The NIST RMF vs NIST AI RMF

Data breaches hit an all-time high in 2023, with many organizations experiencing multiple breaches. In fact, 95% of organizations surveyed by IBM between March 2022 and March 2023 said they had experienced more than one data breach. New cybersecurity risks, including cloud misconfigurations, more sophisticated ransomware, and vendor exploitation attacks, contributed to the increases in data breaches, according to an MIT report.

As the frequency and impact of data breaches and other cyber attacks continue to increase, organizations must implement robust risk management processes to secure a growing attack surface against evolving attack vectors and technologies.

One of the most respected frameworks for managing risks is the NIST Risk Management Framework (RMF). This comprehensive guide will delve into the NIST RMF, exploring its importance, steps, and best practices for implementation.

What is the NIST Risk Management Framework?

Created by the National Institute of Standards and Technology, the RMF is a comprehensive, flexible, repeatable, and measurable 7-step process aimed at integrating security and risk management activities into the system development life cycle. It provides a structured process that ensures information security and risk management are not afterthoughts but integral components of an organization’s overall mission and business processes.

Who does NIST RMF apply to?

NIST RMF can be applied to any type of organization. In addition to federal agencies, state, local, and tribal governments, private sector organizations across industries are encouraged to use this voluntary framework to better manage security and privacy risks.

The benefits of implementing the NIST RMF

NIST RMF is designed to help strengthen the underlying information systems, components, products, and services of any organization. 

Implementing NIST RMF offers benefits to all types of organizations, including:

• Standardization: The RMF provides a standardized approach to risk management, ensuring consistency across various departments and systems and alignment with the organization’s mission and business objectives.
• Compliance: By adhering to the RMF, federal agencies satisfy the requirements in the Federal Information Security Modernization Act of 2014 (FISMA), the Privacy Act of 1974, OMB policies, and Federal Information Processing Standards, among other laws, regulations, and policies. Following RMF guidelines also helps federal agencies as well as other organizations implement the NIST Cybersecurity Framework (CSF).
• Security and privacy protections: The RMF ensures that security and privacy considerations are integrated into every phase of the system development life cycle and that appropriate risk response strategies are implemented. This helps achieve security protections for information and information systems and privacy protections for individuals.
• Proactive security and privacy: The RMF’s emphasis on preparation and continuous monitoring promotes a proactive stance toward managing security and privacy risks.
• Risk-based decision-making: By providing a structured approach to risk assessment, the RMF aids in better decision-making regarding resource allocation and risk mitigation strategies.
• Tailored risk management: Encouraging the tailoring of controls ensures they are relevant and effective for the specific organizational context.

NIST 800-37 Rev 2

The RMF is detailed in NIST Special Publication 800-37, “Guide for Applying the Risk Management Framework to Federal Information Systems.” The latest version, NIST 800-37 Revision 2, builds on the foundation established by Revision 1, offering a more comprehensive and integrated approach to risk management.

Key changes in Revision 2 include:

• The introduction of the Prepare step: The "Prepare" step was introduced in the updated version of the NIST Risk Management Framework, detailed in NIST Special Publication 800-37 Revision 2. This step aims to facilitate more effective, efficient, and cost-effective security and privacy risk management processes by laying the groundwork for the subsequent RMF steps.
• The integration of privacy: Revision 1 focused primarily on information security. Recognizing the growing importance of privacy, Revision 2 integrates privacy risk management processes into the RMF to ensure organizations are building privacy protections into the risk management process alongside security. This includes identifying privacy risks and implementing controls to mitigate these risks.
• The integration of supply chain risk management: Revision 2 also integrates security-related, supply chain risk management (SCRM) concepts into the RMF. This addition recognizes that supply chain risk is a growing concern to organizations as they increasingly rely on third-party providers and commercial off-the-shelf products, services and systems. 
• Alignment with other NIST frameworks: Revision 2 aligns more closely with other NIST frameworks, such as NIST CSF and NIST Privacy Framework, to provide a more cohesive approach to risk management that can be applied across different sectors and frameworks.

NIST Risk Management Framework steps

The NIST RMF consists of seven steps that are critical to the framework's overall effectiveness.  Below you’ll find an overview of each step, including its purpose and series of associated tasks.

Each list of tasks is not exhaustive. You can find a complete list of tasks as well as expected outcomes in NIST SP 800-37.

Please note that the steps below are not numbered because after the Prepare step, the steps can be carried out in non sequential order — although organizations typically do follow the sequential order. 

Prepare

Purpose: Establish a context and priorities for managing security and privacy risk and carry out other essential activities in order to enhance organizational readiness for subsequent RMF activities.

Key tasks:

• Assign roles and responsibilities for risk management processes.
• Establish a risk management strategy and organizational risk tolerance.
• Conduct an organization-wide risk assessment.
• Identify, document, and publish organization-wide common controls.
• Develop and implement an organization-wide strategy for continuous monitoring.

Categorize

Purpose: Categorize the organizational system based on the potential adverse impact resulting from the loss of confidentiality, integrity, and availability of the information processed, stored, and transmitted by the system.

Key tasks:

• Document the characteristics of the system.
• Categorize the system using impact levels (low, moderate, or high) determined for each information type and security objective.
• Review and approve the security categorization.

Select

Purpose: Select tailor, and document appropriate controls based on the system categorization.

Key tasks:

• Identify baseline controls from NIST SP 800-53, or use your own selection process to select controls.
• Tailor the controls you’ve selected based on factors such as the organizational mission, business functions, threats, security and privacy risks, type of system, or risk tolerance.
• Designate controls as system-specific, hybrid, or common and allocate them to the appropriate system elements. 
• Document the controls in security and privacy plans or a single consolidated plan.
• Develop a strategy for continuous monitoring.
• Review and approve the security and privacy plan(s).

Implement

Purpose: Implement the security and privacy controls and describe how they’re employed within the information system.

Key tasks:

• Implement the controls as described in the security and privacy plan(s).
• Document the implementation details, including any changes to planned inputs, expected behavior, and expected outputs. 

Assess

Purpose: Evaluate the security controls to ensure they are correctly implemented and effective.

Key tasks:

• Select an individual or team with the necessary technical expertise and independence to assess the controls.
• Develop, review, and approve the security and privacy assessment plan.
• Conduct the assessment in accordance with the assessment plan.
• Document the assessment results, including findings and recommendations for correcting any deficiencies in the implemented controls.
• Prepare the plan of action and milestones (POA&M) based on the assessment results.

Authorize

Purpose: Authorize the system to operate based on a determination that the risk to

organizational operations and assets, individuals, other organizations, and the Nation is

acceptable. 

Key tasks:

• Prepare and submit the authorization package, including the security and privacy assessment plans and reports, POA&Ms, and executive summary.
• Finalize the risk determination. 
• Identify and implement responses to the risk determined.
• Grant or deny authorization for the information system to operate based on the risk assessment.
• Report authorization decisions and any significant deficiencies and risks to organizational officials.

Monitor

Purpose: Continuously monitor the security controls and information system to ensure ongoing effectiveness and address new risks.

Key tasks:

• Monitor the information system as well as its environment of operation for any changes that may affect its security and privacy posture.
• Conduct ongoing assessments and monitoring to ensure control effectiveness.
• Respond to risk based on the results of continuous monitoring activities, risk assessments, and any outstanding items in POA&Ms.
• Report the security and privacy posture of the system based on the results of monitoring activities on an ongoing basis.
• Review the security and privacy posture of the system on an ongoing basis to determine that risk remains acceptable.
• Update security documentation as needed.

Best Practices for Implementing the NIST RMF

The tips below can help simplify and improve the effectiveness of implementing the RMF.

1. Early and continuous integration: Integrate the RMF process early in the system development life cycle (SDLC) and maintain continuous involvement throughout.
2. Stakeholder engagement: Involve stakeholders from various departments to ensure comprehensive risk management and buy-in.
3. Thorough documentation: Maintain detailed documentation at each step to provide a clear audit trail and support ongoing risk management.
4. Regular training: Ensure staff is regularly trained on RMF processes and updates to maintain a high level of expertise and awareness.
5. Common controls: Use common controls whenever possible to promote standardized, consistent, and cost-effective control implementation across information systems.
6. Leverage automation: Use automated tools for control selection, assessment, and monitoring and wherever else possible to increase the speed, effectiveness, and efficiency of executing the steps in the RMF. Automated continuous monitoring in particular can help reduce the cost and increase the efficiency of your security and privacy programs.

Simplifying NIST RMF compliance with Secureframe

The NIST Risk Management Framework is a vital tool for organizations aiming to manage information system risks effectively. By following its guidelines, organizations can put comprehensive security measures in place and proactively manage risks. 

Secureframe can streamline the implementation process, helping organizations save time, reduce costs, and improve their risk management practices. 

Secureframe customers can:

• Create a custom framework to apply the RMF to their information system and organization and map our pre-built controls and tests to that framework
• Automatically collect evidence to simplify internal and external assessments 
• Continuously monitor their security controls to ensure they’re effective
• Map common controls to multiple framework requirements to reduce duplicate work
• Use Comply AI to automate risk assessments and test remediation
• Link mitigating controls and attach documents to show how you are reducing risk
• Access and customize templates including SSPs, POA&M documents, Separations of Duties Matrix, and more
• Monitor third parties with access to sensitive data in one platform

To learn more about how Secureframe streamlines security and privacy compliance, schedule a demo with a product expert.