ISC2 Governance, Risk and Compliance (CGRC) Practice Question
After tailoring the moderate-impact control baseline for a new payroll application, the system owner is ready to update the System Security Plan (SSP). Which piece of information must be recorded in the SSP for every baseline control that has been marked "not applicable" to the system?
A detailed budget forecast for implementing all remaining baseline controls.
Formal minutes from the risk executive meeting at which the baseline was approved.
A documented rationale explaining why the control is not applicable to the information system.
The security clearance levels of all senior officials who approved the tailoring decision.
NIST guidance (e.g., SP 800-18 Rev. 1 and SP 800-37 Rev. 2) states that the SSP must capture the status of each selected security control, including any that are not implemented or are deemed not applicable. For such controls, the organization is required to document the rationale-typically a risk-based explanation-showing why the control does not apply to the system's operating environment or mission/business needs. Merely listing budgets, meeting minutes, or audit schedules does not satisfy this requirement, nor is it necessary to record personnel clearance levels when justifying non-applicability. Therefore, the SSP must contain a justification for the control's non-applicability.
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ISC2 Governance, Risk and Compliance (CGRC)
Selection and Approval of Framework, Security, and Privacy Controls
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