SA-4(12)_data-ownership
DevOps & SecurityInclude organizational data ownership requirements in the acquisition contract;
How to use this skill
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SA-4(12) Data Ownership
Enhancement of: SA-4
High-Level Description
Family: System and Services Acquisition (SA) Framework: NIST SP 800-53 Rev 5
Contractors who operate a system that contains data owned by an organization initiating the contract have policies and procedures in place to remove the data from their systems and/or return the data in a time frame defined by the contract.
What to Check
- Verify SA-4(12) Data Ownership is documented in SSP
- Validate all 2 control requirements are implemented
- Confirm control is operating effectively
- Review evidence of continuous monitoring for SA-4(12)
- Verify enhancement builds upon base control SA-4
How to Test
Step 1: Review Documentation
Examine the System Security Plan (SSP) and related artifacts for SA-4(12) implementation details. Verify the organization has documented how this control is satisfied.
Step 2: Validate Implementation
# For cloud environments, use cloud-audit-mcp tools
# For on-premises, review system configurations directly
# Example: Check if account management policies exist
grep -r "account.management\|access.control" /etc/security/ 2>/dev/null
Step 3: Test Operating Effectiveness
Verify the control is actively functioning, not just documented. Check logs, configurations, and operational evidence.
Tools
| Tool | Purpose | Usage |
|---|---|---|
| Manual Review | Documentation and interview-based | N/A |
Remediation Guide
Control Statement
Include organizational data ownership requirements in the acquisition contract; and Require all data to be removed from the contractor’s system and returned to the organization within [organization-defined].
Implementation Guidance
Contractors who operate a system that contains data owned by an organization initiating the contract have policies and procedures in place to remove the data from their systems and/or return the data in a time frame defined by the contract.
Risk Assessment
| Finding | Severity | Impact |
|---|---|---|
| SA-4(12) Data Ownership not implemented | Medium | System and Services Acquisition |
| SA-4(12) partially implemented | Low | Incomplete System and Services Acquisition |
CWE Categories
| CWE ID | Title |
|---|---|
| CWE-16 | Configuration |
References
- NIST SP 800-53 Rev 5 - SA-4(12)
- NIST SP 800-53A Rev 5 (Assessment Procedures)
- NIST SP 800-53 Rev 5 Full Catalog
Checklist
- Control documented in SSP
- Implementation evidence collected
- Operating effectiveness validated
- Continuous monitoring in place
- Related controls (none) reviewed