We have a client who wants to connect to snowflake in tenant environment. When I asked chatgpt- it provided an interesting answer- which I want opinions on:
Factors Influencing Boundary Determination
a. Ownership and Control
**Inside the Boundary:** If the organization that owns the analytics system also controls and manages the external data source, or if the data source is part of the same FedRAMP authorization, it might be considered inside the boundary. This means the organization has direct control over security, configuration, and maintenance.
**Outside the Boundary:** If the data source is managed by a different organization or is a third-party service, it is typically outside the boundary. The analytics system would rely on an interconnection agreement or a defined API/data exchange mechanism for accessing this external data source.
b. Data Flow and Integration
**Inside the Boundary:** If the external data source is fully integrated with the analytics system, and the data from the source becomes an inherent part of the analytics system’s processing, storage, or analysis, it might be considered inside the boundary. This typically applies when the data source feeds data in real-time or continuously into the analytics environment.
**Outside the Boundary:** If the external data source is accessed intermittently or used in a way where data flows in and out without permanent storage, the external source usually remains outside the boundary. In this case, the analytics system pulls data, performs analysis, and then discards it or returns results.
c. Security and Authorization
**Inside the Boundary:** If the security controls, access management, and data protection measures of the external data source fall under the same security framework as the analytics system (e.g., covered under the same FedRAMP authorization), it may be considered inside the boundary.
**Outside the Boundary:** If the external data source operates under a different security policy or is not covered by the analytics system's FedRAMP authorization, it is outside the boundary. Any connection between the systems would then need to be authorized through a formal interconnection agreement.
Scenario 2: External Data Source (Outside the Boundary)
The same FedRAMP-authorized analytics platform needs to connect to a third-party weather data provider via API to include weather patterns in its analysis.
The weather data provider is managed by an external organization, and the analytics system does not control how the provider secures or maintains its data.
In this case, the weather data provider is **outside the boundary**, as it operates independently, and the analytics platform only ingests data through defined API calls.
Referencing:
1. FedRAMP Documentation and Guidance
- FedRAMP Authorization Boundary Guidance: FedRAMP provides explicit guidance on defining system boundaries within its "FedRAMP Authorization Boundary Guidance" document. This document emphasizes the need to clearly delineate which components, services, and data flows are inside or outside the system boundary, including how interconnected systems should be handled.
- FedRAMP System Security Plan (SSP) Template: The FedRAMP SSP template requires CSPs to identify the system boundary and describe any external information systems with which it communicates. This template helps distinguish between what is managed within the system and what is considered an external or interconnected system.
Reference:
- FedRAMP Authorization Boundary Guidance
2. NIST Special Publication 800-53 Rev. 5 (Security and Privacy Controls)
- CA-3: System Interconnections: NIST SP 800-53, a fundamental security control framework used by FedRAMP, includes Control CA-3, which focuses on system interconnections. It requires organizations to authorize, document, and monitor information exchanges between systems, emphasizing the distinction between an organization's system and external systems. This control highlights that interconnected systems outside the organization’s direct control should be treated as external systems and require an Interconnection Security Agreement (ISA) or other formal documentation.
- CA-9: Internal System Connections: This control provides guidance on how internal connections are managed, reinforcing the idea that if a system or service is fully managed within the boundary, it remains internal, but if it’s managed externally, it falls outside.
Reference:
3. NIST Special Publication 800-37 Rev. 2 (Risk Management Framework)
- System Boundary Definition: NIST SP 800-37 provides guidance on implementing the Risk Management Framework (RMF) and defines how to establish system boundaries. It stresses the importance of defining the scope of the system by considering all components, data flows, and interconnections. It distinguishes between internal and external systems, requiring organizations to identify systems within their operational control versus those managed by other entities.
Reference:
4. NIST Special Publication 800-47 (Security Guide for Interconnecting Information Technology Systems)
- This publication provides detailed guidance on establishing and managing interconnections between different information systems. It emphasizes that systems managed by different entities, even when interconnected, are considered separate systems and require formal agreements (ISA/MOU) to govern the relationship.
Reference:
Summary of How These References Back Up the Conclusion:
- FedRAMP's Authorization Boundary Guidance establishes how systems must clearly define their boundary, including external versus internal systems.
- NIST SP 800-53 (CA-3) requires documenting and controlling connections with external systems, reinforcing that interconnected systems managed by different organizations are outside the boundary.
- NIST SP 800-37 emphasizes defining the system boundary and distinguishing between components under organizational control versus external systems.
- NIST SP 800-47 further clarifies the need for agreements to manage interconnections between systems controlled by different organizations.
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