What evidence do auditors commonly ask for on CA-7(3) Continuous Monitoring | Trend Analyses?

Organizational continuous monitoring strategy; System-level continuous monitoring strategy; Assessment, authorization, and monitoring policy; Procedures addressing continuous monitoring of system controls; Privacy controls; Assessment report.

What is the most common gap auditors find on CA-7(3)?

Continuous monitoring frequencies and activities are never adjusted using trend analysis of empirical data

NIST SP 800-53 Rev 5 · CA - Assessment, Authorization, and Monitoring

`CA-7(3)` Continuous Monitoring | Trend Analyses

Employ trend analyses to determine if control implementations, the frequency of continuous monitoring activities, and the types of activities used in the continuous monitoring process need to be modified based on empirical data.

Source: NIST SP 800-53 Rev 5, CA-7(3). The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open NIST SP 800-53 Rev 5 in the compliance library.

Base controls and their enhancements. Which apply follows the baseline you are assessed against (for example FedRAMP Moderate or High, or the low, moderate and high baselines of SP 800-53B). Text in square brackets is a parameter your organisation sets.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

System monitoring records · SIEM / log platform

periodic reviewEvidence produced at each review

Assessment report · SIEM / log platform
Impact analyses · SIEM / log platform
Test of Mechanisms supporting trend analyses · SIEM / log platform

governing documentDocuments that govern the control

Organizational continuous monitoring strategy · Policy repository / GRC workspace
System-level continuous monitoring strategy · Policy repository / GRC workspace
Assessment, authorization, and monitoring policy · Policy repository / GRC workspace
Procedures addressing continuous monitoring of system controls · Policy repository / GRC workspace
Privacy controls · Policy repository / GRC workspace
Plan of action and milestones · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your SIEM / log platform on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

Continuous monitoring frequencies and activities are never adjusted using trend analysis of empirical data
Monitoring data is collected but no trend analyses are performed or recorded

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 sheet

CA-7(1) Continuous Monitoring | Independent Assessment · CA-7(4) Continuous Monitoring | Risk Monitoring