Risk Management Framework (RMF)
What is the NIST Risk Management Framework?
The NIST Risk Management Framework (RMF) is a federal guideline for organizations to assess and manage risks to their computers and information systems. This framework was established by the National Institute of Science and Technology to ensure the security of defense and intelligence networks. Federal agencies are required to comply with the risk management framework, but private companies and other organizations may also benefit from following its guidelines. The Risk Management Framework (RMF), provides a disciplined and structured process that integrates information security and risk management activities into the system development life cycle.
RMF is a set of criteria that dictate how United States government IT systems must be architected, secured, and monitored. Originally developed by the Department of Defense (DoD), the RMF was adopted by the rest of the US federal information systems in 2010. The RMF is maintained by the National Institute of Standards and Technology (NIST) and provides a solid foundation for any data security strategy. The RMF builds on several previous risk management frameworks and includes several independent processes and systems. It requires that firms implement secure data governance systems and perform threat modeling to identify cyber risk areas.
The general concept of “risk management” and the “risk management framework” might appear to be quite similar, but it is important to understand the distinction between the two. The risk management process is specifically detailed by NIST in several subsidiary frameworks.
The most important is the elegantly titled “NIST SP 800-37 Rev.1”, which defines the RMF as a 6-step process to architect and engineer a data security process for new IT systems, and suggests best practices and procedures each federal agency must follow when enabling a new system.
In addition to the primary document SP 800-37, the RMF uses supplemental documents SP 800-30, SP 800-53, SP 800-53A, and SP 800-137:
- NIST SP 800-30, entitled Guide for Conducting Risk Assessments, provides an overview of how risk management fits into the system development life cycle (SDLC) and describes how to conduct risk assessments and mitigate risks.
- NIST SP 800-37 discusses the risk management framework itself and contains much of the information we’ll cover in the remainder of this guide.
- Finally, NIST SP 800-39, titled Managing Information Security Risk, defines the multi-tiered, organization-wide approach to risk management crucial for reaching compliance with the RMF.
The Risk Management Framework places standards across the government by aligning controls and language and improving reciprocity. It allows a focus on risk to address the diversity of components, systems, and custom environments as opposed to using a one-size-fits-all solution. It builds security into systems and helps address security concerns faster.
Components of the Risk Management Framework (RMF)
There are five components that make up the RMF. These components include the following:
- Identification: The first component in implementing the Risk Management Framework is to identify the risks that the organization faces. These might include strategic, legal, operational, and privacy risks. It is important to note that risk identification is not a one-time process. The risks that an organization faces tend to change over time, so risk assessments will need to be performed on a periodic basis.
- Measurement and assessment: The goal behind the measurement and assessment component is to create a risk profile for each risk that has been identified. There are a number of different ways that organizations might complete the measurement and assessment phase of the process. In some cases, risk measurement might be based on something as simple as how much capital could potentially be lost as a result of the risk. However, in other cases, measuring the potential impact of a risk might be far more difficult. In the field of information security, for example, an organization might attempt to quantify the cost of a security breach compared with the cost of implementing a security mechanism that can help to mitigate the risk.
- Mitigation: The third component in the framework is risk mitigation. Risk mitigation involves examining the risks that have been identified and determining which risks can and should be eliminated, as opposed to the risks that are deemed to be acceptable. Part of this process involves coming up with mitigation strategies, such as cyber insurance. For example, if an organization identifies cybersecurity risks that need to be dealt with, then it may choose to integrate security controls into its development lifecycle. Such an organization would likely also put additional baseline security controls in place.
- Reporting and monitoring: The fourth component in the process is risk reporting and monitoring. This essentially means regularly reexamining the risks in order to make sure that the risk mitigation strategies the organization has adopted are having the desired effect.
- Governance: The last component in the process is risk governance. Risk governance is the process of making sure that the risk mitigation techniques that have been adopted are put into place and that the employees adhere to those policies.
Risk Management Framework (RMF) Steps
The risk-based approach to security control selection and specification considers effectiveness, efficiency, and constraints due to applicable laws, directives, Executive Orders, policies, standards, or regulations. The following activities related to managing organizational risk (also known as the Risk Management Framework) are paramount to an effective information security program and can be applied to both new and legacy information systems within the context of the system development life cycle and the Federal Enterprise Architecture:
- Step 1: Categorize: Categorize the information system and the information processed, stored, and transmitted by that system based on impact analysis.
- Step 2: Select: Select an initial set of baseline security controls for the information system based on the security categorization; tailoring and supplementing the security control baseline as needed based on the organization's assessment of risk and local conditions.
- Step 3: Implement: Implement the security controls and document how the controls are deployed within the information system and environment of operation.
- Step 4: Assess: Assess the security controls using appropriate procedures to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for the system.
- Step 5: Authorize: Authorize information system operation based upon a determination of the risk to organizational operations and assets, individuals, other organizations, and the Nation resulting from the operation of the information system and the decision that this risk is acceptable.
- Step 6: Monitor: Monitor and assess selected security controls in the information system on an ongoing basis including assessing security control effectiveness, documenting changes to the system or environment of operation, conducting security impact analyses of the associated changes, and reporting the security state of the system to appropriate organizational officials
History of the RMF
The E-Government Act of 2002 (Public Law 107-347) entitled FISMA 2002 (Federal Information Security Management Act) was a law passed in 2002 to protect the economic and national security interests of the United States related to information security.
Congress later passed FISMA 2014 (Federal Information Security Modernization Act) to provide improvements over FISMA 2002 by:
- Codifying Department of Homeland Security (DHS) authority to administer the implementation of information security policies for non-national security federal Executive Branch systems, including providing technical assistance and deploying technologies to such systems;
- Amending and clarifying the Office of Management and Budget's (OMB) oversight authority over federal agency information security practices; and by
- Requiring OMB to amend or revise OMB A-130 to "eliminate inefficient and wasteful reporting."
FISMA required the protection of information and information systems from unauthorized access, use, disclosure, disruption, modification, or destruction in order to provide Confidentiality, Integrity, and Availability. Title III of FISMA 2002 tasked NIST with responsibilities for standards and guidelines, including the development of:
- Standards are to be used by all federal agencies to categorize all information and information systems collected or maintained by or on behalf of each agency based on the objectives of providing appropriate levels of information security according to a range of risk levels. This task was satisfied by FIPS Publication 199;
- Guidelines recommend the types of information and information systems to be included in each category. This task was satisfied by NIST Special Publication 800-60, Volumes 1 and 2; and
- Minimum information security requirements (i.e., management, operational, and technical controls), for information and information systems in each such category. This task was satisfied by the development of FIPS Publication 200.
NIST 800-37 (Risk Management Framework or RMF) was developed to help organizations manage security and privacy risk and to satisfy the requirements of the Federal Information Security Modernization Act of 2014 (FISMA), the Privacy Act of 1974, OMB policies, and Federal Information Processing Standards, among other laws, regulations, and policies.