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M3 Framework - Introduction M3 Framework - Overview Phase 0 - Assessment Phase 1 - Readiness Phase 2 - Selection Phase 3 - Engagement Phase 4 - Migration Phase 5 - Operations Resources
M3 Playbook > Phase 4: Migration
4.11 Conduct Security and Privacy Reviews
4.9 Execute Training for Go-Live
4.11 Conduct Security and Privacy Reviews
Image Map Phase 0: Assessment Phase 1: Readiness Phase 2: Selection Phase 3: Engagement Phase 4: Migration Phase 5: Operations
Objective: Conduct security & privacy reviews to validate the system (data, applications, interfaces, network) is protected, personally identifiable information (PII) & data are secure.

Phase 3 GuidanceResponsible Party - Customer, Provider, Shared
Conduct Privacy Reviews:
1. Develop Privacy Framework to include system categorization, data type, handling, storing and sharing method, and incident response process (S) 2. Develop Privacy documentation and training material (if needed) to provide guidance to all stakeholders (S) 3. Implement Privacy training roadmap and integrate with overall training plan (S) 4. Roll out privacy regulations to all users (S) 5. Document and receive Systems of Record Notice, if required (S)
Conduct Security Reviews:
1. Understand provider security environment and assess against requirements (S)
2. Develop Security documentation and Security Test Plan if applicable (S)
3. Execute security test according to test plan to include both physical and logical security, document and correct issues (S)
4. Request and receive Authority to Operate (ATO) if necessary (S)

• Gap Analysis Report
• Target State Concept of Operations
• Integrated Technical Strategy

• Security Documentation, including Security Test Results and ATO • Privacy Documentation, including Initial Privacy Assessment, FIPS 199, System of Records Notice (SORN), Privacy Impact Assessment
Stakeholders Update
• Program Manager (C, P)
• Functional Lead (C, P)
• Functional SMEs (C,P)
• Data SMEs (C)
• Technical Lead/Solution Architect (C, P)
• Security Lead (C, P)
• ISSO (C, P)
• Network SME (C, P)
• PMO Lead (C, P)

Best Practice
• Understand the customer’s ATO process and allow sufficient time to get documentation through review and approvals
• Develop and define Security/Privacy plan before development as part of the Target State Solution Architecture
• Begin security and privacy planning early and include security steps across all migration phases