Security Control Monitoring
Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls.
What an assessor scores, the objectives
CA.L2-3.12.3 is met only when every one of these 1 objectives, from NIST SP 800-171A, is satisfied. A single missed objective makes the whole requirement not met.
- a.security controls are monitored on an ongoing basis to ensure the continued effectiveness of those controls
How a C3PAO checks it
NIST SP 800-171A defines three assessment methods. For CA.L2-3.12.3, an assessor uses these:
Security planning policy; organizational procedures addressing system security plan development and implementation; procedures addressing system security plan reviews and updates; enterprise architecture documentation; system security plan; records of system security plan reviews and updates; other relevant documents or records
Personnel with security planning and system security plan implementation responsibilities; personnel with information security responsibilities
Organizational processes for system security plan development, review, update, and approval; mechanisms supporting the system security plan
What it means, in context
Continuous monitoring programs facilitate ongoing awareness of threats, vulnerabilities, and information security to support organizational risk management decisions . The terms continuous and ongoing imply that organizations assess and analyze security controls and information security-related risks at a frequency sufficient to support risk -based decisions. The results of continuous monitoring programs generate appropriate risk response actions by organizations . Providing access to security information on a continuing basis through reports or dashboards gives organizational officials the capability to make effective and timely risk management decisions . Automation supports more frequent updates to hardware, software, firmware inventories, and other system information. Effectiveness is further enhanced when continuous monitoring outputs are formatted to provide information that is specific, measurable, actionable, relevant, and timely . Monitoring requirements, including the need for specific monitoring, may also be referenced in other requirements. NIST SP 800-137 provides guidance on continuous monitoring.
Provide a plan for monitoring the state of security controls on a recurring basis that occurs more frequently than the periodic assessments discussed in CA.L2 -3.12.1. This process provides a mechanism to assess the overall security posture of your organization, which directly relates to activities discussed in CA.L2 -3.12.4. As a result, the process not only maintains awareness of vulnerabilities and threats, but it also informs management of the effectiveness of the security controls in determining if security controls are current and for management to make an acceptable risk decision. Example You are responsible for ensuring your company fulfills all cybersecurity requirements for its DoD contracts. You review those requirements and the security controls your company has put in place to meet them. You then create a plan to evaluate each control regularly over the next year. You mark several controls to be evaluated by a third-party security assessor. You assign other IT resources in the organization to evaluate controls within their area of responsibility. To ensure progress you establish recurring meetings with the accountable IT staff to assess continuous monitoring progress, review security information, evaluate risks from gaps in continuous monitoring, and produce reports for your management [a]. Potential Assessment Considerations • Are the security controls that need to be continuously monitored identified [a]? • Is the timeframe for continuous monitoring activities to support risk -based decision making defined [a]? • Is the output of continuous monitoring activities provided to stakeholders [a]?
What passing evidence looks like
Ongoing monitoring that controls keep working: the recurring checks you actually run (log review, compliance dashboard, evidence freshness) named in one note with a recent instance of each.
Common ways contractors fail CA.L2-3.12.3
- !Five points for continuity: the assessor wants to see the controls watched between assessments, not rebuilt for them. Your monthly log review (AU.L2-3.3.3), Intune compliance dashboard, and this platform's freshness nudges are the answer, name them together.
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Prove CA.L2-3.12.3, and the other 109
The Level 2 Accelerator walks all 110 requirements with you, generates your SSP, POA&M, and Audit Room from real evidence, includes the full Level 1 platform, and puts a credentialed officer alongside you for 180 days. Filed in 180 days, or we work free until you are.
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CA.L2-3.12.3 questions, answered
How many points is CMMC requirement CA.L2-3.12.3 worth?+
CA.L2-3.12.3 is worth 5 points in the CMMC Level 2 score under 32 CFR 170.24. If it is not met, you lose 5 from your total of 110.
Can CA.L2-3.12.3 be placed on a POA&M?+
No. CA.L2-3.12.3 must be fully met before you can file. It cannot be deferred to a POA&M, so it is a gate on your assessment.
What family does CA.L2-3.12.3 belong to?+
CA.L2-3.12.3 is in the Security Assessment (CA) family, one of the 14 families of NIST SP 800-171 that make up CMMC Level 2.
- NIST SP 800-171 Rev. 2 3.12.3