CA-8 Penetration Testing
Conduct penetration testing annually on FedRAMP-defined systems and components.
6
artefacts
0
held by a system
2
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Control assessment report with tester names and dates · Document repository
- Authorization to operate memorandum signed by the authorizing official · Document repository
governing documentDocuments that govern the control
- Control implementation statement for CA-8 citing the system mission and inheritance from common controls · Document repository
- Independent assessor statement of independence · Document repository
- System security plan covering the authorization boundary · Policy repository / GRC workspace
- Plan of action and milestones tracking open findings · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- Continuous monitoring metrics collected but not reported to leadership
- Assessment scope omits inherited cloud provider controls
- Reauthorization scheduled past the policy required interval
- Authorization boundary description does not match the asset inventory
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetCA-7(4) Continuous Monitoring | Risk Monitoring. Ensure risk monitoring is an integral part of the continuous monitoring strategy that includes the following: (a) Effectiveness monitoring; (b) Compliance monitoring; and (c) Change monitoring · CA-8(1) Penetration Testing | Independent Penetration Testing Agent or Team. Employ an independent penetration testing agent or team to perform penetration testing on the system or system components