SC-36: Distributed Processing and Storage

To meet the sc-36: distributed processing and storage requirement, you must architect your system so designated processing and storage components are intentionally spread across multiple locations (or equivalent distribution targets), reducing the risk that a single failure, compromise, or disruption takes everything down. Then you must document the design decision, the scope, and keep evidence that the distribution is implemented and maintained. ¹

Key takeaways:

• SC-36 is an architecture requirement: you distribute specified processing and storage components across multiple distribution targets, not just “have backups.”
• Scope and parameters matter: you must define what components are distributed and where they are distributed.
• Audit success depends on evidence: diagrams, configurations, and operating records that prove the distribution exists and remains in place.

SC-36 shows up in assessments when the assessor wants proof that your system can keep operating, protect data, and limit blast radius if a single site, zone, or platform segment fails or is compromised. The control’s language is short, but the operational work is not: you need an explicit decision on which processing and storage components must be distributed, what “multiple” means in your environment, and how you keep the configuration from drifting back to a single point of failure.

This is most relevant for systems handling federal data (including contractor-operated systems) where resilience and fault isolation are part of the security posture, not a “nice-to-have.” ²

A common failure mode is treating SC-36 as generic “high availability.” Assessors typically expect a tighter story: what you distributed, why, where, and how you validate it. This page translates SC-36 into requirement-level steps you can assign to engineering, track in GRC, and defend in an exam.

Regulatory text

Requirement (verbatim excerpt): “Distribute the following processing and storage components across multiple {{ insert: param, sc-36_prm_1 }}: {{ insert: param, sc-36_prm_2 }}.” ¹

What the operator must do

1. Fill in the parameters for your environment:
   • sc-36_prm_1 = the distribution targets (examples in practice: sites, availability zones, data centers, logical enclaves, separate security domains). Your system security plan should name the actual targets you use.
   • sc-36_prm_2 = the specific processing and storage components you are distributing (examples in practice: application tiers, message brokers, databases, file/object storage, key stores, job schedulers).
2. Implement the distribution so those components are not co-resident in a single location or dependency path.
3. Maintain evidence that the distribution is real, current, and enforced through build standards and configuration controls.

This is an architecture and configuration control with security outcomes: fewer single points of failure, reduced impact from localized compromise, and improved survivability under disruption.

Plain-English interpretation (what SC-36 means in practice)

SC-36 requires you to avoid concentrating critical processing and storage in one place. If a single “place” fails or is compromised, operations and data access should not collapse because the designated components were intentionally distributed.

Distribution can be physical (separate facilities) or logical (separate zones/domains) depending on your system and risk. What matters for compliance is that you:

• define the distribution boundaries,
• apply them to the components you name,
• and can prove the system actually runs that way day to day. ²

Who it applies to (entity and operational context)

Entities

• Federal information systems implementing NIST SP 800-53 controls. ²
• Contractor systems handling federal data where NIST SP 800-53 is flowed down through contract terms, ATO expectations, or agency security requirements. ²

Operational contexts where SC-36 is commonly tested

• Production environments hosting mission systems or sensitive datasets.
• Centralized platforms that support many business apps (identity services, shared data layers).
• Hybrid architectures where some components are on-prem and others are hosted, creating hidden “single dependency” paths.
• Systems with strict uptime or continuity expectations (even if SC-36 is not a pure continuity control, assessors often connect it to resilience outcomes).

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

Use this as an implementation runbook you can assign to engineering and track in GRC.

Step 1: Assign ownership and define scope

• Control owner: typically Head of Infrastructure/Cloud Platform or Systems Engineering; GRC owns governance and evidence.
• System scope: identify which systems/enclaves are in scope for SC-36 and which are out (with rationale).
• Component list: enumerate processing and storage components that matter for confidentiality, integrity, and availability (don’t forget “supporting” components like queues, caches, secrets management, and shared file stores).

Deliverable: SC-36 implementation statement in the SSP or control narrative mapped to specific system components. ²

Step 2: Define the distribution targets (“multiple what?”)

Decide and document what “multiple” means for your architecture. Pick one as your baseline and keep it consistent:

• separate facilities,
• separate availability zones,
• separate regions,
• separate network/security zones,
• separate compute clusters with independent control planes.

Practical tip: define distribution targets in a way your team can enforce with policy-as-code, templates, or guardrails.

Deliverable: architecture standard stating the approved distribution targets for in-scope components.

Step 3: Decide which components must be distributed (and why)

Create a short decision matrix and get it approved:

Component	Distributed?	Distribution target	Rationale	Compensating control if “No”
Primary database	Yes/No	e.g., separate zones	prevent single failure domain	backups, tested recovery, isolation
Object storage	Yes/No	e.g., separate sites	durability and access continuity	replication policy, immutability
App tier	Yes/No	e.g., separate clusters	availability and blast radius	autoscaling, golden images

Deliverable: signed SC-36 scope table (architecture + security sign-off).

Step 4: Implement distribution in the platform

Implementation patterns you can use (choose what fits your system):

• Redundant compute across distribution targets (stateless services are easiest).
• Data replication across targets for stateful components (document replication mode and failure behavior).
• Decouple dependencies so one target can run without a control-plane dependency in the other.
• Segmentation controls so a compromise in one zone does not automatically grant access to replicas elsewhere.

Deliverable: updated reference architecture diagram(s) showing where each component runs and where data is stored.

Step 5: Add controls to prevent configuration drift

SC-36 commonly fails in year two because teams “simplify” a deployment.

• Put distribution requirements into build templates and deployment pipelines.
• Require architecture review for exceptions (temporary single-zone runs, maintenance windows, migrations).
• Monitor for drift: alerts when a component’s replicas drop below the required distribution targets.

Deliverable: guardrail controls (pipeline checks, infrastructure policies, monitoring rules) tied to SC-36.

Step 6: Test and prove it works the way you claim

Run operational exercises that show the distributed components continue to function as intended under target loss or isolation. Keep the output. The test can be a tabletop plus a controlled technical test, as long as it produces objective evidence.

Deliverable: test record with date, scope, outcome, and remediation tickets.

Step 7: Operationalize evidence collection (make audits easy)

Set an evidence cadence that fits change velocity:

• after significant architecture change,
• on a recurring schedule aligned to your control testing program,
• and after incidents that affect availability.

Daydream fits naturally here: track SC-36 ownership, link the distribution decision matrix to the system boundary, and request recurring artifacts from engineering so evidence stays current without a fire drill.

Required evidence and artifacts to retain

Keep artifacts that prove design, implementation, and operation:

Design evidence

• SC-36 control narrative in SSP / system control description. ²
• Architecture diagrams showing distribution targets and component placement.
• Approved decision matrix (what is distributed, where, and why).
• Exception register for components not distributed, with compensating controls and approvals.

Implementation evidence

• Infrastructure configuration exports or screenshots showing multi-target deployments (compute and storage).
• Data replication configuration (policies, settings, topology).
• Deployment templates / IaC snippets that encode distribution requirements.
• Network/security zone diagrams that show separation between targets.

Operational evidence

• Monitoring evidence that checks distribution health (replica counts, target availability).
• Change tickets for architecture changes affecting distributed components.
• Test/exercise reports and remediation tracking.

Common exam/audit questions and hangups

Expect these questions and pre-answer them in your package:

1. “What does ‘multiple’ mean for you?” Name the targets and show the standard.
2. “Which components are covered?” Provide the component list and decision matrix.
3. “Show me it’s really distributed today.” Produce current config/state evidence, not last year’s diagram.
4. “What happens if one target is lost?” Show test results or a documented failure-mode analysis.
5. “How do you prevent drift?” Show pipeline guardrails, monitoring, and change governance.

Hangups assessors commonly raise:

• distribution exists for compute, but storage is still centralized;
• replicas exist, but administration/control plane is a single point;
• “we could deploy multi-zone” versus “we are deployed multi-zone.”

Frequent implementation mistakes (and how to avoid them)

1. Mistake: treating backups as distribution.
   Fix: backups support recovery; SC-36 expects designated components to be distributed for ongoing operation and risk reduction. Document how your distribution differs from backup/recovery.

2. Mistake: distributing only the app tier.
   Fix: include stateful dependencies (databases, object stores, key stores, queues). Your component list should explicitly cover both processing and storage. ¹

3. Mistake: undocumented “tribal knowledge.”
   Fix: diagrams, decision matrix, and SSP narrative must match reality. If engineering can’t export configs quickly, you will struggle in an assessment.

4. Mistake: exceptions without compensating controls.
   Fix: if you can’t distribute a component, document a compensating approach (segmentation, tested recovery, strict change control) and get formal approval.

Risk implications (why SC-36 is assessed as a security control)

SC-36 reduces:

• availability risk from localized failures and misconfigurations,
• security risk from a single compromise yielding total system control or total data loss,
• operational risk from maintenance events that otherwise require full outages.

From a GRC perspective, SC-36 also reduces audit risk: you can show that resilience is engineered into the system rather than managed as an ad hoc response.

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and decisions)

• Name the SC-36 control owner and backup owner.
• Inventory processing and storage components for each in-scope system.
• Define and document distribution targets.
• Draft the decision matrix; open exceptions for components that cannot be distributed.

Exit criteria: signed scope + targets + initial component decision matrix.

Next 60 days (implement and document)

• Implement distribution for the highest-risk components first (typically primary storage and critical processing).
• Update diagrams and SSP narrative to match deployed state.
• Add drift prevention guardrails in CI/CD and infrastructure policies.
• Stand up monitoring that detects loss of required distribution.

Exit criteria: evidence package includes current configs, diagrams, and guardrails.

Next 90 days (prove operations and make it repeatable)

• Run a controlled failure/isolation test and document results.
• Close remediation items from test outcomes.
• Operationalize recurring evidence collection (tickets, exports, monitoring reports).
• Configure Daydream (or your GRC system) to issue periodic evidence tasks and store artifacts by system boundary.

Exit criteria: repeatable evidence process plus proof that distribution survives a realistic disruption scenario.

Frequently Asked Questions

Does SC-36 require multi-region, or is multi-zone enough?

SC-36 is parameterized, so the requirement is what you define as your “multiple” distribution targets for the system. Document the chosen targets, justify them, and keep evidence that the designated components are deployed across them. ¹

Are backups and disaster recovery sufficient to satisfy SC-36?

Usually not by themselves. SC-36’s text focuses on distributing processing and storage components, which implies the components themselves are spread across targets, not just recoverable from backups. ¹

How do I scope “processing and storage components” without boiling the ocean?

Start with components that, if lost or compromised, would stop the mission function or expose sensitive data. Put the rest into a backlog and document the rationale, with exceptions where you cannot distribute. ²

What evidence do auditors accept to prove distribution?

Auditors look for a consistent package: diagrams, a written control statement, and current configuration/state evidence that matches the diagrams. Pair that with monitoring outputs or test records to show it stays in place. ²

What’s the fastest way to fail SC-36 in an assessment?

Claim a distributed design but show a centralized storage dependency, a single-zone deployment, or out-of-date diagrams that conflict with current configurations. Keep your decision matrix and exports current to avoid that gap.

Where should SC-36 live in our control framework and tickets?

Track SC-36 as an architecture control owned by infrastructure/platform engineering, with GRC managing evidence collection and exceptions. Daydream works well as the system of record for the decision matrix, approvals, and recurring artifact requests.

Footnotes

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

2. NIST SP 800-53 Rev. 5