Control Assessments

Independent assessors or assessment teams are individuals or groups who conduct impartial assessments of systems. Impartiality means that assessors are free from any perceived or actual conflicts of interest regarding the development, operation, sustainment, or management of the systems under assessment or the determination of control effectiveness. To achieve impartiality, assessors do not create a mutual or conflicting interest with the organizations where the assessments are being conducted, assess their own work, act as management or employees of the organizations they are serving, or place themselves in positions of advocacy for the organizations acquiring their services. Independent assessments can be obtained from elements within organizations or be contracted to public or private sector entities outside of organizations. Authorizing officials determine the required level of independence based on the security categories of systems and/or the risk to organizational operations, organizational assets, or individuals. Authorizing officials also determine if the level of assessor independence provides sufficient assurance that the results are sound and can be used to make credible, risk-based decisions. Assessor independence determination includes whether contracted assessment services have sufficient independence, such as when system owners are not directly involved in contracting processes or cannot influence the impartiality of the assessors conducting the assessments. During the system design and development phase, having independent assessors is analogous to having independent SMEs involved in design reviews. When organizations that own the systems are small or the structures of the organizations require that assessments be conducted by individuals that are in the developmental, operational, or management chain of the system owners, independence in assessment processes can be achieved by ensuring that assessment results are carefully reviewed and analyzed by independent teams of experts to validate the completeness, accuracy, integrity, and reliability of the results. Assessments performed for purposes other than to support authorization decisions are more likely to be useable for such decisions when performed by assessors with sufficient independence, thereby reducing the need to repeat assessments.

Organizations can conduct specialized assessments, including verification and validation, system monitoring, insider threat assessments, malicious user testing, and other forms of testing. These assessments can improve readiness by exercising organizational capabilities and indicating current levels of performance as a means of focusing actions to improve security and privacy. Organizations conduct specialized assessments in accordance with applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Authorizing officials approve the assessment methods in coordination with the organizational risk executive function. Organizations can include vulnerabilities uncovered during assessments into vulnerability remediation processes. Specialized assessments can also be conducted early in the system development life cycle (e.g., during initial design, development, and unit testing).

Organizations may rely on control assessments of organizational systems by other (external) organizations. Using such assessments and reusing existing assessment evidence can decrease the time and resources required for assessments by limiting the independent assessment activities that organizations need to perform. The factors that organizations consider in determining whether to accept assessment results from external organizations can vary. Such factors include the organization’s past experience with the organization that conducted the assessment, the reputation of the assessment organization, the level of detail of supporting assessment evidence provided, and mandates imposed by applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Accredited testing laboratories that support the Common Criteria Program ISO 15408-1 , the NIST Cryptographic Module Validation Program (CMVP), or the NIST Cryptographic Algorithm Validation Program (CAVP) can provide independent assessment results that organizations can leverage.