SC-30(3): Change Processing and Storage Locations

The sc-30(3): change processing and storage locations requirement is about operational resilience and risk reduction under real constraints: you cannot “move everything” all the time, and you cannot improvise during an incident. A CCO, GRC lead, or system owner needs a crisp definition of (1) which processing functions and data stores are in scope, (2) which alternate locations are permitted, and (3) how you execute a location change safely without breaking security controls, data handling rules, or contractual obligations.

This control enhancement is most commonly implemented through pre-approved alternate hosting regions, data replication patterns, and infrastructure-as-code that can redeploy workloads in a different environment or site. For many organizations, the hardest part is not the technical switch; it’s governance: aligning approvals, documenting triggers, ensuring the alternate location meets the same security requirements, and producing evidence that the process is repeatable.

If you implement SC-30(3) well, you reduce outage blast radius and limit exposure to localized threats. If you implement it poorly, you create shadow environments, uncontrolled data sprawl, and audit findings due to missing evidence that the relocation is authorized, secure, and tested.

Regulatory text

Requirement (excerpt): “Change the location of {{ insert: param, sc-30.03_odp.01 }} {{ insert: param, sc-30.03_odp.02 }}].” ¹

How to read this as an operator: the parameters in the OSCAL text are placeholders that your organization must define for your system. In practice, you must:

• Specify which system elements are subject to relocation (for example, specific processing services, data stores, or both).
• Specify the approved alternate locations (for example, alternate data centers, alternate cloud regions, alternate availability zones, alternate enclaves).
• Demonstrate you can execute the relocation under controlled change practices with security equivalence (same or stronger controls) in the new location. ²

Plain-English interpretation

SC-30(3) expects a planned, governed ability to move processing and/or storage away from a current location when risk or operational conditions demand it. “Location” can mean a physical facility, a cloud region, a logical enclave, or another bounded environment, as long as you define it clearly in your system documentation.

What assessors look for:

• You pre-identified alternate locations rather than inventing them during a crisis.
• You have a repeatable method (automation or a runbook) to move the workload and/or data.
• You maintain confidentiality, integrity, availability, and compliance requirements after the move, not just “get it running.”

Who it applies to

Entities: Federal information systems and contractor systems handling federal data commonly implement NIST SP 800-53 controls, including SC-30(3). ²

Operational contexts where SC-30(3) becomes non-negotiable:

• Mission-critical services with continuity requirements.
• Systems with localized threat exposure (facility issues, geopolitical/regional instability, utility failures).
• Architectures with centralized storage or tightly coupled processing where a single site failure is a systemic failure.
• Environments with third parties providing hosting, colocation, managed platforms, or critical data processing.

Systems scope decisions you must make (and document):

• Is the control applied to the full system boundary or only designated components (for example, primary database + core API tier)?
• Does “location change” mean cross-region, cross-account, cross-tenant, cross-data-center, or intra-region?
• What constraints apply (data residency, contractual restrictions, export controls, customer commitments)?

What you actually need to do (step-by-step)

Step 1: Define the relocation objects (the “what”)

Create a short, explicit list of in-scope components and datasets:

• Processing: which services, jobs, or compute clusters must be movable.
• Storage: which data stores (object, block, database), logs, backups, and key material need relocation or re-establishment.

Deliverable: SC-30(3) Relocation Scope Statement tied to your system boundary and architecture diagrams.

Step 2: Define approved alternate locations (the “where”)

For each in-scope object, define allowed destinations:

• Primary location (current steady state).
• Secondary location(s) (pre-approved).
• Any prohibited locations (for example, regions not allowed due to policy or contract).

Make the “where” auditable:

• Name the environment precisely (region/site/enclave/account/subscription).
• Confirm security equivalence expectations (same identity controls, logging, encryption, key management, vulnerability management).

Deliverable: Approved Location Matrix (table) owned by the system owner and approved by security/compliance.

Example matrix fields (keep it simple):

• Component / dataset
• Primary location
• Alternate location(s)
• Trigger type (risk, outage, planned maintenance)
• Data replication method
• RTO/RPO targets (if your program defines them)
• Approval roles

Step 3: Establish the mechanism to change location (the “how”)

Choose an implementation pattern per component:

• Cold relocation: redeploy from code + restore from backup in alternate location.
• Warm relocation: replicated data + standby services that can be promoted.
• Hot relocation: active-active or near-real-time failover with traffic steering.

Then document the mechanism as a runbook:

• Preconditions (replication healthy, keys accessible, dependencies available).
• Execution steps (infrastructure deployment, DNS/traffic switch, storage mount, app config changes).
• Security steps (access control validation, logging validation, secret rotation decisions).
• Validation steps (smoke tests, integrity checks, monitoring confirmation).
• Rollback steps.

Deliverable: SC-30(3) Location Change Runbook (or automated pipeline documentation with human approvals).

Step 4: Put governance around authorization and triggers

Define who can authorize a location change and under what triggers:

• Planned: maintenance, cost optimization (if allowed), lifecycle changes.
• Reactive: incident response, facility outage, elevated threat conditions.

Align with your change management program:

• Emergency change path with post-implementation review.
• Normal change path with pre-approval and scheduling.

Deliverable: Change approval workflow that includes compliance/security sign-off when the relocation changes risk posture.

Step 5: Validate security and compliance equivalence in the alternate location

Before calling SC-30(3) “implemented,” verify the alternate location is not a weaker environment:

• Identity and access controls enforce least privilege.
• Encryption at rest and in transit remains enabled; keys are accessible and controlled appropriately.
• Logs are generated and centralized; detection rules still apply.
• Vulnerability scanning, patching, and configuration baselines apply to the new footprint.

Deliverable: Equivalence checklist completed for each alternate location.

Step 6: Test, record, and repeat

Run a controlled exercise that performs the location change for at least one representative in-scope component and its associated data flow. Capture:

• Change ticket and approvals.
• Execution evidence (pipeline logs, command outputs, deployment records).
• Validation evidence (monitoring dashboards, application health checks).
• Issues found and remediation actions.

Deliverable: Test report plus the evidence pack that an assessor can trace end-to-end. ²

Required evidence and artifacts to retain

Keep artifacts that prove three things: scope, capability, and repeatability.

Core artifacts

• System architecture diagrams showing primary and alternate locations.
• Data flow diagrams identifying where data is processed and stored.
• Approved Location Matrix (primary vs alternate).
• Location Change Runbook or automated failover/redeploy pipeline documentation.
• Change management records (normal and emergency changes) for relocations.
• Configuration baselines / infrastructure-as-code for both locations.
• Replication configuration evidence (where applicable).
• Validation results from relocation tests (screenshots, logs, monitoring exports).
• Risk acceptance or exception records if some components cannot be relocated.

Third-party evidence (when hosting or managed services are involved)

• Contracts/SOW language or third-party attestations that specify permitted hosting locations and relocation support.
• Third-party due diligence showing the alternate location meets required security expectations.

Practical tip: store the evidence as a single “SC-30(3) packet” in your GRC system, mapped to the control owner, procedure, and recurring evidence cadence. Daydream is commonly used to keep this mapping tight so the control doesn’t degrade into scattered tickets and screenshots.

Common exam/audit questions and hangups

Expect questions like:

• “What exactly do you mean by ‘location’ for this system?”
• “Which components are designated for relocation under SC-30(3)?”
• “Show me the approved alternate locations and who approved them.”
• “Demonstrate you can perform the move. Where is the test evidence?”
• “How do you ensure the alternate location enforces the same logging, encryption, and access controls?”
• “If a third party hosts this, what contract terms guarantee you can change locations when needed?”

Hangups that drive findings:

• Alternate location exists but is not documented as approved.
• Runbook exists but has never been executed in a controlled test.
• Teams can redeploy compute but forget stateful components (databases, object storage, keys, logging).

Frequent implementation mistakes and how to avoid them

1. Mistake: treating availability zones as “location change” without documenting the definition.
   Fix: write your location definition (region vs zone vs facility vs enclave) in the scope statement and diagrams.

2. Mistake: failing over the app but not the security tooling.
   Fix: include “security services dependency checks” in the runbook (SIEM forwarding, EDR coverage, config management, vulnerability scanning).

3. Mistake: data sprawl after relocation.
   Fix: define post-move cleanup steps (decommission old resources, validate backup retention, confirm no orphaned replicas).

4. Mistake: third-party constraints discovered during an incident.
   Fix: bake location flexibility into third-party contracting and due diligence; document permitted regions/sites up front.

5. Mistake: evidence is informal and not traceable.
   Fix: standardize the evidence set and attach it to the control record; keep one canonical runbook and one canonical matrix.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat SC-30(3) primarily as an assessment and resilience expectation rather than a control with a specific enforcement history in this dataset. Your real risk is operational: inability to relocate processing or storage can turn a localized disruption into an extended outage, and ad hoc relocation can create unauthorized data residency and security control gaps. ²

Practical 30/60/90-day execution plan

First 30 days (establish governance and scope)

• Assign a control owner and technical owner for SC-30(3).
• Draft the Relocation Scope Statement: in-scope processing components and data stores.
• Produce the first Approved Location Matrix with named alternate destinations.
• Identify top blockers (stateful workloads, licensing, third-party limitations, data residency constraints).
• Stand up the evidence folder/record in your GRC system so artifacts don’t scatter.

Days 31–60 (build the relocation method)

• Write the Location Change Runbook for the highest-risk service first.
• Implement or document the relocation mechanism (cold/warm/hot) for in-scope components.
• Complete the equivalence checklist for the alternate location (IAM, encryption, logging, monitoring, vuln management).
• Align change management paths (normal vs emergency) and define approvers.

Days 61–90 (test and make it repeatable)

• Execute a controlled location change test and capture end-to-end evidence.
• Fix gaps found in the test (missing logs, broken dependencies, manual steps that need automation).
• Update diagrams, matrix, and runbook based on real execution.
• Set an ongoing test and evidence refresh cycle tied to major system changes (new regions, major architecture updates, hosting third-party changes).

Frequently Asked Questions

Does SC-30(3) require active-active multi-region architecture?

No. The control requires the capability to change processing and/or storage locations for designated elements, but it does not mandate a specific architecture pattern. Document the pattern you chose (cold, warm, hot) and prove it works. ²

What counts as a “location” in cloud environments?

Treat “location” as whatever boundary materially changes risk and resilience for your system, commonly a region, separate account/subscription, or separate enclave. Define the boundary explicitly in your scope statement and architecture diagrams. ¹

If a third party hosts our system, can we still meet SC-30(3)?

Yes, if your contract and operating model allow you to move processing and/or storage to an approved alternate location and you can produce evidence of that capability. If the third party cannot support relocation, document an exception and the compensating controls.

Do backups in another location satisfy the storage-location part of the requirement?

Backups help, but assessors typically expect you to show how storage used for operations can be established in an alternate location and how you would restore service there. Document restore steps, key access, integrity checks, and test results.

How do we prevent data residency violations when relocating?

Make residency constraints part of the Approved Location Matrix and prohibit disallowed destinations. Require compliance review in the change workflow for any new destination.

What evidence is most likely to satisfy an assessor quickly?

A clear location matrix, a runbook, and a completed test record with approvals and validation outputs usually answer most questions fast. Keep them in one control packet mapped to SC-30(3) so you can produce them on request.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5