CM-3 (04)—Configuration Change Control | Security and Privacy Representatives
>Control Description
>FedRAMP Baseline Requirements
No FedRAMP-specific parameter values or requirements for this baseline.
>Discussion
Information security and privacy representatives include system security officers, senior agency information security officers, senior agency officials for privacy, or system privacy officers. Representation by personnel with information security and privacy expertise is important because changes to system configurations can have unintended side effects, some of which may be security- or privacy-relevant. Detecting such changes early in the process can help avoid unintended, negative consequences that could ultimately affect the security and privacy posture of systems.
The configuration change control element referred to in the second organization-defined parameter reflects the change control elements defined by organizations in CM-3g.
>Assessment Interview Topics
Questions assessors commonly ask
Process & Governance:
- •What formal policies and procedures govern the implementation of CM-3(4) (Security And Privacy Representatives)?
- •Who are the designated roles responsible for implementing, maintaining, and monitoring CM-3(4)?
- •How frequently is the CM-3(4) policy reviewed and updated, and what triggers policy changes?
- •What training or awareness programs ensure personnel understand their responsibilities related to CM-3(4)?
Technical Implementation:
- •Describe the specific technical mechanisms or controls used to enforce CM-3(4) requirements.
- •What automated tools, systems, or technologies are deployed to implement CM-3(4)?
- •How is CM-3(4) integrated into your system architecture and overall security posture?
- •What configuration settings, parameters, or technical specifications enforce CM-3(4) requirements?
Evidence & Documentation:
- •What documentation demonstrates the complete implementation of CM-3(4)?
- •What audit logs, records, reports, or monitoring data validate CM-3(4) compliance?
- •Can you provide evidence of periodic reviews, assessments, or testing of CM-3(4) effectiveness?
- •What artifacts would you present during a FedRAMP assessment to demonstrate CM-3(4) compliance?
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