SA-4(12)_data-ownership

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

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

CWE Categories

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