How to run an Assessment of your current Commercial Tennant to assess if you need the GCC.

Introduction

In today's digital age, fire departments rely heavily on technology to manage operations, communicate with team members, and store critical data. However, with the increasing stringency of federal and state regulations, it's imperative for fire departments to assess their current IT environments for compliance risks. This article delves into the detailed steps that fire departments can take to evaluate their Microsoft 365 (M365) environments—specifically those operating on the Commercial Cloud—to determine if a migration to the Microsoft Government Community Cloud (GCC) is necessary.

Why Compliance Matters for Fire and EMS Departments

Fire departments handle a plethora of sensitive information, from emergency response plans to personally identifiable information (PII) of citizens and staff. Regulations such as FedRAMP, DFARS, CJIS, IRS Publication 1075, CCPA, and Critical Infrastructure Protection set stringent standards for how this data must be stored, accessed, and protected.

Risks of Non-Compliance:

• Legal Penalties: Civil and criminal penalties, including hefty fines.
• Loss of Funding: Potential loss of federal or state funding and partnerships.
• Operational Risks: Compromised emergency response capabilities due to data breaches or system failures.
• Reputational Damage: Loss of public trust and credibility.

Steps to Assess Your M365 Environment

1. Conduct a Comprehensive Data Inventory

Objective: Identify and classify all data stored within your M365 environment to understand what sensitive information you possess.

Actions:

• Use Data Classification Tools:Navigate to the Microsoft 365 Compliance Center. Utilize "Sensitive Info Types" under "Classification" to detect data such as Social Security Numbers, health records, and criminal justice information.
• Create Custom Classifications: If needed, define custom sensitive information types relevant to your department.
• Run Content Searches: Use the "Content Search" feature to locate and review sensitive data.

Benefits:

• Risk Identification: Pinpoint areas where sensitive data may be at risk.
• Prioritization: Focus efforts on securing the most critical data first.

2. Leverage Compliance Manager for Gap Analysis

Objective: Utilize Microsoft's Compliance Manager to assess your current compliance posture against relevant regulations.

Actions:

• Access Compliance Manager: In the Compliance Center, select "Compliance Manager".
• Add Assessments: Include assessments for regulations such as FedRAMP, CJIS, and IRS Publication 1075.
• Review Control Implementations: Examine required controls and identify which ones are not fully implemented.
• Generate Reports: Export detailed reports for stakeholder review.

Benefits:

• Detailed Insights: Understand specific compliance gaps in your current environment.
• Actionable Data: Receive recommendations on how to address deficiencies.

3. Implement Data Loss Prevention (DLP) Policy Testing

Objective: Simulate DLP policies to detect how often sensitive data is being shared or handled improperly.

Actions:

• Create Test DLP Policies: Use templates related to PII, financial data, and criminal justice information.
• Set Policies to Audit Mode: Configure policies in "Audit only" mode to monitor without disrupting operations.
• Monitor and Analyze Incidents: Review DLP reports to understand the frequency and context of policy matches.

Benefits:

• Awareness: Gain visibility into potential data leakage points.
• Proactive Measures: Adjust policies and training to mitigate risks.

4. Review Audit Logs and User Activity

Objective: Examine how users interact with sensitive data to identify any non-compliant behaviors.

Actions:

• Access Audit Logs: In the Compliance Center, navigate to "Audit log search".
• Filter Relevant Activities: Focus on actions like "File accessed", "File shared", and "Email sent with attachments".
• Analyze Patterns: Look for unauthorized access or unusual activity involving sensitive data.

Benefits:

• Behavioral Insights: Understand user practices that may put data at risk.
• Training Opportunities: Identify areas where staff education is needed.

5. Evaluate Security and Conditional Access Policies

Objective: Ensure your security configurations meet the baseline requirements of necessary regulations.

Actions:

• Access Azure AD Security Settings: Go to Azure Active Directory > "Security" > "Conditional Access".
• Assess Policies: Check for enforcement of multi-factor authentication (MFA), device compliance, and location-based access.
• Align with Regulations: Cross-reference your policies with requirements from FedRAMP, CJIS, etc.

Benefits:

• Strengthened Security Posture: Mitigate unauthorized access risks.
• Regulatory Alignment: Ensure adherence to specific security mandates.

6. Verify Data Residency and Sovereignty

Objective: Confirm that your data is stored in compliant geographical locations.

Actions:

• Check Data Locations: In M365 admin center, review "Organization Profile" for data residency details.
• Assess Compliance: Ensure data is stored within regions approved by relevant regulations.

Benefits:

• Regulatory Compliance: Avoid violations related to data sovereignty.
• Risk Reduction: Minimize exposure to foreign data access laws.

7. Scrutinize Third-Party App Integrations

Objective: Identify any third-party applications connected to your M365 environment that may not meet compliance standards.

Actions:

• List Integrated Apps: In Azure AD, navigate to "Enterprise applications".
• Review Permissions and Compliance: Examine each app's access level and verify its compliance certifications.
• Remove or Replace Non-Compliant Apps: Disconnect apps that pose a risk and seek compliant alternatives.

Benefits:

• Enhanced Security: Reduce potential vulnerabilities introduced by third-party apps.
• Compliance Assurance: Ensure all connected services meet regulatory requirements.

8. Use Microsoft Secure Score for Security Assessment

Objective: Evaluate and improve your security posture using Microsoft's Secure Score.

Actions:

• Access Secure Score Dashboard: In M365 admin center, select "Microsoft Secure Score".
• Review Recommendations: Implement suggested actions that align with compliance needs.
• Monitor Progress: Track improvements in your score over time.

Benefits:

• Quantifiable Metrics: Understand your security level in measurable terms.
• Focused Improvements: Prioritize actions that have the most significant impact.

9. Consult Microsoft's Compliance Documentation

Objective: Understand the compliance certifications and limitations of the Commercial Cloud versus GCC.

Actions:

• Visit Microsoft Trust Center: Explore Microsoft's Compliance Offerings.
• Compare Certifications: Note which regulations are fully supported only in GCC.
• Document Gaps: Highlight areas where the Commercial Cloud falls short.

Benefits:

• Informed Decision-Making: Use concrete data to justify the need for migration.
• Strategic Planning: Align IT strategy with compliance requirements.

10. Perform Authorized Security Testing

Objective: Conduct penetration testing and vulnerability scanning within Microsoft's guidelines to identify security weaknesses.

Actions:

• Review Testing Policies: Follow Microsoft's Penetration Testing Rules of Engagement.
• Use Approved Tools: Employ tools that are permitted under Microsoft's policies.
• Focus on High-Risk Areas: Target sensitive data repositories and critical services.

Benefits:

• Vulnerability Identification: Uncover hidden security flaws.
• Risk Mitigation: Develop strategies to address discovered vulnerabilities.

Interpreting the Results

After completing these steps, fire departments should have a clear understanding of:

• Compliance Gaps: Specific areas where the Commercial Cloud does not meet regulatory requirements.
• Security Risks: Vulnerabilities that could lead to data breaches or non-compliance.
• Actionable Insights: Concrete data to support the migration to GCC.

The Case for Migrating to GCC

Enhanced Compliance:

• Regulatory Alignment: GCC is designed to meet the compliance needs of government entities, covering FedRAMP, CJIS, and more.
• Data Residency: Ensures data is stored within compliant U.S. data centers.

Improved Security:

• Isolated Environment: GCC provides a dedicated infrastructure for government agencies, reducing exposure to risks present in the Commercial Cloud.
• Advanced Features: Access to security and compliance features not available in the Commercial Cloud.

Operational Benefits:

• Collaboration: Securely share information with other agencies and law enforcement.
• Trust: Demonstrate commitment to protecting sensitive data, bolstering public confidence.

Next Steps for Fire Departments

1. Engage Stakeholders: Present findings to leadership and decision-makers.
2. Develop a Migration Plan: Outline the steps, timeline, and resources needed to transition to GCC.
3. Seek Expert Guidance: Consider consulting with IT compliance specialists or Microsoft partners experienced in GCC migrations.
4. Educate Staff: Provide training on new policies and procedures to ensure a smooth transition.

Conclusion

Assessing your M365 environment is not just a regulatory necessity but a critical component of your department's mission to protect and serve. By proactively identifying compliance gaps and security risks, fire departments can make informed decisions about migrating to more secure and compliant platforms like Microsoft GCC.

Remember: The safety of your data is as important as the safety of your community. Taking these steps today can prevent significant legal, financial, and reputational repercussions tomorrow.

A sample form letter from an IT worker within a Fire Department to discuss this topic with management.

Dear Chief [Fire Chief's Last Name],

In light of our ongoing discussions about migrating to the Microsoft Government Community Cloud (GCC), I wanted to provide a comprehensive overview of the steps we can take to assess our current Microsoft 365 (M365) environment. This assessment will help us identify any content that does not meet the compliance requirements of regulations such as FedRAMP, DFARS, CJIS, IRS Publication 1075, CCPA, and Critical Infrastructure Protection.

Purpose of the Assessment

The goal is to:

• Identify Non-Compliant Data: Determine if our current M365 tenant stores or processes data that falls under these regulations.
• Evaluate Compliance Risks: Understand the potential risks associated with keeping such data in the Commercial Cloud.
• Support Migration Decision: Provide concrete evidence to justify the need for migrating to the GCC.

Assessment Steps

1. Inventory of Stored Data

Action:

• Data Classification: Use Microsoft's data classification tools to scan and classify data stored in emails, SharePoint, OneDrive, and Teams.

How-To:

• Access Microsoft 365 Compliance Center: Navigate to the Compliance Center via the admin portal. Go to "Classification" > "Sensitive info types".
• Use Built-in Sensitive Information Types: Microsoft provides predefined sensitive information types that align with various regulations. Examples include Social Security Numbers, Tax Identification Numbers, Criminal Justice data identifiers, etc.
• Create Custom Sensitive Information Types (if needed): Define custom types to match specific data unique to our department.
• Run Content Searches: Use the "Content Search" tool to locate data matching these sensitive types. Export reports summarizing findings.

Explanation:

By classifying and inventorying our data, we can identify specific instances where sensitive information is stored in the Commercial Cloud, which may not meet the strict compliance requirements.

2. Analyze Compliance Using Compliance Manager

Action:

• Compliance Score Evaluation: Utilize the Compliance Manager to assess our compliance posture against relevant regulations.

How-To:

• Access Compliance Manager: In the Compliance Center, navigate to "Compliance Manager".
• Select Relevant Assessments: Add assessments for FedRAMP, CJIS, IRS Publication 1075, etc.
• Review Control Implementations: Examine the list of controls required by each regulation. Identify which controls are not fully implemented in our current environment.
• Generate Reports: Export assessment reports to document compliance gaps.

Explanation:

The Compliance Manager provides a detailed breakdown of compliance requirements and our current status, highlighting areas where the Commercial Cloud may not fulfill specific regulatory controls.

3. Conduct Data Loss Prevention (DLP) Policy Testing

Action:

• Simulate DLP Policies: Implement test DLP policies to detect and report on the transmission of sensitive data.

How-To:

• Navigate to DLP Policies: In the Compliance Center, go to "Policies" > "Data loss prevention".
• Create Test Policies: Use templates for regulations like "U.S. Personally Identifiable Information (PII)", "Financial Data", "Criminal Justice", etc.
• Configure Policy Settings: Set policies to "Audit only" mode to prevent disruption.Define the scope to include emails, SharePoint, OneDrive, and Teams.
• Monitor Policy Matches: Allow the policies to run for a set period (e.g., one week).Review the DLP reports to see how often sensitive data is identified.
• Assess Findings: Analyze incidents where sensitive data was detected, indicating potential compliance issues.

Explanation:

DLP policies help us understand how frequently sensitive data is handled in ways that may violate compliance standards, emphasizing the need for a more secure environment.

4. Evaluate Audit Logs and User Activity

Action:

• Review Audit Logs: Examine user activities related to sensitive data access and sharing.

How-To:

• Access Audit Log Search: In the Compliance Center, navigate to "Audit" > "Audit log search".
• Search for Specific Activities: Filter activities such as "File accessed", "File shared", "Email sent with attachments", etc.
• Focus on Sensitive Data Locations: Narrow down the search to locations known to store sensitive data.
• Export and Analyze Logs: Export the logs for detailed analysis. Look for patterns of potential non-compliant behavior.

Explanation:

Understanding how data is accessed and shared can reveal vulnerabilities and compliance issues, particularly if sensitive data is being mishandled.

5. Assess Conditional Access and Security Policies

Action:

• Review Security Configurations: Check if our security settings meet the baseline requirements of the relevant regulations.

How-To:

• Access Azure AD Conditional Access: Go to the Azure Active Directory admin center. Navigate to "Security" > "Conditional Access".
• Evaluate Policies: Check if policies enforce multi-factor authentication (MFA), device compliance, and location restrictions.
• Compare with Regulatory Requirements: Refer to security control requirements from FedRAMP, CJIS, etc. Identify discrepancies in our current policies.

Explanation:

Regulations often require strict access controls. Identifying gaps in our security policies can highlight areas where the Commercial Cloud may fall short.

6. Check for Data Residency and Sovereignty Compliance

Action:

• Verify Data Storage Locations: Ensure that our data is stored within compliant geographical locations.

How-To:

• Review Data Location Settings: In the M365 admin center, check the "Organization Profile" for data residency details.
• Identify Data Centers Used: Determine which Microsoft data centers host our data.
• Compare with Compliance Requirements: Some regulations require data to be stored within the U.S. or specific regions.
• Document Findings: Note any data stored outside compliant locations.

Explanation:

Data residency is crucial for compliance with certain regulations. The GCC ensures data is stored within compliant U.S. data centers, which may not be guaranteed in the Commercial Cloud.

7. Evaluate Third-Party App Integrations

Action:

• Assess Connected Apps: Identify third-party applications integrated with M365 that may not meet compliance standards.

How-To:

• List All Integrated Apps: In the Azure AD admin center, navigate to "Enterprise applications".
• Review App Permissions: Examine what data and permissions each app has access to.
• Check Compliance Status: Research whether these apps are compliant with our required regulations.
• Disable Non-Compliant Apps: Consider disabling or replacing apps that pose compliance risks.

Explanation:

Third-party apps can introduce vulnerabilities. Ensuring they meet compliance standards is essential to maintaining overall compliance.

8. Perform Security Risk Assessments

Action:

• Use Secure Score: Leverage Microsoft Secure Score to identify security weaknesses.

How-To:

• Access Secure Score: In the M365 admin center, go to "Microsoft Secure Score".
• Review Recommendations: Look at suggested actions to improve security.
• Implement Improvements: Prioritize actions that align with regulatory compliance requirements.
• Track Progress: Monitor changes in the Secure Score as improvements are made.

Explanation:

A higher Secure Score indicates a stronger security posture, which is integral to meeting compliance obligations.

9. Consult Regulatory Compliance Documentation

Action:

• Compare M365 Commercial Cloud Certifications with Requirements: Identify gaps in regulatory certifications between the Commercial Cloud and GCC.

How-To:

• Access Microsoft's Trust Center: Visit the Microsoft Trust Center.
• Review Compliance Offerings: Compare the certifications and attestations held by M365 Commercial Cloud and GCC.
• Document Discrepancies: Note which regulations are fully supported only in the GCC.

Explanation:

Understanding the inherent compliance limitations of the Commercial Cloud reinforces the necessity to migrate to the GCC.

10. Engage in Penetration Testing and Vulnerability Scanning

Action:

• Conduct Security Tests: Perform authorized security testing to identify vulnerabilities.

How-To:

• Follow Microsoft's Testing Guidelines: Review Microsoft's Penetration Testing Rules of Engagement.
• Use Approved Tools: Utilize tools that are permitted within Microsoft's policies.
• Focus on Sensitive Data Repositories: Target areas where sensitive data is stored.
• Analyze Results: Identify vulnerabilities that could lead to non-compliance.

Explanation:

Security testing can uncover weaknesses that may not be evident through configuration reviews alone, highlighting risks that the GCC's enhanced security features could mitigate.

Conclusion and Next Steps

Summary:

By performing these assessments, we can:

• Identify Compliance Gaps: Clearly see where our current environment falls short.
• Quantify Risks: Understand the potential impact of non-compliance.
• Support Migration Justification: Provide evidence-based reasons for moving to the GCC.

Recommendations:

• Proceed with Assessments: Authorize the IT team to carry out these tests.
• Review Findings Together: Schedule a meeting to discuss the results and implications.
• Develop Migration Plan: Based on the findings, finalize our migration strategy to the GCC.

Assistance Offer:

I am fully prepared to lead this assessment and coordinate with our IT staff to ensure it's conducted thoroughly and efficiently.

Final Thoughts

Chief, conducting these tests will provide us with a clear picture of our compliance posture and the risks associated with remaining on the Commercial Cloud. It is a crucial step in safeguarding our department's data, operations, and reputation.

Please let me know if you have any questions or need further clarification on any of these steps.

Respectfully,

[Your Signature]

[Your Name] Project Manager [Fire Department] [Contact Information]

Attachments:

• Detailed Assessment Plan
• Microsoft Compliance Resources
• Proposed Timeline for Assessment Activities