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NISP eMASS DAAPM DCSA | Guidance on Hibernation Procedures

On March 20 2020, DCSA issued a news bulletin discussing the challenges with COVID and measures that cleared contractors should be aware of regarding periods of system inactivity (i.e., hibernation).  In short, if a facility plans to stop work for an extended period of time, an audit variance may be authorized, which will require a Standard Operating Procedure (SOP) to be in place that specifies how the system will be protected during a dormant state. 

As such, DCSA wants to see proof of documented Hibernation procedures, “if” an audit variance is ever requested. This means cleared contractors should develop a formalized - and documented - SOP for system hibernation and include it in their Contingency Plan, or as a stand-alone document.  Hibernation beyond 180 days is permitted only with AO approval. Cleared contractors are to contact their assigned ISSP to determine requirements to obtain AO approval for the hibernation request.

Per the DAAPM, a system hibernation SOP is to include a process for protecting the system using physical security controls (e.g., seals, locks, alarms, and GSA-approved containers), technical controls (e.g., whole disk encryption, disabled accounts, and audit logs), and immediate patching/updates upon return to service.

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