CP-9: System Backup

The cp-9: system backup requirement expects you to run backups of user-level information for the systems and locations your organization defines, and to be able to prove those backups are happening and are recoverable. Operationalize it by scoping “user-level information,” setting backup frequency/retention, securing backup storage, and regularly testing restores with retained evidence. ¹

Key takeaways:

• CP-9 is about performing backups of user-level information, scoped to defined systems/locations. ¹
• Auditors will focus on restore capability and evidence of ongoing operation, not just a written policy. ²
• Assign a control owner, document the procedure, and standardize recurring artifacts so CP-9 is continuously provable. ¹

CP-9 sits in the Contingency Planning family and is a baseline expectation for resilience: if user data is lost, corrupted, encrypted by ransomware, or accidentally deleted, you need a dependable way to restore it. The control text is short, but implementation gets messy fast because “user-level information” spans many platforms (endpoints, SaaS, databases, file shares, collaboration tools) and because backups fail quietly without monitoring and restore testing.

For a Compliance Officer, CCO, or GRC lead, the fastest path to a defensible CP-9 implementation is to treat it as a requirement with four deliverables: (1) a clear scope and data classification for what must be backed up, (2) an engineered backup design (frequency, retention, encryption, access control, immutability where possible), (3) operational routines (monitoring, failure handling, periodic restore tests), and (4) consistent evidence that maps to the requirement and is easy to produce under exam pressure.

This page translates CP-9 into a practical checklist you can assign to IT/SecOps, then validate through artifacts and testing. It also highlights the most common audit hangups: unclear scope, backups that don’t cover SaaS or endpoints, no restore testing, and “we have tooling” without proof.

CP-9: System Backup (requirement-level overview)

Goal: Ensure user-level information is backed up for the organization-defined scope, and that you can demonstrate the backups exist and support recovery. ¹

Target keyword: cp-9: system backup requirement

---

Regulatory text

Control excerpt: “Conduct backups of user-level information contained in {{ insert: param, cp-09_odp.01 }} {{ insert: param, cp-09_odp.02 }};” ¹

What the operator must do with this text:

• Decide what “user-level information” means in your environment and document it in scoping language that your system owners can apply consistently. ²
• Fill in the organization-defined parameters (the placeholders in the excerpt) with your defined systems, environments, or locations where that user-level information resides. Your assessor will expect those definitions to exist somewhere (SSP, policies/standards, or control implementation statements). ¹
• Run backups as an operational process, not a one-time project. “Conduct backups” implies ongoing execution plus handling failures. ²

---

Plain-English interpretation (what CP-9 is really asking)

CP-9 requires that you back up user data wherever it lives in your defined environment, on a schedule and in a way that supports recovery. “Backup” is not satisfied by replication alone, by a snapshot you never test, or by a statement that a managed service “handles it.” You need a backup approach you can explain, operate, and prove with logs and restore results. ²

---

Who it applies to (entity + operational context)

Entities: Federal information systems and contractor systems handling federal data commonly inherit NIST SP 800-53 requirements through contracts, ATO processes, or customer requirements. ²

Operational context (where CP-9 shows up):

• Systems that store or process user-created or user-managed information (documents, records, case files, code, tickets, messages, datasets).
• Hybrid estates where “user-level information” spans on-prem file servers, cloud storage, SaaS collaboration platforms, IaaS/PaaS databases, and endpoints.
• Environments with aggressive change (CI/CD, autoscaling) where backups must be designed to keep up with ephemeral infrastructure but persistent data. ²

Control ownership (practical):

• Primary owner: Infrastructure/IT Operations or Platform Engineering.
• Accountable executive: CIO/CISO delegate.
• GRC role: Define scope, require evidence, verify restore tests, and ensure third-party backup responsibilities are contractually clear. ²

---

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

1) Define CP-9 scope in operator terms

Create a short scoping statement that answers:

• What qualifies as user-level information in your environment (examples: user home directories, shared drives, SaaS content, database records created by users, application uploads). ²
• Which systems are in-scope (production, staging, regulated enclaves, mission systems).
• Which locations/tenants/accounts are in-scope (cloud accounts, regions, M365/Google tenants, SaaS instances). ¹

Output: CP-9 implementation statement in your SSP or control register that fills in the organization-defined parameters.

2) Inventory data stores that contain user-level information

Build or reuse an inventory that maps:

• System/application → data store type → backup mechanism → backup owner.
• Include “shadow IT” hotspots: collaboration tools, low-code platforms, and endpoint storage. ²

Output: Backup coverage matrix (a table auditors can read in minutes).

3) Select backup methods per data store (and document why)

For each store, define:

• Backup type (full, incremental, snapshot-based, application-aware).
• Frequency and retention (define values internally; CP-9 requires backups, and you must specify what “conduct” means for your risk and system criticality). ²
• Storage target(s): separate account/subscription, offline/immutable where feasible, and geographically separated if your risk model requires it.
• Encryption and key management expectations.
• Access controls: who can delete backups, who can restore, and how approvals work. ²

Output: Backup standard + per-system backup configuration records.

4) Implement monitoring and failure handling

Backups that “usually run” fail audits because nobody can show operational control. Require:

• Automated job success/failure monitoring with alerts routed to an on-call queue.
• A ticketing workflow for backup failures with root cause and closure evidence.
• Periodic review of backup reports by the control owner (with sign-off). ²

Output: Backup job logs/reports, alert rules, and incident/ticket evidence for failed jobs.

5) Test restores (prove recoverability)

CP-9’s text focuses on performing backups, but examiners commonly test whether the backup supports recovery in practice. Build a restore testing routine:

• Pick representative systems/data stores.
• Perform restores to a controlled environment.
• Validate integrity (hash checks, application-level checks, record counts where applicable).
• Record results and remediation actions. ²

Output: Restore test plan, restore test records, and corrective action tickets.

6) Address third-party responsibilities explicitly

If user-level information lives in a SaaS platform or is processed by a third party:

• Confirm what the provider backs up versus what you must back up.
• Ensure contracts/SOWs define backup scope, retention, restore SLAs, and evidence access.
• Maintain proof: provider attestations, admin console reports, or backup exports you control. ²

Output: Third-party backup responsibility matrix + contract/SOC report references where relevant.

7) Make it assessable: map to owner, procedure, and recurring artifacts

Turn CP-9 into a control record with:

• Named owner
• Procedure link
• Evidence list and collection cadence
• Systems covered and exceptions (with approval) ¹

Daydream (as a workflow, not a buzzword) fits here by keeping the control narrative, owners, and evidence requests in one place, so backup operations generate compliance-ready artifacts continuously instead of in a scramble.

---

Required evidence and artifacts to retain

Keep artifacts that prove design and operation:

Design evidence

• Backup policy/standard covering scope, retention, encryption, access control. ²
• Backup coverage matrix (system → data store → method → owner).
• Backup architecture diagrams where complexity warrants it.

Operational evidence

• Backup job logs/reports showing successful runs for in-scope systems.
• Monitoring/alert configuration screenshots or exports.
• Tickets for failed backups and resolution notes.
• Restore test results with dates, systems tested, and outcomes.
• Access reviews for backup admin roles and restore permissions. ²

Audit-readiness tip: evidence should be reproducible (exportable reports, immutable logs) and tied to the stated scope. “Here’s a screenshot from one server” rarely passes.

---

Common exam/audit questions and hangups

What auditors ask	What they are testing	What to show
“Define user-level information for this system.”	Scope clarity	SSP/control narrative + examples mapped to systems 2
“Which systems are backed up, and which are excluded?”	Coverage and exceptions	Coverage matrix + exception approvals
“Show backup success over time.”	Operational consistency	Scheduled reports/log exports + alerting evidence
“Can you restore?”	Recoverability	Restore test records + remediation tickets
“Who can delete backups?”	Ransomware/insider risk	IAM roles, MFA, separation of duties evidence 2

Hangup to expect: teams confuse high availability replication with backup. Replication can replicate corruption. Keep a backup mechanism that supports point-in-time recovery and protected retention.

---

Frequent implementation mistakes (and how to avoid them)

1. Scope drift: endpoints and SaaS content get missed.
   Fix: require every system owner to map user data stores to a backup method in the coverage matrix.

2. Backups exist, but nobody reviews failures.
   Fix: make backup failure tickets a required artifact, and add a monthly operational review sign-off.

3. Restore testing is ad hoc.
   Fix: schedule restore tests and require written results, even if the test scope is small at first.

4. Privilege is too broad (backup admins can delete everything).
   Fix: restrict delete permissions, require approvals, and separate restore operators from backup configuration where feasible. ²

5. No evidence strategy.
   Fix: define recurring artifacts upfront. “Map CP-9 to control owner, implementation procedure, and recurring evidence artifacts” is the simplest way to avoid evidence gaps. ¹

---

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for CP-9. You should still treat CP-9 gaps as high-impact operational risk: data loss events, ransomware recovery failures, contractual noncompliance for federal data handling, and audit findings that can delay ATO timelines. ²

---

Practical 30/60/90-day execution plan

Time-boxing helps, but implementation timelines depend on system count, tooling, and data sprawl. Use phases rather than promises.

First 30 days (Immediate stabilization)

• Name the CP-9 control owner and backup engineering owner. ²
• Draft scope: define “user-level information” and the in-scope environments. ¹
• Build the first version of the backup coverage matrix for critical systems.
• Start collecting baseline evidence: current backup reports and any existing restore records.

Days 31–60 (Coverage + operational control)

• Close coverage gaps for top-risk systems (systems with highest mission impact or most sensitive user data).
• Implement monitoring/alerting and a failure ticket workflow.
• Document backup procedures and access controls for backup administration. ²
• Run at least one controlled restore test for a representative system and document results.

Days 61–90 (Prove it under assessment conditions)

• Expand restore tests across system types (file, database, SaaS export where applicable).
• Normalize evidence collection (monthly reports, quarterly access reviews, restore test cadence).
• Formalize exceptions with approvals and compensating controls.
• Optional but practical: use Daydream to assign evidence requests to owners and keep artifacts linked to the CP-9 control record, so you can answer audit requests in hours instead of weeks.

Frequently Asked Questions

Does CP-9 require backups of application code and infrastructure-as-code?

CP-9 is written around “user-level information,” so treat it as focused on user data rather than ephemeral infrastructure. If loss of code or configuration would impair recovery, include repositories and configuration stores in scope as a risk-based decision. ²

Are cloud snapshots enough to satisfy the cp-9: system backup requirement?

Snapshots can be part of a compliant backup design if they are protected, monitored, retained appropriately, and restore-tested. Auditors usually reject “we take snapshots” when there is no evidence of monitoring and successful restores. ²

How do we handle SaaS platforms where the provider “does backups”?

Treat SaaS as shared responsibility. Document what the provider backs up, what restore options exist, and what evidence you can produce; add customer-managed backups or exports where provider capabilities do not meet your recovery needs. ²

What evidence is most persuasive in an audit?

Restore test records, backup success reports over time, and failure tickets with remediation are consistently strong because they show operation, not intent. Pair those with a clear scope statement and a coverage matrix. ²

Who should be the control owner: Security or IT?

IT/Platform teams usually operate backups day-to-day, while Security/GRC defines requirements and verifies evidence. Assign a single accountable owner for CP-9, then list supporting roles for engineering, app owners, and third-party management. ²

How do we document “organization-defined parameters” in the CP-9 text?

Put the definitions in your SSP/control implementation statement or backup standard and reference them directly from the CP-9 control record. The key is consistency: the defined systems/locations must match your evidence set. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5