The National Institute of Standards and Technology (NIST) published the first version of its Cybersecurity Framework (CSF) in 2014. Ten years later NIST released the second iteration of CSF, entitled NIST CSF 2.0. Microsoft and its partners have supported organizations in implementing the original CSF guidance, going as far as building and enhancing an assessment in Microsoft Purview Compliance Manager since 2018. This blog and series will look to apply NIST CSF 2.0 to Microsoft 365 and discuss changes from the previous publication.

It is somewhat improper to look at any particular CSF Functions in a vacuum or singular vantage point. NIST CSWP 29 (the primary document) illustrates and describes CSF Functions as “a wheel because all of the Functions relate to one another. For example, an organization will categorize assets under IDENTIFY and take steps to secure those assets under PROTECT. Investments in planning and testing in the GOVERN and IDENTIFY Functions will support timely detection of unexpected events in the DETECT Function, as well as enabling incident response and recovery actions for cybersecurity incidents in the RESPOND and RECOVER Functions. GOVERN is in the center of the wheel because it informs how an organization will implement the other five Functions.”

NIST CSF 2.0 Wheel

Therefore, despite the blog title, there will be occasional references to other CSF Functions and Categories, as well as future blogs covering other Functions. This discussion will also endeavor to focus primarily on Microsoft 365 but venture into Azure topics periodically by the nature of each solution. This blog or any subsequent blogs in the series will not be an exhaustive review of all possible applications of NIST CSF 2.0, nor exhaustive of the technologies mentioned and their abilities to manage cybersecurity risks.

As a final caveat, Amy Adams in Talladega Nights once spoke of one of the most talented individuals behind a wheel this way, “Ricky Bobby is not a thinker. Ricky Bobby is a driver.” I want to believe I might be the latter.

NIST CSF 2.0 – Protect (PR)

PR as a function is intended to cover “safeguards to manage the organization’s cybersecurity risks” and contains five Categories. The prior CSF publication included six categories, but two were significantly edited and renamed. PR.MA: Maintenance for example was mostly removed with remnants found elsewhere. Let’s first dive into PR.AA. NOTE: Text in green are excerpts from CSF documentation.

Identity Management, Authentication, and Access Control (PR.AA): Access to physical and logical assets is limited to authorized users, services, and hardware and managed commensurate with the assessed risk of unauthorized access

Identity and access are not just about directories and networks. Organizations of all sizes and industries are challenged with controlling access to digital estates that are often complex and boundaryless because of accelerated technology adoption. Microsoft Entra’s family of solutions shown below employs a variety of measures to manage access to resources limited to authorized users, services, and hardware.

To meet the spirit of NIST CSF 2.0 PR.AA and a multitude of organizational scenarios, access decisions will need to be based upon periodic and real-time risk assessment. Automated and agile solutions are also necessitated for IT and security teams to avoid the manual processes traditionally associated with granting and managing access rights. Lastly, organizations will need to begin implementing some of the lates phishing-resistant multifactor authentication approaches using FIDO2 security keys, passkey technology, and/or certificate-based authentication to meet the barrage of sophisticated identity threats.

PR.AA-01: Identities and credentials for authorized users, services, and hardware are managed by the organization

Microsoft Entra ID (fka Azure Active Directory) can serve firstly as the management solution of identities and credentials for “authorized users” in Microsoft 365, along with other infrastructure and platforms. In the Entra ID admin center, you can create and manage user accounts, different types of groups (e.g., security groups, distribution groups), and memberships to groups for enhanced access permissions and group-based policies.

Additionally, Microsoft Entra ID Governance comes with Microsoft Entra ID P2 and enables entitlement management, a feature for managing identity and access lifecycle at scale, automating workflows, assignments, reviews, and expirations. Entitlement management is able to bundle together an “access package” consisting of resources like groups, applications, and SharePoint Online site access that users need to perform their tasks or projects. These access packages can be bound to a department, role type, internal vs external user, newly onboarded employees, etc. Lastly, organizations can automate the creation and removal of identities based on employment status, integrating with HCM or HR systems for efficient governance.

Management of “credentials of authorized users” can also include the management of a self-service password reset (SSPR) process for users. Microsoft Entra’s SSPR allows users to change or reset their password without administrator intervention but reliant on thoughtful policy. This feature is designed to reduce help desk calls and improve productivity by enabling users to unblock themselves if they forget their password or get locked out of their account. Administrators can configure the number of methods required for password reset or unlock, and users are prompted to confirm their registered information periodically.

Microsoft Entra External ID also enables internal users to collaborate with external users (guests) by inviting them to your organization, managing guest accounts in the Microsoft Entra admin center or by PowerShell, and ensuring they have appropriate access while maintaining control over your resources. External ID B2B collaboration is particularly useful for inviting external business partners to access apps and resources using their own credentials. This eliminates the need for managing new credentials, as guests authenticate with their home organization or identity provider. However, it is important to document and enforce least privilege per PR.AA-05 below for these users.

Lastly, Microsoft Entra ID allows for central management of device identities and monitoring, with features like viewing total, stale, noncompliant, and unmanaged devices. By registering and joining devices to Entra ID, organizations can enable Seamless Sign-on to both cloud-based and on-premises resources.

Cross-Function Tip: PR.AA-01 could be included in your organization’s plan for the Detect (DE) Function and Continuous Monitoring (DE.CM) Category. Changes and actions taken by administrators in the management process can be “adverse events” resulting from malicious lateral movement or compromised identities.

PR.AA-02: Identities are proofed and bound to credentials based on the context of interactions

Microsoft Entra ID Conditional Access policies can further prove the authenticity of an authorized user and their access activity, and dynamically adjust the bounds of that identity based upon various conditions. A Conditional Access policy can analyze details of a session or authentication attempt based upon conditions such as the network or location of the session, and the current identity risk of a user (leaked credentials, signs of a password spray attack, etc.) Microsoft Entra also uses industry standard continuous access evaluation (CAE) with token protection features to verify identities and assess based upon context.

During the device registration process in your organization, the user’s identity is also bound to the device based upon Microsoft Entra ID policies. Enrolled Windows devices, for example, will have an encrypted session key issued by Microsoft Entra that ensures token requests are not tampered with when a device is accessed, and subsequently Microsoft 365 applications. Other Microsoft Entra ID mechanisms are in place to prove and bound identities within device interactions, as well as prevent various types of credential theft. You can read more about them here.

For high-risk actions, organizations can require a step up proof of identity in real-time using Microsoft Entra Verified ID. 

PR.AA-03: Users, services, and hardware are authenticated

Starting in 2019, Microsoft provides on-by-default multifactor authentication in all new Microsoft 365 tenants. This can be reviewed and controlled in the Microsoft Entra admin center. In addition, Microsoft started automatically rolling out “Microsoft-managed” Conditional Access policies that force an MFA action when an admin signs into the Microsoft 365 admin portal, and when any user attempts a high-risk sign-in.

You can view the policies and their impact using the new policy view user experience in Microsoft Entra. Within the portal, administrators can also review a policy summary, alerts, recommended actions, and an impact summary. Administrators can also create their own custom policies focused on certain users, groups, or roles if scenarios are not covered by the default policies automatically deployed. It is possible to clone a policy and then make changes to an existing templated policy as well to suit these needs.

Cross-Function Tip: PR.AA-03 can be included in your organization’s plan for the Detect (DE) Function and Continuous Monitoring (DE.CM) Category. Security teams can monitor authentication events using sign-in and audit logs with Microsoft Sentinel and reason over them with support from Microsoft Copilot for Security.

PR.AA-04: Identity assertions are protected, conveyed, and verified

For those less familiar with the term “identity assertion(s)”, NIST 800-63C Digital Identity Guidelines gives an explanation of this requirement in greater detail. You can define Microsoft Entra ID as an Identity Provider or IdP that can convey an assertion to a Relying Party (RP), and these “assertions are statements that contain information about a subscriber”. The RP “uses the information in the assertion to identify the subscriber and make authorization decisions about their access to resources controlled by the RP.” In other instances, Microsoft Entra ID could be considered an RP when receiving assertions from an external IdP to grant guest access to Microsoft 365.

Organizations can, as a part of Microsoft Entra ID P1 and P2, configure Microsoft Entra SAML token encryption with RP apps that support SAML assertions. This encryption ensures that the content of the token cannot be intercepted easily, and personal or corporate data remains secure. OpenID Connect (OIDC) alternatively is another method to enable single sign-on with an OAuth-enabled RP app by exchanging ID tokens issued by Microsoft Entra authentication servers. An organization can register an app in the Microsoft Entra admin center to configure both federated SSO scenarios (and others) for conveying, protecting and verifying identity assertions. It’s important to note that even without token encryption, Microsoft Entra ID already requires encrypted HTTPS/TLS channels for token exchanges, adding a layer of security.

As mentioned in PR.AA-01, eternal IdPs or external Microsoft 365 tenants can convey identity assertions to an organization through External ID. A simple invitation and redemption process lets an external party use their own credentials (via their own IdP) to access your company’s resources as the RP. Once the guest redeems their invitation or completes sign-up, they’re represented in your directory as a user object. Below is a sample flow aligned to B2B collaboration guidance, and gates 1-4 & 6 can be configured as allowable or not.

Cross-Function Tip: PR.AA-04 can be included in your organization’s plan for the Govern (GV) Function and Cybersecurity Supply Chain Risk Management (GV.SC) Category. As an organization works with various partners and suppliers, it’s important to ensure “supply chain risk management is integrated into cybersecurity and enterprise risk management”. Compromised identities from a supplier can directly impact external access and identity assertions for example.

PR.AA-05: Access permissions, entitlements, and authorizations are defined in a policy, managed, enforced, and reviewed, and incorporate the principles of least privilege and separation of duties

Beyond identity, credential and authentication management covered in other AA subcategories, this subcategory can necessitate more robust written and technical policies. A solution to consider first is role-based access control (RBAC) enabled by Microsoft Intune and Microsoft Entra, which helps your organization manage who has access to internal resources and what they can do with those resources. By assigning roles to your users, you can limit what they can see and change. A built-In or custom role defines the set of permissions granted to users assigned to that role. Organizations can manage role assignments following least privilege principles to define which users are assigned to the role, resources they can see, and resources they can change.

With Microsoft Entra ID P2, Microsoft Privileged Identity Management (PIM) also allows an organization to manage, enforce, review, and incorporate least privilege and separation of duties for important administrative roles and entitlements. PIM supports a similar degree of control with groups and the associated entitlements and authorizations in Microsoft 365. From a management perspective, an approval process can be enforced to justify an elevation of a user/identity to a more privileged role and documented within PIM for later review if necessary.

Access to critical assets like sensitive data or information in Microsoft 365 may be authorize to users that do not have elevated administrative roles discussed in the previous paragraph. A user may be an analyst within a financial department, a human resources coordinator, or a junior engineer for a research and development project. Users in these roles may not have entitlements to export large quantities of data or grant entitlements to other users but are equally governed by defined written policies and technical policies administered in Microsoft Purview and Microsoft Entra.

An organization can develop Microsoft Purview sensitivity labels to manage and enforce access authorizations for files, emails, and meetings across Microsoft 365: SharePoint, Teams, PowerBI, OneDrive and more. Label policies can then restrict which users or groups of users have authorization to access the labeled content.  

PR.AA-06: Physical access to assets is managed, monitored, and enforced commensurate with risk

From a Microsoft 365 perspective, there is physical access to two different types of assets:

Physical compute resources (such as servers) and networking components at Azure datacenters across the globe
Endpoints (laptop, mobile device, etc.)

According to the shared responsibility model in the cloud, a PaaS and SaaS offering like Microsoft 365 and it’s comprised solutions alleviate the responsibility of managing monitoring or enforcing access control to physical assets hosted in the Azure data center.

Azure datacenters deploy several safeguards to project physical assets, such as: video surveillance, perimeter fencing, 24×7 security officer postings with background checked personnel, locked server racks and server floors, integrated alarm systems, time and area-bound access granted through a protected ticketing system, and multi-factor access control including biometric scanning. As mentioned in the Category description of PR.AA, “logical access” to Microsoft 365 infrastructure, including customer data, is prohibited from within Microsoft datacenters. For more information about physical access security or to geek out on granular details like the material used to construct perimeter fences (spoiler – it’s steel and concrete), here is your muse.

Beyond the datacenter – laptops, mobile devices, and other endpoints can be considered a physical asset in the sense that unfettered physical access to them could create risk for an organization. The Protect (PR) Function at the highest level is defined as “safeguards to manage the organization’s cybersecurity risks”. Safeguarding endpoints as a physical asset, however, cannot be protected by fences and video surveillance realistically as you would a data center physical asset. Therefore, it is important to evoke other Categories, like Awareness and Training (PR.AT) and Data Security (PR.DS), within the PR Function to train employees to safeguard their endpoints and avoid negative impacts of a lost or stolen device. Organizations can also document this risk in your Organizational Profile and/or System Security plan.

Cross-Function Tip: The Identify (ID) Function contains a Category for Asset Management (ID.AM) that pertains to an organization’s strategy for inventorying and managing physical assets like endpoints. The lifecycle of a hardware component can include wiping and recommissioning/decommissioning previously used devices, as well as a process of remote wiping a lost or stolen machine using Microsoft Intune. Much of ID.AM pertaining to servers and network-related physical assets are managed at the Microsoft datacenter for Microsoft 365 tenants.

“You gotta learn to drive with the fear”

In this blog we covered all of the PR.AA Subcategories, where they apply to Microsoft 365, and how Microsoft solutions address each applicable element. This coverage is not comprehensive of all risk or all strategies; yet, the intent is to prime your organization’s approach. Subsequent blogs will explore other Categories within the Protect Function shown below.

NIST CSF 2.0 Protect (PR) Categories

Organizations establishing or reviewing their risk management practices can appreciate the importance of awareness. A proper identity and access control strategy starts by being risk informed, even if the risks presently outweigh the mitigations. Let’s press into the risk to grow as organizations and security practitioners.

Reese Bobby offered sage wisdom to his son Ricky in the theatrical number, Talladega Nights, “You gotta learn to drive with the fear. And there ain’t nothing more frightening than driving with a live cougar in the car.” Drive with the fear. Drive with a live cougar in the car.

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In a previous blog post in 2023 we mentioned that two Common Criteria (CC) certifications of SQL Server 2022 were in progress. We are excited to announce that CC EAL2 certifications for SQL Server 2022 on Windows and Linux (including enabled by Azure Arc) have been issued! The certifications are compliant to the newly developed and recently certified DBMS cPP.

After SQL’s first CC certification of version 2005 (Yukon), SQL Server 2022 is the 8th major release that has successfully completed this security attestation. To see an extract of the extensive CC history of SQL Server, please refer to the SQL Server security page  (Click on “View our Common Criteria certifications”). Additionally, this document provides important information to understand and use SQL Server 2022 as evaluated and certified.

What CC means

The SQL Server 2022 CC certification consisted of a comprehensive examination conducted by the evaluation facility, based on document reviews for various design representations, independent functional and penetration testing, code analysis, site audits for development sites, data centers and support sites, and a vulnerability assessment. Scope and rigor of this investigation were defined by the newly developed and recently certified DBMS cPP.  The results obtained by the evaluation facility were continuously monitored by the certification body to confirm their accuracy and to ensure comparability with other independent evaluations of the same product type.  (See SQL Server 2022 on Windows and SQL Server 2022 on Linux).

Since SQL Server 2016, all CC certified versions were “cloud connected”, as their development life cycle (including tooling) has progressed step by step to the cloud through the years.  CC for SQL Server 2022 includes an Azure Arc-enabled server configuration (which is shown below and represents an IaaS offering). All these cloud-based tools and techniques are well understood by CC, however, not all hybrid or multi-cloud environment configurations are (yet) supported by CC.  Looking forward, Microsoft is contributing to and building on the work performed in the “CC in the Cloud Technical Working Group (TWG)” to support CC for cloud-based services.

About the CC

CC is an international program which is broadly used as a (cyber) security standard (ISO 15408) to test and improve the IT security measures of commercial products for use in National Security Systems (see e.g. EUCSA, NIAP). As such it serves as a world-wide compliance obligation across regulated industries and authorities and can be applied to almost any type of IT product implemented in hardware, firmware, or software.  IT security measures in the context of the CC are usually a means to protect information (or in other words ‘assets’) from unauthorized disclosure, modification, or loss of use, covering, for example, areas such as identification and authentication, access control, accountability, audit, object re-use, error recovery. Appropriate confidence in the correct and effective implementation of those measures (expressed in terms of assurance requirements and typically specified in an EAL) is needed to help determine whether IT products fulfill their security needs. A competence-tested and licensed evaluation facility therefore evaluates an IT product against a pre-defined security specification, called (collaborative) Protection Profile (PP). A (collaborative) PP represents the security functional and assurance requirements for technology classes and is developed and maintained by an international Technical Community (iTC), made up of CC and technology area experts such as vendors, certification bodies, evaluation facilities, and consultants (see e.g. DBMS-iTC). Under the international Common Criteria Recognition Arrangement (CCRA) and the European Senior Officials Group Information Systems Security (SOG-IS) agreement, all signatories agree to recognize the CC certificates produced by any certificate-authorizing participant. Each certificate-authorizing member of the CCRA or SOG-IS operates a certification body that oversees evaluations conducted by their licensed commercial evaluation facilities.

Learn more about the CC

Please visit the Common Criteria Portal.

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