NIST SP 800-39FPD Appendix D
ROLES AND RESPONSIBILITIES
KEY PARTICIPANTS IN THE RISK MANAGEMENT PROCESS
The following sections describe the roles and responsibilities of key participants involved in an organization's risk management process. Recognizing that organizations have widely varying missions and organizational structures, there may be differences in naming conventions for risk management-related roles and how specific responsibilities are allocated among organizational personnel (e.g., multiple individuals filling a single role or one individual filling multiple roles). However, the basic functions remain the same. The application of the risk management process across the three risk management tiers described in this publication is flexible, allowing organizations to effectively accomplish the intent of the specific tasks within their respective organizational structures to best manage risk.
D.1 HEAD OF AGENCY (CHIEF EXECUTIVE OFFICER)
The head of agency (or chief executive officer) is the highest-level senior official or executive within an organization with the overall responsibility to provide information security protections commensurate with the risk and magnitude of harm (i.e., impact) to organizational operations and assets, individuals, other organizations, and the Nation resulting from unauthorized access, use, disclosure, disruption, modification, or destruction of: (i) information collected or maintained by or on behalf of the agency; and (ii) information systems used or operated by an agency or by a contractor of an agency or other organization on behalf of an agency. Agency heads are also responsible for ensuring that: (i) information security management processes are integrated with strategic and operational planning processes; (ii) senior officials within the organization provide information security for the information and information systems that support the operations and assets under their control; and (iii) the organization has trained personnel sufficient to assist in complying with the information security requirements in related legislation, policies, directives, instructions, standards, and guidelines. Through the development and implementation of strong policies, the head of agency establishes the organizational commitment to information security and the actions required to effectively manage risk and protect the missions/business functions being carried out by the organization. The head of agency establishes appropriate accountability for information security and provides active support and oversight of monitoring and improvement for the information security program. Senior leadership commitment to information security establishes a level of due diligence within the organization that promotes a climate for mission and business success.
The risk executive (function) is an individual or group within an organization that provides a more comprehensive, organization-wide approach to risk management. The risk executive (function) serves as the common risk management resource for senior leaders/executives, mission/business owners, chief information officers, chief information security officers, information system owners, common control providers, enterprise architects, information security architects, information systems/security engineers, information system security managers/officers, and any other stakeholders having a vested interest in the mission/business success of organizations. The risk executive (function) coordinates with senior leaders/executives to:
- Establish risk management roles and responsibilities;
- Develop and implement an organization-wide risk management strategy that guides and informs organizational risk decisions (including how risk is framed, assessed, responded to, and monitored over time);
- Manage threat and vulnerability information with regard to organizational information systems and the environments in which the systems operate;
- Establish organization-wide forums to consider all types and sources of risk (including aggregated risk);
- Determine organizational risk based on the aggregated risk from the operation and use of information systems and the respective environments of operation;
- Provide oversight for the risk management activities carried out by organizations to ensure consistent and effective risk-based decisions;
- Develop a greater understanding of risk with regard to the strategic view of organizations and their integrated operations;
- Establish effective vehicles and serve as a focal point for communicating and sharing risk-related information among key stakeholders internally and externally to organizations;
- Specify the degree of autonomy for subordinate organizations permitted by parent organizations with regard to framing, assessing, responding to, and monitoring risk;
- Promote cooperation and collaboration among authorizing officials to include security authorization actions requiring shared responsibility (e.g., joint/leveraged authorizations);
- Ensure that security authorization decisions consider all factors necessary for mission and business success; and
- Ensure shared responsibility for supporting organizational missions and business functions using external providers receives the needed visibility and is elevated to appropriate decision-making authorities.
The risk executive (function) presumes neither a specific organizational structure nor formal responsibility assigned to any one individual or group within the organization. Heads of agencies or organizations may choose to retain the risk executive (function) or to delegate the function. The risk executive (function) requires a mix of skills, expertise, and perspectives to understand the strategic goals and objectives of organizations, organizational missions/business functions, technical possibilities and constraints, and key mandates and guidance that shape organizational operations. To provide this needed mixture, the risk executive (function) can be filled by a single individual or office (supported by an expert staff) or by a designated group (e.g., a risk board, executive steering committee, executive leadership council). The risk executive (function) fits into the organizational governance structure in such a way as to facilitate efficiency and effectiveness.
The chief information officer is an organizational official responsible for: (i) designating a senior information security officer; (ii) developing and maintaining information security policies, procedures, and control techniques to address all applicable requirements; (iii) overseeing personnel with significant responsibilities for information security and ensuring that the personnel are adequately trained; (iv) assisting senior organizational officials concerning their security responsibilities; and (v) in coordination with other senior officials, reporting annually to the head of the federal agency on the overall effectiveness of the organization's information security program, including progress of remedial actions. The chief information officer, with the support of the risk executive (function) and the senior information security officer, works closely with authorizing officials and their designated representatives to help ensure that:
- An organization-wide information security program is effectively implemented resulting in adequate security for all organizational information systems and environments of operation for those systems;
- Information security considerations are integrated into programming/planning/budgeting cycles, enterprise architectures, and acquisition/system development life cycles;
- Information systems are covered by approved security plans and are authorized to operate;
- Information security-related activities required across the organization are accomplished in an efficient, cost-effective, and timely manner; and
- There is centralized reporting of appropriate information security-related activities.
The chief information officer and authorizing officials also determine, based on organizational priorities, the appropriate allocation of resources dedicated to the protection of the information systems supporting the organization's missions and business functions. For selected information systems, the chief information officer may be designated as an authorizing official or a co-authorizing official with other senior organizational officials. The role of chief information officer has inherent U.S. Government authority and is assigned to government personnel only.
D.4 INFORMATION OWNER/STEWARD
The information owner/steward is an organizational official with statutory, management, or operational authority for specified information and the responsibility for establishing the policies and procedures governing its generation, collection, processing, dissemination, and disposal. In information-sharing environments, the information owner/steward is responsible for establishing the rules for appropriate use and protection of the subject information (e.g., rules of behavior) and retains that responsibility when the information is shared with or provided to other organizations. The owner/steward of the information processed, stored, or transmitted by an information system may or may not be the same as the system owner. A single information system may contain information from multiple information owners/stewards. Information owners/stewards provide input to information system owners regarding the security requirements and security controls for the systems where the information is processed, stored, or transmitted.
The senior information security officer is an organizational official responsible for: (i) carrying out the chief information officer security responsibilities under FISMA; and (ii) serving as the primary liaison for the chief information officer to the organization's authorizing officials, information system owners, common control providers, and information system security officers. The senior information security officer: (i) possesses professional qualifications, including training and experience, required to administer the information security program functions; (ii) maintains information security duties as a primary responsibility; and (iii) heads an office with the mission and resources to assist the organization in achieving more secure information and information systems in accordance with the requirements in FISMA. The senior information security officer (or supporting staff members) may also serve as authorizing official designated representatives or security control assessors. The role of senior information security officer has inherent U.S. Government authority and is assigned to government personnel only.
The authorizing official is a senior official or executive with the authority to formally assume responsibility for operating an information system at an acceptable level of risk to organizational operations and assets, individuals, other organizations, and the Nation. Authorizing officials typically have budgetary oversight for an information system or are responsible for the mission and/or business operations supported by the system. Through the security authorization process, authorizing officials are accountable for the security risks associated with information system operations. Accordingly, authorizing officials are in management positions with a level of authority commensurate with understanding and accepting such information system-related security risks. Authorizing officials also approve security plans, memorandums of agreement or understanding, and plans of action and milestones and determine whether significant changes in the information systems or environments of operation require reauthorization. Authorizing officials can deny authorization to operate an information system or if the system is operational, halt operations, if unacceptable risks exist. Authorizing officials coordinate their activities with the risk executive (function), chief information officer, senior information security officer, common control providers, information system owners, information system security officers, security control assessors, and other interested parties during the security authorization process. With the increasing complexity of missions/business processes, partnership arrangements, and the use of external/shared services, it is possible that a particular information system may involve multiple authorizing officials. If so, agreements are established among the authorizing officials and documented in the security plan. Authorizing officials are responsible for ensuring that all activities and functions associated with security authorization that are delegated to authorizing official designated representatives are carried out. The role of authorizing official has inherent U.S. Government authority and is assigned to government personnel only.
The authorizing official designated representative is an organizational official that acts on behalf of an authorizing official to coordinate and conduct the required day-to-day activities associated with the security authorization process. Authorizing official designated representatives can be empowered by authorizing officials to make certain decisions with regard to the planning and resourcing of the security authorization process, approval of the security plan, approval and monitoring the implementation of plans of action and milestones, and the assessment and/or determination of risk. The designated representative may also be called upon to prepare the final authorization package, obtain the authorizing official's signature on the authorization decision document, and transmit the authorization package to appropriate organizational officials. The only activity that cannot be delegated to the designated representative by the authorizing official is the authorization decision and signing of the associated authorization decision document (i.e., the acceptance of risk to organizational operations and assets, individuals, other organizations, and the Nation).
The common control provider is an individual, group, or organization responsible for the development, implementation, assessment, and monitoring of common controls (i.e., security controls inherited by information systems). Common control providers are responsible for: (i) documenting the organization-identified common controls in a security plan (or equivalent document prescribed by the organization); (ii) ensuring that required assessments of common controls are carried out by qualified assessors with an appropriate level of independence defined by the organization; (iii) documenting assessment findings in a security assessment report; and (iv) producing a plan of action and milestones for all controls having weaknesses or deficiencies. Security plans, security assessment reports, and plans of action and milestones for common controls (or a summary of such information) is made available to information system owners inheriting those controls after the information is reviewed and approved by the senior official or executive with oversight responsibility for those controls.
The information system owner is an organizational official responsible for the procurement, development, integration, modification, operation, maintenance, and disposal of an information system. The information system owner is responsible for addressing the operational interests of the user community (i.e., users who require access to the information system to satisfy mission, business, or operational requirements) and for ensuring compliance with information security requirements. In coordination with the information system security officer, the information system owner is responsible for the development and maintenance of the security plan and ensures that the system is deployed and operated in accordance with the agreed-upon security controls. In coordination with the information owner/steward, the information system owner is also responsible for deciding who has access to the system (and with what types of privileges or access rights) and ensures that system users and support personnel receive the requisite security training (e.g., instruction in rules of behavior). Based on guidance from the authorizing official, the information system owner informs appropriate organizational officials of the need to conduct the security authorization, ensures that the necessary resources are available for the effort, and provides the required information system access, information, and documentation to the security control assessor. The information system owner receives the security assessment results from the security control assessor. After taking appropriate steps to reduce or eliminate vulnerabilities, the information system owner assembles the authorization package and submits the package to the authorizing official or the authorizing official designated representative for adjudication.
The information system security officer is an individual responsible for ensuring that the appropriate operational security posture is maintained for an information system and as such, works in close collaboration with the information system owner. The information system security officer also serves as a principal advisor on all matters, technical and otherwise, involving the security of an information system. The information system security officer has the detailed knowledge and expertise required to manage the security aspects of an information system and, in many organizations, is assigned responsibility for the day-to-day security operations of a system. This responsibility may also include, but is not limited to, physical and environmental protection, personnel security, incident handling, and security training and awareness. The information system security officer may be called upon to assist in the development of the security policies and procedures and to ensure compliance with those policies and procedures. In close coordination with the information system owner, the information system security officer often plays an active role in the monitoring of a system and its environment of operation to include developing and updating the security plan, managing and controlling changes to the system, and assessing the security impact of those changes.
D.11 INFORMATION SECURITY ARCHITECT
The information security architect is an individual, group, or organization responsible for ensuring that the information security requirements necessary to protect the organizational missions/business functions are adequately addressed in all aspects of enterprise architecture including reference models, segment and solution architectures, and the resulting information systems supporting those missions and business processes. The information security architect serves as the liaison between the enterprise architect and the information system security engineer and also coordinates with information system owners, common control providers, and information system security officers on the allocation of security controls as system-specific, hybrid, or common controls. In addition, information security architects, in close coordination with information system security officers, advise authorizing officials, chief information officers, senior information security officers, and the risk executive (function), on a range of security-related issues including, for example, establishing information system boundaries, assessing the severity of weaknesses and deficiencies in the information system, plans of action and milestones, risk mitigation approaches, security alerts, and potential adverse effects of vulnerabilities.
The information system security engineer is an individual, group, or organization responsible for conducting information system security engineering activities. Information system security engineering is a process that captures and refines information security requirements and ensures that the requirements are effectively integrated into information technology component products and information systems through purposeful security architecting, design, development, and configuration. Information system security engineers are an integral part of the development team (e.g., integrated project team) designing and developing organizational information systems or upgrading legacy systems. Information system security engineers employ best practices when implementing security controls within an information system including software engineering methodologies, system/security engineering principles, secure design, secure architecture, and secure coding techniques. System security engineers coordinate their security-related activities with information security architects, senior information security officers, information system owners, common control providers, and information system security officers.
The security control assessor is an individual, group, or organization responsible for conducting a comprehensive assessment of the management, operational, and technical security controls employed within or inherited by an information system to determine the overall effectiveness of the controls (i.e., the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for the system). Security control assessors also provide an assessment of the severity of weaknesses or deficiencies discovered in the information system and its environment of operation and recommend corrective actions to address identified vulnerabilities. In addition to the above responsibilities, security control assessors prepare the final security assessment report containing the results and findings from the assessment. Prior to initiating the security control assessment, an assessor conducts an assessment of the security plan to help ensure that the plan provides a set of security controls for the information system that meet the stated security requirements.
The required level of assessor independence is determined by the specific conditions of the security control assessment. For example, when the assessment is conducted in support of an authorization decision or ongoing authorization, the authorizing official makes an explicit determination of the degree of independence required in accordance with federal policies, directives, standards, and guidelines. Assessor independence is an important factor in: (i) preserving the impartial and unbiased nature of the assessment process; (ii) determining the credibility of the security assessment results; and (iii) ensuring that the authorizing official receives the most objective information possible in order to make an informed, risk-based, authorization decision. The information system owner and common control provider rely on the security expertise and the technical judgment of the assessor to: (i) assess the security controls employed within and inherited by the information system using assessment procedures specified in the security assessment plan; and (ii) provide specific recommendations on how to correct weaknesses or deficiencies in the controls and address identified vulnerabilities.
- 59 Organizations may define other roles (e.g., facilities manager, human resources manager, systems administrator) to support the risk management process.
- 60 Caution is exercised when one individual fills multiples roles in the risk management process to ensure that the individual retains an appropriate level of independence and remains free from conflicts of interest.
- 61 When an organization has not designated a formal chief information officer position, FISMA requires the associated responsibilities to be handled by a comparable organizational official.
- 62 Federal information is an asset of the Nation, not of a particular federal agency or its subordinate organizations. In that spirit, many federal agencies are developing policies, procedures, processes, and training needed to end the practice of information ownership and implement the practice of information stewardship. Information stewardship is the careful and responsible management of federal information belonging to the Nation as a whole, regardless of the entity or source that may have originated, created, or compiled the information. Information stewards provide maximum access to federal information to elements of the federal government and its customers, balanced by the obligation to protect the information in accordance with the provisions of FISMA and any associated security-related federal policies, directives, regulations, standards, and guidance.
- 63 The responsibility of authorizing officials described in FIPS 200, was extended in NIST Special Publication 800-53 to include risks to other organizations and the Nation.
- 64 Organizations can have multiple common control providers depending on how information security responsibilities are allocated organization-wide. Common control providers may also be information system owners when the common controls are resident within an information system.
- 65 The information system owner serves as the focal point for the information system. In that capacity, the information system owner serves both as an owner and as the central point of contact between the authorization process and the owners of components of the system including, for example: (i) applications, networking, servers, or workstations; (ii) owners/stewards of information processed, stored, or transmitted by the system; and (iii) owners of the missions and business functions supported by the system. Some organizations may refer to information system owners as program managers or business/asset owners.
- 66 The responsibility for deciding who has access to specific information within an information system (and with what types of privileges or access rights) may reside with the information owner/steward.
- 67 Depending on how the organization has organized its security authorization activities, the authorizing official may choose to designate an individual other than the information system owner to compile and assemble the information for the security authorization package. In this situation, the designated individual must coordinate the compilation and assembly activities with the information system owner.
- 68 Organizations may also define an information system security manager or information security manager role with similar responsibilities as an information system security officer or with oversight responsibilities for an information security program. In these situations, information system security officers may, at the discretion of the organization, report directly to information system security managers or information security managers.