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03.16.03External System Services

>Control Description

Require the providers of external system services used for the processing, storage, or transmission of CUI to comply with the following security requirements: organization-defined security requirements. Define and document user roles and responsibilities with regard to external system services, including shared responsibilities with external service providers. Implement processes, methods, and techniques to monitor security requirement compliance by external service providers on an ongoing basis.

>Assessment Interview Topics

Questions assessors commonly ask

Process & Governance:

  • What documented policies and procedures address 03.16.03?
  • Who is accountable for implementing and maintaining 03.16.03 controls?
  • How frequently are 03.16.03 requirements reviewed, and what triggers updates?
  • What process ensures changes to systems maintain compliance with 03.16.03 requirements?
  • How are exceptions to 03.16.03 requirements documented and approved?

Technical Implementation:

  • What technical controls enforce 03.16.03 in your environment?
  • How are 03.16.03 controls configured and maintained across all systems?
  • What automated mechanisms support 03.16.03 compliance?
  • How do you validate that 03.16.03 implementations achieve their intended security outcome?
  • What compensating controls exist if primary 03.16.03 controls cannot be fully implemented?

Evidence & Documentation:

  • What documentation proves 03.16.03 is implemented and operating effectively?
  • Can you provide configuration evidence showing how 03.16.03 is technically enforced?
  • What audit logs or monitoring data demonstrate ongoing 03.16.03 compliance?
  • Can you show evidence of a recent review or assessment of 03.16.03 controls?
  • What artifacts would you provide during an assessment to demonstrate 03.16.03 compliance?

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