SA-9 (05)—External System Services | Processing, Storage, and Service Location
>Control Description
>FedRAMP Baseline Requirements
No FedRAMP-specific parameter values or requirements for this baseline.
>Discussion
The location of information processing, information and data storage, or system services can have a direct impact on the ability of organizations to successfully execute their mission and business functions. The impact occurs when external providers control the location of processing, storage, or services. The criteria that external providers use for the selection of processing, storage, or service locations may be different from the criteria that organizations use.
For example, organizations may desire that data or information storage locations be restricted to certain locations to help facilitate incident response activities in case of information security incidents or breaches. Incident response activities, including forensic analyses and after-the-fact investigations, may be adversely affected by the governing laws, policies, or protocols in the locations where processing and storage occur and/or the locations from which system services emanate.
>Assessment Interview Topics
Questions assessors commonly ask
Process & Governance:
- •What acquisition policies and procedures address the requirements of SA-9(5)?
- •How are security and privacy requirements integrated into the acquisition process?
- •Who is responsible for ensuring that acquisitions comply with SA-9(5)?
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?
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?
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