FedRAMP Authorization: Why ‘Moderate’ Matters

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By Rose Ryan, Cofense Product Marketing Manager

FedRAMP, the federal program created to assess the security of cloud service providers (CSPs), saves time and cuts costs for U.S. government agencies that would otherwise conduct their own assessments. CSPs are granted authorizations at three impact levels: low (includes low-baseline and low-impact SaaS “li-SaaS”), moderate, and high, aligned to the impact levels based on NIST guidelines. While the high-impact level protects the most sensitive government data, the moderate-impact level meets the needs of many agencies. And the gaping chasm in requirements between moderate and low is revealing.

Why Cofense Didn’t Take the Low Road

Why make the financial commitment, endure a rigorous authorization process and establish a continuous monitoring program when we could have simply self-attested our security controls for a li-SaaS classification? Because Cofense is a security company that prioritizes providing the highest level of protection to our customers, and a low-level certification just wasn’t good enough. That’s why Cofense PhishMe chose FedRAMP Moderate.

Moderate vs. Low Impact Levels

Got PII? Cofense Has You Covered

Cofense recognizes that our products and services handle our customers’ personally identifiable information (PII). That’s why we went all in to certify at the FedRAMP moderate level, complying with 325 stringent controls to secure our customers’ data according to confidentiality, availability, and integrity. A moderate FedRAMP authorized CSP has a far more stringent set of controls as compared to CSP with a low or li-SaaS ranking. See a list of controls here.

The impact level of a moderate service offering is based on the sensitivity of the data that an information system processes, stores, and transmits. Cofense opted for moderate FedRAMP compliance for our PhishMe solution. This required the establishment and documentation of a highly secure environment that will withstand comprehensive, rigorous review before we may engage with Federal agencies as a FedRAMP CSP.

Controls: The Numbers Say It All

Additional security controls are added as the levels progress to ensure that government data is adequately protected. High-level systems have 421 baseline controls, moderate-level systems have 325 controls, while low-level systems have only 125 controls and li-SaaS require a minimal 36 controls. Cofense opted for the moderate level, which will allow us to support a mass of government agencies.Additional security controls are added as the levels progress to ensure that government data is adequately protected.

Continuous Assurance with Cofense

With a moderate FedRAMP authorized solution, there is a strict security implementation as well as operational requirements that PII data be protected. With a li-SaaS implementation, there is no such assurance. And it doesn’t end there. FedRAMP requires that authorized CSPs engage in continuous monitoring after authorization is achieved. The authorization can be revoked if the CSP is found to be at any point in non-compliance with FedRAMP requirements. Cofense opted for a moderate FedRAMP authorization embracing these strict requirements and ongoing monitoring to meet our customer’s security needs and assure their peace of mind. Cofense PhishMe has been granted FedRAMP Moderate ATO.

Learn moresee how Cofense is participating in the FedRAMP program.

All third-party trademarks referenced by Cofense whether in logo form, name form or product form, or otherwise, remain the property of their respective holders, and use of these trademarks in no way indicates any relationship between Cofense and the holders of the trademarks. Any observations contained in this blog regarding circumvention of end point protections are based on observations at a point in time based on a specific set of system configurations. Subsequent updates or different configurations may be effective at stopping these or similar threats.
The Cofense® and PhishMe® names and logos, as well as any other Cofense product or service names or logos displayed on this blog are registered trademarks or trademarks of Cofense Inc.

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