SCRM Plans and You: FedRAMP Rev.5, SR-2
Introduction
SCRM, or Supply Chain Risk Management, has become a crucial aspect of modern cybersecurity, particularly as organizations rely on complex supply chains to deliver products and services to customers. However, the risks associated with third-party vendors can be significant, ranging from data breaches and cyber-attacks to natural disasters and other disruptions.
And so, to address these risks organizations need to develop and implement effective SCRM plans. These plans should be comprehensive, flexible, and able to address a wide range of potential risks.
An SCRM plan typically includes the following key components:
- Identification and documentation of all third-party vendors involved in the supply chain
- Assessment of risks associated with each vendor, including the potential impact of a security incident
- Development and implementation of mitigation strategies to address identified risks, including regular monitoring and assessments of vendor security posture
- Ensuring that all vendors comply with the organization's security policies and procedures
These components align with best practices for SCRM planning, such as those outlined in FedRAMP, and can help organizations create effective and comprehensive SCRM plans.
FedRAMP Rev. 5 Control SR-2
FedRAMP rev. 5 provides a set of security controls that cloud service providers must adhere to by law, including control SR-2.
SR-2, and thus a SCRM plan, is required throughout all baselines of FedRAMP from Li-SaaS to High.
FedRAMP control SR-2, Supply Chain Risk Management Plan states:
a. Develop a plan for managing supply chain risks associated with the research and development, design, manufacturing, acquisition, delivery, integration, operations and maintenance, and disposal of the following systems, system components or system services: [Assignment: organization-defined systems, system components, or system services];
b. Review and update the supply chain risk management plan [Assignment: organization-defined frequency] or as required, to address threat, organizational or environmental changes; and
c. Protect the supply chain risk management plan from unauthorized disclosure and modification.
How to Comply with SR-2
Meeting the requirements of FedRAMP control SR-2 can be challenging, particularly for organizations with complex supply chains. However, it is critical to meet these requirements to reduce the risk of security incidents, business disruptions, and maintain customer trust and confidence.
Organizations can take several steps to ensure that they meet the requirements of FedRAMP control SR-2 when developing their SCRM plans.
Developing a SCRM plan typically involves these steps:
- Conducting a thorough inventory of all third-party vendors involved in the supply chain
- Assessing the security posture of each vendor using tools such as questionnaires and assessments
- Developing and implementing a risk management framework that includes processes for identifying, assessing, and mitigating risks associated with third-party vendors
- Regularly monitoring the security posture of all vendors in the supply chain
- Establishing a clear process for vendors to report security incidents promptly and transparently
By following these steps, organizations can develop comprehensive and effective SCRM plans that meet the requirements of FedRAMP control SR-2. Doing so reduces the risk of security incidents, minimizes business disruptions, as well as maintains customer trust and confidence.
Conclusion
In conclusion, SCRM planning is a critical component of modern cybersecurity, particularly for organizations with complex supply chains. Developing and implementing an effective SCRM plan requires a coordinated effort across the organization and adherence to industry standards like FedRAMP or StateRAMP.
By following best practices and meeting regulatory requirements, organizations can mitigate supply chain risks and enhance their overall cybersecurity posture.
Let us know if InfusionPoints can help with your SCRM planning needs, or any other FedRAMP challenges you may have!
Sources:
SR-2: Supply Chain Risk Management Plan - CSF Tools
Cybersecurity Supply Chain Risk Management | CSRC (nist.gov)
Guide to Supply Chain Risk Management Planning — Reciprocity
