BlackAether/Frameworks-and-Controls · Datasets at Hugging Face

Technology Development & Acquisition

Software Release Integrity Verification

TDA-20.1

Mechanisms exist to publish integrity verification information for software releases.

null

Does the organization publish integrity verification information for software releases?

6

Protect

null

X

There is no evidence of a capability to publish integrity verification information for software releases.

SP-CMM1 is N/A, since a structured process is required to publish integrity verification information for software releases.

SP-CMM2 is N/A, since a well-defined process is required to publish integrity verification information for software releases.

Technology Development & Acquisition (TDA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Secure development practices conform to industry-recognized standards for secure engineering (e.g., OWASP, NIST SP 800-218, NIST SP 800-160, etc.). • A procurement team, or similar function, ensures that third party development and/ or acquisitions meet, or exceed, the organization's business, cybersecurity & data privacy requirements to have secure and resilient systems, applications, services and processes. • A Software Assurance Maturity Model (SAMM) governs a secure development lifecycle for the development of systems, applications and services. • Administrative processes exist and technologies are configured to implement secure configuration settings by default to reduce the likelihood of software being deployed with weak security settings, putting the asset at a greater risk of compromise. • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A formal Change Management (CM) program help to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • A Governance, Risk & Compliance (GRC) function, or similar function; o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data for technology development and acquisition. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. • A Project Management Office (PMO), or project management function, enables IAP pre-production testing of cybersecurity & data privacy controls as part of the organization’s established project management processes.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to publish integrity verification information for software releases.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to publish integrity verification information for software releases.

null

PS.2 PS.2.1

null

PS.2 PS.2.1

null

I.2.5.7

null

R-AM-3 R-BC-2 R-BC-3 R-BC-4 R-GV-1 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-AM-3

null

R-BC-2

R-BC-3

R-BC-4

null

R-GV-1

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-11 NT-12 NT-13 MT-1 MT-2 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

null

NT-11

NT-12

NT-13

null

MT-1

MT-2

null

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Technology Development & Acquisition

Archiving Software Releases

TDA-20.2

Mechanisms exist to archive software releases and all of their components (e.g., code, package files, third-party libraries, documentation) to maintain integrity verification information.

null

Does the organization archive software releases and all of their components (e?g?, code, package files, third-party libraries, documentation) to maintain integrity verification information?

8

Protect

null

X

There is no evidence of a capability to archive software releases and all of their components (e.g., code, package files, third-party libraries, documentation) to maintain integrity verification information.

SP-CMM1 is N/A, since a structured process is required to archive software releases and all of their components (e.g., code, package files, third-party libraries, documentation) to maintain integrity verification information.

SP-CMM2 is N/A, since a well-defined process is required to archive software releases and all of their components (e.g., code, package files, third-party libraries, documentation) to maintain integrity verification information.

Technology Development & Acquisition (TDA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Secure development practices conform to industry-recognized standards for secure engineering (e.g., OWASP, NIST SP 800-218, NIST SP 800-160, etc.). • A procurement team, or similar function, ensures that third party development and/ or acquisitions meet, or exceed, the organization's business, cybersecurity & data privacy requirements to have secure and resilient systems, applications, services and processes. • A Software Assurance Maturity Model (SAMM) governs a secure development lifecycle for the development of systems, applications and services. • Administrative processes exist and technologies are configured to implement secure configuration settings by default to reduce the likelihood of software being deployed with weak security settings, putting the asset at a greater risk of compromise. • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A formal Change Management (CM) program help to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • A Governance, Risk & Compliance (GRC) function, or similar function; o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data for technology development and acquisition. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. • A Project Management Office (PMO), or project management function, enables IAP pre-production testing of cybersecurity & data privacy controls as part of the organization’s established project management processes. • Administrative processes exist and technologies are configured to archive software releases and all of its components (e.g., code, package files, third-party libraries, documentation) and maintain integrity verification information.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to archive software releases and all of their components (e.g., code, package files, third-party libraries, documentation) to maintain integrity verification information.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to archive software releases and all of their components (e.g., code, package files, third-party libraries, documentation) to maintain integrity verification information.

null

PS.3 PS.3.1

null

PS.3 PS.3.1 PS.3.2

null

1.2.5.9

null

R-AM-3 R-BC-2 R-BC-3 R-BC-4 R-GV-1 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-AM-3

null

R-BC-2

R-BC-3

R-BC-4

null

R-GV-1

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-11 NT-12 NT-13 MT-1 MT-2 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

null

NT-11

NT-12

NT-13

null

MT-1

MT-2

null

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Technology Development & Acquisition

Software Escrow

TDA-20.3

Mechanisms exist to escrow source code and supporting documentation to ensure software availability in the event the software provider goes out of business or is unable to provide support.

null

E-TDA-13

Does the organization escrow source code and supporting documentation to ensure software availability in the event the software provider goes out of business or is unable to provide support?

7

Protect

X

There is no evidence of a capability to escrow source code and supporting documentation to ensure software availability in the event the software provider goes out of business or is unable to provide support.

SP-CMM1 is N/A, since a structured process is required to escrow source code and supporting documentation to ensure software availability in the event the software provider goes out of business or is unable to provide support.

SP-CMM2 is N/A, since a well-defined process is required to escrow source code and supporting documentation to ensure software availability in the event the software provider goes out of business or is unable to provide support.

Technology Development & Acquisition (TDA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Secure development practices conform to industry-recognized standards for secure engineering (e.g., OWASP, NIST SP 800-218, NIST SP 800-160, etc.). • A procurement team, or similar function, ensures that third party development and/ or acquisitions meet, or exceed, the organization's business, cybersecurity & data privacy requirements to have secure and resilient systems, applications, services and processes. • A Software Assurance Maturity Model (SAMM) governs a secure development lifecycle for the development of systems, applications and services. • Administrative processes exist and technologies are configured to implement secure configuration settings by default to reduce the likelihood of software being deployed with weak security settings, putting the asset at a greater risk of compromise. • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A formal Change Management (CM) program help to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • A Governance, Risk & Compliance (GRC) function, or similar function; o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data for technology development and acquisition. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. • A Project Management Office (PMO), or project management function, enables IAP pre-production testing of cybersecurity & data privacy controls as part of the organization’s established project management processes. • The process owner contracts a reputable third-party escrow agent to provide source code and supporting documentation to ensure software availability in the event the software provider goes out of business or is unable to provide support.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to escrow source code and supporting documentation to ensure software availability in the event the software provider goes out of business or is unable to provide support.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to escrow source code and supporting documentation to ensure software availability in the event the software provider goes out of business or is unable to provide support.

null

TS-1.14

null

1-3-2-2

null

5.3.4

null

R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-GV-1 R-IR-1 R-IR-2 R-IR-3 R-IR-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-GV-1

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

null

MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Third-Party Management

TPM-01

Mechanisms exist to facilitate the implementation of third-party management controls.

- Procurement program - Contract reviews

E-TPM-03

Does the organization facilitate the implementation of third-party management controls?

10

Identify

X

There is no evidence of a capability to facilitate the implementation of third-party management controls.

Third-Party Management (TPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized. • IT personnel use an informal process to govern third-party service providers. • IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects. • Project management is decentralized and generally lacks formal project management managers or broader oversight.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy to determine prioritized and authoritative guidance for third-party management practices. • The CISO, or similar function, develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures to apply defense-in-depth techniques across the enterprise for third-party management. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including third-party management. • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the implementation of third-party management controls.

CC3.3 CC9.1

CC1.1-POF5 CC1.4-POF2 CC1.4-POF3 CC2.3-POF9 CC2.3-POF10 CC9.2-POF1 CC9.2-POF2 CC9.2-POF3 CC9.2-POF4 CC9.2-POF5 CC9.2-POF6 CC9.2-POF7 CC9.2-POF8 CC9.2-POF9 CC9.2-POF10 CC9.2-POF11 CC9.2-POF12

null

15.0 15.2

null

15.2

APO10.01 APO10.02 APO10.03 APO10.04 APO10.05 DSS01.02

Principle 8

IAM-11 SEF-02 STA-01 STA-02 STA-03 STA-07 STA-12 STA-13 UEM-14

POL-01 POL-02

SO4

null

CR 3.12 (7.14)

RQ-06-10 RQ-07-01

null

15.1.1

5.19 5.20 8.30

15.1.1

null

6.12 6.12.1 6.12.1.1

null

OR-3.4

Sec 4(F)(1)

MANAGE 3.0

GV.PO-P4

PW.3 PW.3.1

null

SA-4

SA-4 SR-1

SA-4

SA-4 SR-1

null

SA-4 SR-1

null

SA-4 SR-1

null

SA-4 SR-1

NFO - SA-4

3.1.20.a 3.1.20.b 3.1.20.c.1 3.1.20.c.2 3.1.20.d 3.16.1 3.16.3.a 3.16.3.b 3.16.3.c

null

A.03.17.03.ODP[01]

null

ID.BE-1 ID.SC-1 ID.SC-3

GV.SC GV.SC-01 GV.SC-03 GV.SC-09 ID.RA

A02:2021 A05:2021

12.8

8.2.3 12.8 12.8.1 12.9 12.9.1 12.9.2 A2.1.3

12.8.1

8.2.3 12.8.1 12.9.1 12.9.2 A2.1.3

12.8.1

B.1.1.1

2.8A

1.2.4 1.3.3 6.1.1

12.1

7.2.2.5

RISK-2.J.MIL3 THIRD-PARTIES-2.A.MIL1 THIRD-PARTIES-2.B.MIL1 THIRD-PARTIES-2.C.MIL2 THIRD-PARTIES-2.D.MIL2 THIRD-PARTIES-2.E.MIL2 THIRD-PARTIES-2.F.MIL2 THIRD-PARTIES-2.G.MIL2 THIRD-PARTIES-2.H.MIL3 THIRD-PARTIES-2.I.MIL3 THIRD-PARTIES-2.J.MIL3 THIRD-PARTIES-2.K.MIL3 THIRD-PARTIES-2.L.MIL3 THIRD-PARTIES-2.M.MIL3

EXD:SG3.SP4 OPD:SG1.SP6 RTSE:SG1.SP1 RTSE:SG1.SP2 RTSE:SG1.SP3 RTSE:SG1.SP4 RTSE:SG1.SP5

5.6 6.1 6.2

null

SA-4

null

252.204-7012(m)(1) 252.204-7012(m)(2)(i) 252.204-7012(m)(2)(ii) 252.204-7019(b) 252.204-7019(c)(1) 252.204-7019(c)(2) 252.204-7020(c) 252.204-7021(b) 252.204-7021(c)(1) 252.204-7021(c)(2)

null

52.204-21(c)

52.204-27(b)

null

SA-4

SA-4 SR-1

null

314.4(a) 314.4(a)(1) 314.4(a)(2) 314.4(a)(3) 314.4(e)(2) 314.4(f)(1) 314.4(f)(2) 314.4(f)(3)

164.308(b) 164.308(b)(1) 164.308(b)(2)

null

9.L.C

2.C.8 2.C.8.1 2.C.8.2 SA-4 SR-1

null

15.1 15.2 15.3 15.4 16.2

null

6-1-1305(6) 6-1-1305(7)

null

500.11

Sec 4(2)(b)(ii)(A)(5)

null

38-99-20(F)(1)

null

SA-4 SR-1

SA-4

null

§ 2447(b)(6) § 2447(b)(6)(A) § 2447(b)(6)(B)

3.2.3(7) 3.6.2(74)

null

Art 28.1 Art 28.2 Art 28.3 Art 28.4 Art 28.5 Art 28.6 Art 28.9 Art 28.10 Art 32.1 Art 32.2

Article 21.2(d) Article 21.2(e) Article 21.3

null

Sec 14 Sec 15

Art 16

null

Art 42

null

9.1

SSO-01 SSO-03

null

11.3 11.10 16.1 17.3

null

4-1

null

3.4.1 3.4.2

1-5-3-3 4-1-1 4-1-2 4-1-3 4-1-4

4-1 4-1-1 4-1-1-1 4-1-1-2 4-1-1-3 4-1-1-4 4-1-2

null

Sec 20 Sec 21

null

7.4.1 [OP.EXT.1]

null

A4.a

A4

null

1073 1785

null

15 47 48(a) 48(b) 48(c) 57

16 20 22 28

null

Article 20 Article 21 Article 38(3) Article 42 Article 51 Article 51(1) Article 51(2) Article 51(3) Article 51(4) Article 51(5) Article 51(6)

null

Article 22 Article 23(1)(i) Article 23(1)(ii) Article 23(1)(iii) Article 23(1)(iv) Article 23(2) Article 23(2)(i) Article 23(2)(ii) Article 23(2)(iii) Article 23(2)(iv) Article 23(2)(v) Article 23(2)(vi) Article 23(2)(vii) Article 23(2)(viii) Article 23(3) Article 23(4) Article 23(5)(i) Article 23(5)(ii) Article 23(5)(iii) Article 23(6) Article 23(1) Article 24(3)

15.1.1 15.1.1.14.B 15.1.1.16.B 15.1.2.18.PB

null

16.1

2.2.6.C.01 2.2.6.C.02 23.2.19.C.01

null

3.4.1 3.4.2 3.4.3 9.1.8

null

5.10

null

2.3 4.25

null

x

FAR 52.204-21 NAIC

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

- updated DFARS mapping

Third-Party Management

Third-Party Inventories

TPM-01.1

Mechanisms exist to maintain a current, accurate and complete list of External Service Providers (ESPs) that can potentially impact the Confidentiality, Integrity, Availability and/or Safety (CIAS) of the organization's systems, applications, services and data.

null

E-AST-06 E-DCH-06

Does the organization maintain a current, accurate and complete list of External Service Providers (ESPs) that can potentially impact the Confidentiality, Integrity, Availability and/or Safety (CIAS) of the organization's systems, applications, services and data?

8

Identify

null

X

There is no evidence of a capability to maintain a current, accurate and complete list of Third-Party Service Providers (TSP) that can potentially impact the Confidentiality, Integrity, Availability and/ or Safety (CIAS) of the organization's systems, applications, services and data.

SP-CMM1 is N/A, since a structured process is required to maintain a current, accurate and complete list of Third-Party Service Providers (TSP) that can potentially impact the Confidentiality, Integrity, Availability and/ or Safety (CIAS) of the organization's systems, applications, services and data.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to maintain a current, accurate and complete list of Third-Party Service Providers (TSP) that can potentially impact the Confidentiality, Integrity, Availability and/ or Safety (CIAS) of the organization's systems, applications, services and data.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to maintain a current, accurate and complete list of Third-Party Service Providers (TSP) that can potentially impact the Confidentiality, Integrity, Availability and/ or Safety (CIAS) of the organization's systems, applications, services and data.

null

15.1

null

5.19

null

SR-13

null

SR-13

null

3.7.6.b

null

GV.SC-04 ID.AM-04

null

12.8 12.8.1

12.8.1

K.3.1 K.3.2 K.3.7

null

7.2.2.5

THIRD-PARTIES-1.B.MIL1

null

252.204-7018(c)

null

Art 28.1 Art 28.1(a) Art 28.1(b) Art 28.1(b)(i) Art 28.1(b)(ii) Art 28.2 Art 28.3 Art 28.4(a) Art 28.4(b) Art 28.4(c) Art 28.4(d) Art 28.4(e) Art 28.5 Art 28.6 Art 28.7(a) Art 28.7(b) Art 28.7(c) Art 28.7(d) Art 28.8 Art 28.8(a) Art 28.8(b) Art 28.8(c)

null

Article 21.3

null

A4.a

null

1631 1786 1736 1737 1637 1638

null

49

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

- updated DFARS mapping

Third-Party Management

Third-Party Criticality Assessments

TPM-02

Mechanisms exist to identify, prioritize and assess suppliers and partners of critical systems, components and services using a supply chain risk assessment process relative to their importance in supporting the delivery of high-value services.

- Data Protection Impact Assessment (DPIA)

E-TPM-02

Does the organization identify, prioritize and assess suppliers and partners of critical systems, components and services using a supply chain risk assessment process relative to their importance in supporting the delivery of high-value services?

9

Identify

X

There is no evidence of a capability to identify, prioritize and assess suppliers and partners of critical systems, components and services using a supply chain risk assessment process relative to their importance in supporting the delivery of high-value services.

SP-CMM1 is N/A, since a structured process is required to identify, prioritize and assess suppliers and partners of critical systems, components and services using a supply chain risk assessment process relative to their importance in supporting the delivery of high-value services.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify, prioritize and assess suppliers and partners of critical systems, components and services using a supply chain risk assessment process relative to their importance in supporting the delivery of high-value services.

CC9.1

null

15.3

null

15.3

APO10.04

null

STA-07

null

5.19

null

T1195.003, T1495, T1542, T1542.001, T1542.003, T1542.004, T1542.005, T1553, T1553.006, T1601, T1601.001, T1601.002

null

ID.BE-P3

null

SA-14

null

PM-30(1) RA-9

null

RA-9

PM-30(1)

null

RA-9

null

RA-9

null

RA-9

null

3.17.3.a

null

ID.BE-1 ID.SC-2

GV.OC-04 GV.SC-04 GV.SC-07

null

B.1.1.1

2.8A

1.3.3

12.1

7.2.2.5 7.3.2 7.3.3

THIRD-PARTIES-1.C.MIL2 THIRD-PARTIES-1.D.MIL2 THIRD-PARTIES-1.E.MIL2 THIRD-PARTIES-1.F.MIL3 THIRD-PARTIES-2.A.MIL1 THIRD-PARTIES-2.B.MIL1 THIRD-PARTIES-2.C.MIL2 THIRD-PARTIES-2.D.MIL2 THIRD-PARTIES-2.E.MIL2 THIRD-PARTIES-2.F.MIL2 THIRD-PARTIES-2.G.MIL2 THIRD-PARTIES-2.H.MIL3 THIRD-PARTIES-2.I.MIL3 THIRD-PARTIES-2.J.MIL3 THIRD-PARTIES-2.K.MIL3 THIRD-PARTIES-2.L.MIL3 THIRD-PARTIES-2.M.MIL3

EXD:SG1.SP2 RTSE:SG2.SP1 RTSE:SG2.SP2 RTSE:SG3.SP1 RTSE:SG3.SP2 TM:SG1.SP1

null

RA-9

null

RA-9

null

D1.G.SP.A.3

null

314.4(f)(1)

null

9.L.C

null

8-302 8-311

null

Art 8.4

null

Article 21.3

null

SSO-02 SSO-03

null

16.1 16.6

null

4-1-1-1

null

4-1-1-2

null

A4.a

A4

null

1452

null

50(a) 50(b) 50(c) 50(d) 52

21(b)

null

15.1.1.16.B 15.1.2.18.PB

null

12.7.17.C.01

null

2.3 4.27

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Supply Chain Protection

TPM-03

Mechanisms exist to evaluate security risks associated with the services and product supply chain.

- Data Protection Impact Assessment (DPIA)

E-RSK-02

Does the organization evaluate security risks associated with the services and product supply chain?

9

Identify

X

There is no evidence of a capability to evaluate security risks associated with the services and product supply chain.

SP-CMM1 is N/A, since a structured process is required to evaluate security risks associated with the services and product supply chain.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to evaluate security risks associated with the services and product supply chain.

CC9.1

CC1.1-POF5 CC3.2-POF7 CC9.2-POF1 CC9.2-POF2 CC9.2-POF3 CC9.2-POF4 CC9.2-POF5 CC9.2-POF6 CC9.2-POF7 CC9.2-POF8 CC9.2-POF9 CC9.2-POF10 CC9.2-POF11 CC9.2-POF12

null

APO10.04

null

IAM-11 STA-02 STA-03 STA-13

POL-02

SO10

null

CR 3.12 (7.14)

RQ-07-01

null

15.1.3

5.19 5.21 5.22 8.30

15.1.3

null

6.12.1.3

null

OR-3.4

Sec 4(F)(1)

null

PW.3 PW.3.1

null

SA-12

null

SA-12

SR-2 SR-2(1)

null

SR-2 SR-2(1)

null

SR-2 SR-2(1)

null

SR-2

null

SR-2

null

3.17.1.a 3.17.3.a 3.17.3.b

null

ID.SC-3 ID.SC-4

GV.SC-01 GV.SC-07

A02:2021 A05:2021

null

B.1.1.17

2.8A

1.2.4 1.3.3

12.1 12.2 12.3 12.4 12.5 12.6 12.7 12.8

7.2.2.5

THIRD-PARTIES-1.E.MIL2 THIRD-PARTIES-2.A.MIL1 THIRD-PARTIES-2.B.MIL1 THIRD-PARTIES-2.C.MIL2 THIRD-PARTIES-2.D.MIL2 THIRD-PARTIES-2.E.MIL2 THIRD-PARTIES-2.F.MIL2 THIRD-PARTIES-2.G.MIL2 THIRD-PARTIES-2.H.MIL3 THIRD-PARTIES-2.I.MIL3 THIRD-PARTIES-2.J.MIL3 THIRD-PARTIES-2.K.MIL3 THIRD-PARTIES-2.L.MIL3 THIRD-PARTIES-2.M.MIL3

EXD:SG3.SP1 EXD:SG3.SP2 EXD:SG3.SP3 EXD:SG3.SP4 EXD:SG4.SP1 EXD:SG4.SP2 RTSE:SG2.SP1 RTSE:SG2.SP2 RTSE:SG3.SP1 RTSE:SG3.SP2

null

SA-12

null

SA-12

null

SR-2(1)

null

314.4(f)(1)

null

5.S.B

5.M.B

5.M.B 9.L.C

SR-2 SR-2(1)

null

38-99-20(F)(1)

null

SR-2

null

§ 2447(b)(6) § 2447(b)(6)(A) § 2447(b)(6)(B)

3.6.2(74)

null

Art 28.1 Art 28.2 Art 28.3 Art 28.4 Art 28.5 Art 28.6 Art 28.9 Art 28.10

Article 21.2(d) Article 21.3

null

Art 42

null

SSO-02 SSO-02 SSO-03

null

11.3 16.1 16.3 16.5 17.3 17.11

null

Art 31

Art 18

null

4-1-1-1 4-1-1-2

null

3.4.2

null

Sec 20

Art 20 Art 21

7.4.1 [OP.EXT.1] 7.4.3 [OP.EXT.3]

null

A4.a

null

0731 1452 1632 1789

null

22 28

null

Art 6

null

15.1.1.16.B 15.1.2.18.PB 15.1.3

null

12.7.14.C.01 12.7.14.C.02 12.7.14.C.03 12.7.15.C.01 12.7.15.C.02 12.7.16.C.01 12.7.16.C.02 12.7.16.C.03 12.7.17.C.01 12.7.18.C.01 12.7.18.C.02 12.7.19.C.01 12.7.19.C.02 12.7.20.C.01 12.7.20.C.02 12.7.20.C.03 12.7.20.C.04 12.7.20.C.05 12.7.21.C.01

null

Sec 25 Sec 43

null

3.4.1 3.4.2

null

2.3 4.25

null

Art 21

null

x

NAIC

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Acquisition Strategies, Tools & Methods

TPM-03.1

Mechanisms exist to utilize tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services.

- Data Protection Impact Assessment (DPIA)

null

Does the organization utilize tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services?

9

Identify

X

There is no evidence of a capability to utilize tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services.

SP-CMM1 is N/A, since a structured process is required to utilize tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services.

CC3.3 CC9.1

null

Principle 8

STA-05

null

5.21 5.22

null

T1059.002, T1204.003, T1505, T1505.001, T1505.002, T1505.004, T1546.006, T1554, T1601, T1601.001, T1601.002

null

Sec 4(F)(1)

null

SA-12(1)

null

SR-5 SR-3(1)

null

SR-5

SR-3(1)

null

SR-5

null

SR-5 SR-3(1)

SR-5

null

SR-5

SR-5 SR-3(1)

null

3.17.1.a 3.17.2 3.17.3.a 3.17.3.b

null

GV.SC-05 GV.SC-06

null

B.1.1.24

null

7.2.2.5

THIRD-PARTIES-1.E.MIL2 THIRD-PARTIES-2.A.MIL1 THIRD-PARTIES-2.B.MIL1 THIRD-PARTIES-2.C.MIL2 THIRD-PARTIES-2.D.MIL2 THIRD-PARTIES-2.E.MIL2 THIRD-PARTIES-2.F.MIL2 THIRD-PARTIES-2.G.MIL2 THIRD-PARTIES-2.H.MIL3 THIRD-PARTIES-2.I.MIL3 THIRD-PARTIES-2.J.MIL3 THIRD-PARTIES-2.K.MIL3 THIRD-PARTIES-2.L.MIL3 THIRD-PARTIES-2.M.MIL3

null

SR-5

null

9.L.C

null

38-99-20(F)(1)

null

SR-5

null

3.6.2(74)

null

Article 21.3

null

9.3

SSO-05

null

16.1

null

4-1-1-1 4-1-1-2

null

A4.a

null

1567 1568 1632 1788 1789 1743

null

NAIC

null

R-AM-3 R-BC-1 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-4 R-GV-5

null

R-AM-3

R-BC-1

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

null

R-GV-4

R-GV-5

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Limit Potential Harm

TPM-03.2

Mechanisms exist to utilize security safeguards to limit harm from potential adversaries who identify and target the organization's supply chain.

- Data Protection Impact Assessment (DPIA) - Liability clause in contracts

null

Does the organization utilize security safeguards to limit harm from potential adversaries who identify and target the organization's supply chain?

9

Identify

null

X

There is no evidence of a capability to utilize security safeguards to limit harm from potential adversaries who identify and target the organization's supply chain.

SP-CMM1 is N/A, since a structured process is required to utilize security safeguards to limit harm from potential adversaries who identify and target the organization's supply chain.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize security safeguards to limit harm from potential adversaries who identify and target the organization's supply chain.

CC9.1

P6.4-POF2 P6.5-POF1 P6.5-POF2 P6.6-POF1

null

15.4

null

15.4

null

STA-13

RSM-03

null

RQ-07-01

null

5.19 5.20

null

OR-3.4

null

SA-12(5)

null

SR-3(2)

null

SR-3(2)

null

3.17.3.a 3.17.3.b

null

GV.SC-05 GV.SC-06

null

T.2 T.2.1

null

7.2.2.5

THIRD-PARTIES-1.E.MIL2

null

314.4(f)(1)

null

9.L.C

SR-3(2)

null

Article 21.3

null

SSO-02

null

11.3 16.2

null

4-1-1-1 4-1-1-2

null

A4.a

null

1567

null

56(a) 56(b) 56(c) 56(d)

22

null

Article 20

null

3.4.1 3.4.2

null

2.3 4.25

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Processes To Address Weaknesses or Deficiencies

TPM-03.3

Mechanisms exist to address identified weaknesses or deficiencies in the security of the supply chain

- Data Protection Impact Assessment (DPIA)

null

Does the organization address identified weaknesses or deficiencies in the security of the supply chain

9

Identify

X

There is no evidence of a capability to address identified weaknesses or deficiencies in the security of the supply chain

SP-CMM1 is N/A, since a structured process is required to address identified weaknesses or deficiencies in the security of the supply chain

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to address identified weaknesses or deficiencies in the security of the supply chain

CC9.1

null

APO10.04

null

RQ-07-06

null

5.19 5.22

null

SA-12(15)

null

SR-3

null

SR-3

null

SR-3

null

SR-3

null

SR-3

null

3.17.3.a 3.17.3.b

null

GV.SC-05 GV.SC-06 GV.SC-07

null

T.2.2

null

12.1 12.2 12.3 12.4 12.5 12.6 12.7 12.8

7.2.2.5

null

EXD:SG2.SP2

null

SR-3

null

SR-3

null

SR-3

null

Article 21.3

null

SSO-02

null

A4.a

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Adequate Supply

TPM-03.4

Mechanisms exist to develop and implement a spare parts strategy to ensure that an adequate supply of critical components is available to meet operational needs.

null

Does the organization develop and implement a spare parts strategy to ensure that an adequate supply of critical components is available to meet operational needs?

9

Protect

x

null

SR-5(1)

null

SR-5(1)

null

SR-5(1)

null

R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

- new control for NIST 800-53 R5 SR-5(1)

Third-Party Management

Third-Party Services

TPM-04

Mechanisms exist to mitigate the risks associated with third-party access to the organization’s systems and data.

- Conduct an organizational assessment of risk prior to the acquisition or outsourcing of services. - Maintain and implement policies and procedures to manage service providers (e.g., Software-as-a-Service (SaaS), web hosting companies, collocation providers, or email providers), through observation, review of policies and procedures and review of supporting documentation. - Maintain a program to monitor service providers’ control compliance status at least annually. - Require providers of external system services to comply with organizational security requirements and employ appropriate security controls in accordance with applicable statutory, regulatory and contractual obligations. - Define and document oversight and user roles and responsibilities with regard to external system services. - CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/)

E-CPL-06

Does the organization mitigate the risks associated with third-party access to the organization’s systems and data?

10

Identify

X

null

There is no evidence of a capability to mitigate the risks associated with third-party access to the organization’s systems and data.

SP-CMM1 is N/A, since a structured process is required to mitigate the risks associated with third-party access to the organization’s systems and data.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to mitigate the risks associated with third-party access to the organization’s systems and data.

CC3.3

null

15.4 15.5

null

15.4

15.4 15.5

null

Principle 8

IAM-11 STA-02 UEM-14

POL-01 POL-02

null

RQ-07-01

null

14.2.7 15.1.1

5.19 8.30

14.2.7 15.1.1

null

6.11.2.7 6.12 6.12.1 6.12.1.1

null

T1041, T1048, T1048.002, T1048.003, T1567

OR-3.4

null

SA-9

null

SA-9

null

NFO -SA-9

3.16.3.a 3.16.3.b 3.16.3.c 3.17.2 3.17.3.a 3.17.3.b

null

ID.SC-2

GV.SC-05

A02:2021 A05:2021

12.8.2 12.8.4

8.2.3 12.8.2 12.9 12.9.1 12.9.2

12.8.3

8.2.3 12.8.3 12.9.1 12.9.2

12.8.2

T.2.3 T.3 T.3.1 T.4 T.5

null

1.2.4 1.3.3 8.2.2

12.1 12.2 12.3 12.4 12.5 12.6 12.7 12.8

7.2.2.5

THIRD-PARTIES-1.B.MIL1 THIRD-PARTIES-1.E.MIL2

EXD:SG3.SP4 EXD:SG4.SP1

null

SA-9

null

SA-9

null

314.4(f)(1) 314.4(f)(2) 314.4(f)(3)

null

9.L.C

2.C.8 2.C.10 SA-9

null

8-700

null

SA-9

null

17.03(2)(f)(1)

null

622(2)(d)(A)(v)

null

SA-9

null

Article 21.3

null

9.2

SSO-05

null

11.3 16.1 22.4

null

4-1-1-1 4-1-1-2

null

4-1-1-3

null

Sec 19

null

A4.a

A4

null

1569

null

16 22 28

null

Article 20 Article 21 Article 38(3)

null

Article 22 Article 23(1)(i) Article 23(1)(ii) Article 23(1)(iii) Article 23(1)(iv) Article 23(2) Article 23(2)(i) Article 23(2)(ii) Article 23(2)(iii) Article 23(2)(iv) Article 23(2)(v) Article 23(2)(vi) Article 23(2)(vii) Article 23(2)(viii) Article 23(3) Article 23(4) Article 23(5)(i) Article 23(5)(ii) Article 23(5)(iii) Article 23(6) Article 23(1)

14.2.7 15.1.1 15.1.1.14.B

null

Art 25.1

null

2.3 4.25

null

x

MA 201 CMR 17 OR 6464A

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Third-Party Risk Assessments & Approvals

TPM-04.1

Mechanisms exist to conduct a risk assessment prior to the acquisition or outsourcing of technology-related services.

- Conduct an organizational assessment of risk prior to the acquisition or outsourcing of services. - Maintain a list of service providers. - Maintain and implement controls to manage security providers (e.g., backup tape storage facilities or security service providers), through observation, review of policies and procedures and review of supporting documentation. - Maintain a written agreement that includes an acknowledgment that service providers are responsible for the security of data the service providers possess. - Maintain a program to monitor service providers’ control compliance status, at least annually. - Require that providers of external services comply with organizational digital security requirements and utilize appropriate security controls in accordance with all applicable laws and regulatory requirements.

null

Does the organization conduct a risk assessment prior to the acquisition or outsourcing of technology-related services?

9

Identify

null

X

There is no evidence of a capability to conduct a risk assessment prior to the acquisition or outsourcing of technology-related services.

SP-CMM1 is N/A, since a structured process is required to conduct a risk assessment prior to the acquisition or outsourcing of technology-related services.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to conduct a risk assessment prior to the acquisition or outsourcing of technology-related services.

CC3.4 CC9.2

CC9.2-POF2

null

15.5

null

15.5

APO10.04

Principle 9

STA-05 STA-13

null

RQ-07-01 RQ-07-02

null

5.19

null

MANAGE 3.1

ID.DE-P5

null

SA-9(1)

null

SA-9(1)

null

SA-9(1)

null

SA-9(1)

null

SA-9(1)

null

3.17.2 3.17.3.a 3.17.3.b

null

A.03.17.03.a

null

ID.SC-2

GV.SC-05 GV.SC-06

A02:2021 A05:2021

2.4 12.8 12.8.1 12.8.2 12.8.3 12.8.4

12.8.3

12.8.2

B.1.1.1

null

1.3.3 8.2.2

12.1 12.2 12.3 12.4 12.5 12.6 12.7 12.8

7.2.2.5 7.3.2

RISK-2.J.MIL3 THIRD-PARTIES-1.C.MIL2 THIRD-PARTIES-2.A.MIL1 THIRD-PARTIES-2.B.MIL1 THIRD-PARTIES-2.C.MIL2 THIRD-PARTIES-2.D.MIL2 THIRD-PARTIES-2.E.MIL2 THIRD-PARTIES-2.F.MIL2 THIRD-PARTIES-2.G.MIL2 THIRD-PARTIES-2.H.MIL3 THIRD-PARTIES-2.I.MIL3 THIRD-PARTIES-2.J.MIL3 THIRD-PARTIES-2.K.MIL3 THIRD-PARTIES-2.L.MIL3 THIRD-PARTIES-2.M.MIL3

EXD:SG2.SP1

5.6

null

SA-9(1)

null

SA-9(1)

null

SA-9(1)

null

SA-9(1)

null

SA-9(1)

null

314.4(f)(1) 314.4(f)(3)

null

9.L.C

SA-9(1)

null

SA-9(1)

null

17.03(2)(f)(2)

null

622(2)(d)(A)(v)

null

SA-9(1)

null

§ 2447(b)(6) § 2447(b)(6)(A) § 2447(b)(6)(B)

3.6.2(74)

Art 28.4(a) Art 28.4(b) Art 28.4(c) Art 28.4(d) Art 28.4(e) Art 29.1(a) Art 29.1(b)

null

Article 21.3

null

9.2 9.5

SSO-02 SSO-04

null

16.3 16.5 17.3

null

4-1-1-1 4-1-1-2

null

3.4.1 3.4.2

1-5-3-4 4-1-3-1

4-1-1-2 4-1-1-4

null

Sec 19

null

A4.a

A4

null

1568 1573 1787

null

15 53(a) 53(b)

22 28

null

2.3 4.25 4.27

null

x

MA 201 CMR 17 OR 6464A

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

External Connectivity Requirements - Identification of Ports, Protocols & Services

TPM-04.2

Mechanisms exist to require External Service Providers (ESPs) to identify and document the business need for ports, protocols and other services it requires to operate its processes and technologies.

null

E-CPL-06 E-TDA-07

Does the organization require External Service Providers (ESPs) to identify and document the business need for ports, protocols and other services it requires to operate its processes and technologies?

7

Identify

null

X

There is no evidence of a capability to require Third-Party Service Providers (TSP) to identify and document the business need for ports, protocols and other services it requires to operate its processes and technologies.

SP-CMM1 is N/A, since a structured process is required to require Third-Party Service Providers (TSP) to identify and document the business need for ports, protocols and other services it requires to operate its processes and technologies.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to require Third-Party Service Providers (TSP) to identify and document the business need for ports, protocols and other services it requires to operate its processes and technologies.

null

12.6

null

12.6

null

STA-05 UEM-14

null

SA-9(2)

null

SA-9(2)

null

SA-9(2)

null

SA-9(2)

null

NFO - SA-9(2)

null

A02:2021 A05:2021

null

1.2.5

null

1.2.5

null

1.2.5

null

1.2.5

null

SA-9(2)

null

SA-9(2

null

SA-9(2

null

SA-9(2

null

SA-9(2

null

9.L.C

SA-9(2)

null

6.4

null

SA-9(2

null

SA-9(2)

null

16.3

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Third-Party Management

Conflict of Interests

TPM-04.3

Mechanisms exist to ensure that the interests of external service providers are consistent with and reflect organizational interests.

- Third-party contract requirements for cybersecurity controls

null

Does the organization ensure that the interests of external service providers are consistent with and reflect organizational interests?

8

Identify

null

X

There is no evidence of a capability to ensure that the interests of third-party service providers are consistent with and reflect organizational interests.

Third-Party Management (TPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized. • IT personnel use an informal process to govern third-party service providers.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure that the interests of third-party service providers are consistent with and reflect organizational interests.

CC3.3

null

Principle 8

null

RQ-07-01 RQ-07-07

null

5.19

null

SA-9(4)

null

SA-9(4)

null

SA-9(4)

null

SA-9(4)

null

SA-9(4)

null

GV.SC-05 GV.SC-06

null

K.3.10 K.3.10.1 K.3.10.2 K.3.10.3

null

1.3.3 8.2.2

null

THIRD-PARTIES-1.E.MIL2

null

SA-9(4)

null

SA-9(4)

null

9.L.C

null

SA-9(4)

null

16.3

null

Sec 20 Sec 21

null

A4.a

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Third-Party Processing, Storage and Service Locations

TPM-04.4

Mechanisms exist to restrict the location of information processing/storage based on business requirements.

null

E-AST-23

Does the organization restrict the location of information processing/storage based on business requirements?

10

Identify

null

X

There is no evidence of a capability to restrict the location of information processing/storage based on business requirements.

SP-CMM1 is N/A, since a structured process is required to restrict the location of information processing/storage based on business requirements.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to restrict the location of information processing/storage based on business requirements.

CC9.1

null

APO10.03

null

POL-02

null

RQ-07-01

null

5.21

6.1.3

null

OR-3.4

null

SA-9(5)

null

PE-23 SA-9(5)

null

PE-23 SA-9(5)

null

SA-9(5)

null

SA-9(5)

null

GV.SC-05 GV.SC-06

A02:2021 A05:2021

12.9

3.2.1 12.5.2

3.2.1

null

3.2.1 12.5.2

3.2.1

D.3.1

2.8A

null

THIRD-PARTIES-1.E.MIL2 THIRD-PARTIES-1.F.MIL3

null

SA-9(5)

null

SA-9(5)

null

SA-9(5)

null

SA-9(5)

null

SA-9(5)

null

314.4(f)(1)

null

9.L.C

2.C.7 2.C.10 SA-9(5)

null

SA-9(5)

null

Art 6.1 Art 6.4 Art 26.1 Art 26.2 Art 26.3 Art 28.1 Art 28.2 Art 28.3 Art 28.4 Art 28.5 Art 28.6 Art 28.9 Art 28.10 Art 29 Art 44 Art 45.1 Art 45.2 Art 46.1 Art 46.2 Art 46.3 Art 47.1 Art 47.2 Art 48 Art 49.1 Art 49.2 Art 49.6

Article 21.3

null

Sec 10

Chapter 4 - Art 16

Art 14 Art 27

Art 41

null

Art 34

null

PI-02 PSS-12

null

Sec 7

Sec 2

16.3

Sec 16 Sec 17

Sec 31

null

Art 3 Art 4

Sec 12 Sec 13 Sec 14

null

Sec 13 Sec 14

Art 1 Art 36

Art 14 Art 15

null

Art 7

null

Sec 19 Sec 21

null

Sec 31

null

A4.a

null

Article 44 Article 45(1) Article 45(2)(a) Article 45(2)(b) Article 45(2)(c) Article 46(1) Article 46(2)(a) Article 46(2)(b) Article 46(2)(c) Article 46(2)(d) Article 46(2)(e) Article 46(2)(f) Article 46(3)(a) Article 46(3)(b)

null

1572

null

Article 21 Article 38 Article 38(3) Article 40

null

Art 1

Article 20

null

Sec 9

null

Sec 25

Sec 24 Sec 26

null

Art 17 Art 27

null

Art 9 Art 26

null

Sec 20

Art 7

Art 26

null

Art 23

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Third-Party Contract Requirements

TPM-05

Mechanisms exist to identify, regularly review and document third-party confidentiality, Non-Disclosure Agreements (NDAs) and other contracts that reflect the organization’s needs to protect systems and data.

- Non-Disclosure Agreements (NDAs)

E-TPM-01 E-TPM-03

Does the organization identify, regularly review and document third-party confidentiality, Non-Disclosure Agreements (NDAs) and other contracts that reflect the organization’s needs to protect systems and data?

10

Identify

X

There is no evidence of a capability to identify, regularly review and document third-party confidentiality, Non-Disclosure Agreements (NDAs) and other contracts that reflect the organization’s needs to protect systems and data.

Third-Party Management (TPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized. • IT personnel use an informal process to govern third-party service providers.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify, regularly review and document third-party confidentiality, Non-Disclosure Agreements (NDAs) and other contracts that reflect the organization’s needs to protect systems and data.

CC9.1

CC1.1-POF5 CC2.3-POF10 CC9.2-POF1 CC9.2-POF3 CC9.2-POF9

null

15.4

null

15.4

APO10.03

null

IPY-04 SEF-02 STA-02 STA-04 STA-09 STA-12 UEM-14

CLS-04 IMT-01 LGL-05 LGL-06 LGL-07 LGL-08 POL-01 POL-02 SET-04

null

RQ-06-10 RQ-07-02 RQ-07-03.a RQ-07-03.b RQ-07-03.c RQ-07-04.a RQ-07-04.b RQ-07-04.c RQ-07-04.d RQ-07-04.e RQ-07-04.f RC-07-05 RQ-07-07

null

13.1.2 13.2.4 15.1.2

5.19 5.20 5.21 5.31 6.6 8.21 8.30

5.1.1 CLD.6.3.1 13.1.2 13.2.4 15.1.2

null

6.10.2.4 6.12.1.2

null

OR-3.4

Sec 4(F)(2) Sec 6(D)(1) Sec 6(D)(2) Sec 6(D)(3)

null

ID.DE-P3 GV.PO-P4 GV.AT-P4

PW.3 PW.3.1

null

SA-9(3)

null

SR-3(3)

null

SA-9(3)

null

SA-9(3)

null

SA-9(3)

3.1.1

3.16.3.a 3.16.3.b 3.16.3.c

null

A.03.16.01 A.03.16.01.ODP[01] A.03.16.03.a A.03.16.03.ODP[01] A.03.17.03.b

null

PO.1 PO.1.1 PO.1.2 PO.1.3

ID.SC-3

GV.OC-05 GV.SC-02 GV.SC-05 GV.SC-10

null

2.6 12.9

8.2.3 12.4.2 12.4.2.1 12.8.2 12.8.5 12.9 12.9.1 12.9.2

12.8.2 12.8.5

8.2.3 12.4.2 12.4.2.1 12.8.2 12.8.5 12.9.1 12.9.2

12.8.2 12.8.5

B.1.1.14

2.8A

1.2.4 1.3.3 6.1.1 6.1.2 8.2.1 8.2.2

12.1

7.2.2.5

THIRD-PARTIES-2.F.MIL2

null

6.2 6.3

5.1.1.2 5.1.1.3 5.1.1.4 5.1.1.5 5.1.1.6 5.1.1.7 5.1.1.8 5.1.4

AC.L1-3.1.1

null

AC.L2-3.1.1

null

252.204-7012(m)(1) 252.204-7012(m)(2)(i) 252.204-7012(m)(2)(ii) 252.204-7019(b) 252.204-7019(c)(1) 252.204-7019(c)(2) 252.204-7020(c) 252.204-7021(b) 252.204-7021(c)(1) 252.204-7021(c)(2)

null

52.204-21(c)

52.204-27(b)

null

314.4(a) 314.4(a)(1) 314.4(a)(2) 314.4(a)(3) 314.4(e)(2) 314.4(f)(1) 314.4(f)(2) 314.4(f)(3)

164.308(b)(3) 164.314 164.314(a) 164.314(a)(1) 164.314(a)(2) 164.314(a)(2)(i)(A) 164.314(a)(2)(i)(B) 164.314(a)(2)(i)(C) 164.314(a)(2)(ii) 164.314(a)(2)(iii) 164.314(b)(2) 164.314(b)(2)(i) 164.314(b)(2)(ii) 164.314(b)(2)(iii) 164.314(b)(2)(iv)

null

9.L.C

2.C.9 SA-9(3)

null

5.11

null

6-1-1305(3)(b) 6-1-1305(5) 6-1-1305(5)(a) 6-1-1305(5)(b) 6-1-1305(5)(c) 6-1-1305(5)(d) 6-1-1305(5)(d)(I) 6-1-1305(5)(d)(I)(A) 6-1-1305(5)(d)(I)(B) 6-1-1305(6)

null

Sec 45(a) Sec 45(b) Sec 45(c) Sec 45(d) Sec 50

null

38-99-20(F)(2) 38-99-40(D)(1) 38-99-40(D)(2) 38-99-40(D)(3)

null

§ 2447(b)(6) § 2447(b)(6)(A) § 2447(b)(6)(B)

3.2.3(8) 3.2.3(8)(a) 3.2.3(8)(b)

Art 28.1(a) Art 29.2 Art 30.1 Art 30.2(a) Art 30.2(b) Art 30.2(c) Art 30.2(d) Art 30.2(e) Art 30.2(f) Art 30.2(g) Art 30.2(h) Art 30.3(a) Art 30.3(b) Art 30.3(c) Art 30.3(d) Art 30.3(e)(i) Art 30.3(e)(ii) Art 30.3(e)(iii) Art 30.3(e)(iv) Art 30.3(f)(i) Art 30.3(f)(ii) Art 30.4

null

Art 28.1 Art 28.2 Art 28.3 Art 28.4 Art 28.5 Art 28.6 Art 28.9 Art 28.10 Art 29

Article 21.3

null

Principle 2.3.a Principle 2.3.b(i) Principle 2.3.b(ii) Principle 2.3.b(iii) Principle 2.3.b(iv) Principle 2.3.b(v) Principle 2.3.b(vi) Principle 2.7.a.i Principle 2.7.a.ii Principle 2.7.a.iii Principle 2.7.b Principle 2.7.c Principle 2.7.d Principle 3.10.a.i Principle 3.10.a.ii Principle 3.10.a.ii.1 Principle 3.10.a.ii.2 Principle 3.10.a.ii.3 Principle 3.10.a.iii Principle 3.10.b.i Principle 3.10.c.i

null

Art 42

null

9.4

HR-06 PI-02 SSO-02 SSO-05

null

11.1 11.3 11.10 16.2 19.5 22.4 25.17

null

Art 31

Art 18

Article 12

null

4-1-1 4-1-1-1 4-1-1-2

TPC-25

null

4-1-2 4-1-2-1 4-1-2-2 4-1-2-3

4-1-1-1 4-1-1-3

Article 5 Article 11

null

Sec 20

Art 20 Art 21

7.4.1 [OP.EXT.1]

null

A4.a

null

Article 3 Article 26(1) Article 26(2) Article 26(3) Article 28(1) Article 28(2) Article 28(3)(a) Article 28(3)(b) Article 28(3)(c) Article 28(3)(d) Article 28(3)(e) Article 28(3)(f) Article 28(3)(g) Article 28(3)(h) Article 28(4) Article 28(5) Article 28(6) Article 28(7) Article 28(8) Article 28(9) Article 28(10) Article 29

null

1395 1569 0072 1571 1451 1572 1573 1574 1575 1738

null

15 54(a) 54(b) 54(c) 54(d) 54(e) 54(f) 54(g) 55(a) 55(b) 55(c)

16 20 28

null

Article 20 Article 21 Article 38(3) Article 42

null

Art 6

Article 22 Article 23(1)(i) Article 23(1)(ii) Article 23(1)(iii) Article 23(1)(iv) Article 23(2) Article 23(2)(i) Article 23(2)(ii) Article 23(2)(iii) Article 23(2)(iv) Article 23(2)(v) Article 23(2)(vi) Article 23(2)(vii) Article 23(2)(viii) Article 23(3) Article 23(4) Article 23(5)(i) Article 23(5)(ii) Article 23(5)(iii) Article 23(6) Article 23(1)

6.3.P 6.3.1.P 6.3.1.1.PB 13.1.2 13.2.4 15.1.2 15.1.2.18.PB

null

2.3.30.C.01 23.2.19.C.01

null

Sec 25 Sec 43

null

3.4.1 3.4.2 3.4.3

null

2.3 4.26 4.28

null

Art 21

null

x

FAR 52.204-21 NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

- updated DFARS mapping

Third-Party Management

Security Compromise Notification Agreements

TPM-05.1

Mechanisms exist to compel External Service Providers (ESPs) to provide notification of actual or potential compromises in the supply chain that can potentially affect or have adversely affected systems, applications and/or services that the organization utilizes.

null

Does the organization compel External Service Providers (ESPs) to provide notification of actual or potential compromises in the supply chain that can potentially affect or have adversely affected systems, applications and/or services that the organization utilizes?

9

Detect

null

X

There is no evidence of a capability to compel Third-Party Service Providers (TSP) to provide notification of actual or potential compromises in the supply chain that can potentially affect or have adversely affected systems, applications and/ or services that the organization utilizes.

SP-CMM1 is N/A, since a structured process is required to compel Third-Party Service Providers (TSP) to provide notification of actual or potential compromises in the supply chain that can potentially affect or have adversely affected systems, applications and/ or services that the organization utilizes.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to compel Third-Party Service Providers (TSP) to provide notification of actual or potential compromises in the supply chain that can potentially affect or have adversely affected systems, applications and/ or services that the organization utilizes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to compel Third-Party Service Providers (TSP) to provide notification of actual or potential compromises in the supply chain that can potentially affect or have adversely affected systems, applications and/ or services that the organization utilizes.

null

STA-02

POL-01

null

5.21

null

SR-8

null

SR-8

null

SR-8

null

SR-8

null

SR-8

null

P.8 C.1.8

null

6.2 6.3

null

SR-8

null

SR-8

null

A4.a

null

1576

null

7.2.22.C.01 7.2.23.C.01

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Contract Flow-Down Requirements

TPM-05.2

Mechanisms exist to ensure cybersecurity & data privacy requirements are included in contracts that flow-down to applicable sub-contractors and suppliers.

null

Does the organization ensure cybersecurity & data privacy requirements are included in contracts that flow-down to applicable sub-contractors and suppliers?

9

Protect

null

X

There is no evidence of a capability to ensure cybersecurity & data privacy requirements are included in contracts that flow-down to applicable sub-contractors and suppliers.

SP-CMM1 is N/A, since a structured process is required to ensure cybersecurity & data privacy requirements are included in contracts that flow-down to applicable sub-contractors and suppliers.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure cybersecurity & data privacy requirements are included in contracts that flow-down to applicable sub-contractors and suppliers.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure cybersecurity & data privacy requirements are included in contracts that flow-down to applicable sub-contractors and suppliers.

null

CC9.2-POF1 CC9.2-POF3 CC9.2-POF9

null

RQ-06-10 RQ-07-02 RQ-07-03.a RQ-07-03.b RQ-07-03.c RQ-07-04.a RQ-07-04.b RQ-07-04.c RQ-07-04.d RQ-07-04.e RQ-07-04.f RC-07-05 RQ-07-07

null

SR-3(3)

null

SR-3(3)

null

SR-3(3)

null

SR-3(3)

3.1.1

3.16.3.a 3.16.3.b 3.16.3.c

null

GV.OC-05 GV.SC-02 GV.SC-05 GV.SC-10

null

2.8A

null

7.2.2.5

null

AC.L1-3.1.1

null

AC.L2-3.1.1

null

252.204-7012(m)(1) 252.204-7012(m)(2)(i) 252.204-7012(m)(2)(ii) 252.204-7019(b) 252.204-7019(c)(1) 252.204-7019(c)(2) 252.204-7020(c) 252.204-7021(b) 252.204-7021(c)(1) 252.204-7021(c)(2)

null

52.204-21(c)

52.204-27(b)

null

2.C.9 SR-3(3)

null

3.2.3(8) 3.2.3(8)(a) 3.2.3(8)(b)

Art 29.2

null

Article 21.3

null

Principle 2.3.a Principle 2.3.b(i) Principle 2.3.b(ii) Principle 2.3.b(iii) Principle 2.3.b(iv) Principle 2.3.b(v) Principle 2.3.b(vi) Principle 2.7.a.i Principle 2.7.a.ii Principle 2.7.a.iii Principle 2.7.b Principle 2.7.c Principle 2.7.d Principle 3.10.a.i Principle 3.10.a.ii Principle 3.10.a.ii.1 Principle 3.10.a.ii.2 Principle 3.10.a.ii.3 Principle 3.10.a.iii Principle 3.10.b.i Principle 3.10.c.i

null

Article 12

null

TPC-25

null

Article 5 Article 11

null

A4.a

null

FAR 52.204-21

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

MT-8 MT-9 MT-12 MT-13 MT-14 MT-15 MT-16

null

MT-8

MT-9

null

MT-12

MT-13

MT-14

MT-15

MT-16

- updated DFARS mapping

Third-Party Management

Third-Party Authentication Practices

TPM-05.3

Mechanisms exist to ensure External Service Providers (ESPs) use unique authentication factors for each of its customers.

null

Does the organization ensure External Service Providers (ESPs) use unique authentication factors for each of its customers?

8

Protect

null

X

There is no evidence of a capability to ensure External Service Providers (ESPs) use unique authentication factors for each of its customers.

SP-CMM1 is N/A, since a structured process is required to ensure External Service Providers (ESPs) use unique authentication factors for each of its customers.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active External Service Providers (ESPs), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active External Service Providers (ESPs), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure External Service Providers (ESPs) use unique authentication factors for each of its customers.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure External Service Providers (ESPs) use unique authentication factors for each of its customers.

null

8.2.3

null

8.2.3

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

MT-8 MT-9 MT-12 MT-13 MT-14 MT-15

null

MT-8

MT-9

null

MT-12

MT-13

MT-14

MT-15

null

Third-Party Management

Responsible, Accountable, Supportive, Consulted & Informed (RASCI) Matrix

TPM-05.4

Mechanisms exist to document and maintain a Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to delineate assignment for cybersecurity & data privacy controls between internal stakeholders and External Service Providers (ESPs).

- Customer Responsibility Matrix (CRM) - Shared Responsibility Matrix (SRM) - Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

E-CPL-03

Does the organization document and maintain a Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to delineate assignment for cybersecurity & data privacy controls between internal stakeholders and External Service Providers (ESPs)?

8

Identify

X

There is no evidence of a capability to document and maintain a Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to delineate assignment for cybersecurity & data privacy controls between internal stakeholders and External Service Providers (ESPs).

SP-CMM1 is N/A, since a structured process is required to document and maintain a Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to delineate assignment for cybersecurity & data privacy controls between internal stakeholders and External Service Providers (ESPs).

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active External Service Providers (ESPs), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active External Service Providers (ESPs), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to document and maintain a Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to delineate assignment for cybersecurity & data privacy controls between internal stakeholders and External Service Providers (ESPs).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to document and maintain a Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to delineate assignment for cybersecurity & data privacy controls between internal stakeholders and External Service Providers (ESPs).

null

CC9.2-POF3

null

RQ-06-04 RQ-07-02 RQ-07-04.a RQ-07-04.b RC-07-08

null

4.3(c)

null

5.23

5.1.1 6.1.1 CLD.6.3.1

null

3.16.3.b

null

A.03.16.03.b A.03.17.03.b

null

PO.2 PO.2.1 PO.2.2 PO.2.3

null

GV.OC-02 GV.OC-04 GV.RM-05 GV.SC-02 GV.SC-05 GV.RR-02 ID.AM-04

null

12.4.1 12.8.2 12.8.5 12.9 12.9.1 12.9.2

12.8.2 12.8.5

12.4.1 12.8.2 12.8.5 12.9.1 12.9.2

12.8.2 12.8.5

null

2.8A

1.2.4

null

7.2.2.5

THIRD-PARTIES-1.A.MIL1

null

3.2.3(8) 3.2.3(8)(a) 3.2.3(8)(b) 3.3.2(16) 3.5(55)

null

Article 21.3

null

1-2-1-1

null

A4.a

A4

null

6.3.P 6.3.1.P 6.3.1.1.PB 6.1.1.13.PB 6.1.3.13.PB

null

RASCI

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Third-Party Scope Review

TPM-05.5

Mechanisms exist to perform recurring validation of the Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to ensure cybersecurity & data privacy control assignments accurately reflect current business practices, compliance obligations, technologies and stakeholders.

null

E-TPM-03

Does the organization perform recurring validation of the Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to ensure cybersecurity & data privacy control assignments accurately reflect current business practices, compliance obligations, technologies and stakeholders?

10

Identify

X

There is no evidence of a capability to perform recurring validation of the Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to ensure cybersecurity & data privacy control assignments accurately reflect current business practices, compliance obligations, technologies and stakeholders.

SP-CMM1 is N/A, since a structured process is required to perform recurring validation of the Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to ensure cybersecurity & data privacy control assignments accurately reflect current business practices, compliance obligations, technologies and stakeholders.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to perform recurring validation of the Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to ensure cybersecurity & data privacy control assignments accurately reflect current business practices, compliance obligations, technologies and stakeholders.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to perform recurring validation of the Responsible, Accountable, Supportive, Consulted & Informed (RASCI) matrix, or similar documentation, to ensure cybersecurity & data privacy control assignments accurately reflect current business practices, compliance obligations, technologies and stakeholders.

null

CC2.2-POF9

null

3.17.2 3.17.3.a 3.17.3.b

null

A.03.16.03.c

null

GV.SC-05 ID.IM-02

null

12.5.2.1 12.5.3 12.8 12.8.1 A3.2.1 A3.2.3

12.8.1

12.5.2.1 12.5.3 12.8.1

12.8.1

null

2.8A

null

3.5(55)

null

Article 21.3

null

1793

null

R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

null

MT-8 MT-9 MT-12 MT-13 MT-14 MT-15 MT-16

null

MT-8

MT-9

null

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

First-Party Declaration (1PD)

TPM-05.6

Mechanisms exist to obtain a First-Party Declaration (1PD) from applicable External Service Providers (ESPs) that provides assurance of compliance with specified statutory, regulatory and contractual obligations for cybersecurity & data privacy controls, including any flow-down requirements to subcontractors.

null

Does the organization obtain a First-Party Declaration (1PD) from applicable External Service Providers (ESPs) that provides assurance of compliance with specified statutory, regulatory and contractual obligations for cybersecurity & data privacy controls, including any flow-down requirements to subcontractors?

7

Identify

null

X

null

There is no evidence of a capability to obtain a First-Party Declaration (1PD) from applicable External Service Providers (ESPs) that provides assurance of compliance with specified statutory, regulatory and contractual obligations for cybersecurity & data privacy controls, including any flow-down requirements to subcontractors.

SP-CMM1 is N/A, since a structured process is required to obtain a First-Party Declaration (1PD) from applicable External Service Providers (ESPs) that provides assurance of compliance with specified statutory, regulatory and contractual obligations for cybersecurity & data privacy controls, including any flow-down requirements to subcontractors.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active External Service Providers (ESPs), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active External Service Providers (ESPs), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to obtain a First-Party Declaration (1PD) from applicable External Service Providers (ESPs) that provides assurance of compliance with specified statutory, regulatory and contractual obligations for cybersecurity & data privacy controls, including any flow-down requirements to subcontractors.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to obtain a First-Party Declaration (1PD) from applicable External Service Providers (ESPs) that provides assurance of compliance with specified statutory, regulatory and contractual obligations for cybersecurity & data privacy controls, including any flow-down requirements to subcontractors.

null

CC9.2-POF9 CC9.2-POF11

null

RQ-07-02 RQ-07-03.a RQ-07-03.b RQ-07-03.c

null

2.8A

8.2.2

null

7.2.2.5

THIRD-PARTIES-2.G.MIL2

null

3.2.3(9)

null

Article 21.3

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

MT-8 MT-9 MT-12 MT-13 MT-14 MT-15 MT-16

null

MT-8

MT-9

null

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Break Clauses

TPM-05.7

Mechanisms exist to include "break clauses" within contracts for failure to meet contract criteria for cybersecurity and/or data privacy controls.

null

E-TPM-05

Does the organization include "break clauses" within contracts for failure to meet contract criteria for cybersecurity and/or data privacy controls?

9

Protect

X

null

There is no evidence of a capability to include "break clauses" within contracts for failure to meet contract criteria for cybersecurity and/ or data privacy controls.

SP-CMM1 is N/A, since a structured process is required to include "break clauses" within contracts for failure to meet contract criteria for cybersecurity and/ or data privacy controls.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to include "break clauses" within contracts for failure to meet contract criteria for cybersecurity and/ or data privacy controls.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to include "break clauses" within contracts for failure to meet contract criteria for cybersecurity and/ or data privacy controls.

null

P6.4-POF2 P6.5-POF1 P6.5-POF2 P6.6-POF1

null

GV.SC-05

null

2.8A

null

7.2.2.5

null

Art 28.7(a) Art 28.7(b) Art 28.7(c) Art 28.7(d) Art 28.8 Art 28.8(a) Art 28.8(b) Art 28.8(c)

null

Article 21.3

null

1804

null

50(g)

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

MT-12 MT-13 MT-14 MT-15 MT-16

null

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Third-Party Personnel Security

TPM-06

Mechanisms exist to control personnel security requirements including security roles and responsibilities for third-party providers.

null

Does the organization control personnel security requirements including security roles and responsibilities for third-party providers?

9

Identify

null

X

null

There is no evidence of a capability to control personnel security requirements including security roles and responsibilities for third-party providers.

Third-Party Management (TPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized. • IT personnel use an informal process to govern third-party service providers.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to control personnel security requirements including security roles and responsibilities for third-party providers.

CC9.1

CC1.1-POF5

null

APO10.03

null

STA-04

POL-02

null

5.2 5.19 8.30

6.1.1

null

OR-3.4

null

ID.IM-P2 GV.PO-P4 GV.AT-P4

null

PO.2 PO.2.1 PO.2.2 PO.2.3

ID.GV-2 PR.AT-3

GV.SC-05 GV.SC-06

null

K.8.3.1.1

null

6.1.1 6.1.2

12.1

7.2.2.5

null

OPD:SG1.SP6

null

D1.G.SP.B.7 D4.RM.Co.B.2 D4.RM.Co.B.5

null

9.L.C

1.9.3

null

5.11

null

Article 21.3

null

11.1 11.3 18.10 19.5

null

A4.a

null

1569

null

Article 52

null

6.1.1.13.PB 6.1.3.13.PB

null

2.3

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Monitoring for Third-Party Information Disclosure

TPM-07

Mechanisms exist to monitor for evidence of unauthorized exfiltration or disclosure of organizational information.

null

Does the organization monitor for evidence of unauthorized exfiltration or disclosure of organizational information?

8

Identify

null

X

null

There is no evidence of a capability to monitor for evidence of unauthorized exfiltration or disclosure of organizational information.

SP-CMM1 is N/A, since a structured process is required to monitor for evidence of unauthorized exfiltration or disclosure of organizational information.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to monitor for evidence of unauthorized exfiltration or disclosure of organizational information.

CC9.1

null

STA-11

POL-02

SO4

null

3.1.22.b

null

ID.IM-02 DE.CM-06

null

P.8 C.1.8

null

12.1

null

9.L.C

null

17.04(3)

null

SSO-04

null

11.5 11.11

null

4.27

null

x

MA 201 CMR 17

null

x

R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-4 R-SA-1

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Third-Party Management

Review of Third-Party Services

TPM-08

Mechanisms exist to monitor, regularly review and audit External Service Providers (ESPs) for compliance with established contractual requirements for cybersecurity & data privacy controls.

null

E-TPM-03

Does the organization monitor, regularly review and audit External Service Providers (ESPs) for compliance with established contractual requirements for cybersecurity & data privacy controls?

9

Identify

null

X

There is no evidence of a capability to monitor, regularly review and audit Third-Party Service Providers (TSP) for compliance with established contractual requirements for cybersecurity & data privacy controls.

SP-CMM1 is N/A, since a structured process is required to monitor, regularly review and audit Third-Party Service Providers (TSP) for compliance with established contractual requirements for cybersecurity & data privacy controls.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to monitor, regularly review and audit Third-Party Service Providers (TSP) for compliance with established contractual requirements for cybersecurity & data privacy controls.

CC3.4 CC9.1

CC1.4-POF2 CC1.4-POF3 CC9.2-POF6 CC9.2-POF10 CC9.2-POF12

null

15.6

null

15.6

APO09.03 APO09.04 APO09.05 APO10.05

Principle 9

STA-05 STA-07 STA-10 STA-11 STA-13 UEM-14

POL-02

SO4

null

13.1.2 15.2.1

5.19 5.20 5.22 8.21

13.1.2 15.2.1

null

6.12.2 6.12.2.1

null

T1059.002, T1078, T1204.003, T1505, T1505.001, T1505.002, T1505.004, T1546.006, T1554, T1601, T1601.001, T1601.002

null

MANAGE 3.0 MANAGE 3.1

null

PW.3 PW.3.1 PW.3.2

null

SA-12(2)

null

SR-6 SR-6(1)

null

SR-6

SR-6(1)

null

SR-6

null

SR-6

null

SR-6

null

A.03.16.03.c

null

ID.SC-4

GV.SC-05 GV.SC-09 ID.IM-02

A02:2021 A05:2021

null

12.4.2 12.4.2.1 12.8.4

12.8.4

12.4.2 12.4.2.1 12.8.4

12.8.4

L.9.4

2.8A

null

12.1

7.2.2.5

RISK-2.J.MIL3 THIRD-PARTIES-1.F.MIL3

null

SR-6

null

SR-6

null

314.4(f)(3)

null

9.L.C

2.C.10 SR-6

null

§ 2447(b)(6) § 2447(b)(6)(A) § 2447(b)(6)(B)

3.2.3(9)

Art 28.6

null

Article 21.3

null

SSO-04 SSO-05

null

11.4 11.5

null

4-1-1-4

null

A4.a

null

1793

null

58(a) 58(b) 58(c)

28

null

Article 24(3)

13.1.2 15.2.1

null

3.4.3

null

4.27

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Third-Party Deficiency Remediation

TPM-09

Mechanisms exist to address weaknesses or deficiencies in supply chain elements identified during independent or organizational assessments of such elements.

null

E-TPM-03

Does the organization address weaknesses or deficiencies in supply chain elements identified during independent or organizational assessments of such elements?

9

Identify

null

X

There is no evidence of a capability to address weaknesses or deficiencies in supply chain elements identified during independent or organizational assessments of such elements.

SP-CMM1 is N/A, since a structured process is required to address weaknesses or deficiencies in supply chain elements identified during independent or organizational assessments of such elements.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to address weaknesses or deficiencies in supply chain elements identified during independent or organizational assessments of such elements.

CC4.2 CC9.1

P6.4-POF2 P6.5-POF1 P6.5-POF2 P6.6-POF1

null

APO10.04

Principle 17

SEF-02 SEF-06

POL-01

SO10

null

RQ-07-06

null

10.1

null

5.19

null

GV.SC-05 GV.SC-06 ID.RA-06

A02:2021 A05:2021

null

A3.3.1.2

null

T.2.1

2.8A

null

12.1

7.2.2.5

RISK-2.J.MIL3

null

9.L.C

null

6.11

null

§ 2447(b)(6) § 2447(b)(6)(A) § 2447(b)(6)(B)

null

Article 21.3 Article 21.4

null

SSO-04

null

4-1-2-3

null

A4.a

null

4.7.1

null

2.7 4.27

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Managing Changes To Third-Party Services

TPM-10

Mechanisms exist to control changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party.

- Contact requirement to report changes to service offerings that may impact the contract. - CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/)

null

Does the organization control changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party?

8

Identify

X

There is no evidence of a capability to control changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party.

SP-CMM1 is N/A, since a structured process is required to control changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to control changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party.

CC3.4 CC9.1

CC3.4-POF5

null

15.7

null

15.7

APO10.04

Principle 9

STA-05 STA-10 STA-13

null

15.2.2

5.20 5.22

15.2.2

null

6.12.2.2

null

SA-4

null

SA-4

null

SA-4

null

SA-4

NFO - SA-4

3.16.1

null

GV.SC-05

null

B.1.1.5 B.1.1.10

2.8A

null

7.1 7.1.1 7.1.2 7.1.3

null

THIRD-PARTIES-1.F.MIL3

EXD:SG3.SP4 RTSE:SG1.SP1 RTSE:SG1.SP2 RTSE:SG1.SP3 RTSE:SG1.SP4 RTSE:SG1.SP5

null

SA-4

null

SA-4

null

9.L.C

SA-4

null

17.03(2)(d)(B)(i)

null

SA-4

null

Article 21.3

null

SSO-04 SSO-05

null

7.4.2 [OP.EXT.2]

null

A4.a

null

1794

null

Article 24(3)

15.2.2

null

4.27

null

x

MA 201 CMR 17

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Third-Party Management

Third-Party Incident Response & Recovery Capabilities

TPM-11

Mechanisms exist to ensure response/recovery planning and testing are conducted with critical suppliers/providers.

null

Does the organization ensure response/recovery planning and testing are conducted with critical suppliers/providers?

8

Identify

null

X

null

There is no evidence of a capability to ensure response/recovery planning and testing are conducted with critical suppliers/providers.

SP-CMM1 is N/A, since a structured process is required to ensure response/recovery planning and testing are conducted with critical suppliers/providers.

Third-Party Management (TPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Third-party management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for third-party management. • A procurement function maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data. • Procurement contracts: o Require TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Contain "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies).

Third-Party Management (TPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Procurement contracts and layered defenses provide safeguards to limit harm from potential adversaries who identify and target the organization's supply chain. • A Governance, Risk & Compliance (GRC) function, or similar function; o provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to third-party management. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats. o Evaluates risks associated with weaknesses or deficiencies in supply chain elements identified during first and/ or third-party reviews. o Enables the implementation of third-party management controls. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity & data privacy controls as part of “business as usual” pre-production testing. • A procurement team, or similar function: o Maintains a list of all active Third-Party Service Providers (TSP), including pertinent contract information that will assist in a risk assessment. o Requires TSP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. o Includes "break clauses" in all TSP contracts to enable penalty-free, early termination of a contract for cause, based on the TSP's cybersecurity and/ or data privacy practices deficiency(ies). o Controls changes to services by suppliers, taking into account the criticality of business information, systems and processes that are in scope by the third-party. o Requires a risk assessment prior to the acquisition or outsourcing of technology-related services. o Monitors, regularly reviews and audits supplier service delivery for compliance with established contract agreements. o Uses tailored acquisition strategies, contract tools and procurement methods for the purchase of unique systems, system components or services. • A Shared Responsibility Matrix (SRM) is documented for every TSP that directly or indirectly affects sensitive/regulated data.

Third-Party Management (TPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure response/recovery planning and testing are conducted with critical suppliers/providers.

CC7.3 P6.5 P6.6

null

SEF-02 SEF-06

IMT-01 OPA-05 OPA-06 POL-01

null

5.19

null

Sec 6(D)(1) Sec 6(D)(2) Sec 6(D)(3)

null

IR-4(10)

null

IR-4(10)

null

IR-4(10)

null

IR-4(10)

null

IR-4(10)

null

ID.SC-5

GV.SC-08

null

10.7 10.7.1 10.7.2 10.7.3

null

10.7.2 10.7.3

10.7.1 10.7.2 10.7.3

null

K.2.9

null

6.2 6.3

null

38-99-40(D)(1) 38-99-40(D)(2) 38-99-40(D)(3)

null

3.2.3(8)(b)

null

25.17

null

4-1-2-2

null

A4.a

null

4.28

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Threat Management

Threat Intelligence Program

THR-01

Mechanisms exist to implement a threat intelligence program that includes a cross-organization information-sharing capability that can influence the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, response and recovery activities.

null

E-THR-04

Does the organization implement a threat intelligence program that includes a cross-organization information-sharing capability that can influence the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, response and recovery activities?

8

Identify

X

There is no evidence of a capability to implement a threat intelligence program that includes a cross-organization information-sharing capability that can influence the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, response and recovery activities.

Threat Management (THR) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized. • IT personnel subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The HR department, in conjunction with cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage threats. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for threat management. o Subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy to determine prioritized and authoritative guidance for Thread Management (TM) practices. • The CISO, or similar function, develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures to apply defense-in-depth techniques across the enterprise for TM. • A Governance, Risk & Compliance (GRC) function, or similar function, provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to TM. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including TM. • A Security Operations Center (SOC), or similar function: o Subscribes to threat feeds to maintain situational awareness of emerging threats. o Develops Indicators of Exposure (IOE) to better understand potential attack vectors that attackers could use to attack the organization. o Implements a Threat Awareness Program (TAP) that includes a cross-organization information-sharing capability. o Implements a “threat hunting” capability to actively identify internal threats. • An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, integrated team of cybersecurity, IT, data privacy and business function representatives that can execute coordinated incident response operations, including a cross-discipline incident handling capability. • Cybersecurity personnel enable security awareness training on recognizing and reporting potential indicators of insider threat.

Threat Management (THR) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to implement a threat intelligence program that includes a cross-organization information-sharing capability that can influence the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, response and recovery activities.

CC3.3

CC3.2-POF7 CC3.3-POF1 CC3.3-POF2 CC3.3-POF3 CC3.3-POF4 CC3.3-POF5

null

Principle 8

null

5.7

null

Sec 4(D)(4)

null

PM-16

null

PM-15 PM-16

null

PM-15 PM-16

null

PM-15 PM-16

null

PM-15 PM-16

null

3.12.3 3.14.3

3.14.3.a 3.14.3.b 3.14.3.c

null

3.11.1e

null

ID.BE-2 ID.RA-3

DE.AE DE.AE-07

null

12.6

6.3 A3.5.1

null

C.1.7

null

THREAT-1.I.MIL2 THREAT-1.L.MIL3 THREAT-1.M.MIL3 THREAT-2.A.MIL1 THREAT-2.B.MIL1 THREAT-2.C.MIL1 THREAT-2.E.MIL2 THREAT-2.F.MIL2 THREAT-2.G.MIL2 THREAT-2.H.MIL2 THREAT-2.I.MIL3 THREAT-2.J.MIL3 THREAT-2.K.MIL3 THREAT-3.A.MIL2 RISK-2.J.MIL3

COMM:SG1.SP1 OTA:SG1.SP2 OTA:SG2.SP1

8.2

null

CA.L2-3.12.3 SI.L2-3.14.3

TBD - 3.11.1e

null

CA.L2-3.12.3 SI.L2-3.14.3

CA.L2-3.12.3 SI.L2-3.14.3 RA.L3-3.11.1e

PM-16

null

D1.G.SP.Inn.1

null

8.S.B

null

CIP-014-2 R4

8-103

null

500.1

null

38-99-20(D)(4)

null

PM-15 PM-16

null

Art 13.1 Art 45.1 Art 45.1(a) Art 45.1(b) Art 45.1(c) Art 45.2 Art 45.3

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

3.10 5.3

null

23.1 23.4

null

3.3.16

2-10-4 2-13-1 2-13-2 2-13-3 2-13-4

null

B4.d C1.d

null

17

null

4.2.1 13.5.1 13.5.2 14.3.1 14.3.2 14.3.3

null

6.2

null

1.3

3.1.2 3.1.5

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Threat Management

Indicators of Exposure (IOE)

THR-02

Mechanisms exist to develop Indicators of Exposure (IOE) to understand the potential attack vectors that attackers could use to attack the organization.

- Indicators of Exposure (IoE)

E-THR-01

Does the organization develop Indicators of Exposure (IOE) to understand the potential attack vectors that attackers could use to attack the organization?

8

Identify

X

There is no evidence of a capability to develop Indicators of Exposure (IOE) to understand the potential attack vectors that attackers could use to attack the organization.

SP-CMM1 is N/A, since a structured process is required to develop Indicators of Exposure (IOE) to understand the potential attack vectors that attackers could use to attack the organization.

Threat Management (THR) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The HR department, in conjunction with cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage threats. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for threat management. o Subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Security Operations Center (SOC), or similar function: o Subscribes to threat feeds to maintain situational awareness of emerging threats. o Develops Indicators of Exposure (IOE) to better understand potential attack vectors that attackers could use to attack the organization. o Implements a Threat Awareness Program (TAP) that includes a cross-organization information-sharing capability. o Implements a “threat hunting” capability to actively identify internal threats. • An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, integrated team of cybersecurity, IT, data privacy and business function representatives that can execute coordinated incident response operations, including a cross-discipline incident handling capability. • Cybersecurity personnel enable security awareness training on recognizing and reporting potential indicators of insider threat.

Threat Management (THR) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Threat Management (THR) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

CC3.3

null

Principle 8

null

RQ-08-01 RQ-08-02

null

5.7

null

DE.AE-07

null

G.3.2

null

8.2

null

23.3

null

2-12-2-8

null

B4.d C1.d

null

14.3.1 14.3.2 14.3.3

null

R-AC-4 R-AM-1 R-AM-3 R-BC-1 R-BC-2 R-BC-4 R-BC-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-4

R-AM-1

null

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

null

R-EX-6

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Threat Management

Threat Intelligence Feeds

THR-03

Mechanisms exist to maintain situational awareness of evolving threats by leveraging the knowledge of attacker tactics, techniques and procedures to facilitate the implementation of preventative and compensating controls.

- US-CERT mailing lists & feeds - InfraGard - Internal newsletters

E-THR-03

Does the organization maintain situational awareness of evolving threats by leveraging the knowledge of attacker tactics, techniques and procedures to facilitate the implementation of preventative and compensating controls?

8

Identify

X

There is no evidence of a capability to maintain situational awareness of evolving threats by leveraging the knowledge of attacker tactics, techniques and procedures to facilitate the implementation of preventative and compensating controls.

Threat Management (THR) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized. • IT personnel subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The HR department, in conjunction with cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage threats. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for threat management. o Subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Security Operations Center (SOC), or similar function: o Subscribes to threat feeds to maintain situational awareness of emerging threats. o Develops Indicators of Exposure (IOE) to better understand potential attack vectors that attackers could use to attack the organization. o Implements a Threat Awareness Program (TAP) that includes a cross-organization information-sharing capability. o Implements a “threat hunting” capability to actively identify internal threats. • An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, integrated team of cybersecurity, IT, data privacy and business function representatives that can execute coordinated incident response operations, including a cross-discipline incident handling capability. • Cybersecurity personnel enable security awareness training on recognizing and reporting potential indicators of insider threat.

Threat Management (THR) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to maintain situational awareness of evolving threats by leveraging the knowledge of attacker tactics, techniques and procedures to facilitate the implementation of preventative and compensating controls.

null

MON-11

null

RQ-08-01 RQ-08-02

null

7.4 7.4(a) 7.4(b) 7.4(c) 7.4(d)

null

5.7

null

T1068, T1210, T1211, T1212

TS-4.2

Sec 4(D)(4)

null

SI-5 SI-5(1)

SI-5

SI-5 SI-5(1)

PM-16(1) SI-5 SI-5(1)

null

SI-5

SI-5 SI-5(1)

PM-16(1)

null

SI-5

SI-5 SI-5(1)

null

SI-5

3.14.3

3.2.1.b 3.2.2.b 3.14.3.a

null

A.03.14.03.a A.03.14.03.b[01] A.03.14.03.b[02] A.03.14.03.c

3.14.6e

null

ID.RA-2 RS.AN-5

ID.RA-02 ID.RA-08

null

6.2 12.4

6.3.1

null

6.3.1

null

K.12.4

null

THREAT-1.A.MIL1 THREAT-1.L.MIL3 THREAT-1.M.MIL3 THREAT-2.K.MIL3 RISK-2.J.MIL3

COMM:SG2.SP1 COMM:SG2.SP2

4.5 5.2 5.3 8.2

5.10.4.4

null

SI.L2-3.14.3

TBD - 3.14.6e

SI.L1-b.1.xii

SI.L2-3.14.3

SI.L2-3.14.3 SI.L3-3.14.6e

SI-5

null

52.204-21(b)(1)(xii)

null

SI-5

null

D2.TI.Ti.B.1

null

8.S.B 8.M.C

null

7.L.A 8.L.B 9.L.D

SI-5

null

8-103

17.3

null

SI-5

null

622(2)(d)(B)(iii)

38-99-20(D)(4)

null

SI-5

null

3.3.3(21)

Art 13.1

null

5.3

null

23.2

null

2-10-3-5 2-13-3-5

1-8-3 2-12-2-8

null

B4.d C1.d

null

12.1.1 12.1.2 12.1.3

null

3.7

3.1.5

null

x

FAR 52.204-21 NAIC OR 6464A

null

x

R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Threat Management

Insider Threat Program

THR-04

Mechanisms exist to implement an insider threat program that includes a cross-discipline insider threat incident handling team.

- Insider threat program

E-THR-04

Does the organization implement an insider threat program that includes a cross-discipline insider threat incident handling team?

8

Identify

X

There is no evidence of a capability to implement an insider threat program that includes a cross-discipline insider threat incident handling team.

Threat Management (THR) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized. • IT personnel subscribe to threat feeds to maintain situational awareness of emerging threats. • The HR department, in conjunction with IT/cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage insider threats.

Threat Management (THR) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The HR department, in conjunction with cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage threats. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for threat management. o Subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Security Operations Center (SOC), or similar function: o Subscribes to threat feeds to maintain situational awareness of emerging threats. o Develops Indicators of Exposure (IOE) to better understand potential attack vectors that attackers could use to attack the organization. o Implements a Threat Awareness Program (TAP) that includes a cross-organization information-sharing capability. o Implements a “threat hunting” capability to actively identify internal threats. • An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, integrated team of cybersecurity, IT, data privacy and business function representatives that can execute coordinated incident response operations, including a cross-discipline incident handling capability. • Cybersecurity personnel enable security awareness training on recognizing and reporting potential indicators of insider threat. • The HR department, in conjunction with cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage threats.

Threat Management (THR) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to implement an insider threat program that includes a cross-discipline insider threat incident handling team.

CC3.3

CC3.3-POF1 CC3.3-POF2 CC3.3-POF3 CC3.3-POF4 CC3.3-POF5

null

Principle 8

null

PM-12

null

PM-12

null

PM-12

null

PM-12

null

PM-12

null

K.16.2

null

IMC:SG1.SP1

null

PM-12

null

PM-12

null

1625 1626

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Threat Management

Insider Threat Awareness

THR-05

Mechanisms exist to utilize security awareness training on recognizing and reporting potential indicators of insider threat.

null

Does the organization utilize security awareness training on recognizing and reporting potential indicators of insider threat?

8

Identify

null

X

null

There is no evidence of a capability to utilize security awareness training on recognizing and reporting potential indicators of insider threat.

Threat Management (THR) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized. • IT personnel subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The HR department, in conjunction with cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage threats. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for threat management. o Subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Security Operations Center (SOC), or similar function: o Subscribes to threat feeds to maintain situational awareness of emerging threats. o Develops Indicators of Exposure (IOE) to better understand potential attack vectors that attackers could use to attack the organization. o Implements a Threat Awareness Program (TAP) that includes a cross-organization information-sharing capability. o Implements a “threat hunting” capability to actively identify internal threats. • An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, integrated team of cybersecurity, IT, data privacy and business function representatives that can execute coordinated incident response operations, including a cross-discipline incident handling capability. • Cybersecurity personnel enable security awareness training on recognizing and reporting potential indicators of insider threat.

Threat Management (THR) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize security awareness training on recognizing and reporting potential indicators of insider threat.

null

AT-2(2)

null

AT-2(2)

null

AT-2(2)

null

AT-2(2)

null

AT-2(2)

null

AT-2(2)

null

3.2.3

3.2.1.a.3 3.2.2.a

3.2.3[a] 3.2.3[b]

null

K.16.2

null

AT.L2-3.2.3

null

AT.L2-3.2.3

AT-2(2)

null

AT-2(2)

null

AT-2(2)

null

AT-2(2)

null

AT-2(2)

null

AT-2(2)

null

AT-2(2)

null

1625 1626

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Threat Management

Vulnerability Disclosure Program (VDP)

THR-06

Mechanisms exist to establish a Vulnerability Disclosure Program (VDP) to assist with the secure development and maintenance of products and services that receives unsolicited input from the public about vulnerabilities in organizational systems, services and processes.

- "bug bounty" program

E-TDA-16

Does the organization establish a Vulnerability Disclosure Program (VDP) to assist with the secure development and maintenance of products and services that receives unsolicited input from the public about vulnerabilities in organizational systems, services and processes?

8

Detect

X

There is no evidence of a capability to establish a Vulnerability Disclosure Program (VDP) to assist with the secure development and maintenance of products and services that receives unsolicited input from the public about vulnerabilities in organizational systems, services and processes.

SP-CMM1 is N/A, since a structured process is required to establish a Vulnerability Disclosure Program (VDP) to assist with the secure development and maintenance of products and services that receives unsolicited input from the public about vulnerabilities in organizational systems, services and processes.

Threat Management (THR) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The HR department, in conjunction with cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage threats. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for threat management. o Subscribe to threat feeds to maintain situational awareness of emerging threats. • A Vulnerability Disclosure Program (VDP) is formed to receive and triage unsolicited input from the public about vulnerabilities in organizational systems, services and processes.

Threat Management (THR) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Security Operations Center (SOC), or similar function: o Subscribes to threat feeds to maintain situational awareness of emerging threats. o Develops Indicators of Exposure (IOE) to better understand potential attack vectors that attackers could use to attack the organization. o Implements a Threat Awareness Program (TAP) that includes a cross-organization information-sharing capability. o Implements a “threat hunting” capability to actively identify internal threats. • An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, integrated team of cybersecurity, IT, data privacy and business function representatives that can execute coordinated incident response operations, including a cross-discipline incident handling capability. • Cybersecurity personnel enable security awareness training on recognizing and reporting potential indicators of insider threat. • A Vulnerability Disclosure Program (VDP) is formed to receive and triage unsolicited input from the public about vulnerabilities in organizational systems, services and processes.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to establish a Vulnerability Disclosure Program (VDP) to assist with the secure development and maintenance of products and services that receives unsolicited input from the public about vulnerabilities in organizational systems, services and processes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to establish a Vulnerability Disclosure Program (VDP) to assist with the secure development and maintenance of products and services that receives unsolicited input from the public about vulnerabilities in organizational systems, services and processes.

null

TRN-03 SET-05

null

RA-5(11)

null

RA-5(11)

null

RA-5(11)

null

6.3.1

null

6.3.1

null

5.2

null

RA-5(11)

null

1616 1755 1756 1717

Principle 2

null

5.9.23.C.01 5.9.24.C.01 5.9.24.C.02 5.9.25.C.01 5.9.26.C.01 5.9.26.C.02 5.9.27.C.01

null

13.2.2

null

x

R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-4 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-IR-4 R-SA-1

null

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Threat Management

Threat Hunting

THR-07

Mechanisms exist to perform cyber threat hunting that uses Indicators of Compromise (IoC) to detect, track and disrupt threats that evade existing security controls.

null

E-THR-05

Does the organization perform cyber threat hunting that uses Indicators of Compromise (IoC) to detect, track and disrupt threats that evade existing security controls?

4

Detect

X

There is no evidence of a capability to perform cyber threat hunting that uses Indicators of Compromise (IoC) to detect, track and disrupt threats that evade existing security controls.

SP-CMM1 is N/A, since a structured process is required to perform cyber threat hunting that uses Indicators of Compromise (IoC) to detect, track and disrupt threats that evade existing security controls.

Threat Management (THR) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The HR department, in conjunction with cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage threats. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for threat management. o Subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Security Operations Center (SOC), or similar function: o Subscribes to threat feeds to maintain situational awareness of emerging threats. o Develops Indicators of Exposure (IOE) to better understand potential attack vectors that attackers could use to attack the organization. o Implements a Threat Awareness Program (TAP) that includes a cross-organization information-sharing capability. o Implements a “threat hunting” capability to actively identify internal threats. • An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, integrated team of cybersecurity, IT, data privacy and business function representatives that can execute coordinated incident response operations, including a cross-discipline incident handling capability. • Cybersecurity personnel enable security awareness training on recognizing and reporting potential indicators of insider threat.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to perform cyber threat hunting that uses Indicators of Compromise (IoC) to detect, track and disrupt threats that evade existing security controls.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to perform cyber threat hunting that uses Indicators of Compromise (IoC) to detect, track and disrupt threats that evade existing security controls.

null

T1068, T1190, T1195, T1195.001, T1195.002, T1210, T1211, T1212

null

RA-10 SC-48

null

RA-10 SC-48

null

RA-10

null

RA-10

null

3.11.2e

null

7.3.7(a) 7.3.7(b) 7.3.7(c)

RISK-2.J.MIL3

null

TBD - 3.11.2e

null

RA.L3-3.11.2e

null

C2.b

null

3.1.2 3.1.6

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Threat Management

Tainting

THR-08

Mechanisms exist to embed false data or steganographic data in files to enable the organization to determine if data has been exfiltrated and provide a means to identify the individual(s) involved.

null

Does the organization embed false data or steganographic data in files to enable the organization to determine if data has been exfiltrated and provide a means to identify the individual(s) involved?

1

Detect

X

There is no evidence of a capability to embed false data or steganographic data in files to enable the organization to determine if data has been exfiltrated and provide a means to identify the individual(s) involved.

SP-CMM1 is N/A, since a structured process is required to embed false data or steganographic data in files to enable the organization to determine if data has been exfiltrated and provide a means to identify the individual(s) involved.

SP-CMM2 is N/A, since a well-defined process is required to embed false data or steganographic data in files to enable the organization to determine if data has been exfiltrated and provide a means to identify the individual(s) involved.

Threat Management (THR) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Security Operations Center (SOC), or similar function: o Subscribes to threat feeds to maintain situational awareness of emerging threats. o Develops Indicators of Exposure (IOE) to better understand potential attack vectors that attackers could use to attack the organization. o Implements a Threat Awareness Program (TAP) that includes a cross-organization information-sharing capability. o Implements a “threat hunting” capability to actively identify internal threats. • An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, integrated team of cybersecurity, IT, data privacy and business function representatives that can execute coordinated incident response operations, including a cross-discipline incident handling capability. • Cybersecurity personnel enable security awareness training on recognizing and reporting potential indicators of insider threat.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to embed false data or steganographic data in files to enable the organization to determine if data has been exfiltrated and provide a means to identify the individual(s) involved.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to embed false data or steganographic data in files to enable the organization to determine if data has been exfiltrated and provide a means to identify the individual(s) involved.

null

SI-20

null

SI-20

null

SI-20

null

SI-20

null

SI-20

null

R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-4 R-BC-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-IR-1 R-SA-1

null

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-1

null

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Threat Management

Threat Catalog

THR-09

Mechanisms exist to develop and keep current a catalog of applicable internal and external threats to the organization, both natural and manmade.

null

Does the organization develop and keep current a catalog of applicable internal and external threats to the organization, both natural and manmade?

5

Protect

X

There is no evidence of a capability to develop and keep current a catalog of applicable internal and external threats to the organization, both natural and manmade.

SP-CMM1 is N/A, since a structured process is required to develop and keep current a catalog of applicable internal and external threats to the organization, both natural and manmade.

Threat Management (THR) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The HR department, in conjunction with cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage threats. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for threat management. o Subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Security Operations Center (SOC), or similar function: o Subscribes to threat feeds to maintain situational awareness of emerging threats. o Develops Indicators of Exposure (IOE) to better understand potential attack vectors that attackers could use to attack the organization. o Implements a Threat Awareness Program (TAP) that includes a cross-organization information-sharing capability. o Implements a “threat hunting” capability to actively identify internal threats. • An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, integrated team of cybersecurity, IT, data privacy and business function representatives that can execute coordinated incident response operations, including a cross-discipline incident handling capability. • Cybersecurity personnel enable security awareness training on recognizing and reporting potential indicators of insider threat.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to develop and keep current a catalog of applicable internal and external threats to the organization, both natural and manmade.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to develop and keep current a catalog of applicable internal and external threats to the organization, both natural and manmade.

null

ID.RA-03

null

3.3 5.3

null

R-BC-1 R-BC-2 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-1 R-SA-2

null

R-BC-1

R-BC-2

null

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Threat Management

Threat Analysis

THR-10

Mechanisms exist to identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats.

null

Does the organization identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats?

7

Protect

X

There is no evidence of a capability to embed false data or steganographic data in files to identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats.

SP-CMM1 is N/A, since a structured process is required to identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats.

Threat Management (THR) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Threat management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The HR department, in conjunction with cybersecurity personnel, helps ensure secure practices are implemented in personnel management operations to help manage threats. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for threat management. o Subscribe to threat feeds to maintain situational awareness of emerging threats.

Threat Management (THR) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Security Operations Center (SOC), or similar function: o Subscribes to threat feeds to maintain situational awareness of emerging threats. o Develops Indicators of Exposure (IOE) to better understand potential attack vectors that attackers could use to attack the organization. o Implements a Threat Awareness Program (TAP) that includes a cross-organization information-sharing capability. o Implements a “threat hunting” capability to actively identify internal threats. • An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, integrated team of cybersecurity, IT, data privacy and business function representatives that can execute coordinated incident response operations, including a cross-discipline incident handling capability. • Cybersecurity personnel enable security awareness training on recognizing and reporting potential indicators of insider threat.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats.

null

PM-06-08 RQ-09-03.a RQ-09-03.b RQ-09-03.c RQ-09-03.d RQ-09-03.e RQ-09-03.f RQ-09-04 RQ-15-01 RQ-15-02 RQ-15-03 RQ-15-04 RQ-15-05 RQ-15-06 RQ-15-07 RQ-15-08 RQ-15-09 RQ-15-10 RQ-15-11.a RQ-15-11.b RQ-15-11.c RQ-15-12.a RQ-15-12.b RQ-15-12.c RQ-15-12.d RQ-15-12.e RQ-15-13.a RQ-15-13.b RQ-15-13.c RQ-15-13.d RQ-15-14 RQ-15-15 RQ-15-16

null

3.14.3.a 3.14.3.b 3.14.3.c

null

ID.RA-04

null

17 CFR 229.106(B)(2)

null

3.10 5.3

null

R-BC-1 R-BC-2 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-1 R-SA-2

null

R-BC-1

R-BC-2

null

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Vulnerability & Patch Management Program (VPMP)

VPM-01

Mechanisms exist to facilitate the implementation and monitoring of vulnerability management controls.

- Vulnerability & Patch Management Program (ComplianceForge)

E-MNT-03 E-THR-05 E-VPM-01

Does the organization facilitate the implementation and monitoring of vulnerability management controls?

9

Protect

null

X

There is no evidence of a capability to facilitate the implementation and monitoring of vulnerability management controls.

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy to determine prioritized and authoritative guidance for Attack Surface Management (ASM) practices. • The CISO, or similar function, develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures to apply defense-in-depth techniques across the enterprise for ASM. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including ASM. • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the implementation and monitoring of vulnerability management controls.

null

CC3.2-POF7

null

7.0 7.1 18.0

7.1

DSS05.07 MEA01.01

null

AIS-07 TVM-01 TVM-02 UEM-07

CLS-06 SAP-05 VLN-01 VLN-02 VLN-04

null

RQ-08-05 RQ-08-06 RQ-08-07.a RQ-08-07.b

null

12.6.1

8.8

12.6.1

null

6.9.6 6.9.6.1

null

T1003, T1003.001, T1027, T1027.002, T1047, T1055, T1055.001, T1055.002, T1055.003, T1055.004, T1055.005, T1055.008, T1055.009, T1055.011, T1055.012, T1055.013, T1055.014, T1059, T1059.001, T1059.005, T1059.006, T1068, T1072, T1106, T1137, T1137.003, T1137.004, T1137.005, T1189, T1190, T1195, T1195.001, T1195.002, T1195.003, T1204, T1204.001, T1204.003, T1210, T1211, T1212, T1213.003, T1221, T1495, T1525, T1542, T1542.001, T1542.003, T1542.004, T1542.005, T1546.006, T1546.010, T1546.011, T1547.006, T1548.002, T1550.002, T1552, T1552.006, T1553, T1553.006, T1555.005, T1559, T1559.002, T1566, T1566.001, T1566.003, T1574, T1574.002, T1601, T1601.001, T1601.002, T1606, T1606.001, T1611

TS-4.0

Sec 4(D)(4)

null

PR.PO-P10

RV.1 RV.1.1 RV.1.2 RV.1.3 RV.3 RV.3.1 RV.3.2

null

SI-2 SI-3(2)

SI-2

SI-2 SI-3(2)

SI-2 SI-3

null

SI-2 SI-3

null

SI-2 SI-3

null

SI-2 SI-3

null

SI-2 SI-3

3.14.1

3.11.2.a 3.11.2.b 3.11.2.c 3.14.1.a 3.14.1.b

3.14.1[a] 3.14.1[b] 3.14.1[c] 3.14.1[d] 3.14.1[e] 3.14.1[f]

A.03.14.01.a[01] A.03.14.01.a[02] A.03.14.01.a[03]

null

ID.RA-1 PR.IP-12

ID.RA-01 ID.RA-08

A05:2021 A06:2021

null

6.3 6.3.1 6.3.3 11.3

6.3.1 6.3.3

null

6.3.1 6.3.3

null

T.1

2.2 2.7

5.2.5 5.2.6

null

THREAT-1.A.MIL1 THREAT-1.B.MIL1 THREAT-1.I.MIL2 RISK-2.I.MIL3

TM:SG4.SP2 VAR:SG1.SP1 VAR:SG2.SP2 VAR:SG2.SP3 VAR:SG3.SP1 VAR:SG4.SP1

5.1 5.2

5.10.4 5.10.4.1

SI.L1-3.14.1

SI.L1-b.1.xii

SI.L2-3.14.1

SI-2 SI-3(2)

null

52.204-21(b)(1)(xii)

null

SI-2 SI-3(2)

SI-2

SI-2 SI-3(2)

SI-2

SI-2 SI-3(2)

SI-2

SI-2 SI-3(2)

SI-2

null

D2.TI.Ti.B.2 D3.DC.Th.B.1 D1.RM.RA.E.2 D3.DC.Th.E.5 D3.DC.Th.A.1 D3.CC.Re.Ev.2

null

314.4(d)(2)

null

2.S.A 7.S.A

2.M.A 7.M.D

2.M.A 7.M.D 7.L.A 7.L.B 9.L.A

SI-2 SI-3

null

8-311 8-610

9.1 17.1

null

5.6

SI-2

SI-2 SI-3(2)

III.E III.E.1 III.E III.E.2.a III.E.2.b

null

38-99-20(D)(4)

null

SI-2 SI-3

SI-2

SI-2 SI-3(2)

null

§ 2447(c)(7)

3.3.3(21) 3.4.4(36)(a)

Art 9.4(f) Art 25.1 Art 25.2 Art 25.3

null

Art 32.1 Art 32.2

Article 21.2(e)

null

Sec 14 Sec 15

Art 16

null

5.6

OPS-18 PSS-02

null

22.1 22.2

null

2-3-1-3 2-9 2-9-2

TPC-11

3.3.17

2-3-4 2-10-1 2-10-2 2-10-3 2-10-4 2-11-1 2-11-2 2-11-3 2-11-4 5-1-3-8

2-9 2-9-1 2-9-2

null

Sec 19

null

B4.d

null

5

null

1163 1460 1143 1493

null

17

null

12.6.1 12.6.1.18.PB

null

6.2.4.C.01

null

4.2(a) 4.2(b)

4.2.1 7.4.1 7.4.2

null

6.16

null

2.2.5 2.6 2.6.1 3.1.2 3.1.3

null

x

FAR 52.204-21 NAIC Lockton

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Vulnerability & Patch Management

Attack Surface Scope

VPM-01.1

Mechanisms exist to define and manage the scope for its attack surface management activities.

null

Does the organization define and manage the scope for its attack surface management activities?

5

Protect

X

null

There is no evidence of a capability to define and manage the scope for its attack surface management activities.

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Defines the scope of ASM activities. o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to define and manage the scope for its attack surface management activities.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to define and manage the scope for its attack surface management activities.

null

CC2.2-POF9

null

MEA01.01

null

TVM-07

CLS-06 VLN-02 SET-01 SET-04

null

RQ-09-01.a RQ-09-01.b RQ-09-01.c RQ-09-02

null

4.3

null

8.8

null

TS-4.0

null

SA-11(6) SA-11(7)

null

SA-11(6) SA-11(7)

null

3.11.2.a 3.14.1.a

null

3.14.3e

null

6.3.1 6.3.2 11.3.1 11.3.1.1 11.3.1.2 11.3.1.3 11.3.2 11.3.2.1

6.3.1

6.3.1 6.3.2

null

6.3.1

6.3.1 11.3.1 11.3.1.3 11.3.1.2 11.3.2.1

6.3.1

6.3.1 6.3.2 11.3.1 11.3.1.1 11.3.1.2 11.3.1.3 11.3.1.2 11.3.2.1

null

T.1 T.1.1 T.1.2

2.2 2.7 7.3A

5.2.5 5.2.6

null

THREAT-1.A.MIL1 THREAT-1.B.MIL1 THREAT-1.D.MIL1 THREAT-1.E.MIL2 THREAT-1.J.MIL3

VAR:SG1.SP1

null

TBD - 3.14.3e

null

SI.L3-3.14.3e

null

SA-11(6)

null

9.1 17.1

null

PSS-02

null

2-10-1-1

TPC-27 TPC-28 TPC-29

null

2-11-3-1 5-1-3-8

2-9-1-1

null

B4.d

null

Principle 2.1 Principle 2.2 Principle 2.3 Principle 2.4 Principle 6.3 Principle 6.4 Principle 6.5 Principle 6.6

Principle 2.1 Principle 2.2 Principle 2.3 Principle 2.4 Principle 2.5 Principle 6.1 Principle 6.2 Principle 6.3 Principle 6.4

null

4.4.4

null

6.2.4.C.01

null

13.1.2

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Vulnerability Remediation Process

VPM-02

Mechanisms exist to ensure that vulnerabilities are properly identified, tracked and remediated.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - NNT Change Tracker (https://www.newnettechnologies.com)

null

Does the organization ensure that vulnerabilities are properly identified, tracked and remediated?

10

Protect

X

There is no evidence of a capability to ensure that vulnerabilities are properly identified, tracked and remediated.

SP-CMM1 is N/A, since a structured process is required to ensure that vulnerabilities are properly identified, tracked and remediated.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Vulnerability & Patch Management (VPM) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

CC4.2

CC5.3-POF4

null

7.2 7.7

7.2

7.2 7.7

DSS03.01 DSS03.02 DSS03.03 DSS03.04 DSS03.05 DSS06.04 MEA01.05

Principle 17

AIS-07 TVM-03

CLS-06 VLN-02 VLN-04

null

RQ-08-07.b RQ-08-08 RQ-09-04 RQ-09-07.a RQ-09-07.b RQ-09-07.c RQ-09-07.d RQ-15-17.a RQ-15-17.b RQ-15-17.c RQ-15-17.d

null

10.1

null

12.6.1

8.8

12.6.1

null

TS-4.0

null

RV.2 RV.2.1 RV.2.2

null

PM-4 SC-18(1)

null

PM-4 SC-18(1)

null

PM-4 SC-18(1)

null

PM-4

null

PM-4

null

3.11.2.b 3.14.1.a

3.11.3[a] 3.11.3[b]

null

RS.MI-3

ID.RA-01 ID.RA-06 ID.RA-08

A05:2021 A06:2021

null

11.3 11.3.1 11.3.1.1 11.3.1.2 11.3.1.3 11.3.2 11.3.2.1 A3.3.1.2

11.3.2 11.3.2.1

null

11.3.2

11.3.1 11.3.1.3 11.3.1.2 11.3.2.1

null

11.3.1 11.3.1.1 11.3.1.2 11.3.1.3 11.3.1.2 11.3.2.1

null

T.1.3

2.2 2.7

null

7.1

null

THREAT-1.G.MIL2 THREAT-1.H.MIL2 THREAT-2.D.MIL1 RISK-2.I.MIL3

EC:SG3.SP2 EF:SG2.SP1 EF:SG2.SP2 KIM:SG3.SP2 PM:SG2.SP2 RISK:SG5.SP1 TM:SG3.SP2 VAR:SG1.SP2

null

SI.L1-b.1.xii

null

PM-4

null

52.204-21(b)(1)(xii)

null

2.S.A 7.S.A

2.M.A 7.M.D

2.M.A 7.M.D 7.L.B

PM-4 SC-18(1)

null

9.1 17.1

6.11

null

5.6

null

III.E.2.a III.E.2.b

null

17.03(2)(j)

null

622(2)(d)(A)(i)

null

PM-4

null

Article 21.4

null

OPS-18 PSS-02

null

22.8 22.11 22.13

null

2-9-1-2

TPC-11 TPC-91

null

2-10-3-3 5-1-3-8

2-9-1-2

null

B4.d

null

5

null

21

null

4.7.1 12.6.1 12.6.1.18.PB

null

6.2.6.C.01 23.2.19.C.01

null

4.2(a) 4.2(b)

13.6.1(a) 13.6.1(b) 13.6.1(c)

null

2.7

3.2.6

null

x

FAR 52.204-21 MA 201 CMR 17 OR 6464A

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Vulnerability Ranking

VPM-03

Mechanisms exist to identify and assign a risk ranking to newly discovered security vulnerabilities using reputable outside sources for security vulnerability information.

- US-CERT

null

Does the organization identify and assign a risk ranking to newly discovered security vulnerabilities using reputable outside sources for security vulnerability information?

8

Identify

null

X

null

There is no evidence of a capability to identify and assign a risk ranking to newly discovered security vulnerabilities using reputable outside sources for security vulnerability information.

SP-CMM1 is N/A, since a structured process is required to identify and assign a risk ranking to newly discovered security vulnerabilities using reputable outside sources for security vulnerability information.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify and assign a risk ranking to newly discovered security vulnerabilities using reputable outside sources for security vulnerability information.

null

TVM-08

VLN-04

null

RQ-08-05 RQ-08-06 RQ-08-07.a RQ-09-03.c

null

8.8

null

RS.AN-5

ID.RA-01 ID.RA-05

A05:2021 A06:2021

6.1

6.3.1 11.3

6.3.1

null

6.3.1

null

T.1.6

null

THREAT-1.G.MIL2 RISK-2.I.MIL3

null

7.M.D

null

III.E.2.b

null

OPS-18 OPS-22 PSS-02

null

22.8

null

2-9-1-2

null

2-10-3-2

2-9-1-2 2-9-1-3

null

B4.d

null

1163

null

x

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Vulnerability Exploitation Analysis

VPM-03.1

Mechanisms exist to identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats exploiting known vulnerabilities.

null

Does the organization identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats exploiting known vulnerabilities?

5

Protect

null

X

There is no evidence of a capability to identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats exploiting known vulnerabilities.

SP-CMM1 is N/A, since a structured process is required to identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats exploiting known vulnerabilities.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats exploiting known vulnerabilities.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify, assess, prioritize and document the potential impact(s) and likelihood(s) of applicable internal and external threats exploiting known vulnerabilities. activities.

null

RQ-08-05 RQ-08-06 RQ-08-07.a RQ-09-03.a RQ-09-03.b RQ-09-03.c RQ-09-03.d RQ-09-03.e RQ-09-03.f RQ-09-04

null

ID.RA-04

null

R-BC-1 R-BC-2 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-1 R-SA-2

null

R-BC-1

R-BC-2

null

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Continuous Vulnerability Remediation Activities

VPM-04

Mechanisms exist to address new threats and vulnerabilities on an ongoing basis and ensure assets are protected against known attacks.

- NNT Change Tracker (https://www.newnettechnologies.com)

E-MNT-03 E-THR-05

Does the organization address new threats and vulnerabilities on an ongoing basis and ensure assets are protected against known attacks?

8

Protect

null

X

null

There is no evidence of a capability to address new threats and vulnerabilities on an ongoing basis and ensure assets are protected against known attacks.

SP-CMM1 is N/A, since a structured process is required to address new threats and vulnerabilities on an ongoing basis and ensure assets are protected against known attacks.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Vulnerability & Patch Management (VPM) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

CC4.2

null

7.7 12.1 18.3

12.1

7.7 12.1 18.3

DSS03.01 DSS03.02 DSS03.03 DSS03.04 DSS03.05 DSS06.04 MEA01.05

Principle 17

AIS-07 TVM-03

CLS-06 VLN-03

null

10.2

null

RV.1 RV.1.1 RV.1.2 RV.1.3

null

SC-18(1)

null

SC-18(1)

null

SC-18(1)

null

3.11.2.b 3.14.1.a 3.14.1.b

null

RS.MI-3

ID.RA-06

A05:2021 A06:2021

6.6

6.3.3

null

6.3.3

null

T.1.1.1 T.1.1.2 T.1.2.1 T.1.2.2

2.7

null

RISK-2.I.MIL3

KIM:SG3.SP2 VAR:SG1.SP2

null

SI.L1-b.1.xii

null

52.204-21(b)(1)(xii)

null

D1.RM.RA.E.1

null

7.L.B

SC-18(1)

null

9.1 17.1

6.11

null

Article 21.4

null

OPS-18 PSS-02

null

22.6 22.11

null

2-9-1-3

null

2-10-3-3

2-9-1-2 2-9-1-3

null

B4.d

null

1801

null

21

null

4.6 4.6.1

null

6.2.6.C.01 23.2.19.C.01

null

13.6.1(a) 13.6.1(b) 13.6.1(c)

null

2.7

null

x

FAR 52.204-21

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Stable Versions

VPM-04.1

Mechanisms exist to install the latest stable version of any software and/or security-related updates on all applicable systems.

null

Does the organization install the latest stable version of any software and/or security-related updates on all applicable systems?

8

Identify

null

X

There is no evidence of a capability to install the latest stable version of any software and/ or security-related updates on all applicable systems.

SP-CMM1 is N/A, since a structured process is required to install the latest stable version of any software and/ or security-related updates on all applicable systems.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to install the latest stable version of any software and/ or security-related updates on all applicable systems.

null

12.1

null

CLS-06

null

NDR 3.10 (15.7.3(1))

null

N.3 N.3.1 N.3.3 N.3.4

null

12.22

null

Principle 6.7

null

1467 1483

null

7.4.1 7.4.2

null

x

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Flaw Remediation with Personal Data (PD)

VPM-04.2

Mechanisms exist to identify and correct flaws related to the collection, usage, processing or dissemination of Personal Data (PD).

null

Does the organization identify and correct flaws related to the collection, usage, processing or dissemination of Personal Data (PD)?

8

Identify

null

X

null

There is no evidence of a capability to identify and correct flaws related to the collection, usage, processing or dissemination of Personal Data (PD).

SP-CMM1 is N/A, since a structured process is required to identify and correct flaws related to the collection, usage, processing or dissemination of Personal Data (PD).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Vulnerability & Patch Management (VPM) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

null

DSS06.04

null

10.1

null

A06:2021

null

P.1.5.4

null

7.L.B

null

Art 5.1

null

Sec 4

null

4.7.1

null

x

null

x

null

R-AC-4 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-3

null

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-3

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Software & Firmware Patching

VPM-05

Mechanisms exist to conduct software patching for all deployed operating systems, applications and firmware.

- Patch management tools

E-MNT-03

Does the organization conduct software patching for all deployed operating systems, applications and firmware?

10

Protect

null

X

There is no evidence of a capability to conduct software patching for all deployed operating systems, applications and firmware.

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Vulnerability & Patch Management (VPM) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

null

7.3 7.4 12.1 18.3

7.3 7.4 12.1

7.3 7.4 12.1 18.3

null

UEM-07

CCM-07 CLS-06 SAP-05 VLN-01

null

HDR 3.10 (14.5.1) NDR 3.10 (15.7.1)

null

12.6.1

8.8

12.6.1

null

6.9.6 6.9.6.1

null

TS-4.2

null

SI-2 SI-3(2)

SI-2

SI-2 SI-3(2)

SI-2 SI-2(4) SI-3

null

SI-2 SI-3

SI-2(4)

null

SI-2 SI-3

null

SI-2 SI-3

null

SI-2 SI-3

3.11.3

3.11.2.b 3.14.1.a 3.14.1.b

null

A.03.11.02.b A.03.11.02.ODP[01] A.03.14.01.b[01] A.03.14.01.b[02] A.03.14.01.ODP[01] A.03.14.01.ODP[02]

null

ID.RA-06

A06:2021

6.1 6.2

6.3.3

null

6.3.3

null

N.3

2.2

5.2.5 5.2.6

null

TM:SG4.SP2 VAR:SG2.SP2 VAR:SG2.SP3 VAR:SG3.SP1 VAR:SG4.SP1

null

5.10.4.1

null

RA.L2-3.11.3

null

SI.L1-b.1.xii

RA.L2-3.11.3

SI-2 SI-3(2)

null

52.204-21(b)(1)(xii)

null

SI-2 SI-3(2)

SI-2

SI-2 SI-3(2)

SI-2

SI-2 SI-3(2)

SI-2

SI-2 SI-3(2)

SI-2

null

2.S.A 7.S.A

2.M.A 7.M.D

SI-2 SI-2(4) SI-3

null

CIP-007-6 R2

8-311 8-610

9.1 17.1

null

SI-2

SI-2 SI-3(2)

III.E III.E.1

null

17.04(6)

null

622(2)(d)(B)(iii)

null

SI-2 SI-3

SI-2

SI-2 SI-3(2)

null

§ 2447(c)(7)

null

Art 9.4(f)

null

PSS-03

null

12.21

null

2-3-1-3

TPC-11 TPC-78

null

2-3-3-3 2-10-3-4 5-1-3-9

2-3-1-3 2-4-1-15

null

B4.d

null

5

null

Principle 2.5 Principle 2.6 Principle 6.5 Principle 6.6

Principle 2.6 Principle 2.7 Principle 2.8 Principle 6.5 Principle 6.6

null

1143 1493 1690 1691 1692 1693 1694 1695 1696 1751 1697

null

21

null

12.6.1 12.6.1.18.PB

null

23.2.19.C.01

null

4.2(a) 4.2(b)

7.4.1 7.4.2

null

6.16

null

4.5 4.7 4.9

2.6 2.6.1

null

x

FAR 52.204-21 MA 201 CMR 17 OR 6464A Lockton

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Centralized Management of Flaw Remediation Processes

VPM-05.1

Mechanisms exist to centrally-manage the flaw remediation process.

- Patch management tools

null

Does the organization centrally-manage the flaw remediation process?

9

Protect

X

There is no evidence of a capability to centrally-manage the flaw remediation process.

SP-CMM1 is N/A, since a structured process is required to centrally-manage the flaw remediation process.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to centrally-manage the flaw remediation process.

null

7.4 18.3

7.4

7.4 18.3

null

AIS-07 TVM-05 UEM-07

CCM-07 CLS-06 VLN-01

null

NDR 3.10 (15.7.3(1))

null

TS-4.2

null

SI-2(1)

null

SI-2(1)

PL-9 SI-2(4)

PL-9

null

SI-2(4)

null

PL-9

null

PL-9

null

ID.RA-01

A06:2021

6.2 6.4.5 6.4.5.1 6.4.5.2 6.4.5.3 6.4.5.4 6.4.6

6.3 6.3.1 6.3.2 6.3.3 6.4 6.4.1 6.4.2 6.4.3

6.3.1 6.3.3 6.4.3

6.3.1 6.3.2 6.3.3 6.4.1 6.4.2 6.4.3

null

6.3.1 6.3.3

6.3.1 6.3.2 6.3.3 6.4.1 6.4.2 6.4.3

null

T.1

null

RISK-2.I.MIL3

null

SI-2(1)

null

SI-2(1)

null

SI-2(1)

null

SI-2(4)

null

6.11

null

5.6

null

17.04(7)

null

Article 21.4

null

PSS-03

null

12.21 22.11 22.12

null

TPC-91

null

B4.d

null

0300 0298

null

7.4.1 7.4.2

null

x

MA 201 CMR 17

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Automated Remediation Status

VPM-05.2

Automated mechanisms exist to determine the state of system components with regard to flaw remediation.

- Vulnerability scanning tools - CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/)

null

Does the organization use automated mechanisms to determine the state of system components with regard to flaw remediation?

9

Protect

null

X

There is no evidence of a capability to determine the state of system components with regard to flaw remediation.

SP-CMM1 is N/A, since a structured process is required to determine the state of system components with regard to flaw remediation.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to determine the state of system components with regard to flaw remediation.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to determine the state of system components with regard to flaw remediation.

null

7.4

null

SI-2(2)

null

SI-2(2)

SI-2(2) SI-2(4)

null

SI-2(2)

SI-2(4)

null

SI-2(2)

null

A06:2021

null

J.3.2

null

SI-2(2)

null

SI-2(2)

null

SI-2(2)

null

SI-2(2)

null

SI-2(2)

null

SI-2(2) SI-2(4)

null

SI-2(2)

null

SI-2(2)

null

22.11 22.12

null

x

null

x

R-AM-3 R-EX-6 R-EX-7 R-GV-1 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-2 R-IR-3

null

R-AM-3

null

R-EX-6

R-EX-7

R-GV-1

null

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-2

R-IR-3

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

null

Vulnerability & Patch Management

Time To Remediate / Benchmarks For Corrective Action

VPM-05.3

Mechanisms exist to track the effectiveness of remediation operations through metrics reporting.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - NNT Change Tracker (https://www.newnettechnologies.com)

null

Does the organization track the effectiveness of remediation operations through metrics reporting?

6

Protect

null

X

There is no evidence of a capability to track the effectiveness of remediation operations through metrics reporting.

SP-CMM1 is N/A, since a structured process is required to track the effectiveness of remediation operations through metrics reporting.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Vulnerability & Patch Management (VPM) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

null

TVM-03

null

SI-2(3)

null

SI-2(3)

null

SI-2(3)

null

A06:2021

null

J.1.5

null

SI-2(3)

null

SI-2(3)

null

SI-2(3)

null

SI-2(3)

null

SI-2(3)

null

SI-2(3)

III.E.2.a

null

SI-2(3)

null

OPS-19

null

12.22

null

TPC-91

null

13.6.1(b)

null

x

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-2 R-IR-3

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

null

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-2

R-IR-3

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Automated Software & Firmware Updates

VPM-05.4

Automated mechanisms exist to install the latest stable versions of security-relevant software and firmware updates.

null

Does the organization use automated mechanisms to install the latest stable versions of security-relevant software and firmware updates?

5

Protect

null

X

null

There is no evidence of a capability to install the latest stable versions of security-relevant software and firmware updates.

SP-CMM1 is N/A, since a structured process is required to install the latest stable versions of security-relevant software and firmware updates.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to install the latest stable versions of security-relevant software and firmware updates.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to install the latest stable versions of security-relevant software and firmware updates.

null

7.4

null

TVM-04 TVM-05

CCM-06 CCM-07 CLS-06 IAM-22 IOT-03 IOT-09 VLN-03

null

NDR 3.10 (15.7.3(1))

null

SI-2(5)

null

SI-2(4) SI-2(5)

null

SI-2(4) SI-2(5)

null

SI-2(5)

null

SI-2(5)

null

J.2.10.1

null

SI-2(4) SI-2(5)

null

§ 2447(c)(7)

null

TPC-78

null

2-10-3-5

2-3-1-3

null

B4.d C1.d

null

4.2(a)

7.4.1 7.4.2

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

null

Vulnerability & Patch Management

Removal of Previous Versions

VPM-05.5

Mechanisms exist to remove old versions of software and firmware components after updated versions have been installed.

null

Does the organization remove old versions of software and firmware components after updated versions have been installed?

5

Protect

null

X

There is no evidence of a capability to remove old versions of software and firmware components after updated versions have been installed.

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Vulnerability & Patch Management (VPM) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

null

SI-2(6)

null

SI-2(6)

null

SI-2(6)

null

I.3.7 M.1.22 U.1.2

null

SI-2(6)

null

x

R-AM-3 R-EX-6 R-EX-7 R-GV-1 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-2 R-IR-3

null

R-AM-3

null

R-EX-6

R-EX-7

R-GV-1

null

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-2

R-IR-3

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Vulnerability Scanning

VPM-06

Mechanisms exist to detect vulnerabilities and configuration errors by recurring vulnerability scanning of systems and web applications.

- External vulnerability scans (unauthenticated) - Internal vulnerability scans (authenticated) - Nessus (https://www.tenable.com/products/nessus/nessus-professional) - Qualys (https://www.qualys.com/) - Rapid7 (https://www.rapid7.com/) - CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/)

E-VPM-05

Does the organization detect vulnerabilities and configuration errors by recurring vulnerability scanning of systems and web applications?

9

Detect

null

X

There is no evidence of a capability to detect vulnerabilities and configuration errors by recurring vulnerability scanning of systems and web applications.

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs). • Vulnerability scanning services may not be internal competencies and have to be outsourced.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements. • Comprehensive vulnerability scanning is utilized to detect vulnerabilities and configuration errors for systems, applications and services across the enterprise. Scanning is performed in accordance with statutory, regulatory and contractual obligations for scope, recurrence and rescanning.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Vulnerability & Patch Management (VPM) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

CC7.1

CC7.1-POF5

null

7.5 7.6

null

7.5 7.6

DSS05.07

null

TVM-03 TVM-07

VLN-04

null

8.8

null

T1011.001, T1021.001, T1021.003, T1021.004, T1021.005, T1021.006, T1046, T1047, T1052, T1052.001, T1053, T1053.001, T1053.002, T1053.003, T1053.005, T1059, T1059.001, T1059.005, T1059.007, T1068, T1078, T1091, T1092, T1098.004, T1127, T1127.001, T1133, T1137, T1137.001, T1176, T1190, T1195, T1195.001, T1195.002, T1204.003, T1210, T1211, T1212, T1213, T1213.001, T1213.002, T1213.003, T1218, T1218.003, T1218.004, T1218.005, T1218.008, T1218.009, T1218.012, T1218.013, T1218.014, T1221, T1482, T1484, T1505, T1505.001, T1505.002, T1505.003, T1505.004, T1525, T1528, T1530, T1542.004, T1542.005, T1543, T1546.002, T1546.014, T1547.006, T1547.007, T1547.008, T1548, T1548.002, T1548.003, T1552, T1552.001, T1552.002, T1552.004, T1552.006, T1557, T1558.004, T1559, T1559.002, T1560, T1560.001, T1562, T1562.010, T1563, T1563.001, T1563.002, T1574, T1574.001, T1574.004, T1574.005, T1574.007, T1574.008, T1574.009, T1574.010, T1578, T1578.001, T1578.002, T1578.003, T1612

TS-4.0

null

RA-5

null

RA-5

null

RA-5

null

RA-5

null

RA-5

3.11.2

3.11.2.a

3.11.2[a] 3.11.2[b] 3.11.2[c] 3.11.2[d] 3.11.2[e]

A.03.11.02.a[01] A.03.11.02.a[02] A.03.11.02.a[03] A.03.11.02.a[04]

null

DE.CM-8

null

A05:2021 A06:2021

11.2

6.4.1 11.3.1 11.3.1.1 11.3.1.2 11.3.1.3 11.3.2 11.3.2.1

11.3.2 11.3.2.1

6.4.1 11.3.2 11.3.2.1

null

11.3.2

11.3.1 11.3.1.3 11.3.1.2 11.3.2.1

null

6.4.1 11.3.1 11.3.1.1 11.3.1.2 11.3.1.3 11.3.1.2 11.3.2.1

null

T.1.1 T.1.1.1 T.1.1.2 T.1.2 T.1.2.1 T.1.2.2

2.7

null

THREAT-1.B.MIL1 THREAT-1.C.MIL1 THREAT-1.D.MIL1 THREAT-1.F.MIL2 THREAT-1.K.MIL3

MON:SG2.SP1 MON:SG2.SP2 MON:SG2.SP3 MON:SG2.SP4 VAR:SG2.SP1 VAR:SG2.SP2 VAR:SG2.SP3 VAR:SG3.SP1 VAR:SG4.SP1

5.6

null

RA.L2-3.11.2

null

RA.L2-3.11.2

RA-5

null

RA-5

null

D3.DC.Th.E.5

null

314.4(d)(2) 314.4(d)(2)(ii)

null

2.S.A 7.S.A

7.M.A 7.M.B

7.M.A 7.M.B 7.L.A 9.L.A 9.L.B

RA-5

null

CIP-010-2 R3

8-614

null

5.6

RA-5

null

500.05

null

622(2)(B)(iii) 622(2)(d)(A)(iii)

null

RA-5

null

Art 25.1 Art 25.2 Art 25.3

null

5.6

OPS-22 PSS-02 PSS-03

null

3.4 9.25 12.30 22.3 22.6

null

2-9-1-1 2-9-2

TPC-85

null

2-10-3-1

null

B2.b B4.d

null

Principle 2.2 Principle 2.3 Principle 2.4 Principle 6.2 Principle 6.3 Principle 6.4

Principle 2.2 Principle 2.3 Principle 2.4 Principle 2.5

null

1163 1698 1699 1700 1701 1702 1752 1703

null

6.2.5.C.01

null

13.1.1 13.1.2

null

6.15

null

2.5

3.1.3

null

x

OR 6464A

x

R-AC-2 R-AC-3 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Update Tool Capability

VPM-06.1

Mechanisms exist to update vulnerability scanning tools.

null

Does the organization update vulnerability scanning tools?

8

Protect

null

X

There is no evidence of a capability to update vulnerability scanning tools.

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative processes exist and technologies are configured update vulnerability scanning tools.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements. • Administrative processes exist and technologies are configured update vulnerability scanning tools.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to update vulnerability scanning tools.

null

TVM-04 TVM-05

null

RA-5(1) RA-5(2)

null

RA-5(1) RA-5(2)

RA-5 RA-5(2)

null

RA-5 RA-5(2)

null

RA-5 RA-5(2)

null

RA-5

null

RA-5

NFO - RA-5(1) NFO - RA-5(2)

3.11.2.c

null

A.03.11.02.c[01] A.03.11.02.c[02] A.03.11.02.c[03]

null

11.3.1

null

11.3.1

null

11.3.1

null

T.3.1 T.4

null

RA-5(1) RA-5(2)

null

RA-5(1) RA-5(2)

null

RA-5(1) RA-5(2)

null

RA-5(2)

null

RA-5 RA-5(2)

null

RA-5(1) RA-5(2)

null

RA-5

null

RA-5(1) RA-5(2)

null

PSS-03

null

22.7

null

Principle 2.2 Principle 6.2

null

1808

null

x

R-AC-2 R-AC-3 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Breadth / Depth of Coverage

VPM-06.2

Mechanisms exist to identify the breadth and depth of coverage for vulnerability scanning that define the system components scanned and types of vulnerabilities that are checked for.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - NNT Change Tracker (https://www.newnettechnologies.com)

null

Does the organization identify the breadth and depth of coverage for vulnerability scanning that define the system components scanned and types of vulnerabilities that are checked for?

8

Protect

null

X

There is no evidence of a capability to identify the breadth and depth of coverage for vulnerability scanning that define the system components scanned and types of vulnerabilities that are checked for.

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative processes exist to identify the breadth and depth of coverage for vulnerability scanning that define the system components scanned and types of vulnerabilities that are checked for.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements. • Administrative processes exist to identify the breadth and depth of coverage for vulnerability scanning that define the system components scanned and types of vulnerabilities that are checked for.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify the breadth and depth of coverage for vulnerability scanning that define the system components scanned and types of vulnerabilities that are checked for.

null

VLN-04

null

RA-5(3)

null

RA-5(3)

null

RA-5(3)

null

RA-5(3)

null

RA-5(3)

null

11.3.1

null

11.3.1

null

11.3.1

null

G.3.2

null

THREAT-1.B.MIL1 THREAT-1.C.MIL1 THREAT-1.D.MIL1 THREAT-1.F.MIL2 THREAT-1.K.MIL3

null

RA-5(3)

null

RA-5(3)

null

RA-5(3)

null

RA-5(3)

null

RA-5(3)

null

RA-5(3)

null

RA-5(3)

null

22.6

null

2-9-2-1

null

2-11-3-1

null

B4.d

null

x

R-AC-2 R-AC-3 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Privileged Access

VPM-06.3

Mechanisms exist to implement privileged access authorization for selected vulnerability scanning activities.

- Authenticated scans

null

Does the organization implement privileged access authorization for selected vulnerability scanning activities?

9

Protect

null

X

There is no evidence of a capability to implement privileged access authorization for selected vulnerability scanning activities.

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to implement privileged access authorization for selected vulnerability scanning activities.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to implement privileged access authorization for selected vulnerability scanning activities.

null

IAM-09

null

RA-5(5)

null

RA-5(5)

null

RA-5(5)

null

RA-5(5)

null

3.11.2

null

T.1

null

RA.L2-3.11.2

null

RA.L2-3.11.2

RA-5(5)

null

RA-5(5)

null

RA-5(5)

null

RA-5(5)

null

RA-5(5)

null

RA-5(5)

null

RA-5(5)

null

RA-5(5)

null

22.9

null

x

null

x

R-AC-2 R-AC-3 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Trend Analysis

VPM-06.4

Automated mechanisms exist to compare the results of vulnerability scans over time to determine trends in system vulnerabilities.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/)

null

Does the organization use automated mechanisms to compare the results of vulnerability scans over time to determine trends in system vulnerabilities?

9

Identify

null

X

There is no evidence of a capability to compare the results of vulnerability scans over time to determine trends in system vulnerabilities.

SP-CMM1 is N/A, since a structured process is required to compare the results of vulnerability scans over time to determine trends in system vulnerabilities.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative processes exist and technologies are configured to compare the results of vulnerability scans over time to determine trends in system vulnerabilities.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements. • Administrative processes exist and technologies are configured to compare the results of vulnerability scans over time to determine trends in system vulnerabilities.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to compare the results of vulnerability scans over time to determine trends in system vulnerabilities.

null

RA-5(6)

null

RA-5(6)

null

RA-5(6)

null

RA-5(6)

null

RA-5(6)

null

I.4.2

null

RA-5(6)

null

RA-5(6)

null

5.6

null

RA-5(6)

null

RA-5(6)

null

OPS-20

null

22.10

null

x

null

x

R-AC-2 R-AC-3 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

null

Vulnerability & Patch Management

Review Historical Event Logs

VPM-06.5

Mechanisms exist to review historical event logs to determine if identified vulnerabilities have been previously exploited.

null

Does the organization review historical event logs to determine if identified vulnerabilities have been previously exploited?

9

Detect

null

X

There is no evidence of a capability to review historical event logs to determine if identified vulnerabilities have been previously exploited.

SP-CMM1 is N/A, since a structured process is required to review historical event logs to determine if identified vulnerabilities have been previously exploited.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Vulnerability & Patch Management (VPM) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

null

RA-5(8)

null

RA-5(8)

null

RA-5(8)

null

J.3.2

null

RA-5(8)

null

RA-5(8)

null

RA-5(8)

null

RA-5(8)

null

RA-5(8)

null

RA-5(8)

null

OPS-20

null

22.10

null

x

null

x

R-AC-2 R-AC-3 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

- wordsmithed control

Vulnerability & Patch Management

External Vulnerability Assessment Scans

VPM-06.6

Mechanisms exist to perform quarterly external vulnerability scans (outside the organization's network looking inward) via a reputable vulnerability service provider, which include rescans until passing results are obtained or all “high” vulnerabilities are resolved, as defined by the Common Vulnerability Scoring System (CVSS).

null

E-VPM-05

Does the organization perform quarterly external vulnerability scans (outside the organization's network looking inward) via a reputable vulnerability service provider, which include rescans until passing results are obtained or all “high” vulnerabilities are resolved, as defined by the Common Vulnerability Scoring System (CVSS)?

9

Detect

null

X

There is no evidence of a capability to perform quarterly external vulnerability scans (outside the organization's network looking inward) via a reputable vulnerability service provider, which include rescans until passing results are obtained or all “high” vulnerabilities are resolved, as defined by the Comm on Vulnerability Scoring System (CVSS).

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to perform quarterly external vulnerability scans (outside the organization's network looking inward) via a reputable vulnerability service provider, which include rescans until passing results are obtained or all “high” vulnerabilities are resolved, as defined by the Comm on Vulnerability Scoring System (CVSS).

null

7.5

null

7.5

null

11.2 11.2.2 11.2.3

6.4.1 11.3.2 11.3.2.1

null

6.4.1

null

6.4.1

null

T.1.2 T.1.2.1 T.1.2.2 T.1.3 T.1.3 T.1.6

null

PSS-02

null

22.3

null

R-AC-2 R-AC-3 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Internal Vulnerability Assessment Scans

VPM-06.7

Mechanisms exist to perform quarterly internal vulnerability scans, which includes all segments of the organization's internal network, as well as rescans until passing results are obtained or all “high” vulnerabilities are resolved, as defined by the Common Vulnerability Scoring System (CVSS).

null

E-VPM-05

Does the organization perform quarterly internal vulnerability scans, which includes all segments of the organization's internal network, as well as rescans until passing results are obtained or all “high” vulnerabilities are resolved, as defined by the Common Vulnerability Scoring System (CVSS)?

9

Detect

null

X

There is no evidence of a capability to perform quarterly internal vulnerability scans, which includes all segments of the organization's internal network, as well as rescans until passing results are obtained or all “high” vulnerabilities are resolved, as defined by the Comm on Vulnerability Scoring System (CVSS).

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to perform quarterly internal vulnerability scans, which includes all segments of the organization's internal network, as well as rescans until passing results are obtained or all “high” vulnerabilities are resolved, as defined by the Comm on Vulnerability Scoring System (CVSS).

null

7.6

null

7.6

null

11.2 11.2.1 11.2.3

11.3.1.2 11.3.1.3

null

11.3.1.3

null

11.3.1.2 11.3.1.3

null

T.1.1 T.1.1.1 U.1.12.2 T.1.1.2 T.1.3

null

PSS-02

null

22.3

null

R-AC-2 R-AC-3 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Acceptable Discoverable Information

VPM-06.8

Mechanisms exist to define what information is allowed to be discoverable by adversaries and take corrective actions to remediated non-compliant systems.

null

Does the organization define what information is allowed to be discoverable by adversaries and take corrective actions to remediated non-compliant systems?

5

Protect

null

X

null

There is no evidence of a capability to define what information is allowed to be discoverable by adversaries and take corrective actions to remediated non-compliant systems.

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative processes and technologies prevent the public disclosure of internal address information.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements. • Administrative processes and technologies prevent the public disclosure of internal address information.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to define what information is allowed to be discoverable by adversaries and take corrective actions to remediated non-compliant systems.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to define what information is allowed to be discoverable by adversaries and take corrective actions to remediated non-compliant systems.

null

RA-5(4)

null

RA-5(4)

null

RA-5(4)

null

RA-5(4)

null

1.4.5

null

1.4.5

null

1.4.5

null

P.9.6 T.1.5.6

null

RA-5(4)

null

RA-5(4)

null

RA-5(4)

null

RA-5(4)

null

RA-5(4)

null

14.1.14.C.01

null

x

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-7 R-GV-1 R-SA-1

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

null

R-EX-7

R-GV-1

null

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Correlate Scanning Information

VPM-06.9

Automated mechanisms exist to correlate the output from vulnerability scanning tools to determine the presence of multi-vulnerability/multi-hop attack vectors.

null

Does the organization use automated mechanisms to correlate the output from vulnerability scanning tools to determine the presence of multi-vulnerability/multi-hop attack vectors?

5

Detect

null

X

There is no evidence of a capability to correlate the output from vulnerability scanning tools to determine the presence of multi-vulnerability/multi-hop attack vectors.

SP-CMM1 is N/A, since a structured process is required to correlate the output from vulnerability scanning tools to determine the presence of multi-vulnerability/multi-hop attack vectors.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to correlate the output from vulnerability scanning tools to determine the presence of multi-vulnerability/multi-hop attack vectors.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to correlate the output from vulnerability scanning tools to determine the presence of multi-vulnerability/multi-hop attack vectors.

null

RA-5(10)

null

RA-5(10)

null

RA-5(10)

null

RA-5(10)

null

RA-5(10)

null

x

R-AM-3 R-EX-6 R-EX-7 R-GV-1 R-SA-1

null

R-AM-3

null

R-EX-6

R-EX-7

R-GV-1

null

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

null

Vulnerability & Patch Management

Penetration Testing

VPM-07

Mechanisms exist to conduct penetration testing on systems and web applications.

null

E-VPM-02 E-VPM-03

Does the organization conduct penetration testing on systems and web applications?

9

Detect

null

X

null

There is no evidence of a capability to conduct penetration testing on systems and web applications.

Vulnerability & Patch Management (VPM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized. • IT personnel apply software patches through an informal process. • Occasional vulnerability scanning is conducted on High Value Assets (HVAs). • Penetration testing services may not be internal competencies and have to be outsourced.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel conduct annual penetration testing on network segments hosting High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements. • Cybersecurity personnel conduct annual penetration testing on network segments hosting High Value Assets (HVAs).

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to conduct penetration testing on systems and web applications.

null

18.0 18.1 18.2 18.4 18.5

null

18.1 18.2

18.1 18.2 18.4 18.5

null

TVM-06

SET-02 SET-04

null

T1021.001, T1021.005, T1053, T1053.001, T1053.002, T1053.003, T1053.005, T1059, T1068, T1078, T1176, T1195.003, T1204.003, T1210, T1211, T1212, T1213, T1213.001, T1213.002, T1482, T1484, T1495, T1505, T1505.001, T1505.002, T1505.004, T1525, T1528, T1530, T1542, T1542.001, T1542.003, T1542.004, T1542.005, T1543, T1548, T1548.002, T1550.001, T1552, T1552.001, T1552.002, T1552.004, T1552.006, T1553, T1553.006, T1554, T1558.004, T1560, T1560.001, T1562, T1563, T1574, T1574.001, T1574.005, T1574.007, T1574.008, T1574.009, T1574.010, T1578, T1578.001, T1578.002, T1578.003, T1601, T1601.001, T1601.002, T1612

TS-4.1

null

CA-8

null

CA-8

CA-8 SA-11(5)

null

CA-8

SA-11(5)

null

CA-8

null

3.12.1e

null

11.3 11.3.1 11.3.2 11.3.3 11.3.4

11.4 11.4.1 11.4.2 11.4.3 11.4.4 11.4.5 11.4.6 11.4.7 A3.2.4

null

11.4.1 11.4.3 11.4.4 11.4.5

null

11.4.5

null

11.4.1 11.4.2 11.4.3 11.4.4 11.4.5

11.4.1 11.4.2 11.4.3 11.4.4 11.4.5 11.4.6 11.4.7

null

T.1.5.4 T.1.5.5 T.1.5.12

7.3A

null

VAR:SG2.SP1 VAR:SG2.SP2

5.6

null

TBD - 3.12.1e

null

CA.L3-3.12.1e

null

CA-8

null

CA-8

null

CA-8

null

314.4(d)(2) 314.4(d)(2)(i)

null

7.L.A

CA-8 SA-11(5)

null

8-610 8-614

null

CA-8

III.F.2.c

null

500.05

null

CA-8

null

CA-8

null

Art 26.1 Art 26.2 Art 26.3 Art 26.4 Art 26.5 Art 26.6 Art 26.7 Art 26.8 Art 26.8(a) Art 26.8(b) Art 26.8(c)

null

5.6

OPS-19 PSS-02

null

3.4 12.30 17.17 22.4 22.5

null

2-10 2-10-1-1 2-10-1-2 2-10-2

TPC-27 TPC-28 TPC-29

null

2-11-3-1

2-10 2-10-1 2-10-1-1 2-10-1-2 2-10-1-3 2-10-1-4 2-10-2

null

B4.d

null

1163

null

13.2.1 13.2.3 13.2.4

null

6.15

null

2.6

null

x

null

x

R-AC-2 R-AC-3 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Independent Penetration Agent or Team

VPM-07.1

Mechanisms exist to utilize an independent assessor or penetration team to perform penetration testing.

null

E-VPM-04

Does the organization utilize an independent assessor or penetration team to perform penetration testing?

6

Detect

null

X

null

There is no evidence of a capability to utilize an independent assessor or penetration team to perform penetration testing.

SP-CMM1 is N/A, since a structured process is required to utilize an independent assessor or penetration team to perform penetration testing.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative processes exist to use an independent assessor or penetration team to perform penetration testing.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements. • Administrative processes exist to use an independent assessor or penetration team to perform penetration testing.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize an independent assessor or penetration team to perform penetration testing.

null

SET-02 SET-03 SET-04

null

CA-8(1)

null

CA-8(1)

null

CA-8(1)

null

CA-8(1)

null

11.4.1 11.4.2 11.4.3 11.4.5 11.4.6

null

11.4.5

null

11.4.5

null

11.4.1 11.4.2 11.4.3 11.4.5

11.4.1 11.4.2 11.4.3 11.4.5 11.4.6

null

T.1.5.2

null

5.6

null

CA-8(1)

null

CA-8(1)

null

CA-8(1)

null

CA-8(1)

null

7.L.A

null

CA-8(1)

null

CA-8(1)

null

Art 27.1(a) Art 27.1(b) Art 27.1(c) Art 27.1(d) Art 27.1(e) Art 27.2(a) Art 27.2(b) Art 27.2(c) Art 27.3

null

OPS-19 PSS-02

null

17.16 17.17 22.4 22.5

null

2-10-1-2

null

B4.d

null

R-AC-2 R-AC-3 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Technical Surveillance Countermeasures Security

VPM-08

Mechanisms exist to utilize a technical surveillance countermeasures survey.

- Facility sweeping for "bugs" or other unauthorized surveillance technologies.

null

Does the organization utilize a technical surveillance countermeasures survey?

1

Detect

null

X

null

There is no evidence of a capability to utilize a technical surveillance countermeasures survey.

SP-CMM1 is N/A, since a structured process is required to utilize a technical surveillance countermeasures survey.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative processes exist to use a technical surveillance countermeasures survey.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements. • Administrative processes exist to use a technical surveillance countermeasures survey.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize a technical surveillance countermeasures survey.

null

RA-6

null

RA-6

null

RA-6

null

E.1.5

null

IMC:SG2.SP1 VAR:SG2.SP1

null

8.1.13.C.01 8.1.13.C.02

null

R-EX-6 R-EX-7 R-GV-1 R-SA-1

null

R-EX-6

R-EX-7

R-GV-1

null

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Reviewing Vulnerability Scanner Usage

VPM-09

Mechanisms exist to monitor logs associated with scanning activities and associated administrator accounts to ensure that those activities are limited to the timeframes of legitimate scans.

- Security Incident Event Manager (SIEM)

null

Does the organization monitor logs associated with scanning activities and associated administrator accounts to ensure that those activities are limited to the timeframes of legitimate scans?

3

Detect

null

X

There is no evidence of a capability to monitor logs associated with scanning activities and associated administrator accounts to ensure that those activities are limited to the timeframes of legitimate scans.

SP-CMM1 is N/A, since a structured process is required to monitor logs associated with scanning activities and associated administrator accounts to ensure that those activities are limited to the timeframes of legitimate scans.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Logs of vulnerability scanning activities and associated administrator accounts are reviewed to ensure that those activities are limited to the timeframes of legitimate scans.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements. • Logs of vulnerability scanning activities and associated administrator accounts are reviewed to ensure that those activities are limited to the timeframes of legitimate scans.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Vulnerability & Patch Management (VPM) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

null

J.3.2

null

x

null

R-AM-3 R-BC-1 R-BC-2 R-GV-1 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-SA-1

null

R-AM-3

R-BC-1

R-BC-2

null

R-GV-1

null

R-GV-6

R-GV-7

R-GV-8

R-IR-1

null

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Vulnerability & Patch Management

Red Team Exercises

VPM-10

Mechanisms exist to utilize "red team" exercises to simulate attempts by adversaries to compromise systems and applications in accordance with organization-defined rules of engagement.

- "red team" exercises

null

Does the organization utilize "red team" exercises to simulate attempts by adversaries to compromise systems and applications in accordance with organization-defined rules of engagement?

3

Detect

null

X

null

There is no evidence of a capability to utilize "red team" exercises to simulate attempts by adversaries to compromise systems and applications in accordance with organization-defined rules of engagement.

SP-CMM1 is N/A, since a structured process is required to utilize "red team" exercises to simulate attempts by adversaries to compromise systems and applications in accordance with organization-defined rules of engagement.

Vulnerability & Patch Management (VPM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative processes exist to use red team exercises to simulate attempts by adversaries to compromise systems and applications in accordance with organization-defined rules of engagement.

Vulnerability & Patch Management (VPM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Defines the scope of ASM activities. o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization’s overall Patch& Vulnerability & Patch Management Program (VPMP). • A Security Operations Center (SOC), or similar function: o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners. • Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements. • Administrative processes exist to use red team exercises to simulate attempts by adversaries to compromise systems and applications in accordance with organization-defined rules of engagement.

Vulnerability & Patch Management (VPM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize "red team" exercises to simulate attempts by adversaries to compromise systems and applications in accordance with organization-defined rules of engagement.

null

SET-03

null

CA-8(2)

null

CA-8(2)

null

CA-8(2)

null

DE.DP-3

null

T.1.5.13 T.1.5.14

null

5.6

null

CA-8(2)

null

CA-8(2)

null

D3.DC.Ev.Int.2

null

III.F.2.c

null

5.6

null

2-13-1-9

null

13.3.1 13.3.2 13.4.1 13.4.2

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

WEB-01

Mechanisms exist to facilitate the implementation of an enterprise-wide web management policy, as well as associated standards, controls and procedures.

null

Does the organization facilitate the implementation of an enterprise-wide web management policy, as well as associated standards, controls and procedures?

8

Protect

X

There is no evidence of a capability to facilitate the implementation of an enterprise-wide web management policy, as well as associated standards, controls and procedures.

Web Security (WEB) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • The management of Internet-facing technologies are decentralized. • Internet-facing technologies are governed no differently from internal network assets.

Web Security (WEB) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Internet-facing technologies management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for Internet-facing technologies management. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed (e.g., Demilitarized Zones (DMZs)). • Internet-facing technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to facilitate the implementation of an enterprise-wide web management policy, as well as associated standards, controls and procedures.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the implementation of an enterprise-wide web management policy, as well as associated standards, controls and procedures.

null

6.10.1.3

null

A.03.13.01.a[01] A.03.13.01.a[02] A.03.13.01.b A.03.13.01.c

null

1.3.1 1.3.2 1.3.4

6.4 6.4.1 6.4.2

null

6.4.1 6.4.2

null

6.4.1 6.4.2

null

P.6.1

null

5.4

null

AC.L1-b.1.iv

null

52.204-21(b)(1)(iv)

null

6.M.A

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

2-12 2-12-1-1 2-12-1-2

null

2-15-1 2-15-2 2-15-3 2-15-4

null

8.8.2 [MP.S.2]

null

14.5.6.C.01 14.5.7.C.01 14.5.8.C.01

null

x

FAR 52.204-21

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Web Security

Unauthorized Code

WEB-01.1

Mechanisms exist to prevent unauthorized code from being present in a secure page as it is rendered in a client’s browser.

null

Does the organization prevent unauthorized code from being present in a secure page as it is rendered in a client’s browser?

9

Protect

null

X

There is no evidence of a capability to prevent unauthorized code from being present in a secure page as it is rendered in a client’s browser.

SP-CMM1 is N/A, since a structured process is required to prevent unauthorized code from being present in a secure page as it is rendered in a client’s browser.

Web Security (WEB) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Internet-facing technologies management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for Internet-facing technologies management. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed (e.g., Demilitarized Zones (DMZs)). • Internet-facing technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to prevent unauthorized code from being present in a secure page as it is rendered in a client’s browser.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to prevent unauthorized code from being present in a secure page as it is rendered in a client’s browser.

null

6.4.3

null

6.4.3

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

MT-8 MT-9 MT-12 MT-13 MT-14 MT-15

null

MT-8

MT-9

null

MT-12

MT-13

MT-14

MT-15

null

Web Security

Use of Demilitarized Zones (DMZ)

WEB-02

Mechanisms exist to utilize a Demilitarized Zone (DMZ) to restrict inbound traffic to authorized devices on certain services, protocols and ports.

null

Does the organization utilize a Demilitarized Zone (DMZ) to restrict inbound traffic to authorized devices on certain services, protocols and ports?

9

Protect

null

X

There is no evidence of a capability to utilize a Demilitarized Zone (DMZ) to restrict inbound traffic to authorized devices on certain services, protocols and ports.

SP-CMM1 is N/A, since a structured process is required to utilize a Demilitarized Zone (DMZ) to restrict inbound traffic to authorized devices on certain services, protocols and ports.

Web Security (WEB) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Internet-facing technologies management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for Internet-facing technologies management. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed (e.g., Demilitarized Zones (DMZs)). • Internet-facing technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

Web Security (WEB) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize a Demilitarized Zone (DMZ) to restrict inbound traffic to authorized devices on certain services, protocols and ports.

null

13.1.3

8.22

null

6.10.1.3

null

TS-1.9 TS-1.15 TS-2.0

null

A.03.13.01.b

null

1.3.1 1.3.2 1.3.4

null

N.7 N.7.1 N.7.3

1.1

null

5.4

null

SC.L1-b.1.xi

null

52.204-21(b)(1)(xi)

null

6.M.A 6.M.B

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

TPC-41

null

2-4-1-10 2-4-1-13

null

x

FAR 52.204-21

x

null

R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-4 R-SA-1

null

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Web Application Firewall (WAF)

WEB-03

Mechanisms exist to deploy Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats.

- Web Application Firewall (WAF)

null

Does the organization deploy Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats?

8

Protect

null

X

There is no evidence of a capability to deploy Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats.

SP-CMM1 is N/A, since a structured process is required to deploy Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats.

Web Security (WEB) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Internet-facing technologies management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for Internet-facing technologies management. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed (e.g., Demilitarized Zones (DMZs)). • Internet-facing technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

Web Security (WEB) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to deploy Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats.

null

4.4 13.10

null

4.4

4.4 13.10

null

TS-2.4

null

SC-7(17)

null

SC-7(17)

null

SC-7(17)

null

6.4 6.4.1 6.4.2

null

6.4.1 6.4.2

null

6.4.1 6.4.2

null

I.3.19

null

6.M.A

SC-7(17)

null

TPC-79

null

2-15-3-1

null

4.3 4.4

null

x

null

R-AM-1 R-AM-3 R-BC-1 R-BC-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-IR-4 R-SA-1

null

R-AM-1

null

R-AM-3

R-BC-1

null

R-BC-4

null

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Client-Facing Web Services

WEB-04

Mechanisms exist to deploy reasonably-expected security controls to protect the confidentiality and availability of client data that is stored, transmitted or processed by the Internet-based service.

- OWASP

null

Does the organization deploy reasonably-expected security controls to protect the confidentiality and availability of client data that is stored, transmitted or processed by the Internet-based service?

10

Protect

null

X

There is no evidence of a capability to deploy reasonably-expected security controls to protect the confidentiality and availability of client data that is stored, transmitted or processed by the Internet-based service.

SP-CMM1 is N/A, since a structured process is required to deploy reasonably-expected security controls to protect the confidentiality and availability of client data that is stored, transmitted or processed by the Internet-based service.

Web Security (WEB) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Internet-facing technologies management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for Internet-facing technologies management. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed (e.g., Demilitarized Zones (DMZs)). • Internet-facing technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

Web Security (WEB) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to deploy reasonably-expected security controls to protect the confidentiality and availability of client data that is stored, transmitted or processed by the Internet-based service.

null

C.1.2

null

8.2

null

AC.L1-b.1.iv

null

52.204-21(b)(1)(iv)

null

2-12 2-12-1-1 2-12-1-2

null

Sec 19

null

x

FAR 52.204-21

x

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Cookie Management

WEB-05

Mechanisms exist to provide individuals with clear and precise information about cookies, in accordance with applicable legal requirements for cookie management.

null

Does the organization provide individuals with clear and precise information about cookies, in accordance with applicable legal requirements for cookie management?

5

Identify

null

X

There is no evidence of a capability to provide individuals with clear and precise information about cookies, in accordance with applicable legal requirements for cookie management.

SP-CMM1 is N/A, since a structured process is required to provide individuals with clear and precise information about cookies, in accordance with applicable legal requirements for cookie management.

Web Security (WEB) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Internet-facing technologies management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for Internet-facing technologies management. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed (e.g., Demilitarized Zones (DMZs)). • Internet-facing technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

Web Security (WEB) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide individuals with clear and precise information about cookies, in accordance with applicable legal requirements for cookie management.

null

7.1.1

null

P.6.1.6

null

(25)

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

null

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Strong Customer Authentication (SCA)

WEB-06

Mechanisms exist to implement Strong Customer Authentication (SCA) for consumers to reasonably prove their identity.

null

Does the organization implement Strong Customer Authentication (SCA) for consumers to reasonably prove their identity?

8

Protect

null

X

There is no evidence of a capability to implement Strong Customer Authentication (SCA) for consumers to reasonably prove their identity.

SP-CMM1 is N/A, since a structured process is required to implement Strong Customer Authentication (SCA) for consumers to reasonably prove their identity.

Web Security (WEB) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Internet-facing technologies management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for Internet-facing technologies management. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed (e.g., Demilitarized Zones (DMZs)). • Internet-facing technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

Web Security (WEB) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Web Security (WEB) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

null

IAM-01 IAM-02 IAM-14

null

PR.AC-P1

null

8.3.10

null

8.3.10

null

P.5.5.6.6

null

Art 4

null

PSS-05

null

2-12-1-1

null

x

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Web Security Standard

WEB-07

Mechanisms exist to ensure the Open Web Application Security Project (OWASP) Application Security Verification Standard is incorporated into the organization's Secure Systems Development Lifecycle (SSDLC) process.

null

Does the organization ensure the Open Web Application Security Project (OWASP) Application Security Verification Standard is incorporated into the organization's Secure Systems Development Lifecycle (SSDLC) process?

9

Protect

null

X

There is no evidence of a capability to ensure the Open Web Application Security Project (OWASP) Application Security Verification Standard is incorporated into the organization's Secure Systems Development Lifecycle (SSDLC) process.

SP-CMM1 is N/A, since a structured process is required to ensure the Open Web Application Security Project (OWASP) Application Security Verification Standard is incorporated into the organization's Secure Systems Development Lifecycle (SSDLC) process.

SP-CMM2 is N/A, since a well-defined process is required to ensure the open Web Application Security Project (OWASP) Application Security Verification Standard is incorporated into the organization's Secure Systems Development Lifecycle (SSDLC) process.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure the Open Web Application Security Project (OWASP) Application Security Verification Standard is incorporated into the organization's Secure Systems Development Lifecycle (SSDLC) process.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure the Open Web Application Security Project (OWASP) Application Security Verification Standard is incorporated into the organization's Secure Systems Development Lifecycle (SSDLC) process.

null

16.0 16.1 16.7

null

16.1 16.7

null

AIS-04

null

1.1.10 1.2.11.6 1.3.2.3.8

null

2-12-1-2

null

1239 0971

null

14.5.7.C.01 14.5.8.C.01

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Web Application Framework

WEB-08

Mechanisms exist to ensure a robust Web Application Framework is used to aid in the development of secure web applications, including web services, web resources and web APIs.

null

Does the organization ensure a robust Web Application Framework is used to aid in the development of secure web applications, including web services, web resources and web APIs?

9

Protect

null

X

There is no evidence of a capability to ensure a robust Web Application Framework is used to aid in the development of secure web applications, including web services, web resources and web APIs.

SP-CMM1 is N/A, since a structured process is required to ensure a robust Web Application Framework is used to aid in the development of secure web applications, including web services, web resources and web APIs.

SP-CMM2 is N/A, since a well-defined process is required to ensure a robust Web Application Framework is used to aid in the development of secure web applications, including web services, web resources and web APIs.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure a robust Web Application Framework is used to aid in the development of secure web applications, including web services, web resources and web APIs.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure a robust Web Application Framework is used to aid in the development of secure web applications, including web services, web resources and web APIs.

null

16.0 16.1

null

16.1

null

AIS-04

null

1.1.10 1.2.11.6 1.3.2.3.8

null

2-12-1-1

null

1239

null

14.5.7.C.01 14.5.8.C.01

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Validation & Sanitization

WEB-09

Mechanisms exist to ensure all input handled by a web application is validated and/or sanitized.

null

Does the organization ensure all input handled by a web application is validated and/or sanitized?

9

Protect

null

X

There is no evidence of a capability to ensure all input handled by a web application is validated and/ or sanitized.

SP-CMM1 is N/A, since a structured process is required to ensure all input handled by a web application is validated and/ or sanitized.

SP-CMM2 is N/A, since a well-defined process is required to ensure all input handled by a web application is validated and/ or sanitized.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure all input handled by a web application is validated and/ or sanitized.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure all input handled by a web application is validated and/ or sanitized.

null

I.1.16

null

1240

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Secure Web Traffic

WEB-10

Mechanisms exist to ensure all web application content is delivered using cryptographic mechanisms (e.g., TLS).

null

Does the organization ensure all web application content is delivered using cryptographic mechanisms (e?g?, TLS)?

9

Protect

null

X

There is no evidence of a capability to ensure all web application content is delivered using cryptographic mechanisms (e.g., TLS).

SP-CMM1 is N/A, since a structured process is required to ensure all web application content is delivered using cryptographic mechanisms (e.g., TLS).

SP-CMM2 is N/A, since a well-defined process is required to ensure all web application content is delivered using cryptographic mechanisms (e.g., TLS).

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure all web application content is delivered using cryptographic mechanisms (e.g., TLS).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure all web application content is delivered using cryptographic mechanisms (e.g., TLS).

null

I.3.6.1

null

2-12-1-1

null

1552

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Output Encoding

WEB-11

Mechanisms exist to ensure output encoding is performed on all content produced by a web application to reduce the likelihood of cross-site scripting and other injection attacks.

null

Does the organization ensure output encoding is performed on all content produced by a web application to reduce the likelihood of cross-site scripting and other injection attacks?

9

Protect

null

X

There is no evidence of a capability to ensure output encoding is performed on all content produced by a web application to reduce the likelihood of cross-site scripting and other injection attacks.

SP-CMM1 is N/A, since a structured process is required to ensure output encoding is performed on all content produced by a web application to reduce the likelihood of cross-site scripting and other injection attacks.

SP-CMM2 is N/A, since a well-defined process is required to ensure output encoding is performed on all content produced by a web application to reduce the likelihood of cross-site scripting and other injection attacks.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure output encoding is performed on all content produced by a web application to reduce the likelihood of cross-site scripting and other injection attacks.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure output encoding is performed on all content produced by a web application to reduce the likelihood of cross-site scripting and other injection attacks.

null

C.1.8

null

1241

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Web Browser Security

WEB-12

Mechanisms exist to ensure web applications implement Content-Security-Policy, HSTS and X-Frame-Options response headers to protect both the web application and its users.

null

Does the organization ensure web applications implement Content-Security-Policy, HSTS and X-Frame-Options response headers to protect both the web application and its users?

9

Protect

null

X

There is no evidence of a capability to ensure web applications implement Content-Security-Policy, HSTS and X-Frame-Options response headers to protect both the web application and its users.

SP-CMM1 is N/A, since a structured process is required to ensure web applications implement Content-Security-Policy, HSTS and X-Frame-Options response headers to protect both the web application and its users.

SP-CMM2 is N/A, since a well-defined process is required to ensure web applications implement Content-Security-Policy, HSTS and X-Frame-Options response headers to protect both the web application and its users.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure web applications implement Content-Security-Policy, HSTS and X-Frame-Options response headers to protect both the web application and its users.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure web applications implement Content-Security-Policy, HSTS and X-Frame-Options response headers to protect both the web application and its users.

null

2-12-1-1

null

1424

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Web Security

Website Change Detection

WEB-13

Mechanisms exist to detect and respond to Indicators of Compromise (IoC) for unauthorized alterations, additions, deletions or changes on websites that store, process and/or transmit sensitive / regulated data.

null

Does the organization detect and respond to Indicators of Compromise (IoC) for unauthorized alterations, additions, deletions or changes on websites that store, process and/or transmit sensitive / regulated data?

8

Detect

null

X

There is no evidence of a capability to detect and respond to Indicators of Compromise (IoC) for unauthorized alterations, additions, deletions or changes on websites that store, process and/ or transmit sensitive / regulated data.

SP-CMM1 is N/A, since a structured process is required to detect and respond to Indicators of Compromise (IoC) for unauthorized alterations, additions, deletions or changes on websites that store, process and/ or transmit sensitive / regulated data.

SP-CMM2 is N/A, since a well-defined process is required to detect and respond to Indicators of Compromise (IoC) for unauthorized alterations, additions, deletions or changes on websites that store, process and/ or transmit sensitive / regulated data.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to detect and respond to Indicators of Compromise (IoC) for unauthorized alterations, additions, deletions or changes on websites that store, process and/ or transmit sensitive / regulated data.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to detect and respond to Indicators of Compromise (IoC) for unauthorized alterations, additions, deletions or changes on websites that store, process and/ or transmit sensitive / regulated data.

null

11.6 11.6.1

11.6.1

null

11.6.1

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

MT-8 MT-9 MT-12 MT-13 MT-14 MT-15

null

MT-8

MT-9

null

MT-12

MT-13

MT-14

MT-15

null

Web Security

Publicly Accessible Content Reviews

WEB-14

Mechanisms exist to routinely review the content on publicly accessible systems for sensitive/regulated data and remove such information, if discovered.

null

Does the organization routinely review the content on publicly accessible systems for sensitive/regulated data and remove such information, if discovered?

7

Identify

null

X

null

There is no evidence of a capability to routinely review the content on publicly accessible systems for sensitive/regulated data and remove such information, if discovered.

SP-CMM1 is N/A, since a structured process is required to routinely review the content on publicly accessible systems for sensitive/regulated data and remove such information, if discovered.

SP-CMM2 is N/A, since a well-defined process is required to routinely review the content on publicly accessible systems for sensitive/regulated data and remove such information, if discovered.

Web Security (WEB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Validated Architecture Design Review (VADR) evaluates Internet-facing design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A change notification capability exists to scan web pages for changes, which are reviewed by appropriate personnel to determine if changes are authorized or unuathorized. • Ongoing content reviews are performed to ensure web pages do not contain non-public information. • Security engineering, or a similar function, ensures that Internet-facing devices conform to industry-recognized standards for configuration hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. This includes creating special hardening requirements for High-Value Assets (HVAs). • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for Internet-facing technologies. • Technologies are configured to implement Strong Customer Authentication (SCA) for consumers to prove their identity. • Administrative processes exist and technologies are configured to provide Internet-facing individuals (e.g., customers, users, clients, etc.) with clear and precise information about cookies, in accordance with regulatory requirements for cookie management. • An IT Asset Management (ITAM) function, or similar function, categorizes network devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • Boundary protections: o Utilize Web Application Firewalls (WAFs) to provide defense-in-depth protection for application-specific threats. o Restrict inbound traffic to authorized devices on certain services, protocols and ports.

Web Security (WEB) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity & data privacy controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to routinely review the content on publicly accessible systems for sensitive/regulated data and remove such information, if discovered.

null

3.1.22.b

null

A.03.01.22.b[01] A.03.01.22.b[02]

null

R-AC-4 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-4 R-GV-6 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

null

R-AC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

null

R-GV-4

null

R-GV-6

null

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

null

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

- New control