FedRAMP for The Private Sector: What You Need to Know

FedRAMP is the Federal Risk and Authorization Management Program, and it’s one of the common security frameworks used by the government, its agencies, and the contractors that work with it. However, it’s not solely restricted to the government: FedRAMP can be used in the private sector just as well. The question is, how does it work if you want to do so, do you need to follow it, and what are the benefits of doing so?

Detailing FedRAMP

As mentioned above, FedRAMP is the Federal Risk and Authorization Management Program. It’s meant to be a standardized way to handle security authorization, assessment, and continuous monitoring for cloud-based software and services. The goal of the system is to provide a comprehensive set of security controls to monitor and enforce to validate business processes, secure data, and guarantee security.

Anyone who operates a cloud service – a cloud service provider or CSP – can make use of FedRAMP’s framework. It’s a way to codify, simplify, and standardize security in a way that lives up to widely agreed-upon minimum standards. “Good enough for government work” in this case isn’t innuendo. The federal government takes information security seriously, so these standards at least are certain to be viable.

FedRAMP is rules by a variety of governance bodies and organizations that provide assurance, validation, and oversight to both FedRAMP standards as a whole, and to CSPs looking to adhere to FedRAMP standards. These bodies include:

• The FedRAMP program management office, or PMO. This is the office that provides overall oversight and governance for the FedRAMP program.
• The Joint Authorization Board, or JAB. For cloud service providers of a moderate or high impact level (learn more about FedRAMP impact levels here), the JAB is responsible for issuing the Authority to Operate or Provisional Authority to Operate (ATO or P-ATO respectively). They review and approve policies and procedures, as well as review guidance for the program from the PMO.
• Third-Party Assessment Organizations. Certified 3PAOs, as they are called, are organizations like ourselves who are accredited and authorized by the JAB to provide independent, third-party assessments and auditing of cloud service providers, to make sure they’re meeting FedRAMP standards.
• The FedRAMP Oversight Management Council, or FOMC. This is the group responsible for providing guidance for the overall program and assurance of the success of the enforcement.
• The FedRAMP Security Monitoring Working Group. Technology and information security change rapidly, and large institutions like NIST and the government as a whole can’t adapt rapidly enough to those changes. Issuing new versions of FedRAMP standards every few months – and consequently changing the rules for thousands of CSPs practically before they’ve adapted to the previous change – is unsustainable. The SMWG provides interim and ongoing best practices, support, and advice for FedRAMP adherents in between major revisions of the FedRAMP and NIST standards.

These groups all work together to guide and govern FedRAMP as an ongoing, evolving and maintained set of standards for the security and operation of cloud service providers.

What Are the Benefits of Pursuing FedRAMP Compliance?

Or, more specifically, why should you consider pursuing FedRAMP compliance over other security standards, like ISO standards, general NIST standards, or another framework?

• It’s a high level of trust and oversight. FedRAMP is one of the most important general-use security standards within the federal government. That means the standards are high and comprehensive, and that it’s reviewed and updated on a regular basis to be as applicable as possible to new and emerging technologies.
• Obtaining FedRAMP certification is a badge of honor showing your CSP’s dedication to protecting confidential information. If you’re bold enough to commit to government-controlled information standards, you’re certainly good enough for less controlled and regulated information.
• FedRAMP, being a widely-used standard, has a variety of tools and services that have been created to help a business meet, monitor, and certify FedRAMP standards. These can range from government-created tools to scripts and spreadsheets to dedicated systems like Ignyte.
• FedRAMP is also a common security framework for high-level CSPs, which means there are many talented individuals with experience in the framework and who can help with advice or as consultants to help you achieve compliance.

As a private sector cloud service provider, even if you don’t want to pursue a government contract, meeting the FedRAMP standards is a good idea for a baseline level of security that is acknowledged, verified, and reputable. Plus, if you then choose to pursue a government contract, you’ve already done most of the work.

Make no mistake; obtaining FedRAMP compliance is not easy. Thousands of businesses have done it, of course, but it’s usually a lengthy process full of auditing, comprehensive business process documentation, systems controls, more auditing, process implementation, training, validation, monitoring, and even more auditing. Many businesses need to spin up dedicated teams of employees specifically to take both control of and responsibility for the security and systems necessary to adhere to FedRAMP standards.

Does Your CSP Need FedRAMP Authorization?

The answer depends.

If you’re a cloud service provider and you intend to work with the federal government on a contract, or with one of the federal government’s many agencies, or as part of the supply lines for the federal government, then you will very likely need to adhere to FedRAMP standards.

It’s also possible, depending on your impact level, the kinds of information you’re handling, and the agency you’re working with, that you may have to adhere to even higher standards or additional standards. For example, if you’re a cloud service provider operating in the healthcare space and handling patient information, you will generally need to adhere to HIPAA standards. If you’re looking to serve as a cloud platform working with a government agency that handles defense information, you will likely need to adhere to ITAR, the International Traffic in Arms Regulation. These are usually in addition to, and have some overlap with, FedRAMP standards.

What if, on the other hand, you have no current interest in working with the federal government or its agencies?

Well, there are other situations where you may be required to adhere to FedRAMP standards. In particular, if your clients are themselves working with federal agencies, they may need to ensure that the applications they use adhere to FedRAMP standards; your choice is to lose them as a client or adhere to those standards to be on the approved list of services. Or, maybe, you want to work with a state government. State governments don’t have the same security governance, but as elements of the government overall, working with them usually means adhering to greater standards.

If you don’t meet any of those situations, you likely don’t need to adhere to FedRAMP standards. However, there are still two significant reasons why you might want to, regardless.

The first is if you later decide you want to accept a government contract or even work with multiple agencies on multiple contracts. As a generalist CSP, being able to provide services to a variety of government agencies has the potential to be extremely lucrative and, more importantly, stable.

The second reason is simply that FedRAMP security standards are an excellent baseline to reach and maintain. They ensure that you’re taking security and proper handling of user information seriously, and that rigorous data controls are enforced throughout your organization. Even in the absence of governmental pressure, this is protection against third-party intrusion, monitoring that ensures you’re aware of attempts and unauthorized access, and that you’re evolving as technology evolves.

What is the Process to Become FedRAMP Authorized?

FedRAMP authorization begins when you, as the CSP, develop and submit a system security plan to the PMO. This plan is a document that identifies all of the features and functions of your business and processes, ranging from your hardware to your software to the ways you handle data and beyond. The SSP also identifies which elements of your system are governed by which security controls from the NIST documentation on the matter. Analyzing your entire business and all business processes from top to bottom and categorizing them according to NIST security controls is a long and arduous process, so while this is the “first step,” it can also be considered one of the most significant in the whole process.

If your SSP is approved by the PMO, they will assign you a designated 3PAO to audit your systems. You will work with the 3PAO to evaluate your systems according to those security controls and their processes. In the event that you fail part of the audit, you will likely have to take swift action to improve and try again or be denied your authority to operate.

In some cases, minor security controls can be delayed in implementation so long as you have a POAM, or Plan of Action and Milestones roadmap, which outlines that you know there’s an issue and you have a plan to fix it with specific steps, milestones, and individuals responsible for it. You can learn more about POAMs here.

Once you pass your audits, the 3PAO goes back to the PMO and delivers their report. The PMO can then issue you the authority to operate. At this point, you need to establish continuous monitoring, which ensures not just that your security controls are active but that they are continuously active and kept up to date. If ConMon fails, you have a whole new set of issues to contend with.

Is FedRAMP Authorization Worth Pursuing?

While the FedRAMP authorization process is long and difficult, it’s worth doing for the peace of mind both your business and your clients feel when using a service that has verified security. We live in a world where data breaches are common and growing, and the financial impact can be devastating for businesses and customers alike.

In fact, as you can see from editorials like this one, many people intentionally seek out FedRAMP authorized cloud providers for their services even when they aren’t governmental agencies or part of the governmental supply lines. Why? Specifically because they’re aware that FedRAMP is a high standard and that any CSP that is willing to go through the work to adhere to it is one that can be trusted to take security seriously.

That said, there are other security standards you can pursue and adhere to that are at least equivalent to FedRAMP without having to jump through all of the same hoops with governmental auditing, 3PAOs, documentation, and more. Perhaps the largest reason that private sector cloud service providers don’t pursue FedRAMP authorization if they don’t have to is that the requirements to receive it are harder when the security you achieve can be achieved in other, less difficult ways.

As a cloud service provider, you need to choose between FedRAMP, a different security standard, and a more free-form approach to security. However, we always recommend something like FedRAMP. The benefits are significant, and the drawbacks are mostly front-loaded; once you’ve jumped through the hoops once, it’s much easier to handle them again later unless you let security slip in the meantime.

Fortunately, there are many resources at your disposal that can help. In addition to the government’s own guidance on how to implement FedRAMP security controls, you can make use of systems like the Ignyte Platform. We developed Ignyte as a platform to eliminate the need to keep track of all of your security controls and information in siloed software like office spreadsheets and make it both centralized and easily accessible to everyone in your organization who needs it. You can count on us, both because we’ve designed our system from the ground up to help businesses adhere to security frameworks like FedRAMP, CMMC, HITRUST, HIPPA, and others and because as a certified 3PAO, we know both what it’s like to go through the authorization process and what goes into an audit.

If you’re interested in seeing what Ignyte can do for you, all you need to do is book a demo today. Alternatively, you can browse our features and frameworks or reach out to us with any questions you may have. We look forward to working with you!

*** This is a Security Bloggers Network syndicated blog from Ignyte authored by Max Aulakh. Read the original post at: https://www.ignyteplatform.com/blog/fedramp/fedramp-for-private-sector/