02_02_A309b_SP_800-128 _Security_Impact_Analysis_excerpts.docx

2.3.9 SECURITY IMPACT ANALYSIS

Security impact analysis is the analysis conducted by qualified staff within an organization to determine the extent to which changes to the information system affect the security posture of the system. Because information systems are typically in a constant state of change, it is important to understand the impact of changes on the functionality of existing security controls and in the context of organizational risk tolerance. Security impact analysis is incorporated into the documented configuration change control process.

The analysis of the security impact of a change occurs when changes are analyzed and evaluated for adverse impact on security, preferably before they are approved and implemented, but also in the case of emergency/unscheduled changes. Once the changes are implemented and tested, a security impact analysis (and/or assessment) is performed to ensure that the changes have been implemented as approved, and to determine if there are any unanticipated effects of the change on existing security controls.

Security impact analysis is performed as a part of the Controlling Configuration Changes phase of SecCM and supports the implementation of NIST SP 800-53 control CM-4 Security Impact Analysis.

3.3.3 CONDUCT SECURITY IMPACT ANALYSIS

This is one of the most critical steps in the configuration change control process with respect to SecCM. Organizations spend significant resources developing and maintaining the secure state of information systems; failing to properly analyze a change for its security impact can undo this effort and expose the organization to attack. The security impact analysis activity provides the linkage between configuration change control and improved security. The management of changes through a structured process has its own benefits – for instance, increased efficiency. However, it is only when those changes are evaluated for their security impact that the configuration change control process realizes benefits for the security posture of an information system.

Very large organizations or ISOs of large and complex systems may find it helpful to create a Configuration Review Board to manage and conduct security impact analyses and report the findings to the relevant CCB.

Changes are examined for impact on security, and for mitigating controls that can be implemented to reduce any resulting vulnerability. Security impact analyses are conducted by individuals or teams with technical knowledge of the information system throughout the SDLC such that the impact of changes on security is considered at every phase:23 Initiation Phase (Before a Change is Deployed) Security impact analysis before a change is deployed is critical in ascertaining whether the change will impact the secure state of the information system. The initial security impact analysis is conducted before the change is approved by the CCB. If there are security concerns with a change, they can be addressed/mitigated before time and energy are spent in building, testing, and/or rolling out the change.

Development/Acquisition and Implementation/Assessment Phases Security impact analysis is not a one-time event conducted during the initiation phase to support the decisions of the CCB when approving changes. When the change is initially proposed and reviewed, the manner in which it will be built and implemented may not be known, something which can greatly influence the security impact of the change. For instance, for a custom-built component during the design phase, security impact analysis is performed on technical design documents to ensure that the design considers security best practices, implements the appropriate controls, and would not need to be redeveloped at a later date due to introduced vulnerabilities. Developers ensure that security is taken into account as they build the component, and the design is tested during implementation to confirm that expected controls were implemented and that no new or unexpected vulnerabilities were introduced.

Operations and Maintenance Phase (After a Change is Deployed) – This confirms that the original security impact analysis was correct, and that unexpected vulnerabilities or impacts to security controls not identified in the testing environment have not been introduced. Additionally, the security impact of unscheduled and unauthorized changes is analyzed during the operations and maintenance phase.

The process for a security impact analysis consists of the following steps:

i. Understand the Change - If the change is being proposed, develop a high-level architecture overview which shows how the change will be implemented. If the change has already occurred (unscheduled/unauthorized), request follow-up documentation/information and review it or use whatever information is available (e.g., audit records, interview staff who made the change, etc.) to gain insight into the change.

ii. Identify Vulnerabilities - If the change involves a COTS hardware or software product, identifying vulnerabilities may include, for example, a search of the National Vulnerability Database (NVD)24 which enumerates vulnerabilities, user experience, etc. Organizations can leverage this information to address known issues and remove or mitigate them before they become a concern. Other public databases of vulnerabilities, weaknesses, and threats may also be searched (e.g., US-CERT). Some automated vulnerability scanning tools (SCAP-validated tools where possible) are able to search various public vulnerability databases that apply to IT products/CPE names of IT products. If the change involves custom development, a more in-depth analysis of the security impact is conducted. Although application security is beyond the scope of this publication, there are many best practices and useful sources of information for how to ensure the security of software code.

iii. Assess Risks - Once a vulnerability has been identified, a risk assessment is needed to identify the likelihood of a threat exercising the vulnerability and the impact of such an event. Although vulnerabilities may be identified in changes as they are proposed, built, and tested, the assessed risk may be low enough that the risk can be accepted without remediation (i.e., risk acceptance). In other cases, the risk may be high enough that the change is not approved (i.e., risk avoidance), or that safeguards and countermeasures are implemented to reduce the risk (i.e., risk mitigation).25

iv. Assess Impact on Existing Security Controls - In addition to assessing the risk from the change, organizations analyze whether and how a change will impact existing security controls. For example, the change may involve installation of software that alters the existing baseline configuration, or the change itself may cause or require changes to the existing baseline configuration. The change may also affect other systems or system components that depend on the function or component being changed, either temporarily or permanently. For example, if a database that is used to support auditing controls is being upgraded to the latest version, auditing functionality within the system may be halted while the upgrade is being implemented.

v. Plan Safeguards and Countermeasures - In cases where risks have been identified and are unacceptable, organizations use the security impact analysis to revise the change or to plan safeguards and countermeasures to reduce the risk. For instance, if the security impact analysis reveals that the proposed change causes a modification to a common secure configuration setting, plans to rework the change to function within the existing setting are initiated. If a change involves new elevated privileges for users, plans to mitigate the additional risk are made (e.g., submission of requests for higher clearance levels for those users or implementation of stronger access controls).

See Appendix I for a sample Security Impact Analysis Template.

SDLC Phase: Operations and Maintenance phase

Primary Roles: ISSO

Supporting Roles: AO; ISO; ISA; System/Software Developer

Expected Input: Change request and/or any supporting documentation; System Security Plan including the current approved baseline configuration; system audit records; relevant COTS vulnerability information

Expected Output: Identified vulnerabilities; risk assessment of identified vulnerabilities including any potential countermeasures; analysis of the security impact of the change