What evidence do auditors commonly ask for on CP-9(3) System Backup | Separate Storage for Critical Information?

Contingency planning policy; Procedures addressing system backup; Contingency plan; Backup storage location(s); System backup configurations and associated documentation; System backup logs or records.

What is the most common gap auditors find on CP-9(3)?

Backups of the organization-defined critical software and security information are kept in the same facility as the operational system

NIST SP 800-53 Rev 5 · CP - Contingency Planning

`CP-9(3)` System Backup | Separate Storage for Critical Information

Store backup copies of organization-defined critical system software and other security-related information in a separate facility or in a fire rated container that is not collocated with the operational system.

Source: NIST SP 800-53 Rev 5, CP-9(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 backup logs or records · Backup / DR tooling

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Contingency planning policy · Policy repository / GRC workspace
Procedures addressing system backup · Policy repository / GRC workspace
Contingency plan · Policy repository / GRC workspace
Backup storage location(s) · Policy repository / GRC workspace
System backup configurations and associated documentation · Policy repository / GRC workspace
System security plan · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Backup / DR tooling 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

Backups of the organization-defined critical software and security information are kept in the same facility as the operational system
Critical security-related information to be stored separately was never defined, so separate storage cannot be verified

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

CP-9(2) System Backup | Test Restoration Using Sampling · CP-9(5) System Backup | Transfer to Alternate Storage Site