NIST 800-53 REV 5 • SYSTEM AND SERVICES ACQUISITION
SA-9 — External System Services
Require that providers of external system services comply with organizational security and privacy requirements and employ the following controls: {{ insert: param, sa-09_odp.01 }}; Define and document organizational oversight and user roles and responsibilities with regard to external system services; and Employ the following processes, methods, and techniques to monitor control compliance by external service providers on an ongoing basis: {{ insert: param, sa-09_odp.02 }}.
Supplemental Guidance
External system services are provided by an external provider, and the organization has no direct control over the implementation of the required controls or the assessment of control effectiveness. Organizations establish relationships with external service providers in a variety of ways, including through business partnerships, contracts, interagency agreements, lines of business arrangements, licensing agreements, joint ventures, and supply chain exchanges. The responsibility for managing risks from the use of external system services remains with authorizing officials. For services external to organizations, a chain of trust requires that organizations establish and retain a certain level of confidence that each provider in the consumer-provider relationship provides adequate protection for the services rendered. The extent and nature of this chain of trust vary based on relationships between organizations and the external providers. Organizations document the basis for the trust relationships so that the relationships can be monitored. External system services documentation includes government, service providers, end user security roles and responsibilities, and service-level agreements. Service-level agreements define the expectations of performance for implemented controls, describe measurable outcomes, and identify remedies and response requirements for identified instances of noncompliance.
Practitioner Notes
When your organization uses external services — cloud providers, managed services, outsourced IT — you must ensure those services meet your security requirements. Outsourcing the work does not outsource the risk.
Example 1: Require all external service providers to meet defined security requirements documented in your contracts. Include clauses for incident notification (within 24 hours), data protection standards (encryption at rest and in transit), access controls, and the right to audit or request compliance evidence.
Example 2: For cloud services, review the provider's shared responsibility model to understand exactly what they secure and what you must secure. For Microsoft 365, Microsoft secures the infrastructure; you are responsible for identity management, data classification, DLP policies, and Conditional Access configuration. Document this division of responsibility.