Data Security Solution for US Federal Customers

Federal agencies manage highly classified sensitive data, including personal information, medical records, and tax and income details of all U.S. residents. In some cases, temporary visitor data are also retained. They also handle national security information, including susceptible documents, intergovernmental communication details, and document decisions that could impact the safety of the country. The purpose of this article is to walk you through various regulations as a developer that you should know about while developing security software specifically for federal agencies.

All government agencies in the U.S. are required to comply with strict data regulations specified in the Federal Information Security Management Act (FISMA) and the Federal Risk and Authorization Management Program (FedRAMP). Developers, who design and implement data security solutions for federal customers, should ensure that the solutions help address compliance requirements. Let’s explore these requirements in some detail.

Federal Information Security Management Act (FISMA)

This U.S. law, enacted in the early 2000s, mandates that all federal agencies implement and adhere to specified regulations to protect the information they manage. The main intent of FISMA is to ensure information security, national safety, and economic stability. In compliance with FISMA, all federal agencies must ensure that data remains confidential and is always available to U.S. residents. The three main components of FISMA are data classification, continuous monitoring, and audit and compliance reporting.

Data Classification

Federal agencies are required to classify and store sensitive documents appropriately. Implementing proper access controls and managing data destruction strategies for redundant or obsolete data are critical responsibilities.

Continuous Monitoring

All data must be continuously monitored for threats and potential data leakage. This aligns with the zero-trust principles that have become popular in recent times, although this requirement has been in place for federal customers since the early days of this century.

Audit and Compliance Reporting

Regular auditing of all security controls is mandatory. Incidents and thwarted data breaches must be reported to the Office of Management and Budget (OMB) and Congress.

In addition to the above, FISMA also mandates that all federal organizations comply with the updated NIST 800 series guidelines. It should be noted that FISMA regulations apply to every entity that works with government organizations. This is why federal agencies can’t partner with just any private agency; partners must go through specific certification programs. Even security vendors must adhere to FISMA guidelines to sell their security software to federal agencies. 

Federal Risk And Authorization Management Program (FedRAMP)

FedRAMP is a government program that provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. It specifically applies to cloud-hosted products and not to on-premise components. However, if an on-premise component communicates with a cloud component, the security assessment also applies to the on-premise cloud-interfacing component.

This standard is essential to ensure the safety of federal data. When your cloud-hosted solution needs to be FedRAMP certified, several security features must be addressed in the product. Let’s look at them one by one.

Encryption

FedRAMP requires encryption of Data in Motion (DIM) and Data at Rest (DAR) using FIPS 140-2 validated cryptographic modules. We will explore the FIPS 140-2 regulation in the next section, but for now, this regulation ensures that data is protected at all times.

Multi-Factor Authentication (MFA)

FedRAMP enforces the use of MFA. Simple username and password access is no longer sufficient in any cloud modules.

Continuous Monitoring and Response

Similar to FISMA, FedRAMP mandates continuous monitoring of data in the cloud at all times. All incidents and data violations must be captured and responded to. Security vendors often opt for auto-remediation of security incidents and advise federal customers to configure their systems accordingly.

Penetration Testing and Vulnerability Checks

The cloud software must undergo extensive penetration testing by a third party, and any violations or vulnerabilities should be addressed and documented. Regular penetration testing of all components throughout the year ensures continuous protection. All libraries used in the product need to be checked for vulnerabilities, and any discovered vulnerabilities should be immediately addressed, based on their CVE score (Common Vulnerability Scoring System).

Business Continuity

Contingency plans in case of a disaster must be established and agreed upon by all involved stakeholders. This is critical to ensure the availability and integrity of federal data at all times. In case of data breaches or identified threats, response and mitigation plans must be in place to address and manage the breach.

Data Residency

Federal data must always reside in the United States. Unless explicitly permitted through written documentation from a federal agency, no data should leave the U.S. at any time, even during a disaster recovery scenario.

Certification

Every security vendor seeking FedRAMP certification must first find a sponsor. Any federal agency can act as a sponsor, and after certification, they are likely to use the security product. The certification process includes a rigorous assessment of all components against the criteria mentioned above. There are three levels of FedRAMP certification: low, moderate, and high. The level of certification required by a cloud security vendor depends on the type of data being managed and hosted, as well as the associated risks. FedRAMP low certification is for data with minimal breach impact, while high certification involves data with the greatest breach impact. For all levels of certification, compliance with the NIST SP 800 series must be validated. The number of security controls required for NIST compliance is 125 for low, 325 for moderate, and 421 for high certifications.

Federal Information Processing Standard (FIPS) 140-2

FIPS 140-2 is a federal standard for evaluating and certifying all cryptographic modules in software. All encryption-related tools and libraries, whether internal or external, must be FIPS 140-2 certified, regardless of whether they're used in on-premise or cloud components. This certification has four levels, ranging from basic cryptographic module checks to physical tamper protection, including safeguards against voltage and temperature changes. The standard also specifies which entities and their corresponding roles are authorized to change or rotate cryptographic keys.

Gov Cloud

Gov Cloud is another term that you often come across when dealing with cloud software for federal agencies. Gov Cloud refers to cloud services designed for federal agencies, featuring enhanced security, compliance, and data residency controls to meet strict and strenuous requirements. These cloud environments are inherently FISMA compliant, FedRAMP certified at the highest level and FIPS 140-2 certified at level 4, too. Typically, cloud providers like Amazon, Microsoft, and Google provide these cloud environments to all other software organizations to host and run their software.

Developers' Role

Now that you know all this, what do you need to do and where should you start? Begin with the basics of analyzing the software you are developing and determining where it will be hosted.

If the software is on-premise or in the cloud, a fundamental requirement is to have the software FIPS 140-2 certified. To meet FIPS 140-2 standards, focus on several specific areas: the keys used for encrypting data at rest (stored data) and the encryption used for communication (typically involving TLS keys and ciphers). Ensure that key encryption is handled by FIPS 140-2 certified modules, and address key rotation and access control aspects in your software. In a distributed system with multiple components, communication between these components is a critical vulnerability point where data could be compromised. Ensure that key sizes, key algorithms, and cipher suites used in communication all comply with FIPS 140-2 standards.

Next, if your software is hosted on-premise and does not communicate with or interface with any cloud components (or have external access), then you only need to plan for general high availability, disaster recovery, a mitigation plan in case of data breaches, and business continuity. As a truly on-premise software, the responsibility falls on the federal agency to plan for these aspects based on the guidance from the security software vendor.

If your software interfaces with cloud components or is hosted in the cloud, you need to undergo FedRAMP certification. This certification will ensure compliance with FISMA regulations. If you plan to cater to a federal customer dealing with highly classified data, you need to opt for Gov Cloud. Cloud providers have certified Gov Cloud environments that continuously meet all standards, so your software needs to be hosted there. Start by conducting a security vulnerability assessment of all external libraries used in your product. If there are critical and open vulnerabilities in these libraries, you need to either upgrade or replace them to eliminate any open vulnerabilities.

Next, your software needs to undergo a penetration test to identify all critical vulnerabilities. After addressing these vulnerabilities, plan for high availability and disaster recovery. Design your software to handle these scenarios, and also plan for incident response and business continuity. Focus on all potential negative scenarios and design how your software will behave in those situations.

You can then apply for certifications with a sponsor. Start with a low or medium certification level and progress to higher levels over time. Don’t aim for high certification on your first attempt. Once you are certified, your job is not finished. FedRAMP certification requires continuous engagement and regular upkeep. Assessments need to be conducted quarterly, and any vulnerabilities should be addressed promptly within 90 days. Federal agencies rarely accept exceptions for critical vulnerabilities. For low-severity exceptions, there may be some time allowed, but ultimately, you will need to fix them.

Conclusion

Data security solutions catered to federal agencies require constant upkeep, continuous evaluation, assessment, and certifications to ensure data safety at all times.