SC-36(2)·high·Component: System and Communications ProtectionWhat this control requires
Synchronize organization-defined duplicate systems or system components to ensure that data and services are consistent across distributed locations. This synchronization supports mission or business functions by ensuring that information stored in redundant systems is available and reliable when needed, as required by SC-36 and CP-9(6). This control supports the Synchronization Mechanism capability within the System and Communications Protection family.
In plain English
Synchronize organization-defined duplicate systems or system components to ensure that data and services are consistent across distributed locations. 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 System and Communications Protection, the assessor will trace your implementation back to the catalogue reference (Control SC-36(2)) and look for objective evidence on the latest two assessment cycles.
How to implement
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.
- Information. Document the trigger, the owner and the cadence.
- Data. Document the trigger, the owner and the cadence.
- Consistent. Document the trigger, the owner and the cadence.
- Protection. Document the trigger, the owner and the cadence.
- Scope: management, information, mission, organization, system, functions, protection, components.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policy or standard documents the safeguard. Focus: Synchronization.
Common pitfalls
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
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.
- NIST SP 800-171 Rev. 3 3.4.11 — Information Location
- ISO/IEC 27001:2022 A.5.21 — Managing information security in the ICT supply chain
- HIPAA (45 CFR Part 164) 164.308(a)(1)(ii)(D) — Security Management Process -Information System Activity Review
Related controls in NIST SP 800-53 Rev. 5
- Control SC-30 — Concealment And Misdirection
- Control SC-15(4) — Explicitly Indicate Current Participants
- Control PE-21 — Electromagnetic Pulse Protection
- Control SA-4(4) — Assignment Of Components To Systems
- Control SA-8(1) — Clear Abstractions
- Control SC-29 — Heterogeneity
References
- NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
- Catalogue identifier:
Control SC-36(2)
Topics: governance riskpolicy management