You would never pay $1,000 upfront and $30/month for a security system to protect a shed containing $100 worth of lawn equipment. However, you wouldn’t hesitate to spend that much or more to protect your home and family. The same concept applies in information security. Different kinds of data necessitate different levels of security, which is why FedRAMP security impact levels exist. A government agency that deals with data that is widely available for public consumption doesn’t require as many security controls as an agency that works with classified data.
There are three FedRAMP security impact levels: FedRAMP Low, FedRAMP Moderate, and FedRAMP High. They are based on the three FISMA security objectives outlined in the Federal Information Processing Standard (FIPS199):
* Confidentiality: Protect personal privacy and prevent the unauthorized disclosure of proprietary information.
* Integrity: Prevent the unauthorized modification or destruction of information.
* Availability: Prevent disruptions to information access or use.
FedRAMP Low Security Impact Level
The FedRAMP Low Impact Level applies to cloud service offerings (CSOs) that will be used to work with data that is already publicly available; a breach of this data would not cause significant damage to the government agency or its operations, assets, or individuals. FedRAMP defines two baselines within the Low Impact Level category, the standard Low Baseline and what is known as the LI-SaaS Baseline.
The LI-SaaS Baseline applies to Low-Impact SaaS applications that do not store personally identifiable information (PII) other than what is generally required for login credentials, such as email addresses, usernames, and passwords. The LI-SaaS Baseline has fewer security controls that require testing and verification than the standard Low Baseline, and the required security documentation is consolidated.
FedRAMP Moderate Impact Level
This is the most common impact level, accounting for about 80% of CSOs that attain FedRAMP authorization. It applies to CSOs being used for data that is largely not available for public consumption, such as PII. If Moderate Impact data is breached, the agency’s operations, assets, or individuals would suffer serious adverse effects, such as operational damage, financial loss, or individual harm (though not physical harm or death).
FedRAMP High Impact Level
The FedRAMP High Impact Level, which was released in 2016, applies to CSOs being used by agencies that handle the most highly sensitive unclassified government data, such as law enforcement, emergency services, financial systems, and healthcare systems. A data breach could have catastrophic results, including loss of human life and economic crises. FedRAMP High systems must comply with 421 controls and reduce the probability of human error as much as possible by automating as many processes as possible.
When pursuing FedRAMP authorization, cloud service providers must ensure that they choose the correct security impact level for their CSOs. For example, cloud service providers whose CSOs qualify for standard Low Baseline or LI-SaaS would not decide to pursue a JAB P-ATO, which is more appropriate for CSOs that are Moderate and High Impact.
Michael Peters is the CEO of Lazarus Alliance, Inc., the Proactive Cyber Security™ firm, and Continuum GRC. He has served as an independent information security consultant, executive, researcher, and author. He is an internationally recognized and awarded security expert with years of IT and business leadership experience and many previous executive leadership positions.
He has contributed significantly to curriculum development for graduate degree programs in information security, advanced technology, cyberspace law, and privacy, and to industry standard professional certifications. He has been featured in many publications and broadcast media outlets as the “Go-to Guy” for executive leadership, information security, cyberspace law, and governance.