Understanding the NIST RMF: Breaking down the 7 key steps

The NIST Risk Management Framework (NIST RMF) is a flexible framework that can be tailored to your specific organizational profile and regulatory requirements. It offers a comprehensive approach for managing cybersecurity and operational risks to protect the security and privacy of systems and information. Let’s explore what the framework is all about and how your organization can adopt the 7 steps within the NIST RMF and establish a robust risk management process.

What is the purpose of NIST RMF?

Published by the National Institute of Standards and Technology, a US government agency, the NIST RMF was developed to guide government organizations in safeguarding the confidentiality, integrity, and availability of federal information. It provides a structured, repeatable process for developing and maintaining systems for managing information security risks, outlining 7 steps which include:

1. Prepare different components of the organization and its information system for risk management
2. Categorize the information system based on an impact analysis
3. Select relevant controls from NIST SP 800-53 to protect the system from risks identified during risk assessment
4. Implement and document the performance of the controls
5. Assess whether the controls are appropriate, adequate, and effective
6. Authorize the operation of the system upon verification from a senior official that it is working to maintain risks at an acceptable level
7. Monitor the controls as well as the risks to the system continuously

The NIST Special Publication 800-53 (SP 800-53) – which contains a collection of controls such as access control, cryptographic protection, and more – is used in conjunction with the NIST RMF. While NIST SP 800-53 provides the security and privacy controls that organizations can use to protect their information systems from diverse risks, NIST RMF specifies how these controls must be implemented and establishes a broader framework for managing risks in the long term.

For government departments and agencies, as well as suppliers and service providers handling federal information, adhering to the guidelines and procedures in the NIST RMF is mandatory in compliance with requirements from federal regulations such as the Federal Information Security Modernization Act (FISMA). However, other organizations can voluntarily implement the NIST RMF to effectively safeguard their data and operations against significant threats.

Implementing NIST RMF in 7 steps

With high-level and measurable steps applicable to any technology system, organizations can easily integrate the NIST RMF into their existing workflows or security programs. Follow these steps to incorporate a risk-based approach into your security strategy and implementation:

1. Prepare

The first step in the NIST RMF requires preparing all aspects of your business for organization-wide risk management. The framework highlights 5 essential tasks at the organizational level during this phase:

1. Roles and responsibilities: The organization must assign roles and responsibilities to key personnel who will oversee and execute the risk management framework. This includes Chief Information Security Officers (CISOs), risk and compliance managers, and more.
2. Risk management strategy: Determine risk tolerance or the level of risk the organization deems acceptable. Then, based on this metric, define strategies, policies, and procedures for analyzing, prioritizing, addressing, and monitoring information security risks.
3. Risk assessment: Perform a risk assessment for the organization based on risk assessment results for your information system, taking into account risks arising from internal tools and processes and external systems and providers.
4. Control identification: Identify and document common controls from NIST SP 800-53 and within your organization’s current information system.
5. Continuous monitoring strategy: Develop and put in place mechanisms for monitoring risks and control effectiveness at the organizational level.

Meanwhile, at the system level, this step also delineates tasks such as:

• Identifying stakeholders and requirements for the information system as well as its mission or business focus and authorization boundary
• Performing asset identification and identifying the stages of the information lifecycle including the different information types processed, stored, and transmitted by the system
• Conducting a risk assessment for the system
• Defining the system’s placement within the enterprise architecture
• Allocation of the requirements across the system
• Registration of the system

6clicks can help you easily get started by providing you with a single technology solution with complete functionality for risk management, control management, asset management, and more. You can utilize our powerful risk registers to perform comprehensive risk assessments for your organization and information system and standardize processes and workflows for risk management.

2. Categorize

Next, the Categorize step provides more details about your information system through the following tasks:

• System description: Describe and document the features and functionalities of the system. This could include relevant information such as the system name and identifier, location, manufacturer details, and its purpose. The description should correspond with the security categorization and risk assessment for the system.

• Security categorization: This involves conducting an impact analysis to evaluate the potential impact of information security risks on the system. The NIST RMF specifies companion documents, FIPS 200 and CNSSI 1253, which organizations can use to assign system impact levels based on security objectives such as confidentiality, availability, and integrity.

• Review and approval: If the information system processes personally identifiable information (PII), an authorizing official must review the results and approve the security categorization to ensure that it aligns with the organization’s risk management objectives.

3. Select

Now, the next step in the NIST RMF entails various processes dedicated to configuring the controls you will deploy to manage risks to your information system. These include:

• Control selection: Organizations can select controls for implementation by using control baselines or a pre-defined set of controls such as those in NIST SP 800-53.

• Control tailoring: After selection, the organization can proceed to customize the controls according to established system requirements, risk tolerance, and other factors. This involves grouping common controls, selecting alternative controls, and providing instructions for control implementation.

• Control allocation: Controls must then be designated as human, technical, or hybrid elements and then allocated to specific components of the system, ensuring they are consistent with the organization’s enterprise architecture and security requirements.

Control selection, designation, and allocation must be documented and then reviewed and approved by an authorizing official. The Select step also includes establishing a continuous monitoring strategy for controls at the system level. Breeze through this step with 6clicks’ Controls module that enables you to seamlessly set up, organize, and manage your controls. Then, monitor controls automatically using the Continuous Control Monitoring feature which provides automated control testing and real-time security alerts.

4. Implement

The Implement step revolves around the process of implementing controls and updating supporting documentation in case of changes. The organization must implement the controls as instructed within the implementation plan and ensure that mandatory configurations in accordance with federal requirements are implemented. The NIST RMF also recommends adopting best practices for control implementation, such as systems security engineering principles. Any deviations from the implementation plan – which can include changes to required inputs, expected behavior, and expected outputs – must be documented, and existing documentation must be updated with “as-implemented” control details and descriptions.

5. Assess

Evaluating whether controls are implemented correctly, operating as intended, and producing the right outcomes is crucial to ensuring optimal control implementation. The Assess step in the NIST RMF encompasses the following activities:

1. Assessor selection: The organization can seek an independent assessor or form its own assessment team and conduct self-assessments for its controls.
2. Assessment plan: Formulate assessment plans based on control documentation, outlining specific assessment objectives and procedures. This assessment plan then needs to be reviewed and approved by the authorizing official.
3. Control assessments: Perform control assessments to verify control effectiveness and identify any issues. The organization can leverage automated solutions to streamline and expedite the assessment process.
4. Assessment reports: Results of the control assessment including recommendations for remediation must be documented in assessment reports.
5. Remediation actions: Based on assessment findings, the organization can perform initial remediation actions for control inadequacies that can be easily resolved. Upon implementing corrective measures, the assessment team must reassess the controls and update the assessment reports.
6. Plan of action: Aside from initial remediation, the organization needs to develop a plan of action outlining specific tasks and milestones for addressing control issues that present significant and unacceptable risks.

Control implementation changes brought about by assessments and remediation actions must also be included in existing documentation. For this step, you can leverage 6clicks’ integrated Audit & Assessment capability to accelerate assessments using requirement-based assessment templates and AI-powered automation through Hailey, 6clicks’ AI engine, which can generate assessment responses based on previous data.

6. Authorize

To finalize the deployment of controls and the operation of your information system, an authorization process will be conducted. During the Authorize step, the organization needs to prepare an authorization package, which includes all system and control documentation, control assessment reports, plans of action, and an executive summary. This authorization package will be reviewed by the authorizing official to verify compliance with federal requirements, initiating the following steps:

• Risk analysis & determination: The authorizing official will analyze and determine the level of risk in the system.

• Risk response: Based on the authorizing official’s risk analysis and determination, the organization must respond to the risk either by accepting it or mitigating it. For the latter, mitigation initiatives must be carried out and included in the plan of action.

• Authorization decision: After executing risk response actions, the authorizing official will conduct another review and issue a decision on whether or not the risk is acceptable, after which the use of the controls and the operation of the information system will either be authorized or unauthorized.

A report of the authorization decision will also be submitted by the authorizing official to the organization so leaders can understand the risk decision in the context of the broader organization.

7. Monitor

Finally, the last step of the NIST RMF necessitates consistent surveillance of the information system and its environment according to the continuous monitoring strategy set by the organization. This involves maintaining ongoing control assessments and risk response and continuously updating system and control documentation to address any changes, vulnerabilities, or non-conformities identified during continuous monitoring activities. The organization must also establish a reporting process for communicating the security posture of the system to authorizing officials for ongoing authorization.

Overall, the NIST RMF provides a reliable methodology for rigorous security implementation and proactive risk management.

Effortlessly align with NIST RMF through 6clicks

Establish a strong risk management strategy and easily fulfill the steps of NIST RMF with the 6clicks platform.