SA-4—Acquisition Process
>Control Description
>FedRAMP Baseline Requirements
Additional Requirements and Guidance
SA-4 Requirement: The service provider must comply with Federal Acquisition Regulation (FAR) Subpart 7.103, and Section 889 of the John S. McCain National Defense Authorization Act (NDAA) for Fiscal Year 2019 (Pub. L. 115-232), and FAR Subpart 4.21, which implements Section 889 (as well as any added updates related to FISMA to address security concerns in the system acquisitions process). SA-4 Guidance: The use of Common Criteria (ISO/IEC 15408) evaluated products is strongly preferred. See https://www.niap-ccevs.org/Product/index.cfm or https://www.commoncriteriaportal.org/products/.
>Discussion
Security and privacy functional requirements are typically derived from the high-level security and privacy requirements described in SA-2. The derived requirements include security and privacy capabilities, functions, and mechanisms. Strength requirements associated with such capabilities, functions, and mechanisms include degree of correctness, completeness, resistance to tampering or bypass, and resistance to direct attack.
Assurance requirements include development processes, procedures, and methodologies as well as the evidence from development and assessment activities that provide grounds for confidence that the required functionality is implemented and possesses the required strength of mechanism. SP 800-160-1 describes the process of requirements engineering as part of the system development life cycle. Controls can be viewed as descriptions of the safeguards and protection capabilities appropriate for achieving the particular security and privacy objectives of the organization and for reflecting the security and privacy requirements of stakeholders.
Controls are selected and implemented in order to satisfy system requirements and include developer and organizational responsibilities. Controls can include technical, administrative, and physical aspects. In some cases, the selection and implementation of a control may necessitate additional specification by the organization in the form of derived requirements or instantiated control parameter values.
The derived requirements and control parameter values may be necessary to provide the appropriate level of implementation detail for controls within the system development life cycle. Security and privacy documentation requirements address all stages of the system development life cycle. Documentation provides user and administrator guidance for the implementation and operation of controls.
The level of detail required in such documentation is based on the security categorization or classification level of the system and the degree to which organizations depend on the capabilities, functions, or mechanisms to meet risk response expectations. Requirements can include mandated configuration settings that specify allowed functions, ports, protocols, and services. Acceptance criteria for systems, system components, and system services are defined in the same manner as the criteria for any organizational acquisition or procurement.
>Cross-Framework Mappings
>Assessment Interview Topics
Questions assessors commonly ask
Process & Governance:
- •What acquisition policies and procedures address the requirements of SA-4?
- •How are security and privacy requirements integrated into the acquisition process?
- •Who is responsible for ensuring that acquisitions comply with SA-4?
- •How is security integrated throughout your system development lifecycle (SDLC)?
Technical Implementation:
- •How are security requirements defined and documented in acquisition contracts?
- •What mechanisms ensure that acquired systems and services meet security requirements?
- •How do you validate that vendors and service providers comply with specified security controls?
- •What security practices are required at each phase of the SDLC?
- •What secure coding practices and standards are required for developers?
Evidence & Documentation:
- •Can you provide examples of acquisition documentation that includes security requirements?
- •What evidence demonstrates that acquired systems meet security specifications?
- •Where is acquisition security documentation maintained throughout the system lifecycle?
- •Can you show evidence of security activities performed during development?
- •Can you provide code review or static analysis results?
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