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CA-7(5)Continuous Monitoring | Consistency Analysis

IL5
IL6

>Control Description

Employ the following actions to validate that policies are established and implemented controls are operating in a consistent manner: organization-defined actions.

>DoD Impact Level Requirements

No specific parameter values or requirements for this impact level.

>Discussion

Security and privacy controls are often added incrementally to a system. As a result, policies for selecting and implementing controls may be inconsistent, and the controls could fail to work together in a consistent or coordinated manner. At a minimum, the lack of consistency and coordination could mean that there are unacceptable security and privacy gaps in the system.

At worst, it could mean that some of the controls implemented in one location or by one component are actually impeding the functionality of other controls (e.g., encrypting internal network traffic can impede monitoring). In other situations, failing to consistently monitor all implemented network protocols (e.g., a dual stack of IPv4 and IPv6) may create unintended vulnerabilities in the system that could be exploited by adversaries. It is important to validate--through testing, monitoring, and analysis--that the implemented controls are operating in a consistent, coordinated, non-interfering manner.

>Assessment Interview Topics

Questions assessors commonly ask

Process & Governance:

  • What formal policies and procedures govern the implementation of CA-7(5) (Consistency Analysis)?
  • Who are the designated roles responsible for implementing, maintaining, and monitoring CA-7(5)?
  • How frequently is the CA-7(5) policy reviewed and updated, and what triggers policy changes?
  • What training or awareness programs ensure personnel understand their responsibilities related to CA-7(5)?

Technical Implementation:

  • Describe the specific technical mechanisms or controls used to enforce CA-7(5) requirements.
  • What automated tools, systems, or technologies are deployed to implement CA-7(5)?
  • How is CA-7(5) integrated into your system architecture and overall security posture?
  • What configuration settings, parameters, or technical specifications enforce CA-7(5) requirements?

Evidence & Documentation:

  • What documentation demonstrates the complete implementation of CA-7(5)?
  • What audit logs, records, reports, or monitoring data validate CA-7(5) compliance?
  • Can you provide evidence of periodic reviews, assessments, or testing of CA-7(5) effectiveness?
  • What artifacts would you present during a FedRAMP assessment to demonstrate CA-7(5) compliance?

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