NIST Special Publication 800-171 Revision 2

Date Published: January 28th, 2021

Withdrawn on May 14, 2024. Superseded by SP 800-171 Rev. 3

Author(s): Ron Ross (NIST), Victoria Pillitteri (NIST), Kelley Dempsey (NIST), Mark Riddle (NARA), Gary Guissanie (IDA)

Note: A Class Deviation is in effect as of May 2, 2024 (DEVIATION 2024O0013). The deviation clause requires contractors, who are subject to 252.204-7012, to comply with National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 Revision 2, instead of the version of NIST SP 800-171 in effect at the time the solicitation is issued or as authorized by the contracting officer. Click Here

3.11.1: Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI.

Control Family: Risk Assessment

Control Type: Basic

SPRS Value: 3

SPRS Supplemental Guidance: N/A

CMMC Level(s):

  • RA.L2-3.11.1

Top Ten Failed Requirement:

No

Referenced in:

DFARS 252.204-7012

Derived From: NIST SP 800-53r4

  • RA-3

NIST Supplemental Guidance:

[SP 800-30]

Discussion:

Clearly defined system boundaries are a prerequisite for effective risk assessments. Such risk assessments consider threats, vulnerabilities, likelihood, and impact to organizational operations, organizational assets, and individuals based on the operation and use of organizational systems. Risk assessments also consider risk from external parties (e.g., service providers, contractors operating systems on behalf of the organization, individuals accessing organizational systems, outsourcing entities). Risk assessments, either formal or informal, can be conducted at the organization level, the mission or business process level, or the system level, and at any phase in the system development life cycle.

[SP 800-30] provides guidance on conducting risk assessments.

Upon assessment, assessors must determine if- 

3.11.1[a] the frequency to assess risk to organizational operations, organizational assets, and individuals is defined.
3.11.1[b] risk to organizational operations, organizational assets, and individuals resulting from the operation of an organizational system that processes, stores, or transmits CUI is assessed with the defined frequency

Assessors are instructed to-

Examine: [SELECT FROM: Risk assessment policy; security planning policy and procedures; procedures addressing organizational risk assessments; system security plan; risk assessment; risk assessment results; risk assessment reviews; risk assessment updates; other relevant documents or records].

Interview: [SELECT FROM: Personnel with risk assessment responsibilities; personnel with information security responsibilities].

Test: [SELECT FROM: Organizational processes for risk assessment; mechanisms supporting or for conducting, documenting, reviewing, disseminating, and updating the risk assessment].

FURTHER DISCUSSION

Risk arises from anything that can reduce an organization’s assurance of mission/business success; cause harm to image or reputation; or harm individuals, other organizations, or the Nation. Organizations assess the risk to their operations and assets at regular intervals. Areas where weakness or vulnerabilities could lead to risk may include:

  • poorly designed and executed business processes;

  • inadvertent actions of people, such as disclosure or modification of information;

  • intentional actions of people inside and outside the organization;

  • failure of systems to perform as intended;

  • failures of technology; and

  • external events, such as natural disasters, public infrastructure and supply chain failures.

When conducting risk assessments use established criteria and procedures. The results of formal risk assessments are documented. It is important to note that risk assessments differ from vulnerability assessments (see RA.L2-3.11.2). A vulnerability assessment provides input to a risk assessment along with other information such as results from likelihood analysis and analysis of potential treat sources.

Risk assessments should be performed at defined regular intervals. Mission risks include anything that will keep an organization from meeting its mission. Function risk is anything that will prevent the performance of a function. Image and reputation risks refer to intangible risks that have value and could cause damage to potential or future trust relationships.173

This requirement, RA.L2-3.11.1, which requires periodically assessing the risk to organization systems, assets, and individuals, is a baseline Risk Assessment requirement. RA.L2-3.11.1 enables other Risk Assessment requirements (e.g., RA.L2-3.11.3, Vulnerability Remediation), as well as CA.L2-3.12.2, Plan of Action.

Example

You are a system administrator. You and your team members are working on a big government contract requiring you to store CUI. As part of your periodic (e.g., annual) risk assessment exercise, you evaluate the new risk involved with storing CUI [a,b]. When conducting the assessment you consider increased legal exposure, financial requirements of safeguarding CUI, potentially elevated attention from external attackers, and other factors. After determining how storing CUI affects your overall risk profile, you use that as a basis for a conversation on how that risk should be mitigated.

Potential Assessment Considerations

  • Have initial and periodic risk assessments been conducted [b]?

  • Are methods defined for assessing risk (e.g., reviewing security assessments, incident reports, and security advisories, identifying threat sources, threat events, and vulnerabilities, and determining likelihood, impact, and overall risk to the confidentiality of CUI) [b]?