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Governance, risk, and compliance / Lab walkthrough

Run my security
risk assessment lab.

Practice the full GRC cycle: find control gaps, map them to NIST SP 800-53, rate the risk, and turn findings into a tracked remediation plan.

NIST SP 800-53 Rev. 5FIPS 199PCI DSSRBACPOA&M

Why I built this lab

Security isn’t only tools. I wanted to practice the governance side: finding control gaps, mapping them to a real framework, and turning findings into a tracked plan, the same workflow GRC and risk teams use.

Make it your own. This is how I did it, not the only way. Feel free to adjust the lab to your liking: change the names, tools, or scope, or take it further. What matters is that you understand what you built and why.

Before you start

  • A copy of NIST SP 800-53 Rev. 5 (free from csrc.nist.gov).
  • A spreadsheet for your risk register and POA&M, and a document for your policy.
  • The Bayou Bites Café practice scenario and worksheets below.

What you’ll learn

  • Security control assessment and gap analysis
  • Rating impact on confidentiality, integrity, and availability
  • Risk-based remediation planning
  • POA&M tracking
  • RBAC and least-privilege design
  • Writing a policy aligned to PCI DSS

Practice scenario · fictional company

Bayou Bites Café

Bayou Bites Café is a family-owned restaurant with 3 locations and 22 employees. The owner hired you to assess their security before they renew their card processing contract.

Their systems

  • A cloud point-of-sale (POS) system with card terminals at every location. It processes credit card payments.
  • One back-office Windows PC per location for scheduling, payroll, and inventory.
  • An online ordering website run by a vendor, with an admin login for the café.
  • One Wi-Fi network per location, shared by guests, staff, and the POS terminals.
  • The owner’s laptop, used for email and banking.

Your assessment notes

  1. Everyone logs in to the POS with one shared manager account, manager1. Former employees still know the password.
  2. The POS terminals and the Wi-Fi routers still use the vendor’s default passwords.
  3. Last year an IT consultant found 8 issues. The list lives in an old email. Only 2 were fixed, and nobody owns the rest.
  4. Nobody reviews POS, router, or antivirus logs. Alerts go to an inbox no one checks.
  5. The café has never done a formal risk assessment. The owner says, “We’re too small to be a target.”
  6. When a phishing email compromised a cashier’s email account, the only response was changing that one password. There is no plan for what to do when something goes wrong.
  7. Guest Wi-Fi and the POS terminals are on the same network.
  8. Antivirus on two back-office PCs expired six months ago.
  9. A shift lead who left three months ago still has active accounts in the scheduling system and the online ordering admin.
⬇ Risk register worksheet (.csv) ⬇ POA&M worksheet (.csv)

Opens in Excel or Google Sheets (File → Import). The first row of each is filled in as an example.

Answer key: try it yourself first, then tap to compare

FIPS 199: SC Bayou Bites POS = {(confidentiality, MODERATE), (integrity, MODERATE), (availability, MODERATE)}, so the overall category is Moderate. Card data leaking would hurt customers and the business, altered orders or prices cause real loss, and a POS outage stops sales. Rating confidentiality High is reasonable too, if you can explain why.

NoteMain controlWhy
1AC-6 Least PrivilegeA shared admin login gives everyone more access than they need and no accountability.
2PCI DSS: secure configurationsVendor default passwords are public knowledge and must be changed.
3CA-5 Plan of Action and MilestonesKnown findings have no owners, dates, or tracking.
4CA-7 Continuous MonitoringNo one watches logs or alerts, so problems go unnoticed.
5RA-3 Risk AssessmentRisks have never been identified or rated.
6RA-7 Risk ResponseThere is no defined way to respond to findings or incidents.
7PCI DSS: network security controlsThe POS should be separated from guest Wi-Fi.
8PCI DSS: malware protectionExpired antivirus leaves the PCs unprotected.
9AC-6, plus access reviewsA former employee still has access. Periodic access reviews would have caught it.

Highest risks to fix first: notes 1, 2, 7, and 9. They directly expose card data or give access to people who shouldn’t have it.

How it fits together

  1. Scope the systemPick an organization and what you’re assessing.
  2. Categorize with FIPS 199Rate impact on C, I, and A.
  3. Find control gapsMap deficiencies to NIST 800-53.
  4. Plan remediationRisk-based fixes, RBAC, access reviews.
  5. Track with a POA&MOwners, deadlines, status, evidence.

Step by step

  1. Scope your system

    Read the Bayou Bites Café scenario above. In a few sentences, describe what you’re assessing: the business, its systems, the data it handles (especially card payments), and who uses each system.

  2. Categorize it with FIPS 199

    Rate the potential impact of a loss of confidentiality, integrity, and availability as low, moderate, or high. The highest of the three sets the overall category. Write it in the FIPS 199 format:

    text
    SC Bayou Bites POS = {(confidentiality, ?), (integrity, ?), (availability, ?)}

    Ask yourself: what happens if card data leaks (C)? If prices or orders are changed (I)? If the registers go down on a Friday night (A)?

  3. Identify control gaps

    Go through the nine assessment notes in the scenario. For each one, write the finding in your risk register and map it to a NIST SP 800-53 Rev. 5 control (or a PCI DSS requirement). My lab focused on these controls:

    • AC-6 Least Privilege: users have more access than their job needs.
    • CA-5 Plan of Action and Milestones: findings are not tracked to completion.
    • CA-7 Continuous Monitoring: security status is not watched over time.
    • RA-3 Risk Assessment: risks are not formally identified and rated.
    • RA-7 Risk Response: there is no defined way to respond to findings.
  4. Rate the risk

    For each gap, rate its impact and how likely it is to happen, then combine them with this simple matrix. Fix the Highs first.

    text
                     Impact: Low    Moderate   High
    Likelihood High:         Moderate  High       High
    Likelihood Moderate:     Low       Moderate   High
    Likelihood Low:          Low       Low        Moderate

    The first row of the risk register worksheet is filled in as an example.

  5. Write remediation strategies

    For each control, write a risk-based remediation strategy that explains what changes, why it reduces risk, and who owns it.

  6. Recommend RBAC and access reviews

    Design role-based access so people only get what their role needs, and add periodic access reviews to catch excessive access to sensitive information.

  7. Build a POA&M tracker

    Create a Plan of Action and Milestones to track remediation to completion. My tracker covered risk severity, ownership, deadlines, status, and evidence. Use the POA&M worksheet above. Its first row shows a finished example:

    text
    ID | Weakness | NIST control | Risk severity | Owner | Milestones | Due date | Status | Evidence of completion
  8. Write a PCI DSS-aligned policy

    Write a short security policy for Bayou Bites’ point-of-sale environment. Name a technical owner for each requirement. A simple outline:

    1. Purpose and scope: which systems and locations it covers.
    2. Network security controls: keep the POS on its own network, separate from guest Wi-Fi.
    3. Secure configuration: change every vendor default password before a device goes live.
    4. Malware protection: keep antivirus current on every back-office computer.
    5. Roles and ownership: who is responsible for each requirement.
    6. Review: how often the policy is reviewed and updated.
  9. Compare with the answer key

    When you’re done, open the answer key at the top of the page and compare. It’s fine if your mappings differ, as long as you can explain why.

Check your work

Interview ready

Be ready to explain

  • How you used FIPS 199 to decide how critical the system is.
  • Why you chose AC-6, CA-5, CA-7, RA-3, and RA-7, and how they connect.
  • How a POA&M turns findings into accountable, trackable work.
  • How RBAC and access reviews reduce excessive access.
  • How continuous monitoring (CA-7) ties to detection work like my Sentinel lab.

Know your work front to back and you’ll be ready when someone says “walk me through it.”

This walkthrough follows my lab. Portals and menus change over time, so names may look slightly different when you try it. See my original write-up on GitHub

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