is stored in (developer insert GSA system name). GSA may use this information pursuant to its published Privacy Act system of records notice (insert link to applicable GSA Privacy Act SORN).

Note: Systems that access data a user creates must assume a user may include privacy data/PII in the system unless the data creation is restricted to data controlled by the system.

All contractor staff who have significant privacy information responsibilities must complete GSA’s specialized Privacy 201 Training. This includes contractors who work with PII as part of their work duties (e.g.; Human Resource staff, Finance staff, and managers/supervisors).

https://www.gsa.gov/reference/gsa-privacy-program/privacy-act-statement-for-design-research https://www.gsa.gov/reference/gsa-privacy-program/privacy-act-statement-for-design-research https://www.gsa.gov/portal/content/104265

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2.7 Additional Stipulations

1. Deliverables shall be labeled Sensitive But Unclassified (SBU) or contractor selected designation per document sensitivity. External transmission/dissemination of SBU to or from a Government computer must be encrypted. Certified encryption modules must be used in accordance with FIPS PUB 140-2, “Security Requirements for Cryptographic Modules.”

2. The Contractor shall certify applications are fully functional and operate correctly as intended on systems using the United States Government Configuration Baseline (USGCB). This includes Internet Explorer configured to operate on Windows. The standard installation, operation, maintenance, update, and/or patching of software shall not alter the configuration settings from the approved USGCB configuration. The information technology should also use the Windows Installer Service for installation to the default “program files” directory and should be able to silently install and uninstall.

Applications designed for normal end users shall run in the standard user context without elevated system administration privileges.