SA-9 External System Services
a. Require that providers of external system services comply with organizational security and privacy requirements and employ the following controls: organization-defined controls; b. Define and document organizational oversight and user roles and responsibilities with regard to external system services; and c. Employ the following processes, methods, and techniques to monitor control compliance by external service providers on an ongoing basis: organization-defined processes, methods, and techniques.
Source: NIST SP 800-53 Rev 5, SA-9. 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.
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
none for this control
periodic reviewEvidence produced at each review
- Test of Organizational processes for monitoring security and privacy control compliance by external service providers on an ongoing basis; mechanisms for monitoring security and privacy control compliance by external service providers on an ongoing basis · SIEM / log platform
governing documentDocuments that govern the control
- System and services acquisition policy · Policy repository / GRC workspace
- System and services acquisition procedures · Policy repository / GRC workspace
- Procedures addressing methods and techniques for monitoring control compliance by external service providers of system services · Policy repository / GRC workspace
- Acquisition documentation · Document repository
- Contracts · Vendor register / contract repository
- Service level agreements · Vendor register / contract repository
- Interagency agreements · Vendor register / contract repository
- Licensing agreements · Vendor register / contract repository
- List of organizational security and privacy requirements for external provider services · Policy repository / GRC workspace
First move
Common gaps auditors find
- External service provider agreements do not require compliance with the organization-defined controls and privacy requirements
- No defined process monitors external service provider control compliance on an ongoing basis
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-8(33) Security and Privacy Engineering Principles | Minimization · SA-9(1) External System Services | Risk Assessments and Organizational Approvals