ATO in Cybersecurity

From Risk to Authorization: Understanding ATO in Cybersecurity

Art Clomera

Vice President, Operations

The Authorization to Operate (ATO) is crucial for the US Federal Government and the Department of Defense (DoD). It represents an official management decision granted by a senior organizational official. The ATO Cybersecurity decision authorizes the operation of an information system and explicitly acknowledges the associated risks to agency operations, assets, individuals, other organizations, and the nation. The value of the ATO process lies in securing the agency’s information systems and is unique to the US federal government. However, ATO is extensive and can take several months to achieve. Furthermore, the cost is highly variable, depending on the Authorized Official (AO) assigned to the system. But it’s worth it. For cybersecurity professionals, there is no better process to ensure that information systems operate securely, uphold national defense priorities, and defend against adversaries seeking to exploit vulnerabilities. Ultimately, achieving ATO is a testament to a federal agency’s dedication to security and compliance, which is vital to safeguarding the government and the nation’s defense capabilities.

What is ATO in Cybersecurity?

Authorization to Operate (ATO) is the formal decision by a senior Federal official or officials. This decision grants approval for the operation of an information system while explicitly acknowledging and accepting the associated risks to various aspects, including agency operations, mission, functions, image, reputation, agency assets, other organizations, and the Nation as a whole. The granting of an ATO is contingent upon successfully implementing a predefined set of security and privacy controls. It is important to note that the authorization concept extends to common controls inherited by agency information systems, further emphasizing the critical role of security controls in this process. Now, let’s delve into the steps that make up the ATO process.

Breaking Down the ATO Activities of the Authorization Step in the NIST Risk Management Framework (RFM) Process

ATO is comprehensively outlined within Step 6 of the RMF process (NIST SP 800-37 rev 2 Risk Management Framework for Information Systems and Organizations: A System Life Cycle Approach for Security and Privacy): Authorization Step – Risk-based Decisions (NIST SP 800-39 Managing Information Security Risk). It’s a pivotal step in the RMF process, as it determines whether a system is authorized to operate based on its security posture and compliance with established security controls and standards. The Authorized Official’s (AO’s) involvement and the Authorization Decision Document issuance are critical elements of this process. In the Federal/DoD, these steps within the ATO process are instrumental in ensuring that their information systems operate securely, uphold national defense priorities, and protect sensitive data from adversaries seeking to exploit vulnerabilities.

Authority to Operate (ATO) Activities include:

1. Prepare Authorization Package 2. Authorization Package Submission 3. Authorize Decision 4. Authorization Decision Document 5. Continuous Monitoring of Security Controls 6. Reauthorization Each activity needs to be meticulously executed to ensure the utmost security and compliance. It’s time to break it down:

Step 1: Prepare Authorization Package

As a cornerstone of the (RMF), the significance of this step cannot be overstated, as the Authorization Package becomes the foundation upon which the entire authorization process rests. It is also the primary reference point for the Authorizing Official (AO) to make informed decisions regarding system authorization within the Federal Government. During this phase, the organization compiles a comprehensive authorization package. But, the Authorization Package is more than just a collection of documents. It encompasses an in-depth analysis of the system’s security posture, including its alignment with DoD-specific directives and policies. What’s inside the Authorization Package? At a minimum, the authorization package includes:
  • Executive summary
  • System Security Plan (SSP)
  • Privacy Plan
  • Security Control Assessment (detailed documentation of security control implementations, compliance risk assessments, supporting evidence, or other documentation) [e.g. penetration testing results, and compliance reports]
  • Privacy Control Assessment, and any relevant Plans of Action & Milestones (POA&M)
  • Detailed documentation of security control implementations, compliance risk assessments, penetration testing results, and compliance reports
Furthermore, it addresses the challenges and threats Federal Agencies face, such as cyber threats targeting national defense assets and organizations.

Step 2: Authorization Package Submission

For DoD information systems, this step is instrumental to maintaining high security and safeguarding national defense assets and sensitive data against evolving threats and vulnerabilities. In this step, the security controls implemented within the system are rigorously assessed via testing, evaluation, and validation to ensure the controls effectively mitigate risks and comply with security standards. All findings and results are meticulously documented. Ultimately, this documentation plays a critical role for the Authorizing Official (AO) in their decision-making process. An (AO) is appointed to oversee the authorization process. The AO is typically a senior-level agency official with the authority to make decisions regarding information system ATO and explicitly accept the risk (In Accordance with [IAW] NIST SP 800-39) to agency operations, agency assets, or tailored set of deviations based on the implementation of agreed-upon set of security controls. Within the Federal Agency, the AO is responsible for determining the degree of acceptable risk based on mission requirements, reviewing the Authorization Package, and granting or denying ATO. Federal Agencies ATOs are granted by an Authorizing Official. These AOs must be Federal employees rather than contractors to ensure accountability and authority. The AO’s decision is based on the security control assessment findings and the authorization package. If the AO approves the authorization package, an Authorization Decision Document (step 5) is issued, outlining the specific conditions under which the Authorization to Operate (ATO) is granted.

Step 3: Authorization Decision

Based on the findings from the authorization package (Step 1), the AO decides whether to grant or deny authorization. The decision is reached after carefully evaluating whether the system’s security controls pose an acceptable level of risk to agency operations, assets, and other critical components. This step holds immense significance within the Federal Agency as it directly impacts government interests, ensuring that only secure and reliable systems are authorized to operate, safeguarding against potential threats and vulnerabilities. The AO risk management process (framing, assessing, responding, and monitoring risk applied) across all 3 tiers (Tier 1: the organization, Tier 2: Mission/Business processes, and Tier 3: Information Systems). A system authorization can be an initial authorization, an ongoing authorization, or a reauthorization. Initial authorization is defined as the initial risk determination and risk acceptance decision based on a complete, all-implemented system-level security or common controls review Ongoing authorization is defined as the subsequent (follow-on) risk determinations and risk acceptance decisions taken at agreed-upon and documented frequencies IAW the organization’s mission/business requirements and organizational risk tolerance. Reauthorization is defined as the static, single point-in-time risk determination and risk acceptance decision that occurs after initial authorization.

Step 4: Authorization Decision Document

There are two types of authorization decisions that an AO can make: ATO and Denial of ATO. If the AO approves the authorization, an Authorization Decision Document is issued. This document outlines the specific conditions under which the ATO was granted. What information does it hold? Details include the ATO’s expiration date, additional requirements or constraints, and the signature (should be digitally signed to ensure authenticity)of the AO. This document is the formal authorization for the system to operate, providing clear guidelines and conditions for the ATO. Specifically within the Federal Agencies, this step ensures that ATOs are issued with strict adherence to Federal, national defense and security standards. This is the only activity that cannot be delegated by the AO to the designated representative is the authorization decision and signing of the associated authorization decision document (i.e., the acceptance of risk). The authorization decision is transmitted from the AO to system owners, common control providers, and other key organizational officials. The authorization decision includes the following information:
  • Authorization Decision
  • Terms and conditions for the authorization
  • Time-driven authorization frequency or authorization termination date
  • Events that may trigger a review of the authorization decision (if any)
  • For common controls, the [FIPS 199] impact level supported by those control

Step 5: Continuous Monitoring of Security Controls

Even after receiving ATO, continuous monitoring of the security controls is essential to ensure that the system’s security posture remains robust. Continuous monitoring helps to amortize the resource expenditures for reauthorization activities over the authorization period. Continuous monitoring of security controls using automated support tools (e.g. IPKeys CLaaS) facilitates near-real-time risk management and represents a significant change in the way security authorization activities have been employed in the past. Near-real-time risk management of information systems can be facilitated by employing automated support tools to execute various steps in the RMF including authorization-related activities. The documents in the authorization package are considered “living documents” and are updated accordingly based on actual events that may affect the security state of the information system. NIST Open Security Controls Assessment Language (OSCAL) provides an automation language for sustaining authorization packages. IPKeys CLaaS leverages NIST OSCAL for RMF-related assessment assets (tools used to perform assessments) and documentation (e.g. SSP, SAP, SAR, POA&M). Federal agency personnel diligently track and respond to alterations, incidents, or emerging threats. They also adapt continuously to technological changes and address emerging vulnerabilities specific to national defense throughout the system’s operational lifespan.

Step 6: Reauthorization

ATO isn’t a once-off process. The ATO may need to be renewed periodically in response to system changes, security control updates, or evolving threat landscapes. The ATO reauthorization process for Federal Agencies involves thoroughly reassessing security controls, ensuring they remain aligned with the latest directives, policies, and emerging threats unique to national defense. It also reviews any modifications to the system that might impact security, safeguarding against vulnerabilities introduced by system updates or changes. Formal reauthorization actions occur at the discretion of the AO IAW federal or organizational policy. Federal organizations should maximize the use of security and risk-related information produced as part of the continuous monitoring processes. Formal reauthorization actions can be either time-driven or event-driven. Time-driven reauthorizations occur when the authorization termination date is reached (if one is specified). If the information system is under ongoing authorization, time-driven reauthorizations may not be necessary. Authorization termination dates are influenced by federal and/or organizational policies and by the requirements of authorizing officials which may establish maximum authorization periods.

Wrapping Up

It’s important to understand that the ATO process is more than just a checklist. Instead, the journey to achieving ATO is a dynamic and ongoing commitment to ensuring that information systems operate securely, upholding Federal and national defense priorities, and defending against adversaries seeking to exploit vulnerabilities. At IPKeys, we recognize the ATO process’s importance and offer solutions to streamline this journey that allows organizations to focus on core business decisions while maintaining the highest cybersecurity and national security standards.

Automate Your Cybersecurity Program With IPKeys

Advanced Analytics Tools

The ATO process generates vast amounts of data, which can be overwhelming. Our Cyber Lab-as-a-Service (CLaaS®), developed in partnership with DISA and tailored for government cybersecurity and compliance experts (including Program Executive Officers and Authorization Officers,) functions as your Federal agency’s primary cyber leadership dashboard. It’s designed to enable proactive responses to cybersecurity threats and simplifies the ATO process.

Industry-Driven, DoD Optimized

Our hands-on teams are trained to meet the unique demands of DoD information systems, ensuring they align seamlessly with this sector’s strict compliance standards, directives, and policies. We are experts at upholding operational efficiency while meeting the stringent security requirements mandated by federal agencies.

OSCAL (Open Security Controls Assessment Language)

IPKeys is pioneering the adoption of OSCAL within our cybersecurity automation solutions to keep our clients updated with the latest standards and technologies. Our commitment to OSCAL streamlines the process of documenting, assessing, and reporting on security controls. This reduces administrative overhead, enhances accuracy, and ensures consistency in compliance efforts.

NIST RMF Automation

IPKeys offers a range of solutions to automate the RMF process, including advanced analytics, industry-driven, DoD-optimized tools, and the use of OSCAL. The toolset incorporates a proprietary correlation engine that integrates cyber monitoring, alerting, and compliance into a single instrument, providing near real-time visualization of RMF cybersecurity data and processes. Talk to our team about ways we can improve your ATO workflow while reducing overheads. Our mission is to provide tailored solutions that streamline the compliance efforts of federal government agencies.

ATO in Cybersecurity – Common FAQs

Let’s address some common questions related to ATO in cybersecurity, providing clarity on federal agency information on this vital topic:

What is the Meaning of ATO in RMF?

ATO in Risk Management Frameworks identifies the government’s official authorization for an information system to operate based on evaluating security controls and risks.

What is a Security Assessment Report (SAR)?

The Security Assessment Report (SAR) summarizes a thorough analysis of an information system’s security controls. It’s a vital part of the Authorization-to-Operate (ATO) process, where a senior agency official decides system authorization based on risk evaluation and security impact analysis.

What are Security Controls?

NIST SP 800-53 security controls are the technical safeguards or countermeasures employed within a federal agency’s information system to manage, operationalize, and technically secure the system. These controls are evaluated during the Federal ATO process to determine whether the associated security controls pose an acceptable level of federal risk.

What is a System Security Plan (SSP)?

The Security Assessment Report (SAR) condenses a comprehensive evaluation of an information system’s security controls. It plays a crucial role in the Authorization-to-Operate (ATO) process, wherein a senior agency official grants system authorization after assessing risks and security impact.

More from IPKeys

Want IPKeys insights and news delivered directly to your email?

We'll notify you when new content is published at the email below (and you can opt-out any time)

Thank you! Your submission has been received!

We will never share your information with any third-parties without your permission, nor will we ever spam you. We take privacy very seriously and you can read our full privacy policy here.