SA-21 Developer Screening. Require that the developer of [organization-defined]: Has appropriate access authorizations as determined by assigned [organization-defined] ; and Satisfies the following additional personnel screening criteria: [organization-defined]
Developer Screening. Require that the developer of [organization-defined]: Has appropriate access authorizations as determined by assigned [organization-defined] ; and Satisfies the following additional personnel screeni.
5
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
- The additional personnel screening criteria defined, and evidence each developer satisfies them · HR system / LMS
- Records of rescreening or of access withdrawal when a developer no longer meets the criteria · Document repository
governing documentDocuments that govern the control
- Definition of the systems, components or services whose developers must be screened · Document repository
- The assigned access authorisations required of those developers · Document repository
- Contract clauses imposing the screening requirement on the developer organisation · HR system / LMS
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
- Screening imposed on the prime developer with subcontracted developers unscreened
- Screening evidence held by the developer and never verified by the organisation
- No re-screening trigger, so authorisation persists after the basis for it lapses
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 sheetSA-20 Customized Development of Critical Components. Reimplement or custom develop the following critical system components: [organization-defined] · SA-22 Unsupported System Components