CP-10(6): Component Protection

CP-10(6) requires you to protect the specific system components you rely on to recover and reconstitute systems after an incident or outage, such as backup repositories, golden images, recovery tools, and rebuild automation. Operationalize it by inventorying recovery components, applying strong access controls and integrity protections, isolating them from production threats, and producing repeatable evidence that protection is operating. ¹

Key takeaways:

• Scope the requirement to “recovery and reconstitution components,” not your whole environment. ¹
• Protect for confidentiality, integrity, and availability: restrict access, harden, isolate, and monitor recovery assets. ¹
• Evidence matters: map ownership, procedures, and recurring artifacts so you can prove control operation on demand. ¹

The cp-10(6): component protection requirement is a narrow control with outsized operational impact: if attackers or accidents can tamper with your recovery components, you may be unable to restore service, or you may rebuild compromised systems and reintroduce malware. CP-10(6) focuses on the assets used to recover and reconstitute your system, which often live outside day-to-day operational oversight, sit in separate accounts, or are managed by infrastructure teams that do not treat them as “production.” ¹

For a CCO, compliance officer, or GRC lead, the fastest path is to translate CP-10(6) into a short list: which components are in scope, who owns them, what protections must be in place, and what evidence proves those protections. This page gives you requirement-level implementation guidance you can hand to IT, Security Operations, Infrastructure, and Backup administrators, then validate through targeted checks and artifacts. ²

Regulatory text

Requirement (CP-10(6)): “Protect system components used for recovery and reconstitution.” ¹

Operator meaning: Identify the exact components you will depend on during recovery (backup data and the platforms that store it, golden images, configuration baselines, orchestration scripts, recovery accounts/keys, and any rebuild tooling), then apply protections that prevent unauthorized access or tampering and that keep these components available when you need them. Your implementation should be provable with repeatable evidence. ¹

Plain-English interpretation (what CP-10(6) is asking you to ensure)

CP-10(6) expects that your recovery capability cannot be easily sabotaged. Recovery components are high-value targets because they can:

• Stop recovery (deleted backups, locked backup consoles, lost keys).
• Poison recovery (tampered images/scripts that reintroduce compromise).
• Expose sensitive data (backup repositories often contain broad data sets). ¹

A practical interpretation: treat recovery components as a protected subsystem with tighter controls than general infrastructure, and validate those controls the same way you validate production controls. ²

Who it applies to (entity and operational context)

Typical in-scope entities

• Federal information systems.
• Contractor systems handling federal data. ¹

Operational contexts where this comes up in audits

• You operate centralized backup and recovery (on-prem, cloud, or hybrid).
• You rely on infrastructure-as-code (IaC) and golden images for rebuild.
• You have a disaster recovery environment, warm site, or recovery accounts.
• You depend on third parties for backup tooling, managed recovery, or cloud-native snapshots. In those cases, your responsibility becomes: define requirements, verify third-party controls, and retain evidence you reviewed them.

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

Use this as an implementation checklist you can assign to a control owner.

Step 1: Define “recovery and reconstitution components” for your system

Create a scoped inventory that includes:

• Backup repositories (object storage buckets, backup appliances, tape, snapshot services).
• Backup management plane (backup console, scheduling server, agents).
• Golden images and templates (VM templates, container base images, AMIs).
• Reconstitution tooling (provisioning pipelines, IaC repos, configuration management).
• Recovery credentials (break-glass accounts, vaults, keys, tokens).
• Recovery runbooks and diagrams (because controlled documentation is part of reconstitution). ¹

Output: “CP-10(6) Recovery Components Register” with system name, component, owner, location/account, and critical dependencies.

Step 2: Assign ownership and a minimum protection standard

Pick one accountable owner per component class (Backup Admin, Cloud Platform, IAM, SRE). Then set minimum requirements that you can test:

• Access control: tightly restricted admin roles, separate admin identities, least privilege.
• Segmentation/isolation: separate accounts/subscriptions, separate network segments, limited inbound management paths.
• Integrity: immutability controls where feasible; signed images; protected source control; controlled change.
• Availability: redundancy appropriate to the system’s recovery design; protected from accidental deletion by guardrails.
• Monitoring: alerts on privileged access, deletion attempts, policy changes, and unusual restore activity. ¹

Practical standard format: a one-page “Recovery Component Protection Standard” that engineering teams can implement consistently.

Step 3: Protect the backup management plane as if it is production security tooling

Attackers often go after the console, not the backup data first. Confirm:

• MFA and strong authentication for backup admin access.
• Admin access only from controlled endpoints or management network.
• Separate roles for viewing backups vs. deleting backups vs. changing retention.
• Logged actions for policy edits, retention changes, and deletion. ¹

Evidence target: screenshots or exported config showing roles, MFA settings, and audit logging enabled.

Step 4: Add integrity protections to reconstitution paths (images, scripts, pipelines)

Reconstitution means “rebuild from known-good.” You need a defensible chain of custody:

• Approved golden image process (build, scan, approve, publish).
• Protected repositories for IaC and configuration scripts with branch protection and change review.
• Secrets kept in a vault, not embedded in scripts.
• Controlled CI/CD permissions for pipelines that can build images or deploy core infrastructure. ¹

Operational check: can a single compromised developer account modify the golden image pipeline and push to “approved”? If yes, you have a CP-10(6) gap.

Step 5: Design for “can’t delete, can’t encrypt, can’t silently change”

Implement guardrails that make common failure modes harder:

• Immutable backup copies where supported by your platform.
• Separate credentials for backup storage vs. production admins.
• Dual control or approval for destructive operations (delete vault, change retention to near-zero, disable backups).
• Offline or logically isolated copies when your threat model includes ransomware. ¹

Step 6: Test recovery with an explicit “component protection” lens

During recovery exercises, add test cases that confirm protections:

• Attempt an unauthorized retention change (should be blocked and alerted).
• Validate you can retrieve golden images and rebuild scripts without using production admin accounts.
• Validate audit logs exist for restore operations and policy changes.
• Confirm break-glass access works and is monitored. ²

Step 7: Map to control owner, procedure, and recurring evidence (assessment readiness)

CP-10(6) commonly fails on evidence, not intent. Establish:

• Named control owner.
• Written implementation procedure (what is protected, how, and who reviews).
• Recurring evidence artifacts on a schedule your program can sustain (config exports, access reviews, monitoring checks). ¹

Daydream fit (earned mention): Many teams track this with spreadsheets until audits approach. Daydream can map CP-10(6) to owners, procedures, and recurring artifacts so evidence collection becomes routine rather than a fire drill. ¹

Required evidence and artifacts to retain

Maintain artifacts that prove both design and operation:

Evidence type	What to retain	What it proves
Recovery Components Register	Inventory with owners and locations	You identified in-scope recovery assets 1
Protection Standard / Procedure	Written standard + implementation steps	Defined expectations and repeatability 2
Access control evidence	Role mappings, MFA settings, access review results	Only authorized staff can administer recovery components 1
Logging/monitoring evidence	Audit log configuration, alert rules, sample events	Tampering attempts are detectable 1
Integrity controls evidence	Image signing/approval records, repo protections, pipeline permissions	Reconstitution inputs are controlled 1
Recovery test records	Exercise reports with CP-10(6) checks	Protections work under recovery conditions 2

Common exam/audit questions and hangups

Expect assessors to probe these areas:

• “Show me what you consider ‘components used for recovery and reconstitution.’” ¹
• “Who can delete backups or change retention, and how do you review that access?” ¹
• “How do you know golden images and rebuild scripts are not tampered with?” ¹
• “Can production admins access the backup console? If yes, why is that acceptable?” ¹
• “Show logs for backup policy changes and restore activity.” ¹

Hangup you can prevent: teams provide a generic backup policy but cannot show concrete protection of the backup management plane or the reconstitution toolchain.

Frequent implementation mistakes (and how to avoid them)

1. Treating “backups exist” as compliance. CP-10(6) is about protecting the components, not only producing backups. Fix: document the component set and protection controls. ¹

2. Forgetting the management plane. Backup consoles and snapshot policies get compromised. Fix: restrict admin access paths, require MFA, and log admin actions. ¹

3. Leaving golden images and IaC repos in normal developer workflows. Attackers can poison rebuild inputs. Fix: require approvals, protect branches, and lock down pipeline permissions. ¹

4. No evidence package. You can have good controls and still fail an assessment if you cannot show operation. Fix: predefine recurring artifacts and store them centrally under the control. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for CP-10(6), so you should treat this as an assessment and mission-risk driver rather than a “case law” control. The operational risk is straightforward: if recovery components are compromised, you can lose availability, rebuild into a compromised state, or expose broad sets of regulated data stored in backups. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and ownership)

• Publish the Recovery Components Register for the system and confirm owners.
• Document the minimum “Recovery Component Protection Standard.”
• Identify the most sensitive recovery assets (backup console, backup storage, golden images, secrets vault) and confirm basic access controls and logging are on. ¹

Days 31–60 (implement hardening and guardrails)

• Separate privileges for recovery administration from production administration where feasible.
• Add integrity controls to image and IaC pipelines (approvals, protected branches, controlled pipeline permissions).
• Implement alerts for destructive or high-risk actions (retention changes, delete attempts, policy disablement, mass restore activity). ¹

Days 61–90 (prove operation and close evidence gaps)

• Run a recovery exercise that includes CP-10(6)-specific negative test cases (unauthorized change attempts, credential boundaries, log review).
• Build a standing evidence package: config exports, access review results, and exercise reports stored under the CP-10(6) control record.
• If third parties provide backup/recovery tooling, update third-party due diligence to require evidence of protections around recovery components you depend on. ²

Frequently Asked Questions

What counts as a “component used for recovery and reconstitution” under CP-10(6)?

Include anything you must trust to restore service: backup data, the backup console, golden images, rebuild scripts, and the credentials used to run recovery. If you would be blocked from restoring without it, treat it as in scope. ¹

Do we have to isolate recovery components from production?

CP-10(6) does not prescribe a specific architecture, but isolation is a common way to “protect” recovery components from threats that affect production admin paths. Document your design choice and show how it prevents unauthorized access or tampering. ¹

How do I demonstrate integrity for golden images and rebuild automation?

Show a controlled process: restricted permissions to modify image pipelines and IaC repos, enforced approvals, and audit logs for changes. Pair that with a recovery test record that confirms you can rebuild from approved inputs. ¹

What evidence do auditors usually accept for CP-10(6)?

Auditors typically want an inventory of recovery components, access control proof (roles and reviews), logging/monitoring configuration, and a recovery exercise report. Keep artifacts consistent and dated so you can show operation over time. ¹

We outsource backups to a third party. Are we still on the hook?

Yes. You still need to ensure the recovery components you depend on are protected, which usually means contract requirements, due diligence, and retained evidence of the third party’s controls. Your internal runbooks should also cover how you access and restore from the third party securely. ²

How do I keep CP-10(6) from becoming an audit scramble?

Assign a single control owner, define recurring evidence artifacts, and collect them continuously. Tools like Daydream can help you track owners, procedures, and evidence requests so you are not rebuilding proof during audit season. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5