Vice President, Operations
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) ProcessATO 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 PackageAs 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
Step 2: Authorization Package SubmissionFor 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 DecisionBased 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 DocumentThere 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