Software Compliance Testing for NIST SP 800-82 (LOW)
NIST SP 800-82r3 is a guide to Operational Technology (OT) security, offering recommendations for managing cybersecurity risks to systems, assets, and data. It provides a roadmap for organizations to enhance their cybersecurity posture and protect critical infrastructure by recommending a risk management framework that includes identifying critical assets, threats, and vulnerabilities specific to the OT environment.
Through our Software Compliance Testing service for NIST SP 800-82 (LOW), we assess and test vendors’ software solutions to ensure they support NIST SP 800-82 (LOW) control baseline. After a thorough evaluation, we feature these solutions on our website.
NIST SP 800-82 (LOW) Compliance Testing Controls
Compliance Testing for NIST SP 800-82 (LOW) relies on credible, objective testing controls based on the intent of NIST SP 800-82 (LOW) control baseline. This approach incorporates insights from consultants’ perspective, and various specialists, including affected software vendors, developers, users, and industry groups, to align with organizational needs. NIST SP 800-82 (LOW) compliance testing controls cover the following software controls categories:
Application and DevOps Security
Security Testing and Evaluation (SA-4, SA-11): includes controls related to security testing during the acquisition process and conducting system security testing. These controls, while broader in scope, relate to ensuring the security of applications being integrated into or developed for OT environments.
Asset Inventory and Management
System Inventory Control (PM-5): includes the PM-5 control, requiring organizations to develop, maintain, and update system inventories. This is essential for understanding the assets within the OT environment, assessing risks, and applying appropriate security controls.
Vulnerability Scanning (RA-5): Effective vulnerability scanning, relies heavily on a comprehensive asset inventory. Knowing the assets, their versions, and configurations allows for targeted and accurate vulnerability assessments.
Awareness and Training
Training Tailored to OT (AT-2, AT-3): highlights the need for security awareness and training programs specifically designed for OT environments.
Backup and Recovery
Data Backup and Recovery (CP-2, CP-10): includes controls for data backup and recovery, recognizing their criticality in OT.
OT-Specific Backup Considerations: While the controls themselves are general, the OT context adds specific considerations:
Criticality of Real-Time Data: OT environments often involve real-time data, so backup and recovery strategies must account for minimizing data loss and potential downtime.
Legacy System Challenges: Backing up legacy OT systems can be complex due to their age, proprietary protocols, and potential lack of modern backup features.
Audit and Compliance Management
Audit and Accountability (AU-2, AU-3, AU-6): Specific controls related to audit trail management, content, and analysis are included. This data supports compliance reporting and provides valuable insights during incident investigations.
Data Security
Data Protection at Rest and in Transit (SC-13, SC-28, SC-32): addresses data security comprehensively, with controls covering data-at-rest and data-in-transit protection.
Cryptography (SC-13, SC-28): recognizes the role of cryptography in securing OT data. It encourages the use of encryption and other cryptographic techniques but advises careful evaluation to avoid negative performance impacts on OT systems, which are often sensitive to latency.
Data Flow Control (AC-4): includes a control for information flow enforcement (AC-4) to regulate data movement within and between OT networks and other systems. This is particularly relevant for protecting sensitive OT data from unauthorized disclosure or modification.
Endpoint and Device Protection
Physical Security (PE-3, PE-19): emphasizes the significance of physical security controls (e.g., physical access restrictions, environmental monitoring) as a fundamental aspect of endpoint protection in OT.
Boundary Protection (SC-7, SC-32): Controls related to boundary protection, such as firewalls and network segmentation, help isolate and protect OT endpoints from unauthorized access and threats originating from external networks.
Access Control (AC Family): Access control mechanisms, covered extensively in the AC family of controls, are crucial for securing endpoints by limiting who and what can interact with OT devices and systems.
Identity Management and Access Control
Access Control Policy and Procedures (AC-1): This control stresses the importance of defining and documenting policies and procedures for managing access to OT systems.
Access Enforcement (AC-3): This control ensures that access control mechanisms are in place and enforced consistently across OT systems.
Separation of Duties (AC-5): This control recommends separating critical duties to prevent conflicts of interest and reduce the risk of unauthorized activities.
Least Privilege (AC-6): This control emphasizes granting users the minimum level of access necessary to perform their duties, reducing the potential damage from accidental or malicious activities.
Identification and Authentication (Organizational Users) (IA-2): This control focuses on identifying and authenticating organizational users to verify their identities before granting access to systems.
Identification and Authentication (Non-Organizational Users) (IA-8): This control focuses on identifying and authenticating non-organizational users, such as vendors and contractors, before granting access to OT systems.
Authenticator Management (IA-5): This control focuses on managing the different methods used for authentication, such as passwords, tokens, and biometrics, to ensure their security and effectiveness.
Incident Response
Dedicated Control Family (AC Family): dedicates an entire family of controls to Identity and Access Management (AC-1 through AC-24), reflecting its criticality in OT.
Third-Party Access: highlights the need to manage access for third-party vendors and contractors, who often require access to OT systems for maintenance or support.
Multi-factor Authentication (IA-2): encourages the use of multi-factor authentication (MFA) whenever feasible to strengthen authentication mechanisms, especially for privileged accounts.
Logging and Threat Detection
Logging for Audit and Security (AU-2, AU-3, AU-6): includes controls for audit trail management, which are essential for both security monitoring and post-incident investigations.
Network Monitoring (SI-4): emphasizes continuous security monitoring, including network monitoring, to detect anomalies and potential security incidents. This often involves collecting and analyzing logs from network devices and security tools.
Intrusion Detection and Prevention Systems (SI-4): The use of intrusion detection and prevention systems (IDPS) is recommended for real-time threat detection and response within OT environments.
Network Security
Segmentation as a Core Principle (SC-7): Network segmentation is a foundational principle in Appendix F’s approach to OT network security.
Firewall Implementation (SC-7): Firewalls are highlighted as crucial for enforcing segmentation, controlling traffic flow between OT zones, and protecting against unauthorized access.
Secure Remote Access (AC-17): Recognizing the risks associated with remote access, the overlay includes a dedicated control for securing remote connections to OT systems. This often involves using VPNs, strong authentication, and access restrictions.
Posture and Vulnerability Management
Continuous Assessment (RA-5): stresses the importance of continuous vulnerability and posture assessments in OT.
Configuration Hardening (CM-2, CM-7): Hardening OT systems through secure configuration practices is emphasized to reduce the attack surface and mitigate vulnerabilities.
Risk Assessment and Management
Risk Assessment (RA Family): The RA family of controls provides specific guidance on conducting risk assessments, analyzing threats and vulnerabilities, and determining risk responses.
Risk-Based Decision Making: emphasizes that decisions regarding security control selection, implementation, and tailoring should be driven by risk assessments and the organization’s risk tolerance.
Software Bill Of Materials (SBOM)
NIST SP 800-82 does not explicitly mention SBOMs.
Zero Trust Network Access
NIST SP 800-82 does not explicitly mention ZTNA. The underlying concept of Zero Trust Architecture (ZTA) aligns with NIST SP 800-82 recommendations for network segmentation, strong authentication, and least privilege access, but ZTNA as a specific technology or solution is not covered.
Continuous Evaluation Process
Compliance Labs has developed the compliance continuous testing process as a fundamental aspect of the NIST SP 800-82 (LOW) compliance testing controls. The continuous evaluation process will monitor new cybersecurity regulations and standards compliance controls or frameworks best practices and update testing criteria to drive software compliance effectiveness and quality over the long term.