CM.L2-3.4.5 · NIST SP 800-171 3.4.5

Access Restrictions For Change

Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.

5 points if not metMust be fully met, cannot POA&M8 assessment objectives

What an assessor scores, the objectives

CM.L2-3.4.5 is met only when every one of these 8 objectives, from NIST SP 800-171A, is satisfied. A single missed objective makes the whole requirement not met.

  • a.physical access restrictions associated with changes to the system are defined
  • b.physical access restrictions associated with changes to the system are documented
  • c.physical access restrictions associated with changes to the system are approved
  • d.physical access restrictions associated with changes to the system are enforced
  • e.logical access restrictions associated with changes to the system are defined
  • f.logical access restrictions associated with changes to the system are documented
  • g.logical access restrictions associated with changes to the system are approved
  • h.logical access restrictions associated with changes to the system are enforced

How a C3PAO checks it

NIST SP 800-171A defines three assessment methods. For CM.L2-3.4.5, an assessor uses these:

Examine

Configuration management policy; procedures addressing access restrictions for changes to the system; system security plan; configuration management plan; system design documentation; system architecture and configuration documentation; system configuration settings and associated documentation; logical access approvals; physical access approvals; access credentials; change control records; system audit logs and records; other relevant documents or records

Interview

Personnel with logical access control responsibilities; personnel with physical access control responsibilities; personnel with information security responsibilities; system or network administrators

Test

Organizational processes for managing access restrictions associated with changes to the system; mechanisms supporting, implementing, and enforcing access restrictions associated with changes to the system

What it means, in context

Any changes to the hardware, software, or firmware components of systems can potentially have significant effects on the overall security of the systems . Therefore, organizations permit only qualified and authorized individuals to access systems for purposes of initiating changes, including upgrades and modifications . Access restrictions for change also include software libraries . Access restrictions include physical and logical access co ntrol requirements, workflow automation, media libraries, abstract layers (e.g., changes implemented into external interfaces rather than directly into systems), and change windows (e.g., changes occur only during certain specified times) . In addition to s ecurity concerns, commonly-accepted due diligence for configuration management includes access restrictions as an essential part in ensuring the ability to effectively manage the configuration. NIST SP 800-128 provides guidance on configuration change control.

Define, identify, and document qualified individuals authorized to make physical and logical changes to the organization’ s hardware, software, software libraries , or firmware components. Control of configuration management activities may involve: • physical access control that prohibits unauthorized users from gaining physical access to an asset (e.g., requiring a special key card to enter a server room); • logical access control that prevents unauthorized users from logging onto a system to make configuration ch anges ( e.g., requiring specific credentials for modifying configuration settings, patching software, or updating software libraries); • workflow automation in which configuration management workflow rules define human tasks and data or files are routed between people authorized to do configuration management based on pre-defined business rules ( e.g., passing an electronic form to a manager requesting approval of configuration change made by an authorized employee); • an abstraction layer for configuration management that requires changes be made from an external system through constrained interface ( e.g., software updates can only be made from a patch management system with a specific IP address); and • utilization of a configur ation management change window ( e.g., software updates are only allowed between 8:00 AM and 10:00 AM or between 6:00 PM and 8:00 PM). Example Your datacenter requires expanded storage capacity in a server. The change has been approved, and security is planning to allow an external technician to access the building at a specific date and time under the supervision of a manager [a,b,c,d]. A system administrator creates a temporary privileged account that can be used to log into the server ’s operating system and update storage settings [e,f,g]. On the appointed day , the technician is escorted into the datacenter, upgrades the hardware, expands the storage in the operating system (OS), and departs. The manager verifies the upgrade and disables the privileged account [h]. Potential Assessment Considerations • Are only employees who are approved to make physical or logical changes on systems allowed to do so [a,d,e,h]? • Are authorized personnel approved and documented by the service owner and IT security [a,e]? • Does all change documentation include the name of the authorized employee making the change [b,d,f,h]?

What passing evidence looks like

The written rule for who may change what (physical and logical), and the enforcement: admin role limits, locked server room or closet, documented and matching.

Common ways contractors fail CM.L2-3.4.5

  • !Eight objectives because it wants definition, documentation, approval, AND enforcement for both physical and logical change access. Walk all four verbs in your write up or objectives fail piecemeal.

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CM.L2-3.4.5 questions, answered

How many points is CMMC requirement CM.L2-3.4.5 worth?+

CM.L2-3.4.5 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 CM.L2-3.4.5 be placed on a POA&M?+

No. CM.L2-3.4.5 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 CM.L2-3.4.5 belong to?+

CM.L2-3.4.5 is in the Configuration Management (CM) family, one of the 14 families of NIST SP 800-171 that make up CMMC Level 2.

Key references
  • NIST SP 800-171 Rev. 2 3.4.5