CP-8(3)·high·Component: Contingency PlanningWhat this control requires
Acquire alternate telecom services from providers separate from the primary to reduce shared vulnerabilities. Ensure continuity during disruptions. If using the same provider, verify physical/logical separation per risk assessments. This control supports the Diversification capability within the Contingency Planning family.
In plain English
Acquire alternate telecom services from providers separate from the primary to reduce shared vulnerabilities. In practice, this means you can prove you policy management-level controls on a defined cadence.
Why it matters
SP 800-53 is the catalogue every U.S. federal authorisation (FedRAMP, FISMA, CMMC) and most regulated industries point at. A missing control surfaces as a Plan of Action & Milestones (POA&M) item that an Authorizing Official must approve before the Authority To Operate is granted or renewed.
This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.
What an auditor looks for
A 3PAO (FedRAMP) or Independent Assessor (NIST RMF) tests against NIST SP 800-53A assessment procedures. For each control they expect a documented implementation that addresses every assessment objective (Examine, Interview, Test) and an implementation summary in the System Security Plan.
Within Contingency Planning, the assessor will trace your implementation back to the catalogue reference (Control CP-8(3)) and look for objective evidence on the latest two assessment cycles.
How to implement
Business Continuity
BC/DR. Define RTO/RPO per service, test backup restoration quarterly, and run a tabletop of full-region failover annually.
Backups. Immutable backups (S3 Object Lock / Azure immutable storage / GCS bucket lock) plus an air-gapped copy for ransomware resilience.
Physical Security
Inheritance. For cloud-only operations, inherit physical controls from the provider's SOC 2 / ISO 27001 report and document the inheritance in the SoA.
Policy Management
Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.
Operational checklist
- Policy. Document the trigger, the owner and the cadence.
- Security. Document the trigger, the owner and the cadence.
- Physical. Document the trigger, the owner and the cadence.
- Separation. Document the trigger, the owner and the cadence.
- Separate. Document the trigger, the owner and the cadence.
- Scope: management, assessments, services, capability, security policy, vulnerability, separation.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policy or standard documents the safeguard. Focus: Separation Of Primary And Alternate Providers.
Common pitfalls
- DR plans that have never been tested in earnest, or that depend on an MFA token only one person can produce.
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
- Scans that hit only the perimeter; missing authenticated scans of OS, runtime libs and base images so most CVEs are invisible.
How it maps to other frameworks
Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.
- ISO/IEC 27001:2022 A.7.3 — Securing offices, rooms and facilities
- HIPAA (45 CFR Part 164) 164.308(a)(5)(i) — Security Awareness and Training
- NIST SP 800-171 Rev. 3 3.12.1 — Security Assessment
- BSI C5:2020 SP-01 — Documentation, communication and provision of policies and instructions
- CIS Controls v8 7.1 — Establish and Maintain a Vulnerability Management Process
Related controls in NIST SP 800-53 Rev. 5
- Control CP-7(1) — Separation From Primary Site
- Control CP-7(2) — Accessibility
- Control SA-19(4) — Anti-Counterfeit Scanning
- Control CP-8 — Telecommunications Services
- Control SA-8(7) — Reduced Complexity
- Control SA-12(11) — Penetration Testing / Analysis Of Elements, Processes, And Actors
References
- NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
- Catalogue identifier:
Control CP-8(3)
Topics: governance riskbusiness continuityphysical securitypolicy managementvulnerability management