NIST Risk Management Framework compliance with RecordPoint
The National Institute of Standards and Technology Risk Management Framework (NIST RMF) is a guidance document for federal agencies in the United States and contractors that work with the federal government. It defines a risk management process that blends security, privacy, and information systems controls into a unified workflow to manage risk.
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What is the NIST Risk Management Framework?
The RMF was first published in 2010, and designed to help organizations comply with the Federal Information Security Modernization Act of 2014 (a revision of the 2002 version), the Privacy Act of 1974, and Federal Information Processing Standards, among others.
The RMF is designed to be technology neutral. It makes no judgment on which technology solutions are best to reduce risk; rather, it is meant to be used as part of a comprehensive approach to identifying and mitigating risks in information systems. This is a vital process, especially with threats becoming more pervasive in the cybersecurity landscape. The RMF includes a few different components for organizations to pay attention to with regards to compliance.
NIST RMF components:
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Compliance with the NIST RMF
Government contractors and U.S. federal agencies are the ones who must comply with the NIST RMF. For other organizations, the framework is voluntary. Regardless, to comply with the framework, companies must follow a few key steps:
Categorize the system
To start, companies need to classify the system to be evaluated for risk. This involves categorizing the system's associated information assets based on their sensitivity and the potential impact on the organization. In practice, companies need to analyze data sensitivity and assess the potential impact on confidentiality, integrity, and availability, and ultimately assign security categories.
Select the controls
The next step is for organizations to choose and adapt their security controls based on the system's categorization and specific needs. In this step, reference NIST SP 800-37 to select appropriate security controls and then customize them to align with any of the system’s unique characteristics and operational environment.
Implement the controls
The chosen security controls need to be implemented within the system. This means that organizations need to create detailed security plans that include how each control will be implemented, as well as monitored and managed. After that, teams then integrate the controls into the information system's design and operations.
Assess controls
Security assessments need to be conducted on a regular basis to make sure that any implemented controls are effective. Organizations need to develop a Security Assessment Plan (SAP) that defines the objectives, methods, and scope of the assessment. This plan can ensure teams can efficiently evaluate the effectiveness of controls.
Storage Authorize the system
After the assessment is completed, organizations need to review their findings and decide whether to adopt the policies or not. This then leads to authorizing the system, and enables teams to fine-tune any aspects of the system that don't suit the business. Reviewing findings is critical to ensure that the system is secure overall.
Monitor the controls
Lastly, organizations need a continuous monitoring plan that includes regular security assessments, vulnerability scanning, and incident response along with detection and response capabilities and other security monitoring tools. Prompt reporting of security incidents, vulnerabilities, and compliance deviations is paramount for continuous compliance. Organizations also need to take regular corrective actions to maintain compliance.
Penalties for noncompliance
The NIST RMF is mandated for U.S. federal agencies and the contractors who work with federal agencies. As a result, violations of the RMF are adjudicated under the False Claims Act. From February 2024, the penalties for making a false claim to the US Government range from $13,946 to $27,894 per violation. It isn't uncommon for an organization to face hundreds — or even thousands — of violations in a single DOJ action.
Frequently asked questions
No. The NIST Risk Management Framework is designed as a collection of best practices that companies can choose to use as part of constructing their risk management program. NIST is a government agency, but has no power to compel private industry to follow its guidance.
There are seven steps included in the NIST RMF: Prepare, Categorize, Select, Implement, Assess, Authorize, and Monitor. These steps are designed to assist companies in developing a risk management program that can apply to new as well as legacy systems.
The NIST Risk Management Framework is useful for any organization of any size. It provides a process that integrates security, privacy, and cyber supply chain risk management activities into the system development life cycle. The RMF is valuable for organizations of any size and industry.
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