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

Business Continuity & Disaster Recovery

Isolated Recovery Environment

BCD-14

Mechanisms exist to utilize an isolated, non-production environment to perform data backup and recovery operations through offline, cloud or off-site capabilities.

null

Does the organization utilize an isolated, non-production environment to perform data backup and recovery operations through offline, cloud or off-site capabilities?

5

Recover

X

There is no evidence of a capability to utilize an isolated, non-production environment to perform data backup and recovery operations through offline, cloud or off-site capabilities.

SP-CMM1 is N/A, since a structured process is required to utilize an isolated, non-production environment to perform data backup and recovery operations through offline, cloud or off-site capabilities.

Business Continuity & Disaster Recovery (BCD) 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: • Business Continuity / Disaster Recovery (BC/DR) 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for BC/DR management. • BC/DR roles are formally assigned as an additional duty to existing IT/cybersecurity personnel. • Recovery Time Objectives (RTOs) identify business-critical systems and services, which are given priority of service in alternate processing and storage sites. • IT personnel develop Disaster Recovery Plans (DRP) to recover business-critical systems and services. • Data/process owners conduct a Business Impact Analysis (BIA) at least annually, or after any major technology or process change, to identify assets critical to the business in need of protection, as well as single points of failure. • IT/cybersecurity personnel work with business stakeholders to develop Business Continuity Plans (BCPs) to ensure business functions are sustainable both during and after an incident within Recovery Time Objectives (RTOs). • IT personnel use a backup methodology (e.g., grandfather, father & s on rotation) to store backups in a secondary location, separate from the primary storage site. • IT personnel configure business-critical systems to transfer backup data to the alternate storage site at a rate that is capable of meeting Recovery Time Objectives (RTOs) and Recovery Point Objectives (RPOs). • IT personnel maintain technologies that are compatible with existing network and infrastructure configuration.

Business Continuity & Disaster Recovery (BCD) 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 formal Business Continuity & Disaster Recovery (BC/DR) program exists with defined roles and responsibilities to restore functionality in the event of a catastrophe, emergency, or significant disruptive incident that is handled in accordance with the Continuity of Operations Plan (COOP). • BC/DR personnel work with business stakeholders to identify business-critical systems, services, internal teams and third-party service providers. • Application/system/process owners conduct a Business Impact Analysis (BIA) at least annually, or after any major technology or process change, to identify assets critical to the business in need of protection, as well as single points of failure. • Recovery Time Objectives (RTOs) are defined. • Recovery Point Objectives (RPOs) are defined. • Controls are assigned to sensitive/regulated assets to comply with specific BC/DR requirements to facilitate recovery operations in accordance with RTOs and RPOs. • IT personnel work with business stakeholders to develop Disaster Recovery Plans (DRP) to recover business-critical systems and services within RPOs. • Business stakeholders work with IT personnel to develop Business Continuity Plans (BCPs) to ensure business functions are sustainable both during and after an incident within RTOs. • The data backup function is formally assigned with defined roles and responsibilities. • Recoveries are performed into an isolated, non-production environment. • Logical and physical access controls restricts access to backup and restoration hardware. • IT personnel maintain technologies that are compatible with existing network and infrastructure configuration.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to utilize an isolated, non-production environment to perform data backup and recovery operations through offline, cloud or off-site capabilities.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize an isolated, non-production environment to perform data backup and recovery operations through offline, cloud or off-site capabilities.

null

11.4

null

RC.RP-03

null

K.1

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-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

Business Continuity & Disaster Recovery

Reserve Hardware

BCD-15

Mechanisms exist to purchase and maintain a sufficient reserve of spare hardware to ensure essential missions and business functions can be maintained in the event of a supply chain disruption.

null

Does the organization purchase and maintain a sufficient reserve of spare hardware to ensure essential missions and business functions can be maintained in the event of a supply chain disruption?

7

Recover

X

null

There is no evidence of a capability to purchase and maintain a sufficient reserve of spare hardware to ensure essential missions and business functions can be maintained in the event of a supply chain disruption.

SP-CMM1 is N/A, since a structured process is required to purchase and maintain a sufficient reserve of spare hardware to ensure essential missions and business functions can be maintained in the event of a supply chain disruption.

SP-CMM2 is N/A, since a well-defined process is required to purchase and maintain a sufficient reserve of spare hardware to ensure essential missions and business functions can be maintained in the event of a supply chain disruption.

Business Continuity & Disaster Recovery (BCD) 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 formal Business Continuity & Disaster Recovery (BC/DR) program exists with defined roles and responsibilities to restore functionality in the event of a catastrophe, emergency, or significant disruptive incident that is handled in accordance with the Continuity of Operations Plan (COOP). • BC/DR personnel work with business stakeholders to identify business-critical systems, services, internal teams and third-party service providers. • Application/system/process owners conduct a Business Impact Analysis (BIA) at least annually, or after any major technology or process change, to identify assets critical to the business in need of protection, as well as single points of failure. • Recovery Time Objectives (RTOs) are defined. • Recovery Point Objectives (RPOs) are defined. • Controls are assigned to sensitive/regulated assets to comply with specific BC/DR requirements to facilitate recovery operations in accordance with RTOs and RPOs. • IT personnel work with business stakeholders to develop Disaster Recovery Plans (DRP) to recover business-critical systems and services within RPOs. • Business stakeholders work with IT personnel to develop Business Continuity Plans (BCPs) to ensure business functions are sustainable both during and after an incident within RTOs. • The data backup function is formally assigned with defined roles and responsibilities. • Based on the criticality of the asset, the organization purchases and maintains a sufficient reserve of spare hardware to ensure essential equipment can be maintained in the event of supply chain disruptions. • Within the BCPs, alternate communications channels have been defined and alternative decision-makers are designated if primary decision-makers are unavailable.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to purchase and maintain a sufficient reserve of spare hardware to ensure essential missions and business functions can be maintained in the event of a supply chain disruption.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to purchase and maintain a sufficient reserve of spare hardware to ensure essential missions and business functions can be maintained in the event of a supply chain disruption.

null

B5.b

null

1789

null

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

null

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

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

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

Business Continuity & Disaster Recovery

AI & Autonomous Technologies Incidents

BCD-16

Mechanisms exist to handle failures or incidents with Artificial Intelligence (AI) and Autonomous Technologies (AAT) deemed to be high-risk.

null

Does the organization handle failures or incidents with Artificial Intelligence (AI) and Autonomous Technologies (AAT) deemed to be high-risk?

10

Respond

X

There is no evidence of a capability to handle failures or incidents with Artificial Intelligence (AI) and Autonomous Technologies (AAT) deemed to be high-risk.

SP-CMM1 is N/A, since a structured process is required to handle failures or incidents with Artificial Intelligence (AI) and Autonomous Technologies (AAT) deemed to be high-risk.

SP-CMM2 is N/A, since a well-defined process is required to handle failures or incidents with Artificial Intelligence (AI) and Autonomous Technologies (AAT) deemed to be high-risk.

Business Continuity & Disaster Recovery (BCD) 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 formal Business Continuity & Disaster Recovery (BC/DR) program exists with defined roles and responsibilities to restore functionality in the event of a catastrophe, emergency, or significant disruptive incident that is handled in accordance with the Continuity of Operations Plan (COOP). • BC/DR personnel work with business stakeholders to identify business-critical systems, services, internal teams and third-party service providers. • Application/system/process owners conduct a Business Impact Analysis (BIA) at least annually, or after any major technology or process change, to identify assets critical to the business in need of protection, as well as single points of failure. • Recovery Time Objectives (RTOs) are defined. • Recovery Point Objectives (RPOs) are defined. • Controls are assigned to sensitive/regulated assets to comply with specific BC/DR requirements to facilitate recovery operations in accordance with RTOs and RPOs. • IT personnel work with business stakeholders to develop Disaster Recovery Plans (DRP) to recover business-critical systems and services within RPOs. • Business stakeholders work with IT personnel to develop Business Continuity Plans (BCPs) to ensure business functions are sustainable both during and after an incident within RTOs. • The data backup function is formally assigned with defined roles and responsibilities.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to handle failures or incidents with Artificial Intelligence (AI) and Autonomous Technologies (AAT) deemed to be high-risk.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to handle failures or incidents with Artificial Intelligence (AI) and Autonomous Technologies (AAT) deemed to be high-risk.

null

GOVERN 6.2

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-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

Capacity & Performance Planning

Capacity & Performance Management

CAP-01

Mechanisms exist to facilitate the implementation of capacity management controls to ensure optimal system performance to meet expected and anticipated future capacity requirements.

- Splunk - Resource monitoring

null

Does the organization facilitate the implementation of capacity management controls to ensure optimal system performance to meet expected and anticipated future capacity requirements?

8

Protect

null

X

null

There is no evidence of a capability to facilitate the implementation of capacity management controls to ensure optimal system performance to meet expected and anticipated future capacity requirements.

Capability & Performance Planning (CAP) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel work with business stakeholders to identify business-critical systems and services. • IT personnel work with business stakeholders to identify growth requirements and add capacity accordingly.

Capability & Performance Planning (CAP) 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: • Capacity 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for capability management. • IT personnel work with: o Business stakeholders to identify business-critical systems and services. o Business stakeholders to identify single points of failure from a system/applications/services perspective. • IT infrastructure personnel: o Create and maintain infrastructure performance metrics to understand current resource needs. o Deploy preventative technologies to minimize the effect of Denial of Service (DoS) attacks against business-critical services.

Capability & Performance Planning (CAP) 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 provide guidance for capacity and performance planning 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 organization. This CONOPS for capacity and performance planning may be incorporated as part of a broader operational plan for the cybersecurity & data privacy program. • A Governance, Risk & Compliance (GRC) team, 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. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program and establishes a clear and authoritative accountability structure for capacity and performance planning operations. • IT personnel work with business stakeholders to identify business-critical systems and services, as part of the organization’s IT Asset Management (ITAM) program. • Automated tools continuously monitor the operating state and health status of systems/applications/services. • Business stakeholders conduct a Business Impact Analysis (BIA) to determine acceptable downtime constraints and any dependencies between applications or systems, to objectively determine the criticality of systems, applications or services, as well as the order is which systems need to be restored. • Demand is managed for computing resources based on BIA-defined prioritization. • Based on BIA results, IT infrastructure personnel deploy preventative technologies to minimize the effect of Denial of Service (DoS) attacks. • IT architects identify appropriate solutions to make sure service levels can be met. • IT infrastructure personnel: o Create an annual infrastructure growth plan with input from both technology and business stakeholders. o Create and maintain infrastructure performance metrics to understand current resource needs. o Produce a capacity plan that covers current use, forecasted needs and support costs for new systems, applications and services. • Automated tools continuously monitor the operating state and health status of systems, applications and services. • IT personnel work with business stakeholders to identify single points of failure from a system/applications/services perspective.

Capability & Performance Planning (CAP) 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 capacity management controls to ensure optimal system performance to meet expected and anticipated future capacity requirements.

A1.1

A1.1-POF1 A1.1-POF3

null

IVS-02

SNT-03

null

CR 7.2 (11.4.1)

null

12.1.3

8.6

12.1.3

null

6.9.1.3

null

T1564.009

null

PR.DS-P4

null

SC-5 SC-5(3)

SC-5

SC-5 SC-5(3)

null

SC-5

SC-5(3)

null

SC-5

null

PR.DS-4

PR.IR-03 PR.IR-04

null

K.1

null

SC-5

null

SC-5

null

D5.IR.Pl.B.5 D5.IR.Pl.B.6 D5.IR.Pl.E.3 D3.PC.Im.E.4

null

8-701

null

SC-5

null

SC-5

null

3.5(56)

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

8.8

OPS-01 OPS-02 OPS-03

null

25.2

null

Sec 19.1 Sec 19.2

null

7.1.4 [OP.PL.4]

null

1579 1580 1581

null

12.1.3 12.1.3.9.PB

null

8.1.1

null

6.1

null

x

null

x

R-AM-3 R-BC-1 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-4 R-GV-5 R-SA-1

null

R-AM-3

R-BC-1

null

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

null

R-GV-4

R-GV-5

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 MT-15 MT-16

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

MT-16

null

Capacity & Performance Planning

Resource Priority

CAP-02

Mechanisms exist to control resource utilization of systems that are susceptible to Denial of Service (DoS) attacks to limit and prioritize the use of resources.

- Splunk - Resource monitoring

null

Does the organization control resource utilization of systems that are susceptible to Denial of Service (DoS) attacks to limit and prioritize the use of resources?

8

Protect

null

X

null

There is no evidence of a capability to control resource utilization of systems that are susceptible to Denial of Service (DoS) attacks to limit and prioritize the use of resources.

SP-CMM1 is N/A, since a structured process is required to control resource utilization of systems that are susceptible to Denial of Service (DoS) attacks to limit and prioritize the use of resources.

Capability & Performance Planning (CAP) 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: • Capacity 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for capability management. • IT personnel work with: o Business stakeholders to identify business-critical systems and services. o Business stakeholders to identify single points of failure from a system/applications/services perspective. • IT infrastructure personnel: o Create and maintain infrastructure performance metrics to understand current resource needs. o Deploy preventative technologies to minimize the effect of Denial of Service (DoS) attacks against business-critical services.

Capability & Performance Planning (CAP) 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: • IT personnel work with business stakeholders to identify business-critical systems and services, as part of the organization’s IT Asset Management (ITAM) program. • Automated tools continuously monitor the operating state and health status of systems/applications/services. • Business stakeholders conduct a Business Impact Analysis (BIA) to determine acceptable downtime constraints and any dependencies between applications or systems, to objectively determine the criticality of systems, applications or services, as well as the order is which systems need to be restored. • Demand is managed for computing resources based on BIA-defined prioritization. • Based on BIA results, IT infrastructure personnel deploy preventative technologies to minimize the effect of Denial of Service (DoS) attacks. • IT architects identify appropriate solutions to make sure service levels can be met. • IT infrastructure personnel: o Create an annual infrastructure growth plan with input from both technology and business stakeholders. o Create and maintain infrastructure performance metrics to understand current resource needs. o Produce a capacity plan that covers current use, forecasted needs and support costs for new systems, applications and services. • Automated tools continuously monitor the operating state and health status of systems, applications and services.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to control resource utilization of systems that are susceptible to Denial of Service (DoS) attacks to limit and prioritize the use of resources.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to control resource utilization of systems that are susceptible to Denial of Service (DoS) attacks to limit and prioritize the use of resources.

A1.1

null

T1564.009

null

SC-5 SC-5(1) SC-5(2) SC-6

SC-5

SC-5 SC-5(1) SC-5(2) SC-6

null

SC-5

SC-5(1) SC-5(2) SC-6

null

SC-5

null

SC-5(2)

null

SC-5(2)

null

N.1

null

SC-5 SC-6

null

SC-5 SC-6

SC-5

SC-5 SC-6

SC-5

null

SC-5

SC-5 SC-6

null

SC-5

SC-5 SC-6

null

1579 1580 1581

null

x

R-AM-3 R-BC-1 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-4 R-GV-5 R-SA-1

null

R-AM-3

R-BC-1

null

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

null

R-GV-4

R-GV-5

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 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

Capacity & Performance Planning

Capacity Planning

CAP-03

Mechanisms exist to conduct capacity planning so that necessary capacity for information processing, telecommunications and environmental support will exist during contingency operations.

null

Does the organization conduct capacity planning so that necessary capacity for information processing, telecommunications and environmental support will exist during contingency operations?

8

Protect

null

X

There is no evidence of a capability to conduct capacity planning so that necessary capacity for information processing, telecommunications and environmental support will exist during contingency operations.

Capability & Performance Planning (CAP) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel work with business stakeholders to identify business-critical systems and services. • IT personnel work with business stakeholders to identify growth requirements and add capacity accordingly.

Capability & Performance Planning (CAP) 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: • Capacity 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for capability management. • IT personnel work with: o Business stakeholders to identify business-critical systems and services. o Business stakeholders to identify single points of failure from a system/applications/services perspective. • IT infrastructure personnel: o Create and maintain infrastructure performance metrics to understand current resource needs. o Deploy preventative technologies to minimize the effect of Denial of Service (DoS) attacks against business-critical services.

Capability & Performance Planning (CAP) 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: • IT personnel work with business stakeholders to identify business-critical systems and services, as part of the organization’s IT Asset Management (ITAM) program. • Automated tools continuously monitor the operating state and health status of systems/applications/services. • Business stakeholders conduct a Business Impact Analysis (BIA) to determine acceptable downtime constraints and any dependencies between applications or systems, to objectively determine the criticality of systems, applications or services, as well as the order is which systems need to be restored. • Demand is managed for computing resources based on BIA-defined prioritization. • Based on BIA results, IT infrastructure personnel deploy preventative technologies to minimize the effect of Denial of Service (DoS) attacks. • IT architects identify appropriate solutions to make sure service levels can be met. • IT infrastructure personnel: o Create an annual infrastructure growth plan with input from both technology and business stakeholders. o Create and maintain infrastructure performance metrics to understand current resource needs. o Produce a capacity plan that covers current use, forecasted needs and support costs for new systems, applications and services. • Automated tools continuously monitor the operating state and health status of systems, applications and services.

Capability & Performance Planning (CAP) 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 capacity planning so that necessary capacity for information processing, telecommunications and environmental support will exist during contingency operations.

A1.1

A1.1-POF2

null

12.1.3

8.6

12.1.3

null

PR.DS-P4

null

SC-5 SC-5(2) CP-2(2)

SC-5

SC-5 CP-2(2)

CP-2(2) SC-5 SC-5(2)

null

SC-5

SC-5 CP-2(2)

SC-5(2)

null

SC-5

SC-5 CP-2(2)

null

SC-5(2) CP-2(2)

null

SC-5(2) CP-2(2)

CP-2(2)

null

PR.DS-4

null

N.1

null

CP-2(2) SC-5

null

CP-2(2) SC-5

SC-5

CP-2(2) SC-5

SC-5

CP-2(2) SC-5

SC-5

CP-2(2) SC-5

SC-5

null

CP-2(2)

null

SC-5

CP-2(2) SC-5

null

8.8

OPS-01 OPS-02 OPS-03

null

25.2

null

1579 1580 1581

null

12.1.3 12.1.3.9.PB

null

8.1.3

null

x

R-AM-3 R-BC-1 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-4 R-GV-5 R-SA-1

null

R-AM-3

R-BC-1

null

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

null

R-GV-4

R-GV-5

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 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

Capacity & Performance Planning

Performance Monitoring

CAP-04

Automated mechanisms exist to centrally-monitor and alert on the operating state and health status of critical systems, applications and services.

null

Does the organization use automated mechanisms to centrally-monitor and alert on the operating state and health status of critical systems, applications and services?

7

Detect

null

X

There is no evidence of a capability to centrally-monitor and alert on the operating state and health status of critical systems, applications and services.

SP-CMM1 is N/A, since a structured process is required to centrally-monitor and alert on the operating state and health status of critical systems, applications and services.

Capability & Performance Planning (CAP) 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: • Capacity 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for capability management. • IT personnel work with: o Business stakeholders to identify business-critical systems and services. o Business stakeholders to identify single points of failure from a system/applications/services perspective. • IT infrastructure personnel: o Create and maintain infrastructure performance metrics to understand current resource needs. o Deploy preventative technologies to minimize the effect of Denial of Service (DoS) attacks against business-critical services.

Capability & Performance Planning (CAP) 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: • IT personnel work with business stakeholders to identify business-critical systems and services, as part of the organization’s IT Asset Management (ITAM) program. • Automated tools continuously monitor the operating state and health status of systems/applications/services. • Business stakeholders conduct a Business Impact Analysis (BIA) to determine acceptable downtime constraints and any dependencies between applications or systems, to objectively determine the criticality of systems, applications or services, as well as the order is which systems need to be restored. • Demand is managed for computing resources based on BIA-defined prioritization. • IT architects identify appropriate solutions to make sure service levels can be met. • IT infrastructure personnel: o Create an annual infrastructure growth plan with input from both technology and business stakeholders. o Create and maintain infrastructure performance metrics to understand current resource needs. o Produce a capacity plan that covers current use, forecasted needs and support costs for new systems, applications and services. • Automated tools continuously monitor the operating state and health status of systems, applications and services.

Capability & Performance Planning (CAP) 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-monitor and alert on the operating state and health status of critical systems, applications and services.

null

A1.1-POF1

null

SNT-03

null

N.1

null

8.8

null

3.1

null

R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-EX-6 R-GV-1 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

null

R-EX-6

null

R-GV-1

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-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-10 MT-11 MT-12 MT-13 MT-14

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

MT-10

MT-11

MT-12

MT-13

MT-14

null

Change Management

Change Management Program

CHG-01

Mechanisms exist to facilitate the implementation of a change management program.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - VisibleOps methodology - ITIL infrastructure library - NNT Change Tracker (https://www.newnettechnologies.com) - ServiceNow (https://www.servicenow.com/) - Remedy - Tripwire Enterprise (https://www.tripwire.com/products/tripwire-enterprise/) - Chef (https://www.chef.io/) (https://www.chef.io/) - Puppet (https://puppet.com/)

E-CHG-02

Does the organization facilitate the implementation of a change management program?

10

Protect

null

X

There is no evidence of a capability to facilitate the implementation of a change management program.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Requests for Change (RFC) are submitted to IT personnel. • prior to changes being made, RFCs are informally reviewed for cybersecurity & data privacy ramifications. • Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly.

Change Management (CHG) 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 Change Management (CM) 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 organization, including CM as part of a broader operational plan. • A Governance, Risk & Compliance (GRC) team, 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 CM. • A steering committee is formally established, to provide executive oversight of the cybersecurity & data privacy program, including CM, which establishes a clear and authoritative accountability structure for CM operations. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible.

Change Management (CHG) 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 a change management program.

CC3.4 CC8.1

CC2.2-POF11 CC6.8-POF3 CC8.1-POF1 CC8.1-POF2 CC8.1-POF3 CC8.1-POF4 CC8.1-POF5 CC8.1-POF6 CC8.1-POF7 CC8.1-POF8 CC8.1-POF9 CC8.1-POF10 CC8.1-POF11 CC8.1-POF12 CC8.1-POF13 CC8.1-POF14 CC8.1-POF15

null

Principle 9 Principle 15

CCC-01 CEK-06 CEK-06

CCM-02 CCM-08

SO14

null

6.3

12.1.2

8.19 8.32

12.1.2

null

6.9.1.2

null

T1021.005, T1059.006, T1176, T1195.003, T1213, T1213.001, T1213.002, T1495, T1542, T1542.001, T1542.003, T1542.004, T1542.005, T1543, T1543.002, T1547.007, T1547.011, T1547.013, T1553, T1553.006, T1564.008, T1601, T1601.001, T1601.002

TS-2.6 TS-5.0

Sec 4(D)(2)(f)

null

PR.PO-P2

null

CM-3

null

CM-3

null

CM-3

null

CM-3

3.4.10 3.4.13

CM-3

null

CM-3

null

CM-3

3.4.3

3.4.2.b 3.4.3.a 3.4.3.b 3.4.3.c 3.4.3.d

null

A.03.04.03.b[01] A.03.04.03.b[02]

3.4.1e 3.4.2e

null

PR.IP-3

null

1.2.2 6.5 6.5.1 6.5.2 6.5.3

null

1.2.2 6.5.1 6.5.2

null

6.5.1 6.5.2

null

1.2.2 6.5.1 6.5.2 6.5.3

null

G.1

null

5.2 5.2.1

null

ASSET-4.A.MIL1 ASSET-4.G.MIL2 ARCHITECTURE-5.H.MIL3

ADM:SG3.SP2 TM:SG4.SP2 TM:SG4.SP3

null

CM.L2-3.4.3

TBD - 3.4.1e TBD - 3.4.2e

null

CM.L2-3.4.3

CM.L2-3.4.3 CM.L3-3.4.1e CM.L3-3.4.2e

CM-3

null

§ 11.10 § 11.10(k) § 11.10(k)(1) § 11.10(k)(2)

CM-3

null

CM-3

null

CM-3

null

CM-3

null

314.4(c)(7)

null

CM-3

null

CIP-010-2 R1

8-103 8-104 8-311 8-610

4.3

null

CM-3

null

38-99-20(D)(2)(f)

null

CM-3

null

3.4.4(37) 3.6.3(75) 3.6.3(76)

Art 9.4(e)

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

8.4

DEV-03 DEV-08

null

10.6 14.6 14.7

null

3.3.7

1-6-2

1-5 1-5-1 1-5-2

null

Sec 19.1 Sec 19.2

null

7.3.5 [OP.EXP.5]

null

1211

null

12.1.2 12.1.2.11.PB

null

6.3.6.C.01

null

7.5.1 7.5.2 7.5.3 7.5.4 7.5.5 7.5.6 7.5.7

null

6.1

null

4.17 4.20 6.11

2.5.1

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-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-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

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Change Management

Configuration Change Control

CHG-02

Mechanisms exist to govern the technical configuration change control processes.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Change Control Board (CCB) - Configuration Management Database (CMDB) - Tripwire Enterprise (https://www.tripwire.com/products/tripwire-enterprise/) Enterprise - Chef (https://www.chef.io/) (https://www.chef.io/) - Puppet (https://puppet.com/) - Solarwinds (https://www.solarwinds.com/) - Docker (https://www.docker.com/) - VisibleOps methodology - ITIL infrastructure library

E-CHG-02

Does the organization govern the technical configuration change control processes?

8

Protect

null

X

There is no evidence of a capability to govern the technical configuration change control processes.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Requests for Change (RFC) are submitted to IT personnel. • prior to changes being made, RFCs are informally reviewed for cybersecurity & data privacy ramifications. • Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly. • Asset custodians are assigned responsibilities that cover change management duties, including privileged access to perform change management actions.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • Asset custodians are assigned responsibilities that cover change management duties, including privileged access to perform change management actions.

Change Management (CHG) 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 govern the technical configuration change control processes.

CC3.4 CC8.1

CC6.8-POF3 CC8.1-POF1 CC8.1-POF2 CC8.1-POF3 CC8.1-POF4 CC8.1-POF5 CC8.1-POF6 CC8.1-POF7 CC8.1-POF8 CC8.1-POF9 CC8.1-POF10 CC8.1-POF11 CC8.1-POF12 CC8.1-POF13 CC8.1-POF14 CC8.1-POF15

null

Principle 9

CCC-02 CCC-05 CEK-05

CCM-02 CCM-08 GVN-05

SO14

null

12.1.2 14.2.2

8.19 8.32

12.1.2 14.2.2

null

6.11.2.2

null

T1021.005, T1059.006, T1176, T1195.003, T1213, T1213.001, T1213.002, T1495, T1542, T1542.001, T1542.003, T1542.004, T1542.005, T1543, T1543.002, T1547.007, T1547.011, T1547.013, T1553, T1553.006, T1564.008, T1601, T1601.001, T1601.002

TS-2.6

Sec 4(D)(2)(f)

null

PR.PO-P2

null

CM-3

null

CM-3

CM-3 SA-8(31)

null

CM-3

SA-8(31)

null

CM-3

3.4.10 3.4.13

CM-3

null

CM-3

null

CM-3

3.4.3

3.4.2.b 3.4.3.a 3.4.3.b 3.4.3.c 3.4.3.d

3.4.3[a] 3.4.3[b] 3.4.3[c] 3.4.3[d]

null

3.4.1e 3.4.2e

null

PR.IP-3

null

6.4 6.4.1 6.4.2 6.4.3 6.4.4 6.4.5 6.4.5.1 6.4.5.2 6.4.5.3 6.4.5.4 6.4.6

1.2.2 6.5 6.5.1 6.5.6

null

6.5.1

null

6.5.1

null

6.5.1 6.5.6

null

G.1.3.7

null

5.2.1

null

ASSET-4.B.MIL1 ASSET-4.E.MIL2

ADM:SG3.SP2 TM:SG4.SP2 TM:SG4.SP3

2.1

null

CM.L2-3.4.3

CM.L2-3.4.3 TBD - 3.4.1e TBD - 3.4.2e

null

CM.L2-3.4.3

CM.L2-3.4.3 CM.L3-3.4.1e CM.L3-3.4.2e

CM-3

null

§ 11.10 § 11.10(k) § 11.10(k)(1) § 11.10(k)(2)

CM-3

null

CM-3

null

CM-3

null

CM-3

null

D1.G.IT.B.4

null

314.4(c)(7)

null

CM-3

null

8-103 8-104 8-311 8-610

null

CM-3

null

38-99-20(D)(2)(f)

null

CM-3

null

3.4.4(37) 3.6.3(75) 3.6.3(76)

Art 9.4(e)

null

8.5

DEV-08

null

10.6 14.7

null

TPC-73

null

1-6-3-5

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

null

1211

null

12.1.2 12.1.2.11.PB 14.2.2

null

6.3.6.C.02 6.3.7.C.01 6.3.7.C.02 6.3.7.C.03

null

4.18 4.20

2.5.1 2.5.3

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-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-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

Change Management

Prohibition Of Changes

CHG-02.1

Mechanisms exist to prohibit unauthorized changes, unless organization-approved change requests are received.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - VisibleOps methodology - ITIL infrastructure library - Manual processes/workflows - Application whitelisting

null

Does the organization prohibit unauthorized changes, unless organization-approved change requests are received?

10

Protect

null

X

There is no evidence of a capability to prohibit unauthorized changes, unless organization-approved change requests are received.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Requests for Change (RFC) are submitted to IT personnel. • prior to changes being made, RFCs are informally reviewed for cybersecurity & data privacy ramifications. • Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change. • Copying, deleting, moving and renaming operations are version controlled.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly. • Asset custodians are assigned responsibilities that cover change management duties, including privileged access to perform change management actions.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • Asset custodians are assigned responsibilities that cover change management duties, including privileged access to perform change management actions. • File Integrity Monitoring (FIM) alerts are investigated for unauthorized changes. • FIM alerts are investigated for unauthorized changes and are configured to implement remediation actions up on the detection of unauthorized baseline configurations change(s). • FIM is deployed on systems that store, process or transmit sensitive/regulated/regulated data to monitor the integrity of business-critical files for tampering. • Endpoint technologies detect and report changes with a centralized Change Management (CM) service to discover unauthorized changes.

Change Management (CHG) 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 prohibit unauthorized changes, unless organization-approved change requests are received.

CC6.8

null

CCC-03 CCC-04

GVN-05

null

TS-2.6

null

CM-3(1)

null

CM-3(1)

null

CM-3(1)

null

CM-3(1)

null

CM-3(1)

null

CM-3(1)

null

3.4.2.b

null

1.2.2 6.5 6.5.1

null

1.2.2 6.5.1

null

6.5.1

null

1.2.2 6.5.1

null

G.1.3.8

null

5.2.1

null

ASSET-4.E.MIL2 ARCHITECTURE-5.H.MIL3

null

CM-3(1)

null

CM-3(1)

null

CM-3(1)

null

CM-3(1)

null

4.3

null

3.4.4(37) 3.6.3(75) 3.6.3(76)

null

IDM-02

null

14.7

null

TPC-73

null

1-5-3-4

null

7.5.4

null

2.5.1 2.5.2

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-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-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

Change Management

Test, Validate & Document Changes

CHG-02.2

Mechanisms exist to appropriately test and document proposed changes in a non-production environment before changes are implemented in a production environment.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - VisibleOps methodology - ITIL infrastructure library - NNT Change Tracker (https://www.newnettechnologies.com) - VMware - Docker (https://www.docker.com/)

E-CHG-03

Does the organization appropriately test and document proposed changes in a non-production environment before changes are implemented in a production environment?

9

Protect

null

X

There is no evidence of a capability to appropriately test and document proposed changes in a non-production environment before changes are implemented in a production environment.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Requests for Change (RFC) are submitted to IT personnel. • prior to changes being made, RFCs are informally reviewed for cybersecurity & data privacy ramifications. • Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change. • IT personnel use an informal process to verify the functionality of security controls when anomalies or misconfigurations are discovered.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly. • Up on implementing the RFC, the technician implementing a change tests to ensure anti-malware, logging and other cybersecurity & data privacy controls are still implemented and operating properly. • Results from testing changes are documented. • Up on completing the RFC, the CAB reports the results of cybersecurity & data privacy function verification to senior management.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • Up on implementing the RFC, the technician implementing a change tests to ensure anti-malware, logging and other cybersecurity & data privacy controls are still implemented and operating properly. • Results from testing changes are documented. • A structured set of controls are tested after a change is implemented to ensure cybersecurity controls are operating properly. • Results from testing changes are documented. • CM leverages Information Technology Infrastructure Library (ITIL) Service Management practices to govern CM operations (includes SecDevOps considerations). • Up on completing the RFC, the CAB reports the results of cybersecurity & data privacy function verification to senior management. • Up on implementing the RFC, the technician implementing a change tests to ensure anti-malware, logging and other cybersecurity & data privacy controls are still implemented and operating properly. • A vulnerability assessment is conducted on systems/applications/services to detect any new vulnerabilities that a change may have introduced.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to appropriately test and document proposed changes in a non-production environment before changes are implemented in a production environment.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to appropriately test and document proposed changes in a non-production environment before changes are implemented in a production environment.

CC3.4 CC8.1

null

Principle 9

CCC-02

CCM-08

null

1.2.6

null

14.2.3

8.19 8.32

14.2.3

null

6.11.2.3

null

TS-5.0

null

CM-3(2) CM-5(2)

null

CM-3(2) CM-5(2)

CM-3(2) CM-3(7) SA-8(31)

null

CM-3(2)

CM-3(7) SA-8(31)

null

CM-3(2)

null

CM-3(2)

null

CM-3(2)

NFO - CM-3(2)

null

A.03.04.03.c[01] A.03.04.03.c[02]

null

6.5 6.5.1 6.5.2 A3.2.2.1

null

6.5.1 6.5.2

null

6.5.1 6.5.2

null

6.5.1 6.5.2

null

G.1.5

null

ASSET-4.B.MIL1 ASSET-4.C.MIL2 ASSET-4.D.MIL2 ASSET-4.E.MIL2 ASSET-4.F.MIL2 ASSET-4.G.MIL2 ASSET-4.H.MIL3 ASSET-4.I.MIL3

null

CM-3(2)

null

CM-3(2) CM-5(2)

null

CM-3(2) CM-5(2)

null

CM-3(2)

null

CM-3(2)

null

CM-3(2)

null

CM-3(2)

null

CM-3(2)

null

3.4.4(37) 3.6.3(75) 3.6.3(76)

null

DEV-06 DEV-08 DEV-09

null

10.6 12.21 12.30 14.6 14.8 14.9 14.10

null

1-3-1-2

TPC-73

null

1-6-2-1 1-6-3-5

1-5-3-2

null

14.2.3

null

6.3.8.C.01

null

7.4.2 7.5.3 7.5.5 7.5.7

null

6.11

2.5.3

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-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-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

Change Management

Cybersecurity & Data Privacy Representative for Asset Lifecycle Changes

CHG-02.3

Mechanisms exist to include a cybersecurity and/or data privacy representative in the configuration change control review process.

- Change Control Board (CCB) - Change Advisory Board (CAB) - VisibleOps methodology - ITIL infrastructure library

E-CHG-04

Does the organization include a cybersecurity and/or data privacy representative in the configuration change control review process?

7

Protect

null

X

There is no evidence of a capability to include a cybersecurity and/ or data privacy representative in the configuration change control review process.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Requests for Change (RFC) are submitted to IT personnel. • prior to changes being made, RFCs are informally reviewed for cybersecurity & data privacy ramifications. • Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible.

Change Management (CHG) 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 include a cybersecurity and/ or data privacy representative in the configuration change control review process.

CC3.4

null

Principle 9

null

CCM-08

null

CM-3(4)

null

CM-3(4)

null

CM-3(4)

null

CM-3(4)

null

CM-3(4)

null

CM-3(4)

null

3.4.4

null

G.1.10

null

ASSET-4.E.MIL2

null

CM-3(4)

null

CM-3(4)

null

CM-3(4)

null

CM-3(4)

null

CM-3(4)

null

3.4.4(37) 3.6.3(75) 3.6.3(76)

null

DEV-05 DEV-09

null

14.8

null

1-6-2-2

1-5-2

null

7.5.4

null

2.4 6.11

1.3.1

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-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

Change Management

Automated Security Response

CHG-02.4

Automated mechanisms exist to implement remediation actions upon the detection of unauthorized baseline configurations change(s).

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

null

Does the organization use automated mechanisms to implement remediation actions upon the detection of unauthorized baseline configurations change(s)?

5

Protect

null

X

There is no evidence of a capability to implement remediation actions up on the detection of unauthorized baseline configurations change(s).

SP-CMM1 is N/A, since a structured process is required to implement remediation actions up on the detection of unauthorized baseline configurations change(s).

SP-CMM2 is N/A, since a well-defined process is required to implement remediation actions up on the detection of unauthorized baseline configurations change(s).

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • File Integrity Monitoring (FIM) alerts are investigated for unauthorized changes. • FIM alerts are investigated for unauthorized changes and are configured to implement remediation actions up on the detection of unauthorized baseline configurations change(s). • FIM is deployed on systems that store, process or transmit sensitive/regulated/regulated data to monitor the integrity of business-critical files for tampering. • Endpoint technologies detect and report changes with a centralized Change Management (CM) service to discover unauthorized changes.

Change Management (CHG) 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 remediation actions up on the detection of unauthorized baseline configurations change(s).

null

CCC-04 CCC-06 CCC-09

GVN-05

null

CM-3(5)

null

CM-3(5)

null

CM-3(5)

null

3.4.2e

null

G.1.8

null

TBD - 3.4.2e

null

CM.L3-3.4.2e

null

1-5-4

null

x

R-AC-4 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 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-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

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

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

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

Change Management

Cryptographic Management

CHG-02.5

Mechanisms exist to govern assets involved in providing cryptographic protections according to the organization's configuration management processes.

null

Does the organization govern assets involved in providing cryptographic protections according to the organization's configuration management processes?

5

Protect

null

X

There is no evidence of a capability to govern assets involved in providing cryptographic protections according to the organization's configuration management processes.

SP-CMM1 is N/A, since a structured process is required to govern assets involved in providing cryptographic protections according to the organization's configuration management processes.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • Cryptographic primitives are employed to track file revisions and authentications.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to govern assets involved in providing cryptographic protections according to the organization's configuration management processes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to govern assets involved in providing cryptographic protections according to the organization's configuration management processes.

null

CM-3(6)

null

CM-3(6)

null

CM-3(6)

null

CM-3(6)

null

U.1.19

null

CM-3(6)

null

CM-3(6)

null

CM-3(6)

null

CM-3(6)

null

x

R-AC-1 R-AM-2 R-AM-3

R-AC-1

null

R-AM-2

R-AM-3

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

Change Management

Security Impact Analysis for Changes

CHG-03

Mechanisms exist to analyze proposed changes for potential security impacts, prior to the implementation of the change.

- VisibleOps methodology - ITIL infrastructure library - Change management software

null

Does the organization analyze proposed changes for potential security impacts, prior to the implementation of the change?

9

Protect

null

X

There is no evidence of a capability to analyze proposed changes for potential security impacts, prior to the implementation of the change.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Requests for Change (RFC) are submitted to IT personnel. • prior to changes being made, RFCs are informally reviewed for cybersecurity & data privacy ramifications. • Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • Up on implementing the RFC, the technician implementing a change tests to ensure anti-malware, logging and other cybersecurity & data privacy controls are still implemented and operating properly. • Results from testing changes are documented.

Change Management (CHG) 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 analyze proposed changes for potential security impacts, prior to the implementation of the change.

CC3.4

CC3.4-POF4

null

Principle 9

CCC-03 CCC-05

null

1.2.6

null

TS-5.0

null

CM-4

null

CM-4

3.4.10 3.4.13

CM-4

null

CM-4

3.4.4

A.03.04.04

null

6.4 6.4.1 6.4.2 6.4.3 6.4.4 6.4.5 6.4.5.1 6.4.5.2 6.4.5.3 6.4.5.4

6.5.2 6.5.6 A3.2.2 A3.2.3

null

6.5.2

null

6.5.2

null

6.5.2 6.5.6

null

G.1.7

null

ASSET-4.E.MIL2

TM:SG3.SP1 TM:SG4.SP3

null

CM.L2-3.4.4

null

CM.L2-3.4.4

CM-4

null

CM-4

null

CM-4

null

8-103 8-104 8-311 8-610

null

CM-4

null

CM-4

null

3.4.4(37) 3.6.3(75) 3.6.3(76)

null

DEV-05 BCM-02

null

10.6 14.8

null

1-3-1-2

null

1-5-2 1-5-4

null

21(d)

null

7.5.2

null

x

null

x

R-AC-4 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 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-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

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

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

Change Management

Access Restriction For Change

CHG-04

Mechanisms exist to enforce configuration restrictions in an effort to restrict the ability of users to conduct unauthorized changes.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - VisibleOps methodology - ITIL infrastructure library - Role-based permissions - Mandatory Access Control (MAC) - Application whitelisting

null

Does the organization enforce configuration restrictions in an effort to restrict the ability of users to conduct unauthorized changes?

8

Protect

null

X

There is no evidence of a capability to enforce configuration restrictions in an effort to restrict the ability of users to conduct unauthorized changes.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Requests for Change (RFC) are submitted to IT personnel. • prior to changes being made, RFCs are informally reviewed for cybersecurity & data privacy ramifications. • Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible.

Change Management (CHG) 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 enforce configuration restrictions in an effort to restrict the ability of users to conduct unauthorized changes.

null

CCC-04

null

T1003, T1003.001, T1003.002, T1003.003, T1003.004, T1003.005, T1003.006, T1003.007, T1003.008, T1021, T1021.001, T1021.002, T1021.003, T1021.004, T1021.005, T1021.006, T1047, T1053, T1053.001, T1053.002, T1053.003, T1053.005, T1053.006, T1053.007, T1055, T1055.008, T1056.003, T1059, T1059.001, T1059.006, T1059.008, T1072, T1078, T1078.002, T1078.003, T1078.004, T1098, T1098.001, T1098.002, T1098.003, T1134, T1134.001, T1134.002, T1134.003, T1136, T1136.001, T1136.002, T1136.003, T1137.002, T1176, T1185, T1190, T1195.003, T1197, T1210, T1213, T1213.001, T1213.002, T1218, T1218.007, T1222, T1222.001, T1222.002, T1484, T1489, T1495, T1505, T1505.002, T1525, T1528, T1530, T1537, T1542, T1542.001, T1542.003, T1542.004, T1542.005, T1543, T1543.001, T1543.002, T1543.003, T1543.004, T1546.003, T1547.003, T1547.004, T1547.006, T1547.007, T1547.009, T1547.011, T1547.012, T1547.013, T1548, T1548.002, T1548.003, T1550, T1550.002, T1550.003, T1552, T1552.002, T1552.007, T1553, T1553.006, T1556, T1556.001, T1556.003, T1556.004, T1558, T1558.001, T1558.002, T1558.003, T1559, T1559.001, T1562, T1562.001, T1562.002, T1562.004, T1562.006, T1562.007, T1562.008, T1562.009, T1563, T1563.001, T1563.002, T1564.008, T1569, T1569.001, T1569.002, T1574, T1574.005, T1574.010, T1574.011, T1574.012, T1578, T1578.001, T1578.002, T1578.003, T1599, T1599.001, T1601, T1601.001, T1601.002, T1611, T1619

null

CM-5

null

CM-5

null

CM-5

null

CM-5

3.4.10 3.4.13

CM-5

null

CM-5

3.4.5

3.4.2.b 3.4.5

3.4.5[a] 3.4.5[b] 3.4.5[c] 3.4.5[d] 3.4.5[e] 3.4.5[f] 3.4.5[g] 3.4.5[h]

A.03.04.05[01] A.03.04.05[02] A.03.04.05[03] A.03.04.05[04] A.03.04.05[05] A.03.04.05[06]

null

1.2.8

null

1.2.8

null

1.2.8

null

G.1.3.1

null

ASSET-4.E.MIL2 ARCHITECTURE-5.H.MIL3

TM:SG4.SP1

null

5.7.1

null

CM.L2-3.4.5

null

CM.L2-3.4.5

CM-5

null

CM-5

null

CM-5

null

CM-5

null

CM-5

null

8-311 8-610

null

CM-5

null

CM-5

null

CM-5

null

DEV-09

null

1-5-3-4

null

2.5.2

null

x

null

x

R-AC-1 R-AC-2 R-AC-4 R-AM-2 R-AM-3

R-AC-1

R-AC-2

null

R-AC-4

null

R-AM-2

R-AM-3

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

Change Management

Automated Access Enforcement / Auditing

CHG-04.1

Mechanisms exist to perform after-the-fact reviews of configuration change logs to discover any unauthorized changes.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - VisibleOps methodology - ITIL infrastructure library - NNT Change Tracker (https://www.newnettechnologies.com) - Manual review processes - Tripwire Enterprise (https://www.tripwire.com/products/tripwire-enterprise/) - Puppet (https://puppet.com/) - Chef (https://www.chef.io/) (https://www.chef.io/)

null

Does the organization perform after-the-fact reviews of configuration change logs to discover any unauthorized changes?

3

Detect

null

X

There is no evidence of a capability to perform after-the-fact reviews of configuration change logs to discover any unauthorized changes.

SP-CMM1 is N/A, since a structured process is required to perform after-the-fact reviews of configuration change logs to discover any unauthorized changes.

SP-CMM2 is N/A, since a well-defined process is required to perform after-the-fact reviews of configuration change logs to discover any unauthorized changes.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible.

Change Management (CHG) 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 after-the-fact reviews of configuration change logs to discover any unauthorized changes.

null

CCC-04 CCC-09

null

CR 3.4 (7.6.3(2))

null

CM-5(1)

null

CM-5(1)

null

CM-5(1)

null

CM-5(1)

null

CM-5(1)

null

CM-5(1)

null

M.1.20

null

CM-5(1)

null

CM-5(1)

null

CM-5(1)

null

CM-5(1)

null

CM-5(1)

null

CM-5(1)

null

CM-5(1)

null

1-5-4

null

6.11

null

x

R-AC-4 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 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-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

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

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

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

Change Management

Signed Components

CHG-04.2

Mechanisms exist to prevent the installation of software and firmware components without verification that the component has been digitally signed using an organization-approved certificate authority.

- Privileged Account Management (PAM) - Patch management tools - OS configuration standards

null

Does the organization prevent the installation of software and firmware components without verification that the component has been digitally signed using an organization-approved certificate authority?

3

Protect

null

X

There is no evidence of a capability to prevent the installation of software and firmware components without verification that the component has been digitally signed using an organization-approved certificate authority.

SP-CMM1 is N/A, since a structured process is required to prevent the installation of software and firmware components without verification that the component has been digitally signed using an organization-approved certificate authority.

SP-CMM2 is N/A, since a well-defined process is required to prevent the installation of software and firmware components without verification that the component has been digitally signed using an organization-approved certificate authority.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • Administrative processes exist and technologies configured to prevent the installation of software and firmware components without verification that the component has been digitally signed using a certificate that is recognized and approved by the organization.

Change Management (CHG) 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 prevent the installation of software and firmware components without verification that the component has been digitally signed using an organization-approved certificate authority.

null

CR 3.4 (7.6.1) CR 3.4 (7.6.3(1)) SAR 2.4 (12.2.3(1)) EDR 3.13 (13.8.1) HDR 3.10 (14.5.3(1))

null

CM-5(3)

null

CM-5(3)

CM-14 SI-7(15)

null

SI-7(15)

CM-14

null

SI-7(15)

null

CM-14 SI-7(15)

null

CM-14 SI-7(15)

null

M.3.17

null

CM-5(3)

null

CM-5(3)

null

CM-14 SI-7(15)

null

CM-14 SI-7(15)

null

CM-14

null

CM-5(3)

null

CM-5(3)

null

x

R-AM-2 R-AM-3 R-BC-2 R-BC-4 R-EX-7

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-4

null

R-EX-7

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

Change Management

Dual Authorization for Change

CHG-04.3

Mechanisms exist to enforce a two-person rule for implementing changes to critical assets.

- Separation of Duties (SoD)

null

Does the organization enforce a two-person rule for implementing changes to critical assets?

6

Protect

null

X

There is no evidence of a capability to enforce a two-pers on rule for implementing changes to critical assets.

SP-CMM1 is N/A, since a structured process is required to enforce a two-pers on rule for implementing changes to critical assets.

SP-CMM2 is N/A, since a well-defined process is required to enforce a two-pers on rule for implementing changes to critical assets.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • Critical systems are configured to use dual authorization mechanisms requiring the approval of two authorized individuals in order to execute a change.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to enforce a two-pers on rule for implementing changes to critical assets.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to enforce a two-pers on rule for implementing changes to critical assets.

null

AC-5 CM-5(4)

null

AC-5

AC-5 CM-5(4)

null

AC-5

CM-5(4)

null

AC-5

null

AC-5

null

AC-5

null

AC-5

null

3.1.1e

null

1.1.2.4

null

AM:SG1.SP1 ID:SG1.SP1 ID:SG1.SP2 ID:SG1.SP3

null

TBD - 3.1.1e

null

AC-5

null

AC-5

null

AC-5

null

AC-5

null

AC-5

null

AC-5

null

8-611

null

AC-5

null

AC-5

null

2-2-1-6

null

x

null

x

R-AC-1 R-AC-2 R-AM-1 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-GV-2 R-GV-3 R-GV-6 R-GV-7 R-IR-1

R-AC-1

R-AC-2

null

R-AM-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

null

R-GV-2

R-GV-3

null

R-GV-6

R-GV-7

null

R-IR-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

Change Management

Limit Production / Operational Privileges (Incompatible Roles)

CHG-04.4

Mechanisms exist to limit operational privileges for implementing changes.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Separation of Duties (SoD) - Privileged Account Management (PAM)

null

Does the organization limit operational privileges for implementing changes?

6

Protect

null

X

null

There is no evidence of a capability to limit operational privileges for implementing changes.

SP-CMM1 is N/A, since a structured process is required to limit operational privileges for implementing changes.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to limit operational privileges for implementing changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to limit operational privileges for implementing changes.

null

DSS06.03

null

CCC-04

IAM-04

null

CR 2.1 (6.3.3(4))

null

CM-5(5)

null

CM-5(5)

null

CM-5(5)

null

3.4.5

null

PO.2 PO.2.1

null

1.1.2.6

null

ARCHITECTURE-5.H.MIL3

null

CM-5(5)

null

CM-5(5)

null

CM-5(5)

null

CM-5(5)

null

CM-5(5)

null

CM-5(5)

null

CM-5(5)

null

DEV-09 PSS-08

null

10.4

null

Article 27

null

2.5.2

null

x

R-AC-1 R-AC-2 R-AM-1 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-GV-2 R-GV-3 R-GV-6 R-GV-7 R-IR-1

R-AC-1

R-AC-2

null

R-AM-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

null

R-GV-2

R-GV-3

null

R-GV-6

R-GV-7

null

R-IR-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

Change Management

Library Privileges

CHG-04.5

Mechanisms exist to restrict software library privileges to those individuals with a pertinent business need for access.

- Privileged Account Management (PAM)

null

Does the organization restrict software library privileges to those individuals with a pertinent business need for access?

8

Protect

null

X

There is no evidence of a capability to restrict software library privileges to those individuals with a pertinent business need for access.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Requests for Change (RFC) are submitted to IT personnel. • prior to changes being made, RFCs are informally reviewed for cybersecurity & data privacy ramifications. • Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change. • IT personnel use an informal process to govern changes to the software library to prevent unauthorized changes and create an audit trail of changes made. • LAC is governed to limit the ability of non-administrators from accessing or editing the software library.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly. • IT personnel use a Source Code Manager (SCM) solution to govern modifying, copying, deleting, moving and renaming items in the software library. • SCM supports integrity checking on the source code repository. • SCM uses Role-Based Access Controls (RBAC) to limit the logical access and permissions for users in the software library.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • The CM program includes changes associated with the software library. • IT personnel use a Source Code Manager (SCM) solution to provide application lifecycle support including source code management, project management, reporting, automated builds, testing, release management and requirement management. • SCM governs modifying, copying, deleting, moving and renaming items in the software library. • SCM supports atomic commits . • SCM supports integrity checking on the source code repository. • SCM uses Role-Based Access Controls (RBAC) to limit the logical access and permissions for users in the software library.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to restrict software library privileges to those individuals with a pertinent business need for access.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to restrict software library privileges to those individuals with a pertinent business need for access.

null

TS-1.14

null

PS.1.1

null

CM-5(6)

null

CM-5(6)

null

CM-5(6)

null

CM-5(6)

null

CM-5(6)

null

PS.1 PS.1.1

null

1.1.24.2

null

DEV-07 DEV-08

null

1-3-2-2

null

x

R-AC-1 R-AC-2 R-AM-1 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-GV-2 R-GV-3 R-GV-6 R-GV-7 R-IR-1

R-AC-1

R-AC-2

null

R-AM-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

null

R-GV-2

R-GV-3

null

R-GV-6

R-GV-7

null

R-IR-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

Change Management

Stakeholder Notification of Changes

CHG-05

Mechanisms exist to ensure stakeholders are made aware of and understand the impact of proposed changes.

- Change management procedures - VisibleOps methodology - ITIL infrastructure library

null

Does the organization ensure stakeholders are made aware of and understand the impact of proposed changes?

9

Protect

null

X

There is no evidence of a capability to ensure stakeholders are made aware of and understand the impact of proposed changes.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Requests for Change (RFC) are submitted to IT personnel. • prior to changes being made, RFCs are informally reviewed for cybersecurity & data privacy ramifications. • Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure stakeholders are made aware of and understand the impact of proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure stakeholders are made aware of and understand the impact of proposed changes.

CC8.1

CC2.2-POF11

null

EDM05.01 EDM05.02 EDM05.03

null

CCC-05 CEK-06 TVM-09

null

GOVERN 5.0

null

CM-9

null

CM-9

null

CM-9

null

CM-9

3.4.10 3.4.13

CM-9

null

CM-9

null

CM-9

NFO - CM-9

null

1.1.2.5

null

TM:SG4.SP2

null

CM-9

null

CM-9

null

CM-9

null

x

null

x

R-AC-1 R-AC-2 R-AM-1 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-GV-2 R-GV-3 R-GV-6 R-GV-7 R-IR-1

R-AC-1

R-AC-2

null

R-AM-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

null

R-GV-2

R-GV-3

null

R-GV-6

R-GV-7

null

R-IR-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

Change Management

Cybersecurity Functionality Verification

CHG-06

Mechanisms exist to verify the functionality of cybersecurity controls when anomalies are discovered.

- Information Assurance Program (IAP) - Security Test & Evaluation (STE)

null

Does the organization verify the functionality of cybersecurity controls when anomalies are discovered?

9

Protect

null

X

null

There is no evidence of a capability to verify the functionality of security controls when anomalies are discovered.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Requests for Change (RFC) are submitted to IT personnel. • prior to changes being made, RFCs are informally reviewed for cybersecurity & data privacy ramifications. • Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • Up on implementing the RFC, the technician implementing a change tests to ensure anti-malware, logging and other cybersecurity & data privacy controls are still implemented and operating properly. • A structured set of controls are tested after a change is implemented to ensure cybersecurity controls are operating properly. • Results from testing changes are documented. • A vulnerability assessment is conducted on systems/applications/services to detect any new vulnerabilities that a change may have introduced.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to verify the functionality of security controls when anomalies are discovered.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to verify the functionality of security controls when anomalies are discovered.

null

CR 3.3 (7.5.1) CR 3.3 (7.5.3(1))

null

CM-3(2) SI-6

null

CM-3(2)

CM-3(2) SI-6

CM-3(2) SI-6 SA-8(31)

null

CM-3(2)

CM-3(2) SI-6

SA-8(31)

null

CM-3(2)

CM-3(2) SI-6

3.4.10 3.4.13

null

A.03.04.03.d[01]

null

6.5.2 10.7.3 A3.2.2.1

null

6.5.2

null

6.5.2

null

6.5.2

null

G.2.6.1

null

TM:SG2.SP2

null

CM-3(2) SI-6

null

CM-3(2) SI-6

null

SI-6

CM-3(2) SI-6

null

CM-3(2) SI-6

null

SI-6

CM-3(2) SI-6

null

CM-3(2)

null

8-613

null

CM-3(2)

CM-3(2) SI-6

null

CM-3(2) SI-6

null

10.6 12.30 14.10

null

7.5.5

null

x

null

x

R-AC-2 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-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

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

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-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

Change Management

Report Verification Results

CHG-06.1

Mechanisms exist to report the results of cybersecurity & data privacy function verification to appropriate organizational management.

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

null

Does the organization report the results of cybersecurity & data privacy function verification to appropriate organizational management?

5

Identify

null

X

null

There is no evidence of a capability to report the results of cybersecurity & data privacy function verification to appropriate organizational management.

SP-CMM1 is N/A, since a structured process is required to report the results of cybersecurity & data privacy function verification to appropriate organizational management.

Change Management (CHG) 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: • Change 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for change management. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. • A CAB, or similar function, reviews RFCs for cybersecurity & data privacy ramifications. • A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes. • Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services. • Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly. • Up on completing the RFC, the CAB reports the results of cybersecurity & data privacy function verification to senior management.

Change Management (CHG) 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, ensures compliance with requirements for asset management. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services. • A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently. • The CM function has formally defined roles and associated responsibilities. • Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC). • A Change Advisory Board (CAB), or similar function: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity & data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes. • IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible. • Up on completing the RFC, the CAB reports the results of cybersecurity & data privacy function verification to senior management.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to report the results of cybersecurity & data privacy function verification to appropriate organizational management.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to report the results of cybersecurity & data privacy function verification to appropriate organizational management.

null

SI-6(3)

null

SI-6(3)

null

A.03.04.03.d[01] A.03.04.03.d[02]

null

6.5.2

null

6.5.2

null

6.5.2

null

6.5.2

null

G.1.2

null

R-AM-3 R-GV-3 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-3

null

R-AM-3

null

R-GV-3

null

R-GV-5

R-GV-6

R-GV-7

R-GV-8

null

R-IR-3

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

Cloud Security

Cloud Services

CLD-01

Mechanisms exist to facilitate the implementation of cloud management controls to ensure cloud instances are secure and in-line with industry practices.

- Data Protection Impact Assessment (DPIA)

E-AST-06

Does the organization facilitate the implementation of cloud management controls to ensure cloud instances are secure and in-line with industry practices?

10

Protect

X

There is no evidence of a capability to facilitate the implementation of cloud management controls to ensure cloud instances are secure and in-line with industry practices.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network). • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations. • Technologies exist to support: o A secure infrastructure, including a managed security zone to house cybersecurity & data privacy tools. o A standardized virtualization format. o Cloud access points, including a managed security zone with o Data handling & portability, including a managed security zone to house cybersecurity & data privacy tools o Integrity of multi-tenant CSP assets, including a managed security zone to house cybersecurity & data privacy tools o Integrity of VM images, including a managed security zone to house cybersecurity & data privacy tools. o Processing and storage of service location, including a managed security zone to house cybersecurity & data privacy tools.

Cloud Security (CLD) 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 cloud security 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 organization to ensure that cloud security is incorporated. • 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 to ensure that compliance requirements for cloud security are identified and documented. • A Chief Information Officer (CIO), or similar function, defines the authoritative architecture for use with on-premise, cloud-native and hybrid models, providing governance oversight for operations planning, deployment and maintenance of cloud-based technology assets supporting cybersecurity and data protection requirements. • A Chief Technology Officer (CTO), or similar function, aligns with the CIO’s architectural model to evaluate and implement new cloud-based technologies. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including cloud security, as well as establish a clear and authoritative accountability structure for cloud security operations. • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function, governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. • CAB review processes identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to facilitate the implementation of cloud management controls to ensure cloud instances are secure and in-line with industry practices.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the implementation of cloud management controls to ensure cloud instances are secure and in-line with industry practices.

null

IPY-01 IPY-04 IVS-06 IVS-07 IVS-08 STA-05 STA-06

CLS-01 CLS-05 CLS-12

null

5.23

7.2.2 CLD.12.1.5 CLD.12.4.5

null

TS-1.9

null

NFO – PL-8

null

2.6 12.8.1

1.2.1 12.8.1

12.8.1

1.2.1 12.8.1

12.8.1

1.2.1 12.8.1

12.8.1

J.1

null

5.3.4

null

5.10.1.5

null

AC.L1-b.1.iv

null

52.204-21(b)(1)(iv)

null

4.L.A

2.E.6.1 3.3.1

null

5.8 5.12

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

COS-01 COS-02

null

11.2

null

4-2

TPC-43

3.3.4 3.3.8 3.4.3

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

null

Sec 19.1 Sec 19.2

null

1529 1437 1579 1580 1581

null

4.1 4.2 7.2.2.19.PB 8.1.5.P 8.1.2.7.PB 9.5.P 9.5.1.P 9.5.2.P 9.5.2.1.PB 12.4.5.P 13.1.4.P 15.1.1.16.B

null

18.1

22.1.20.C.01 22.1.20.C.02 22.1.20.C.03 22.1.20.C.04 22.1.20.C.05 22.1.21.C.01 22.1.21.C.02 22.1.21.C.03 22.1.21.C.04 22.1.21.C.05 22.1.21.C.06 22.1.21.C.07 22.1.24.C.01 22.1.24.C.02 22.1.24.C.03 22.1.24.C.04 22.1.25.C.01 22.1.25.C.02 22.1.26.C.01 22.1.26.C.02 22.1.26.C.03 22.1.27.C.01 23.1.54.C.01 23.1.54.C.02 23.2.19.C.01

null

5.11

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-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-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

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

MT-16

null

Cloud Security

Cloud Infrastructure Onboarding

CLD-01.1

Mechanisms exist to ensure cloud services are designed and configured so systems, applications and processes are secured in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

null

Does the organization ensure cloud services are designed and configured so systems, applications and processes are secured in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations?

9

Protect

X

null

There is no evidence of a capability to ensure cloud services are designed and configured so systems, applications and processes are secured in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

SP-CMM1 is N/A, since a structured process is required to ensure cloud services are designed and configured so systems, applications and processes are secured in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

SP-CMM2 is N/A, since a well-defined process is required to ensure cloud services are designed and configured so systems, applications and processes are secured in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned to qualified individuals. • IT architects, in conjunction with cybersecurity architects, ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. • IT architects, in conjunction with cybersecurity architects, ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. • IT architects, in conjunction with cybersecurity architects, implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • IT infrastructure personnel and Data Protection Officers (DPOs) work with business stakeholders to identify business-critical systems and services, as well as associated sensitive/regulated data, including Personal Data (PD). • The DPO function oversees the storage, processing and transmission of PD in CSPs. • An IT Asset Management (ITAM) function, or similar function, governs cloud-based assets leveraging an established Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets to provide oversight of purchasing, updating, repairing and disposing of cloud-based assets. • Formal Change Management (CM) program governs cloud-based systems, applications and services and ensures that no unauthorized changes are made, that all changes are documented, that services are not unnecessarily disrupted and that resources are used efficiently. • An IT infrastructure team, or similar function, enables the implementation of a Content Delivery Network (CDN) by restricting access to the origin server's IP address to the CDN and an authorized management network.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure cloud services are designed and configured so systems, applications and processes are secured in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure cloud services are designed and configured so systems, applications and processes are secured in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

null

TPC-43

null

23.4.9.C.01 23.4.9.C.02 23.4.9.C.03 23.4.10.C.01 23.5.11.C.01 23.5.12.C.01 23.5.12.C.02

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

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

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

Cloud Security

Cloud Infrastructure Offboarding

CLD-01.2

Mechanisms exist to ensure cloud services are decommissioned so that data is securely transitioned to new systems or archived in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

null

Does the organization ensure cloud services are decommissioned so that data is securely transitioned to new systems or archived in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations?

9

Protect

X

null

There is no evidence of a capability to ensure cloud services are decommissioned so that data is securely transitioned to new systems or archived in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

SP-CMM1 is N/A, since a structured process is required to ensure cloud services are decommissioned so that data is securely transitioned to new systems or archived in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

SP-CMM2 is N/A, since a well-defined process is required to ensure cloud services are decommissioned so that data is securely transitioned to new systems or archived in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned to qualified individuals.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure cloud services are decommissioned so that data is securely transitioned to new systems or archived in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure cloud services are decommissioned so that data is securely transitioned to new systems or archived in accordance with applicable organizational standards, as well as statutory, regulatory and contractual obligations.

null

23.4.13.C.01 23.4.13.C.02 23.4.13.C.03

null

R-AM-1 R-AM-3 R-AM-2 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-4 R-SA-1

null

R-AM-1

R-AM-3

R-AM-2

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

null

R-IR-4

R-SA-1

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

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

Cloud Security

Cloud Security Architecture

CLD-02

Mechanisms exist to ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments.

- Architectural review board - System Security Plan (SSP) - Security architecture roadmaps

E-TDA-09

Does the organization ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments?

8

Protect

null

X

null

There is no evidence of a capability to ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network). • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations. • Technologies exist to support: o A secure infrastructure, including a managed security zone to house cybersecurity & data privacy tools. o A standardized virtualization format. o Cloud access points, including a managed security zone with o Data handling & portability, including a managed security zone to house cybersecurity & data privacy tools o Integrity of multi-tenant CSP assets, including a managed security zone to house cybersecurity & data privacy tools o Integrity of VM images, including a managed security zone to house cybersecurity & data privacy tools. o Processing and storage of service location, including a managed security zone to house cybersecurity & data privacy tools.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. • IT architects, in conjunction with cybersecurity architects, ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. • IT architects, in conjunction with cybersecurity architects, ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. • IT architects, in conjunction with cybersecurity architects, implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • IT infrastructure personnel and Data Protection Officers (DPOs) work with business stakeholders to identify business-critical systems and services, as well as associated sensitive/regulated data, including Personal Data (PD). • The DPO function oversees the storage, processing and transmission of PD in CSPs. • An IT Asset Management (ITAM) function, or similar function, governs cloud-based assets leveraging an established Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets to provide oversight of purchasing, updating, repairing and disposing of cloud-based assets. • Formal Change Management (CM) program governs cloud-based systems, applications and services and ensures that no unauthorized changes are made, that all changes are documented, that services are not unnecessarily disrupted and that resources are used efficiently. • An IT infrastructure team, or similar function, enables the implementation of a Content Delivery Network (CDN) by restricting access to the origin server's IP address to the CDN and an authorized management network.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments.

null

IVS-06 IVS-07 IVS-08

CLS-01 CLS-05 CLS-12

null

5.23

CLD.9.5.1 CLD.13.1.4

null

TS-1.9 TS-2.12

null

NFO – PL-8

null

N.1

null

5.3.4

null

AC.L1-b.1.iv

null

52.204-21(b)(1)(iv)

null

4.L.A

2.E.6.1 3.3.1

null

5.12

null

COS-01 COS-02

null

3.3.4 3.3.8 3.4.3

4-2-3-2

null

8.1.2.7.PB 9.5.P 9.5.1.P 9.5.2.P 9.5.2.1.PB 12.4.5.P 13.1.4.P

null

22.1.23.C.01 22.1.23.C.02 22.1.23.C.03 23.1.54.C.01 23.1.54.C.02 23.1.56.C.01 23.2.20.C.01

null

x

FAR 52.204-21 Lockton

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-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

Cloud Security

Cloud Infrastructure Security Subnet

CLD-03

Mechanisms exist to host security-specific technologies in a dedicated subnet.

- Security management subnet

null

Does the organization host security-specific technologies in a dedicated subnet?

6

Protect

null

X

There is no evidence of a capability to host security-specific technologies in a dedicated subnet.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network). • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations. • Network security requirements for managed subnets are identified and documented.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. • Network security requirements for managed subnets are identified and documented.

Cloud Security (CLD) 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 host security-specific technologies in a dedicated subnet.

null

IVS-06 IVS-08

CLS-09

null

CLD.9.5.1

null

SC-7(29)

null

SC-7(29)

null

SC-7(29)

null

3.13.2 NFO – PL-8

null

H.1.1.3

null

SC.L2-3.13.2

AC.L1-b.1.iv

SC.L2-3.13.2

null

52.204-21(b)(1)(iv)

null

4.L.A

null

6.9

null

COS-01 COS-02 COS-05

null

9.2

null

1385 1750

null

12.4.5.P 13.1.4.P

null

22.1.24.C.02

null

x

FAR 52.204-21 Lockton

null

x

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

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-GV-2

null

R-GV-4

R-GV-5

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

- Added NIST 800-53 R5 mapping for SC-7(29)

Cloud Security

Application & Program Interface (API) Security

CLD-04

Mechanisms exist to ensure support for secure interoperability between components with Application & Program Interfaces (APIs).

- Use only open and published APIs

null

Does the organization ensure support for secure interoperability between components with Application & Program Interfaces (APIs)?

9

Protect

null

X

There is no evidence of a capability to ensure support for secure interoperability between components with Application & Program Interfaces (APIs).

SP-CMM1 is N/A, since a structured process is required to ensure support for secure interoperability between components with Application & Program Interfaces (APIs).

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations. Cloud requirements for interoperability between components (APIs) are identified and documented.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. Cloud requirements for interoperability between components (APIs) are identified and documented.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure support for secure interoperability between components with Application & Program Interfaces (APIs).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure support for secure interoperability between components with Application & Program Interfaces (APIs).

null

IPY-01 IPY-02 IPY-03

CLS-07 CLS-12 CLS-13

null

5.23 8.26

null

1.1.4

null

AC.L1-b.1.iv

null

52.204-21(b)(1)(iv)

null

4.L.A

null

PI-01

null

1-3-2-3

null

1817 1818

null

FAR 52.204-21

null

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

null

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

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

null

R-GV-4

R-GV-5

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

Cloud Security

Virtual Machine Images

CLD-05

Mechanisms exist to ensure the integrity of virtual machine images at all times.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - File Integrity Monitoring (FIM) - Docker (https://www.docker.com/) - NNT Change Tracker (https://www.newnettechnologies.com)

null

Does the organization ensure the integrity of virtual machine images at all times?

8

Protect

null

X

There is no evidence of a capability to ensure the integrity of virtual machine images at all times.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network). • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. • Cloud requirements for interoperability implemented through standardized virtualization formats are identified and documented. • The IT Asset Management (ITAM) function uses technical mechanisms to ensure the integrity of virtual machine images throughout the asset lifecycle.

Cloud Security (CLD) 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 the integrity of virtual machine images at all times.

null

IVS-04

null

V.1.5

null

5.10.3

null

2.L.F

3.3.7

null

PSS-11

null

x

null

R-AM-3 R-BC-1 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-IR-1 R-IR-4

null

R-AM-3

R-BC-1

null

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

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

Cloud Security

Multi-Tenant Environments

CLD-06

Mechanisms exist to ensure multi-tenant owned or managed assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users.

- Security architecture review - Defined processes to segment at the network, application, databases layers

null

Does the organization ensure multi-tenant owned or managed assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users?

9

Protect

null

X

There is no evidence of a capability to ensure multi-tenant owned or managed assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network). • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations. • Cloud instances of virtual machines are treated no differently from on-premise VM assets, where no dedicated cloud governance process exists. • Cybersecurity and data privacy requirements for virtual machines are identified and documented. • IT personnel use an informal process to govern VM images. • Cybersecurity and data privacy requirements for multi-tenant CSP environments are identified and documented. • Contracts ensure multi-tenant CSPs: o Facilitate prompt response to suspected or confirmed security incidents and vulnerabilities, including timely notification to affected customers. o Generate security event logs for its clients. o Facilitate prompt forensic investigations in the event of a suspected or confirmed security incident.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. • Contracts ensure multi-tenant CSPs facilitate prompt forensic investigations in the event of a suspected or confirmed security incident. • Contracts ensure multi-tenant CSPs facilitate prompt response to suspected or confirmed security incidents and vulnerabilities, including timely notification to affected customers. • Contracts ensure multi-tenant CSPs generate security event logs for its clients.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure multi-tenant owned or managed assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure multi-tenant owned or managed assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users.

null

IVS-06

null

5.23

CLD.9.5.1

null

TS-1.9 TS-2.12

null

A1.1 A1.1.1 A1.1.2 A1.1.3 A1.1.4

null

A1.1.1 A1.1.2 A1.1.3 A1.1.4

null

N.1

null

5.3.4

null

AC.L1-b.1.iv

null

52.204-21(b)(1)(iv)

null

4.L.A

null

OPS-24

null

10.1 11.3

null

1529

null

9.5.P 9.5.1.P 9.5.2.P 9.5.2.1.PB 13.1.4.P

null

23.1.55.C.01 23.1.55.C.02 23.1.55.C.03 23.2.20.C.01

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

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

Cloud Security

Customer Responsibility Matrix (CRM)

CLD-06.1

Mechanisms exist to formally document a Customer Responsibility Matrix (CRM), delineating assigned responsibilities for controls between the Cloud Service Provider (CSP) and its customers.

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

E-CPL-03

Does the organization formally document a Customer Responsibility Matrix (CRM), delineating assigned responsibilities for controls between the Cloud Service Provider (CSP) and its customers?

8

Identify

X

There is no evidence of a capability to formally document a Customer Responsibility Matrix (CRM), delineating assigned responsibilities for controls between the Cloud Service Provider (CSP) and its customers.

SP-CMM1 is N/A, since a structured process is required to formally document a Customer Responsibility Matrix (CRM), delineating assigned responsibilities for controls between the Cloud Service Provider (CSP) and its customers.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to formally document a Customer Responsibility Matrix (CRM), delineating assigned responsibilities for controls between the Cloud Service Provider (CSP) and its customers.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to formally document a Customer Responsibility Matrix (CRM), delineating assigned responsibilities for controls between the Cloud Service Provider (CSP) and its customers.

null

4.3(c)

null

5.23

6.1.1 CLD.6.3.1

null

TS-1.10

null

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

null

12.4.1

null

12.4.1

null

G.1.3

null

THIRD-PARTIES-1.A.MIL1

null

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

null

23.1.55.C.01 23.1.55.C.02 23.1.55.C.03

null

R-AM-3 R-EX-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 R-SA-1

null

R-AM-3

null

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

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

Cloud Security

Multi-Tenant Event Logging Capabilities

CLD-06.2

Mechanisms exist to ensure Multi-Tenant Service Providers (MTSP) facilitate security event logging capabilities for its customers that are consistent with applicable statutory, regulatory and/or contractual obligations.

null

Does the organization ensure Multi-Tenant Service Providers (MTSP) facilitate security event logging capabilities for its customers that are consistent with applicable statutory, regulatory and/or contractual obligations?

8

Identify

null

X

There is no evidence of a capability to ensure Multi-Tenant Service Providers (MTSP) facilitate security event logging capabilities for its customers that are consistent with applicable statutory, regulatory and/ or contractual obligations.

SP-CMM1 is N/A, since a structured process is required to ensure Multi-Tenant Service Providers (MTSP) facilitate security event logging capabilities for its customers that are consistent with applicable statutory, regulatory and/ or contractual obligations.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure Multi-Tenant Service Providers (MTSP) facilitate security event logging capabilities for its customers that are consistent with applicable statutory, regulatory and/ or contractual obligations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure Multi-Tenant Service Providers (MTSP) facilitate security event logging capabilities for its customers that are consistent with applicable statutory, regulatory and/ or contractual obligations.

null

CLD.12.4.5

null

A1.2 A1.2.1

null

A1.2.1

null

N.1.24

null

12.4.5.P

null

23.5.11.C.01 23.5.12.C.01 23.5.12.C.02

null

R-AM-3 R-EX-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 R-SA-1

null

R-AM-3

null

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

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

Cloud Security

Multi-Tenant Forensics Capabilities

CLD-06.3

Mechanisms exist to ensure Multi-Tenant Service Providers (MTSP) facilitate prompt forensic investigations in the event of a suspected or confirmed security incident.

null

Does the organization ensure Multi-Tenant Service Providers (MTSP) facilitate prompt forensic investigations in the event of a suspected or confirmed security incident?

8

Identify

null

X

There is no evidence of a capability to ensure Multi-Tenant Service Providers (MTSP) facilitate prompt forensic investigations in the event of a suspected or confirmed security incident.

SP-CMM1 is N/A, since a structured process is required to ensure Multi-Tenant Service Providers (MTSP) facilitate prompt forensic investigations in the event of a suspected or confirmed security incident.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure Multi-Tenant Service Providers (MTSP) facilitate prompt forensic investigations in the event of a suspected or confirmed security incident.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure Multi-Tenant Service Providers (MTSP) facilitate prompt forensic investigations in the event of a suspected or confirmed security incident.

null

A1.2 A1.2.2

null

A1.2.2

null

N.2.7

null

R-AM-3 R-EX-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 R-SA-1

null

R-AM-3

null

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

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

Cloud Security

Multi-Tenant Incident Response Capabilities

CLD-06.4

Mechanisms exist to ensure Multi-Tenant Service Providers (MTSP) facilitate prompt response to suspected or confirmed security incidents and vulnerabilities, including timely notification to affected customers.

null

Does the organization ensure Multi-Tenant Service Providers (MTSP) facilitate prompt response to suspected or confirmed security incidents and vulnerabilities, including timely notification to affected customers?

8

Identify

null

X

There is no evidence of a capability to ensure Multi-Tenant Service Providers (MTSP) facilitate prompt response to suspected or confirmed security incidents and vulnerabilities, including timely notification to affected customers.

SP-CMM1 is N/A, since a structured process is required to ensure Multi-Tenant Service Providers (MTSP) facilitate prompt response to suspected or confirmed security incidents and vulnerabilities, including timely notification to affected customers.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure Multi-Tenant Service Providers (MTSP) facilitate prompt response to suspected or confirmed security incidents and vulnerabilities, including timely notification to affected customers.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure Multi-Tenant Service Providers (MTSP) facilitate prompt response to suspected or confirmed security incidents and vulnerabilities, including timely notification to affected customers.

null

A1.2 A1.2.3

null

A1.2.3

null

N.1.23

null

23.5.12.C.01 23.5.12.C.02

null

R-AM-3 R-EX-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 R-SA-1

null

R-AM-3

null

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

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

Cloud Security

Data Handling & Portability

CLD-07

Mechanisms exist to ensure cloud providers use secure protocols for the import, export and management of data in cloud-based services.

- Data Protection Impact Assessment (DPIA) - Security architecture review - Encrypted data transfers (e.g. TLS or VPNs)

null

Does the organization ensure cloud providers use secure protocols for the import, export and management of data in cloud-based services?

4

Protect

null

X

null

There is no evidence of a capability to ensure cloud providers use secure protocols for the import, export and management of data in cloud-based services.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network). • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure cloud providers use secure protocols for the import, export and management of data in cloud-based services.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure cloud providers use secure protocols for the import, export and management of data in cloud-based services.

null

IPY-01 IPY-03 IVS-07

null

V.1.9

null

AC.L1-b.1.iv

null

52.204-21(b)(1)(iv)

null

4.L.A

null

PI-01 PI-02

null

FAR 52.204-21

null

R-AM-3 R-EX-5 R-GV-1 R-IR-3

null

R-AM-3

null

R-EX-5

null

R-GV-1

null

R-IR-3

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

Cloud Security

Standardized Virtualization Formats

CLD-08

Mechanisms exist to ensure interoperability by requiring cloud providers to use industry-recognized formats and provide documentation of custom changes for review.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Data Protection Impact Assessment (DPIA) - Manual review process - Vendor risk assessments - Independent vendor compliance assessments

null

Does the organization ensure interoperability by requiring cloud providers to use industry-recognized formats and provide documentation of custom changes for review?

4

Protect

null

X

There is no evidence of a capability to ensure interoperability by requiring cloud providers to use industry-recognized formats and provide documentation of custom changes for review.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network). • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure interoperability by requiring cloud providers to use industry-recognized formats and provide documentation of custom changes for review.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure interoperability by requiring cloud providers to use industry-recognized formats and provide documentation of custom changes for review.

null

IPY-01 IPY-03 IVS-01

null

V.4.4

null

5.10.3

null

2.L.F

3.3.7

null

PSS-11

null

x

null

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

null

R-AM-3

null

R-BC-3

null

R-EX-1

R-EX-2

null

R-EX-5

null

R-GV-1

null

R-IR-1

null

R-IR-3

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

Cloud Security

Geolocation Requirements for Processing, Storage and Service Locations

CLD-09

Mechanisms exist to control the location of cloud processing/storage based on business requirements that includes statutory, regulatory and contractual obligations.

- Data Protection Impact Assessment (DPIA)

E-AST-06 E-AST-23

Does the organization control the location of cloud processing/storage based on business requirements that includes statutory, regulatory and contractual obligations?

10

Protect

null

X

There is no evidence of a capability to control the location of cloud processing/storage based on business requirements that includes statutory, regulatory and contractual obligations.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network). • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems.

Cloud Security (CLD) 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.

Cloud Security (CLD) 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

DSP-19 UEM-12 UEM-12

null

5.23

6.1.3

null

7.5 7.5.1 7.5.2 8.5.1 8.5.2

null

SA-9(5)

null

SA-9(5) SA-9(8)

null

SA-9(5) SA-9(8)

null

D.3.3

null

AC.L1-b.1.iv

null

SA-9(5)

null

52.204-21(b)(1)(iv)

null

SA-9(5)

null

SA-9(5)

null

SA-9(5)

null

SA-9(5)

null

4.L.A

2.C.7 SA-9(5) SA-9(8)

null

SA-9(5)

null

Art 6 Art 9

null

PI-02 PSS-12

null

25(h)

null

Article 15

null

4-2-1-1

TPC-30

null

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

null

Article 3 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

APP 8

1572 1578

null

Article 38 Article 39 Article 40

null

Article 24(1)

null

22.1.22.C.01 22.1.22.C.02 22.1.22.C.03 22.1.22.C.04 22.1.22.C.05 22.1.22.C.06 23.4.11.C.01 23.4.11.C.02

null

Art 12.1 Art 12.2

null

Art 33 Art 34

null

Art 23

null

x

FAR 52.204-21

null

x

R-AC-4 R-AM-1 R-AM-3 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-IR-1 R-IR-4

null

R-AC-4

R-AM-1

null

R-AM-3

null

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

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

Cloud Security

Sensitive Data In Public Cloud Providers

CLD-10

Mechanisms exist to limit and manage the storage of sensitive/regulated data in public cloud providers.

- Data Protection Impact Assessment (DPIA) - Security and network architecture diagrams - Data Flow Diagram (DFD)

E-AST-08

Does the organization limit and manage the storage of sensitive/regulated data in public cloud providers?

6

Protect

null

X

null

There is no evidence of a capability to limit and manage the storage of sensitive/regulated data in public cloud providers.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network). • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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: • Cloud security management 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity & data privacy-specific tools. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements. • Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. • IT infrastructure personnel and Data Protection Officers (DPOs) work with business stakeholders to identify business-critical systems and services, as well as associated sensitive/regulated data, including Personal Data (PD). • The DPO function oversees the storage, processing and transmission of PD in CSPs.

Cloud Security (CLD) 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 limit and manage the storage of sensitive/regulated data in public cloud providers.

null

DSP-17

null

CLD.9.5.1

null

D.3.3

null

AC.L1-b.1.iv

null

52.204-21(b)(1)(iv)

null

4.L.A

null

6-1-1308(7)

null

11.6

null

8.1.5.P

null

2.3.23.C.01 22.1.22.C.04 22.1.22.C.05

null

FAR 52.204-21

null

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

null

R-AC-4

null

R-AM-3

null

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

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

Cloud Security

Cloud Access Point (CAP)

CLD-11

Mechanisms exist to utilize Cloud Access Points (CAPs) to provide boundary protection and monitoring functions that both provide access to the cloud and protect the organization from the cloud.

- Next Generation Firewall (NGF) - Web Application Firewall (WAF) - Network Routing / Switching - Intrusion Detection / Protection (IDS / IPS) - Data Loss Prevention (DLP) - Full Packet Capture

null

Does the organization utilize Cloud Access Points (CAPs) to provide boundary protection and monitoring functions that both provide access to the cloud and protect the organization from the cloud?

7

Protect

null

X

null

There is no evidence of a capability to utilize Cloud Access Points (CAPs) to provide boundary protection and monitoring functions that both provide access to the cloud and protect the organization from the cloud.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network). • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

SP-CMM2 is N/A, since a well-defined process is required to prevent "side channel attacks" when using a Content Delivery Network (CDN) by restricting access to the origin server's IP address to the CDN and an authorized management network.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. • IT architects, in conjunction with cybersecurity architects, use Cloud Access Points (CAPs) to provide boundary protection and monitoring functions that control access to the cloud and protect the organization as well.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to utilize Cloud Access Points (CAPs) to provide boundary protection and monitoring functions that both provide access to the cloud and protect the organization from the cloud.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize Cloud Access Points (CAPs) to provide boundary protection and monitoring functions that both provide access to the cloud and protect the organization from the cloud.

null

CC6.1-POF5

null

IVS-08

CLS-12 CLS-14

null

P.7

null

4.L.A 6.L.A

null

COS-04

null

9.10 11.8 16.4

null

22.1.24.C.01 22.1.24.C.02 22.1.24.C.03 22.1.24.C.04

null

x

null

R-AC-4 R-AM-3 R-SA-1

null

R-AC-4

null

R-AM-3

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 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

Cloud Security

Side Channel Attack Prevention

CLD-12

Mechanisms exist to prevent "side channel attacks" when using a Content Delivery Network (CDN) by restricting access to the origin server's IP address to the CDN and an authorized management network.

null

Does the organization prevent "side channel attacks" when using a Content Delivery Network (CDN) by restricting access to the origin server's IP address to the CDN and an authorized management network?

3

Protect

null

X

There is no evidence of a capability to prevent "side channel attacks" when using a Content Delivery Network (CDN) by restricting access to the origin server's IP address to the CDN and an authorized management network.

SP-CMM1 is N/A, since a structured process is required to prevent "side channel attacks" when using a Content Delivery Network (CDN) by restricting access to the origin server's IP address to the CDN and an authorized management network.

SP-CMM2 is N/A, since a well-defined process is required to prevent "side channel attacks" when using a Content Delivery Network (CDN) by restricting access to the origin server's IP address to the CDN and an authorized management network.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. IT infrastructure team assigns roles and responsibilities for governing Content Delivery Network (CDN) instances, including provisioning, maintaining and deprovisioning of instances.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to prevent "side channel attacks" when using a Content Delivery Network (CDN) by restricting access to the origin server's IP address to the CDN and an authorized management network.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to prevent "side channel attacks" when using a Content Delivery Network (CDN) by restricting access to the origin server's IP address to the CDN and an authorized management network.

null

CLS-02

null

12.4.2

null

12.4.2

null

N.9

null

1438 1439

null

R-AC-4 R-BC-2 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5

null

R-AC-4

null

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

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

Cloud Security

Hosted Systems, Applications & Services

CLD-13

Mechanisms exist to specify applicable cybersecurity & data protection controls that must be implemented on external systems, consistent with the contractual obligations established with the External Service Providers (ESP) owning, operating and/or maintaining external systems, applications and/or services.

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

null

Does the organization specify applicable cybersecurity & data protection controls that must be implemented on external systems, consistent with the contractual obligations established with the External Service Providers (ESP) owning, operating and/or maintaining external systems, applications and/or services?

9

Protect

X

null

There is no evidence of a capability to specify applicable cybersecurity & data protection controls that must be implemented on external systems, consistent with the contractual obligations established with the External Service Providers (ESP) owning, operating and/or maintaining external systems, applications and/or services.

SP-CMM1 is N/A, since a structured process is required to specify applicable cybersecurity & data protection controls that must be implemented on external systems, consistent with the contractual obligations established with the External Service Providers (ESP) owning, operating and/or maintaining external systems, applications and/or services.

SP-CMM2 is N/A, since a well-defined process is required to specify applicable cybersecurity & data protection controls that must be implemented on external systems, consistent with the contractual obligations established with the External Service Providers (ESP) owning, operating and/or maintaining external systems, applications and/or services.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. IT infrastructure team assigns roles and responsibilities for governing Content Delivery Network (CDN) instances, including provisioning, maintaining and deprovisioning of instances.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to specify applicable cybersecurity & data protection controls that must be implemented on external systems, consistent with the contractual obligations established with the External Service Providers (ESP) owning, operating and/or maintaining external systems, applications and/or services.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to specify applicable cybersecurity & data protection controls that must be implemented on external systems, consistent with the contractual obligations established with the External Service Providers (ESP) owning, operating and/or maintaining external systems, applications and/or services.

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-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

- new control

Cloud Security

Authorized Individuals For Hosted Systems, Applications & Services

CLD-13.1

Mechanisms exist to authorize specified individuals to access External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services.

- Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

null

Does the organization authorize specified individuals to access External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services?

9

Protect

X

null

There is no evidence of a capability to authorize specified individuals to access External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services.

SP-CMM1 is N/A, since a structured process is required to authorize specified individuals to access External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services.

SP-CMM2 is N/A, since a well-defined process is required to authorize specified individuals to access External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. IT infrastructure team assigns roles and responsibilities for governing Content Delivery Network (CDN) instances, including provisioning, maintaining and deprovisioning of instances.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to authorize specified individuals to access External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to authorize specified individuals to access External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services.

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-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

- new control

Cloud Security

Sensitive/Regulated Data On Hosted Systems, Applications & Services

CLD-13.2

Mechanisms exist to define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services , in accordance with all applicable statutory, regulatory and/or contractual obligations.

null

Does the organization define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services , in accordance with all applicable statutory, regulatory and/or contractual obligations?

9

Protect

X

null

There is no evidence of a capability to define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services , in accordance with all applicable statutory, regulatory and/or contractual obligations.

SP-CMM1 is N/A, since a structured process is required to define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services , in accordance with all applicable statutory, regulatory and/or contractual obligations.

SP-CMM2 is N/A, since a well-defined process is required to define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services , in accordance with all applicable statutory, regulatory and/or contractual obligations.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. IT infrastructure team assigns roles and responsibilities for governing Content Delivery Network (CDN) instances, including provisioning, maintaining and deprovisioning of instances.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services , in accordance with all applicable statutory, regulatory and/or contractual obligations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external systems, applications and/or services , in accordance with all applicable statutory, regulatory and/or contractual obligations.

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-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

- new control

Cloud Security

Prohibition On Unverified Hosted Systems, Applications & Services

CLD-14

Mechanisms exist to prohibit access to, or usage of, hosted systems, applications and/or services until applicable cybersecurity & data protection control implementation is verified.

null

Does the organization prohibit access to, or usage of, hosted systems, applications and/or services until applicable cybersecurity & data protection control implementation is verified?

8

Protect

X

null

There is no evidence of a capability to prohibit access to, or usage of, hosted systems, applications and/or services until applicable cybersecurity & data protection control implementation is verified.

SP-CMM1 is N/A, since a structured process is required to prohibit access to, or usage of, hosted systems, applications and/or services until applicable cybersecurity & data protection control implementation is verified.

SP-CMM2 is N/A, since a well-defined process is required to prohibit access to, or usage of, hosted systems, applications and/or services until applicable cybersecurity & data protection control implementation is verified.

Cloud Security (CLD) 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: • Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned. • A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies. • IT architects, in conjunction with cybersecurity architects: o Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. • A Change Advisory Board (CAB), or similar function: o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs. • A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CSP-specific. • Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems. IT infrastructure team assigns roles and responsibilities for governing Content Delivery Network (CDN) instances, including provisioning, maintaining and deprovisioning of instances.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to prohibit access to, or usage of, hosted systems, applications and/or services until applicable cybersecurity & data protection control implementation is verified.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to prohibit access to, or usage of, hosted systems, applications and/or services until applicable cybersecurity & data protection control implementation is verified.

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-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

- new control

Compliance

Statutory, Regulatory & Contractual Compliance

CPL-01

Mechanisms exist to facilitate the identification and implementation of relevant statutory, regulatory and contractual controls.

- Governance, Risk and Compliance Solution (GRC) tool (SCFConnect, SureCloud,Ostendio, ZenGRC, Archer, RSAM, MetricStream, etc.) - Steering committee

E-CPL-01 E-GOV-10

Does the organization facilitate the identification and implementation of relevant statutory, regulatory and contractual controls?

10

Identify

X

null

There is no evidence of a capability to facilitate the identification and implementation of relevant statutory, regulatory and contractual controls.

Compliance (CPL) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to govern statutory, regulatory and contractual compliance obligations. • IT personnel self-identify a set of controls that are used to conduct cybersecurity & data privacy control assessments. • IT personnel perform internal assessments of cybersecurity & data privacy controls to determine compliance status.

Compliance (CPL) 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: • Compliance activities are 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements. • Legal representation is consulted on an as-needed basis. • Cybersecurity personnel perform an informal annual review of existing compliance requirements and researches evolving or new requirements.

Compliance (CPL) 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 statutory, regulatory and contractual obligations. • 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 organization to manage compliance efforts. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program with regards to GRC operations. • 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • Legal representation is consulted on an as-needed basis.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to facilitate the identification and implementation of relevant statutory, regulatory and contractual controls.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the identification and implementation of relevant statutory, regulatory and contractual controls.

CC2.2 CC2.3

CC3.1-POF14

7.1 9

null

MEA02.01 MEA02.02 MEA03.01 MEA03.02 MEA03.03 MEA03.04

Principle 14 Principle 15

A&A-01 A&A-04 GRC-07 STA-06 STA-09 UEM-14

CLS-04 GVN-02 LGL-03 LGL-04 LGL-05 LGL-06 LGL-07 LGL-08 OPA-05

SO25

null

4.2.2

null

4.1 9.1 9.2 9.2.1 9.2.2

18.1.1

5.31 8.34

18.1.1

null

6.15 6.15.1 6.15.1.1

5.1

null

Sec 4(I)

GOVERN 1.1

GV.PO-P5 GV.MT-P3

null

PL-1 PM-8

PL-1

PL-1 PM-8

PL-1

PM-8

null

PL-1

3.3 3.3.3 3.3.4 3.4 3.4.1 3.4.2 3.4.3

PL-1 PM-8

PL-1

null

PM-8

PL-1

null

NFO - PL-1

null

ID.GV-3 PR.IP-5 DE.DP-2

GV.OC-03 GV.SC-03 GV.SC-09

null

12.1

A3.1 A3.1.1

null

L.1

null

1.5 1.5.1 7.1.1

null

7.1.1

PROGRAM-1.G.MIL2 PROGRAM-2.I.MIL3

COMP:SG4.SP1 EF:SG3.SP3 EF:SG4.SP1 RRD:SG1.SP1

null

4.1.1 4.2.1 4.2.2 4.3

null

PL-1 PM-8

6,502

252.204-7008(b) 252.204-7008(c)(1) 252.204-7008(c)(1)(i) 252.204-7008(c)(1)(i)(A) 252.204-7008(c)(1)(i)(B) 252.204-7008(c)(1)(ii) 252.204-7012(b)(1)(i) 252.204-7012(b)(1)(ii) 252.204-7012(b)(2)(i) 252.204-7012(b)(2)(ii)(A) 252.204-7012(b)(2)(ii)(B) 252.204-7012(b)(2)(ii)(C) 252.204-7012(b)(2)(ii)(D) 252.204-7012(b)(3) 252.204-7012(k) 252.204-7012(l) 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(b)(2) 52.204-21(c)

null

§ 11.10 § 11.10(a) § 11.10(b) § 11.10(c) § 11.10(d) § 11.10(e) § 11.10(f) § 11.10(g) § 11.10(h) § 11.10(i) § 11.10(j) § 11.10(k) § 11.10(k)(1) § 11.10(k)(2) § 11.100 § 11.100(c) § 11.100(c)(1) § 11.100(c)(2)

PL-1

null

D1.G.Ov.E.2 D3.PC.Am.B.11

null

314.4(c)

164.302 164.318 164.318(a) 164.318(a)(1) 164.318(a)(2) 164.318(b) 164.318(c) 164.534 164.534(a) 164.534(b) 164.534(c)

null

1.1 1.6 1.7.1 1.7.1.1 1.7.1.2 1.7.2 1.10.1 1.10.2 1.10.3 2.A.1 2.C.9 2.E.1 2.E.2 2.E.4 2.E.4.1 2.E.4.2 2.E.4.3 2.E.4.4 2.E.5.1 2.E.5.2 2.E.6 2.E.6.3 2.F.2 2.F.4 PL-1

null

8-104

null

5.11

PL-1

IV.A IV.B IV.B.1 IV.B.2 IV.C.1 IV.C.2 IV.C.2.a IV.C.2.b IV.C.2.c IV.C.2.d IV.C.2.e IV.C.2.e.i IV.C.2.e.ii IV.C.2.e.iii IV.C.2.e.iv IV.C.2.f

null

1798.91.06(a) 1798.91.06(b) 1798.91.06(c) 1798.91.06(d) 1798.91.06(e) 1798.91.06(f) 1798.91.06(g) 1798.91.06(h) 1798.91.06(i)

7010(a)

null

6-1-1305(1) 6-1-1305(6) 6-1-1307(2) 6-1-1307(3) 6-1-1308(6)

null

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

null

500.19

Sec 4(2)(a) Sec 4(2)(b)(i) Sec 4(2)(b)(ii) Sec 4(2)(b)(ii)(A) Sec 4(2)(b)(ii)(A)(1) Sec 4(2)(b)(ii)(A)(2) Sec 4(2)(b)(ii)(A)(3) Sec 4(2)(b)(ii)(A)(4) Sec 4(2)(b)(ii)(A)(5) Sec 4(2)(b)(ii)(A)(6) Sec 4(2)(b)(ii)(B)(1) Sec 4(2)(b)(ii)(B)(2) Sec 4(2)(b)(ii)(B)(3) Sec 4(2)(b)(ii)(B)(4) Sec 4(2)(b)(ii)(C)(1) Sec 4(2)(b)(ii)(C)(2) Sec 4(2)(b)(ii)(C)(3) Sec 4(2)(b)(ii)(C)(4) Sec 4(2)(c)

null

38-99-20(I)

null

PL-1

Sec 11.175(c)

59.1-576.A 59.1-576.B 59.1-576.C.1 59.1-576.C.2 59.1-576.C.3 59.1-576.C.4 59.1-576.C.5 59.1-576.C.6 59.1-576.C.7 59.1-576.C.8 59.1-576.C.9 59.1-576.C.10 59.1-576.C.11 59.1-576.C.12 59.1-576.C.13 59.1-576.C.14 59.1-576.D 59.1-581.E 59.1-582.A.1 59.1-582.A.2 59.1-582.A.3 59.1-582.A.4 59.1-582.A.5 59.1-582.A.6 59.1-582.A.7 59.1-582.A.8 59.1-582.A.9 59.1-582.B.1 59.1-582.B.2 59.1-582.B.3 59.1-582.B.4 59.1-582.C 59.1-582.D 59.1-582.E 59.1-582.F 59.1-582.G 59.1-582.H

null

3.1(1) 3.8(92) 3.8(93) 3.8(94) 3.8(95) 3.8(96) 3.8(97) 3.8(98)

Art 4.1 Art 4.2 Art 4.3 Art 5.4

Art 2 Art 3 Art 15

Art 1.2 Art 2.1 Art 2.2 Art 3.1 Art 3.2 Art 3.3 Art 6.1 Art 17.3 Art 20.3 Art 23.1 Art 23.2 Art 24.1 Art 24.2 Art 24.3 Art 25.1 Art 25.2 Art 25.3 Art 27.1 Art 27.2 Art 27.3 Art 27.4 Art 27.5 Art 32.1 Art 32.2 Art 32.3 Art 32.4 Art 40.1 Art 40.2 Art 42.2 Art 43 Art 50

Article 21.1

Art 3 Art 29

Principle 3.5.a Principle 3.5.b Principle 3.5.b.i Principle 3.5.b.ii Principle 3.5.b.iii Principle 3.6.a Principle 3.6.b Principle 3.6.b.i Principle 3.6.b.ii Principle 3.6.b.iii Principle 3.6.b.iii.1 Principle 3.6.b.iii.2 Principle 3.6.b.iv Principle 3.6.b.iv.1 Principle 3.6.b.iv.2 Principle 3.6.b.v Principle 3.6.b.vi Principle 3.6.b.vii Principle 3.6.b.viii Principle 3.6.c Principle 3.6.d Principle 3.6.e Principle 3.6.f Principle 3.6.g Principle 3.6.h Principle 3.7.a Principle 3.7.b Principle 3.7.c Principle 3.7.d Principle 3.7.e

Sec 14 Sec 15

Art 16

Art 13

Art 5 Art 41

Sec 5 Sec 32 Sec 33 Sec 34 Sec 35

Art 34

Sec 9 Sec 9a Annex

12.5

SP-01 PI-02 COM-01

Art 10

Sec 7

Sec 2

1.3

Sec 16 Sec 17

Sec 26 Sec 31 Sec 33 Sec 34 Sec 35

4(a) 4(b)(i) 4(b)(ii) 51(1) 51(2)(a) 51(2)(b) 51(2)(c) 52(1)(a) 52(1)(b) 52(1)(c) 52(2) 52(3) 54 55(1)(a) 55(1)(b) 55(2)

Art 3 Art 4

Sec 12 Sec 13 Sec 14

2.1(2) 2.1(3) 3.1(16) 4.1(1) 4.1(6) 4.1(7)

Sec 13 Sec 14

Art 1 Art 36

Art 14 Art 15 Art 16 Art 17

Article 2

Art 7 Art 19

1-4

TPC-20 TPC-21 TPC-43

3.2.2 3.2.3 3.3.13

1-7-1 1-7-2

null

Article 5.1 Article 13 Article 49 Article 59

null

Sec 2 Sec 3 Sec 9 Sec 19 Sec 21

null

7.1.5 [OP.PL.5]

Sec 31

Art 7

Art 12

Sec 15 Sec 16

B3.a

null

Article 3 Article 25(1) Article 25(2) Article 25(3) Article 27(1) Article 27(2)(a) Article 27(2)(b) Article 27(3)Article 27(4) Article 27(5)

null

APP Part 11

null

0078 0854

null

28

31 35 35(a) 35(b) 36

Article 46

Sec 4

Article 32 Article 37 Article 38(4) Article 42

Principle 4

Sec 8

null

Article 20 Article 21 Article 22 Article 26(1) Article 26(1)(i) Article 26(1)(ii) Article 26(2) Article 26(3) Article 26(4) Article 26-2(1) Article 26-2(1)(i) Article 26-2(1)(ii) Article 26-2(2) Article 26-2(3) Article 36 Article 37 Article 38 Article 39 Article 51(1) Article 51(2) Article 52(1) Article 53(2) Article 53(3) Article 53(1) Article 53(2) Article 53(3) Article 53(4) Article 54 Article 55

18.1.1

Sec 9

14.1

1.1.64.C.01 1.1.65.C.01 1.1.66.C.01 1.1.66.C.02 1.1.67.C.01

null

Sec 25

Sec 24

3.1(a) 3.1(b) 3.1(c)

3.2.3

Art 3 Art 29

Art 27

Art 9

Art 10.1 Art 10.2

Sec 6

null

Art 7.1 Art 7.2 Art 7.3 Art 7.4 Art 7.5 Art 7.6 Art 7.7 Art 7.8 Art 7.9 Art 7.10

null

Principle 7

Art 7

Art 4

Art 10

Art 19

Art 9 Art 16 Art 17

Art 23

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-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

- updated DFARS mapping

Compliance

Non-Compliance Oversight

CPL-01.1

Mechanisms exist to document and review instances of non-compliance with statutory, regulatory and/or contractual obligations to develop appropriate risk mitigation actions.

null

E-CPL-05

Does the organization document and review instances of non-compliance with statutory, regulatory and/or contractual obligations to develop appropriate risk mitigation actions?

9

Respond

null

X

null

There is no evidence of a capability to document and review instances of non-compliance with statutory, regulatory and/ or contractual obligations to develop appropriate risk mitigation actions.

SP-CMM1 is N/A, since a structured process is required to document and review instances of non-compliance with statutory, regulatory and/ or contractual obligations to develop appropriate risk mitigation actions.

Compliance (CPL) 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: • Compliance activities are 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements. • Legal representation is consulted on an as-needed basis.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • Legal representation is consulted on an as-needed basis.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to document and review instances of non-compliance with statutory, regulatory and/ or contractual obligations to develop appropriate risk mitigation actions.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to document and review instances of non-compliance with statutory, regulatory and/ or contractual obligations to develop appropriate risk mitigation actions.

null

CC1.1-POF4 CC4.2-POF1 CC4.2-POF2 CC4.2-POF3

null

A&A-05 A&A-06 GRC-04

GVN-04

null

10.1

9.1 9.1(a) 9.1(b) 9.1(c) 9.1(d) 9.1(e) 9.1(f) 10.2 10.2(a) 10.2(a)(1) 10.2(a)(2) 10.2(b) 10.2(b)(1) 10.2(b)(2) 10.2(b)(3) 10.2(c) 10.2(d) 10.2(e) 10.2(f) 10.2(g)

null

GV.OC-03

null

12.4.2

null

12.4.2

null

P.10.6

null

1.5.1

null

ASSET-5.E.MIL3 ASSET-5.F.MIL3 THREAT-3.F.MIL3 RISK-5.F.MIL3 ACCESS-4.F.MIL3 SITUATION-4.F.MIL3 RESPONSE-5.F.MIL3 THIRD-PARTIES-3.F.MIL3 WORKFORCE-4.F.MIL3 ARCHITECTURE-5.F.MIL3 PROGRAM-3.F.MIL3

null

252.204-7019(b)

null

Article 21.4

null

1-6 1-6-1

null

30 31

29 35 35(a) 35(b) 36

null

Article 54

null

Article 40(1) Article 40(2) Article 40(3)

4.7.1 4.7.1.1 4.7.1.2 4.7.1.3 4.7.1.4 4.7.1.5 4.7.1.6 4.7.1.7

null

1.1.68.C.01 1.1.69.C.01 1.1.69.C.02

null

3.2.3 4.5.2 4.5.3

null

5.7

null

6.10 6.14

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-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

- updated DFARS mapping

Compliance

Compliance Scope

CPL-01.2

Mechanisms exist to document and validate the scope of cybersecurity & data privacy controls that are determined to meet statutory, regulatory and/or contractual compliance obligations.

null

E-AST-02 E-CPL-02 E-GOV-10

Does the organization document and validate the scope of cybersecurity & data privacy controls that are determined to meet statutory, regulatory and/or contractual compliance obligations?

10

Identify

X

There is no evidence of a capability to document and validate the scope of cybersecurity & data privacy controls that are determined to meet statutory, regulatory and/ or contractual compliance obligations.

SP-CMM1 is N/A, since a structured process is required to document and validate the scope of cybersecurity & data privacy controls that are determined to meet statutory, regulatory and/ or contractual compliance obligations.

Compliance (CPL) 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: • Compliance activities are 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements. • Data process owners and asset custodians are responsible for performing compliance scoping of control applicability for statutory, regulatory and/ or contractual compliance obligations.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • GRC personnel assist data process owners and asset custodians with performing compliance scoping of control applicability for statutory, regulatory and/ or contractual compliance obligations.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to document and validate the scope of cybersecurity & data privacy controls that are determined to meet statutory, regulatory and/ or contractual compliance obligations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to document and validate the scope of cybersecurity & data privacy controls that are determined to meet statutory, regulatory and/ or contractual compliance obligations.

null

CC2.2-POF9 CC5.2-POF2

7.1

null

4.3 4.3(a) 4.3(b) 4.3(c)

null

GOVERN 1.1 GOVERN 1.3

null

GV.OC-03

null

12.5 12.5.1 12.5.2 A3.2 A3.2.1 A3.2.3

null

12.5.1 12.5.2

null

L.6.1

null

B3.a

null

4.4.4 4.4.4.1 4.6.2.4

null

R-AC-1 R-AM-3 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

null

R-AM-3

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

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

Compliance

Cybersecurity & Data Protection Controls Oversight

CPL-02

Mechanisms exist to provide a cybersecurity & data protection controls oversight function that reports to the organization's executive leadership.

- Governance, Risk and Compliance Solution (GRC) tool (SCFConnect, SureCloud,Ostendio, ZenGRC, Archer, RSAM, MetricStream, etc.) - Steering committee - Formalized SDLC program - Formalized DevOps program - Information Assurance Program (IAP) - Security Test & Evaluation (STE)

E-CPL-07 E-CPL-09 E-GOV-04 E-GOV-05 E-GOV-06 E-GOV-13 E-RSK-03

Does the organization provide a cybersecurity & data protection controls oversight function that reports to the organization's executive leadership?

10

Detect

X

There is no evidence of a capability to provide a cybersecurity & data privacy controls oversight function that reports to the organization's executive leadership.

Compliance (CPL) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to govern statutory, regulatory and contractual compliance obligations. • IT personnel self-identify a set of controls that are used to conduct cybersecurity & data privacy control assessments. • IT personnel perform internal assessments of cybersecurity & data privacy controls to determine compliance status.

Compliance (CPL) 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: • Compliance activities are 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity personnel generate a formal report for each security assessment to document the assessment of cybersecurity & data privacy controls. • Compliance reporting is performed, as required.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • An Audit Committee, or similar function: o Reviews the findings from security assessments and oversees long-term remediation efforts, when applicable. o Provides senior leaders with insights into the appropriateness of the organization's technology and information governance processes through recurring audits on pertinent cybersecurity & data privacy-related topics. o Governs changes to compliance operations to ensure its stability, reliability and ongoing improvement.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to provide a cybersecurity & data privacy controls oversight function that reports to the organization's executive leadership.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide a cybersecurity & data privacy controls oversight function that reports to the organization's executive leadership.

CC1.1 CC2.2 CC2.3

CC1.1-POF3 CC4.2-POF1 CC4.2-POF2 CC4.2-POF3

9

null

MEA02.01 MEA02.02 MEA04.01 MEA04.02 MEA04.03 MEA04.04 MEA04.05 MEA04.06 MEA04.07 MEA04.08 MEA04.09

Principle 1 Principle 14 Principle 15 Principle 19 Principle 20

A&A-02 A&A-05 CEK-09 LOG-10 STA-11

CCM-07 GVN-04 LGL-03 SAP-10

SO25

8.2.7

null

RQ-05-17

9.3 9.3.1 9.3.2 9.3.3 9.3.3.1 9.3.3.2

9.1 9.3 10.2

8.1 10.1

12.7.1 18.2.2 18.2.3

5.31 5.36 6.8 8.8 8.34

12.7.1 18.2.2 18.2.3

null

5.10 5.11 5.12

null

T1001, T1001.001, T1001.002, T1001.003, T1003, T1003.001, T1003.002, T1003.003, T1003.004, T1003.005, T1003.006, T1003.007, T1003.008, T1008, T1021.002, T1021.005, T1029, T1030, T1036, T1036.003, T1036.005, T1036.007, T1037, T1037.002, T1037.003, T1037.004, T1037.005, T1041, T1046, T1048, T1048.001, T1048.002, T1048.003, T1052, T1052.001, T1053.006, T1055.009, T1056.002, T1059, T1059.005, T1059.007, T1068, T1070, T1070.001, T1070.002, T1070.003, T1071, T1071.001, T1071.002, T1071.003, T1071.004, T1072, T1078, T1078.001, T1078.003, T1078.004, T1080, T1090, T1090.001, T1090.002, T1090.003, T1095, T1102, T1102.001, T1102.002, T1102.003, T1104, T1105, T1110, T1110.001, T1110.002, T1110.003, T1110.004, T1111, T1132, T1132.001, T1132.002, T1176, T1185, T1187, T1189, T1190, T1195, T1195.001, T1195.002, T1197, T1201, T1203, T1204, T1204.001, T1204.002, T1204.003, T1205, T1205.001, T1210, T1211, T1212, T1213, T1213.001, T1213.002, T1213.003, T1218, T1218.002, T1218.010, T1218.011, T1218.012, T1219, T1221, T1222, T1222.001, T1222.002, T1489, T1498, T1498.001, T1498.002, T1499, T1499.001, T1499.002, T1499.003, T1499.004, T1528, T1530, T1537, T1539, T1542.004, T1542.005, T1543, T1543.002, T1546.003, T1546.004, T1546.013, T1547.003, T1547.011, T1547.013, T1548, T1548.003, T1550.003, T1552, T1552.001, T1552.002, T1552.004, T1552.005, T1553.003, T1555, T1555.001, T1555.002, T1556, T1556.001, T1557, T1557.001, T1557.002, T1558, T1558.002, T1558.003, T1558.004, T1562, T1562.001, T1562.002, T1562.004, T1562.006, T1563.001, T1564.004, T1565, T1565.001, T1565.003, T1566, T1566.001, T1566.002, T1566.003, T1567, T1568, T1568.002, T1569, T1569.002, T1570, T1571, T1572, T1573, T1573.001, T1573.002, T1574, T1574.004, T1574.007, T1574.008, T1574.009, T1598, T1598.001, T1598.002, T1598.003, T1599, T1599.001, T1602, T1602.001, T1602.002

null

Sec 4(C)(4) Sec 4(C)(4)(a) Sec 4(C)(4)(b) Sec 4(C)(4)(c) Sec 4(E)(2)(a) Sec 4(E)(2)(b) Sec 4(E)(3)

GOVERN 1.5

GV.MT-P4 PR.PO-P5

null

S-5

null

CA-7 CA-7(1) PM-14

CA-7

CA-7 CA-7(1)

CA-7 CA-7(1) PM-14

CA-7

CA-7 CA-7(1)

PM-14

null

CA-7

CA-7 CA-7(1)

3.3.8

PM-14

null

PM-14

null

3.12.1 3.12.3

3.12.1[a] 3.12.1[b] 3.12.3

null

PO.2.3

DE.DP-5 PR.IP-5 PR.IP-7

GV.OC-03 ID.IM-01

null

12.11 12.11.1

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

P.2.2

null

1.5.1 5.2.5 9.3

null

ASSET-5.E.MIL3 ASSET-5.F.MIL3 THREAT-3.F.MIL3 RISK-5.F.MIL3 ACCESS-4.F.MIL3 SITUATION-4.F.MIL3 RESPONSE-5.F.MIL3 THIRD-PARTIES-3.F.MIL3 WORKFORCE-4.F.MIL3 ARCHITECTURE-5.F.MIL3 PROGRAM-3.F.MIL3

COMP:SG4.SP1 CTRL:SG3.SP1 GG2.GP9 GG2.GP10 MON:SG1.SP1 MON:SG1.SP3 OPD:SG1.SP1 OTA:SG4.SP1 RISK:SG6.SP2

null

CA.L2-3.12.1 CA.L2-3.12.3

null

CA.L2-3.12.1 CA.L2-3.12.3

CA-7 CA-7(1) PM-14

null

§ 11.10 § 11.10(a) § 11.10(b) § 11.10(c) § 11.10(d) § 11.10(e) § 11.10(f) § 11.10(g) § 11.10(h) § 11.10(i) § 11.10(j) § 11.10(k) § 11.10(k)(1) § 11.10(k)(2)

CA-7 CA-7(1)

CA-7

CA-7 CA-7(1)

CA-7

CA-7 CA-7(1)

CA-7

CA-7 CA-7(1)

CA-7

null

D5.IR.Pl.Int.3 D1.RM.RMP.E.2 D1.G.Ov.A.2

null

314.4(d)(1)

164.308(a)(8)

null

1.6 CA-7 CA-7(1) PM-14

null

8-202 8-302 8-610 8-614

null

5.7 5.11

CA-7

CA-7 CA-7(1)

null

45.48.520

null

Sec 4(2)(b)(ii)(B)(4)

622(2)(B)(iii)

38-99-20(C)(4) 38-99-20(C)(4)(a) 38-99-20(C)(4)(b) 38-99-20(C)(4)(c) 38-99-20(E)(2)(a) 38-99-20(E)(2)(b) 38-99-20(E)(3)

null

Sec 10 Sec 11

CA-7 PM-14

CA-7

CA-7 CA-7(1)

null

§ 2447(b)(2)(C) § 2447(b)(8) § 2447(b)(8)(A)

3.4.6(41) 3.4.6(42) 3.4.6(43) 3.4.6(43)(a) 3.4.6(43)(b) 3.4.6(44) 3.4.6(45) 3.4.6(46) 3.4.6(47) 3.4.6(48)

null

Art 5.2

null

Art 3

Principle 3.4.b

null

Art 13

Art 41

Sec 5 Sec 32 Sec 33 Sec 34 Sec 35

Art 34

Sec 9 Sec 9a Annex

5.6

SP-03

Art 10

Sec 7

Sec 2

1.3 3.1

Sec 16 Sec 17

Sec 31 Sec 33 Sec 34 Sec 35

null

Art 3 Art 4

Sec 12 Sec 13 Sec 14

4.1(5)(a) 4.1(5)(b) 4.1(5)(c) 4.1(5)(d) 4.1(5)(e) 4.1(5)(f) 4.1(5)(g) 4.1(5)(h) 4.1(5)(i) 4.1(5)(j) 4.1(6) 4.1(7)

Sec 13 Sec 14

Art 1 Art 36

Art 14 Art 15 Art 16 Art 17

null

Art 7 Art 19

1-4

null

3.2.4

1-3-2

1-6 1-6-1

null

Sec 8 Sec 19 Sec 21

null

9

Sec 31

Art 7

Art 12

Sec 15 Sec 16

B3.a

null

APP Part 11

null

29 30 58(b) 58(c)

27 27(a) 27(b) 27(c) 27(d) 27(e) 29

null

Sec 4

Article 54

Principle 4

Sec 8

null

Article 21

4.6 4.6.1 4.6.2 4.6.2.2 4.6.2.6 4.6.3 4.6.3.1 4.6.3.2 4.6.2.3 4.6.2.4 12.7.1 18.2.2 18.2.3

Sec 9

null

6.1.7.C.01 23.2.18.C.01

null

Sec 25 Sec 29

Sec 24

null

3.2.3

null

Art 27

Art 9

null

5.7

null

6.10

null

Principle 7

Art 7

null

x

NAIC OR 6464A

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-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

- renamed control - wordsmithed control

Compliance

Internal Audit Function

CPL-02.1

Mechanisms exist to implement an internal audit function that is capable of providing senior organization management with insights into the appropriateness of the organization's technology and information governance processes.

null

E-CPL-04 E-CPL-07

Does the organization implement an internal audit function that is capable of providing senior organization management with insights into the appropriateness of the organization's technology and information governance processes?

5

Detect

null

X

null

There is no evidence of a capability to implement an internal audit function that is capable of providing senior organization management with insights into the appropriateness of the organization's technology and information governance processes.

SP-CMM1 is N/A, since a structured process is required to implement an internal audit function that is capable of providing senior organization management with insights into the appropriateness of the organization's technology and information governance processes.

SP-CMM2 is N/A, since a well-defined process is required to implement an internal audit function that is capable of providing senior organization management with insights into the appropriateness of the organization's technology and information governance processes.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • An assessor from within a GRC function, or similar function, is selected or a third-party assessor is contracted to perform an independent assessment of cybersecurity & data privacy controls.

Compliance (CPL) 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 internal audit function that is capable of providing senior organization management with insights into the appropriateness of the organization's technology and information governance processes.

null

CC4.1-POF1 CC4.1-POF2 CC4.1-POF3 CC4.1-POF4 CC4.1-POF5 CC4.1-POF6 CC4.1-POF7 CC4.1-POF8

null

APO02.04 MEA02.01 MEA02.02 MEA02.03 MEA02.04 MEA04.01 MEA04.02 MEA04.03 MEA04.04 MEA04.05 MEA04.06 MEA04.07 MEA04.08 MEA04.09

Principle 19 Principle 20

A&A-02 A&A-03 A&A-05 CEK-09 LOG-10

GVN-04

null

RQ-05-17

9.2 9.2.1 9.2.2

9.1

9.2 9.2.1 9.2.1(a)(1) 9.2.1(a)(2) 9.2.1(b) 9.2.2 9.2.2(a) 9.2.2(b) 9.2.2(c)

12.7.1

5.35 8.34

12.7.1

null

Sec 4(E)(2)(a) Sec 4(E)(2)(b)

null

3.12.1

null

ID.IM-02 ID.IM-03

null

L.8

null

1.5.1

null

5.11

null

CA.L2-3.12.1

null

CA.L2-3.12.1

null

38-99-20(E)(2)(a) 38-99-20(E)(2)(b)

null

§ 2447(b)(2)(C) § 2447(b)(8) § 2447(b)(8)(A)

3.3.1(11) 3.3.6(25)

null

Principle 3.4.a Principle 3.4.b

null

1-4-2 2-13-4

null

3.2.5

1-8-1 1-8-3

null

46 60

31 32 33 34 34(a) 34(b)

null

Article 54

null

4.6.2 4.6.2.2 4.6.2.3 12.7.1

null

15.1.1 15.1.2 15.1.3 15.1.4

null

5.4 5.6

null

6.17 6.18 6.19 6.20

null

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-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-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

Compliance

Cybersecurity & Data Protection Assessments

CPL-03

Mechanisms exist to ensure managers regularly review the processes and documented procedures within their area of responsibility to adhere to appropriate cybersecurity & data protection policies, standards and other applicable requirements.

- Information Assurance Program (IAP) - Security Test & Evaluation (STE) - Governance, Risk and Compliance Solution (GRC) tool (SCFConnect, SureCloud,Ostendio, ZenGRC, Archer, RSAM, MetricStream, etc.)

E-CPL-05 E-CPL-07

Does the organization ensure managers regularly review the processes and documented procedures within their area of responsibility to adhere to appropriate cybersecurity & data protection policies, standards and other applicable requirements?

10

Detect

null

X

There is no evidence of a capability to ensure managers regularly review the processes and documented procedures within their area of responsibility to adhere to appropriate cybersecurity & data protection policies, standards and other applicable requirements.

Compliance (CPL) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to govern statutory, regulatory and contractual compliance obligations. • IT personnel self-identify a set of controls that are used to conduct cybersecurity & data privacy control assessments. • IT personnel perform internal assessments of cybersecurity & data privacy controls to determine compliance status.

Compliance (CPL) 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: • Compliance activities are 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity personnel either use an impartial member of its team or a third-party assessor to perform an independent assessment of cybersecurity & data privacy controls.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • Cybersecurity personnel either use an impartial member of its team or a third-party assessor to perform an independent assessment of cybersecurity & data privacy controls.

Compliance (CPL) 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 managers regularly review the processes and documented procedures within their area of responsibility to adhere to appropriate cybersecurity & data protection policies, standards and other applicable requirements.

CC4.1

CC1.1-POF3

9

null

MEA02.01 MEA02.02 MEA02.03 MEA02.04

Principle 16

A&A-02 A&A-05 CEK-09 LOG-10 STA-11

GVN-04 SAP-10

null

10.2.4

null

RQ-05-17

null

9.2

8.1 9.1 9.1(a) 9.1(b) 9.1(c) 9.1(d) 9.1(e) 9.1(f)

18.2.2

5.35 5.36 8.34

18.2.2

null

6.15.2.2

5.12

null

T1190, T1195, T1195.001, T1195.002, T1210

null

Sec 4(C)(4) Sec 4(E)(2)(a) Sec 4(E)(2)(b)

GOVERN 1.5

ID.DE-P5

null

A-3 A-4

null

CA-2

null

CA-2

3.4.9

CA-2

null

CA-2

3.12.1

null

A.03.12.01

null

ID.IM-02 ID.IM-03

null

10.7 10.7.1 10.7.2 10.7.3 11.1 12.4.2

null

10.7.2 10.7.3

10.7.1 10.7.2 10.7.3 12.4.2

null

C.1.9

null

1.5.1 1.5.2 9.3

null

ASSET-5.E.MIL3 ASSET-5.F.MIL3 THREAT-3.F.MIL3 RISK-5.F.MIL3 ACCESS-4.F.MIL3 SITUATION-4.F.MIL3 RESPONSE-5.F.MIL3 THIRD-PARTIES-3.F.MIL3 WORKFORCE-4.F.MIL3 ARCHITECTURE-5.F.MIL3 PROGRAM-3.F.MIL3

CTRL:SG4.SP1 RISK:SG3.SP1

null

CA.L2-3.12.1

null

CA.L2-3.12.1

CA-2

null

§ 11.10 § 11.10(a) § 11.10(b) § 11.10(c) § 11.10(d) § 11.10(e) § 11.10(f) § 11.10(g) § 11.10(h) § 11.10(i) § 11.10(j) § 11.10(k) § 11.10(k)(1) § 11.10(k)(2)

null

314.4(d)(1)

164.308(a)(8)

null

1.6 1.6.1 1.6.2 1.6.3 2.D.3 CA-2

null

8-610

4.1 4.4

null

5.11

null

17.03(2)(h)

null

Sec 4(2)(b)(ii)(B)(4)

622(2)(B)(i) 622(2)(B)(ii) 622(2)(B)(iii) 622(2)(B)(iv)

38-99-20(C)(4) 38-99-20(E)(2)(a) 38-99-20(E)(2)(b)

null

Sec 11

CA-2

null

3.3.6(26) 3.3.6(27) 3.4.6(41) 3.4.6(42) 3.4.6(43) 3.4.6(43)(a) 3.4.6(43)(b) 3.4.6(44) 3.4.6(45) 3.4.6(46) 3.4.6(47) 3.4.6(48)

null

Art 5.2 Art 32.3

Article 21.1

Art 3 Art 29

Principle 3.4.b Principle 3.6.a Principle 3.6.b Principle 3.6.b.i Principle 3.6.b.ii Principle 3.6.b.iii Principle 3.6.b.iii.1 Principle 3.6.b.iii.2 Principle 3.6.b.iv Principle 3.6.b.iv.1 Principle 3.6.b.iv.2 Principle 3.6.b.v Principle 3.6.b.vi Principle 3.6.b.vii Principle 3.6.b.viii Principle 3.6.c Principle 3.6.d Principle 3.6.e Principle 3.6.f Principle 3.6.g Principle 3.6.h Principle 3.7.a Principle 3.7.b Principle 3.7.c Principle 3.7.d Principle 3.7.e

null

Art 13

Art 41

null

Art 34

null

5.6

COM-03

null

Sec 7

Sec 2

3.1

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

Article 11.7 Article 11.8

Art 7

1-4-1 2-13-4

null

3.2.4 3.2.5

1-3-2 1-8-1

1-6 1-6-1 1-6-2

null

Sec 8 Sec 19 Sec 21

null

Sec 31

null

B3.a

null

30

null

Article 38(1) Article 38(2) Article 40

null

Article 40(1) Article 40(2) Article 40(3)

4.6.1 4.6.2 4.6.2.2 4.6.2.5 4.2.6.6 4.6.2.7 18.2.2

Sec 9

null

4.3.16.C.01 6.1.7.C.01 6.1.9.C.01 23.2.18.C.01

null

Sec 25

Sec 24

null

4.5.1

null

Art 9

null

6.10

null

Art 7

null

x

MA 201 CMR 17 OR 6464A 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-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

- renamed control - wordsmithed control

Compliance

Independent Assessors

CPL-03.1

Mechanisms exist to utilize independent assessors to evaluate cybersecurity & data protection controls at planned intervals or when the system, service or project undergoes significant changes.

- Information Assurance Program (IAP) - Security Test & Evaluation (STE)

E-CPL-07

Does the organization utilize independent assessors to evaluate cybersecurity & data protection controls at planned intervals or when the system, service or project undergoes significant changes?

6

Detect

null

X

null

There is no evidence of a capability to utilize independent assessors to evaluate cybersecurity & data protection controls at planned intervals or when the system, service or project undergoes significant changes.

Compliance (CPL) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to govern statutory, regulatory and contractual compliance obligations. • IT personnel self-identify a set of controls that are used to conduct cybersecurity & data privacy control assessments. • IT personnel perform internal assessments of cybersecurity & data protection controls to determine compliance status. • F or specific statutory, regulatory and/ or contractual obligations, stakeholders may contract with a third-party auditor/assessor to perform an independent assessment of cybersecurity & data protection controls.

Compliance (CPL) 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: • Compliance activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity personnel either use an impartial member of its team or a third-party assessor to perform an independent assessment of cybersecurity & data protection controls.

Compliance (CPL) 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 Governance, Risk & Compliance (GRC) function, or similar function, provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data protection controls to ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data protection controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data protection controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • Cybersecurity personnel either use an impartial member of its team or a third-party assessor to perform an independent assessment of cybersecurity & data protection controls.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to utilize independent assessors to evaluate cybersecurity & data protection controls at planned intervals or when the system, service or project undergoes significant changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize independent assessors to evaluate cybersecurity & data protection controls at planned intervals or when the system, service or project undergoes significant changes.

null

MEA03.03 MEA03.04 MEA04.01

null

A&A-05 CEK-09

null

RQ-05-17

null

9.2

null

18.2.1

5.35

18.2.1

null

6.15.2 6.15.2.1

null

CA-7(1)

null

CA-7(1)

null

CA-7(1)

null

CA-7(1)

3.4.9

null

NFO - CA-7(1)

null

B.1.1.28

null

1.5.1 1.5.2

null

5.11 5.11.1 5.11.1.1 5.11.1.2 5.11.2 5.11.3 5.11.4

null

5.11

null

45.48.520

null

Sec 11

null

3.3.6(25) 3.4.6(41) 3.4.6(42) 3.4.6(42) 3.4.6(43)(a) 3.4.6(43)(b)

null

Art 40.2 Art 42.1 Art 42.2 Art 42.3 Art 42.4 Art 42.6 Art 42.7 Art 43.2

null

Art 3

null

COM-03

null

1-4-2

TPC-20 TPC-21

null

1-8-2

1-6-1 1-6-2

null

Sec 60

null

9

null

30

null

Article 38(1) Article 38(2) Article 40

null

4.6.1 4.6.2.5 18.2.1

null

6.1.8.C.01

null

6.13 6.25

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 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

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-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

- wordsmithed control

Compliance

Functional Review Of Cybersecurity & Data Protection Controls

CPL-03.2

Mechanisms exist to regularly review technology assets for adherence to the organization’s cybersecurity & data protection policies and standards.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Internal audit program - NNT Change Tracker (https://www.newnettechnologies.com) - Operational review processes - Regular/yearly policy and standards review process - Governance, Risk and Compliance Solution (GRC) (ZenGRC, Archer, RSAM, Metric stream, etc.)

E-CPL-08

Does the organization regularly review technology assets for adherence to the organization’s cybersecurity & data protection policies and standards?

8

Detect

X

There is no evidence of a capability to regularly review technology assets for adherence to the organization’s cybersecurity & data protection policies and standards.

Compliance (CPL) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to govern statutory, regulatory and contractual compliance obligations. • IT personnel self-identify a set of controls that are used to conduct cybersecurity & data privacy control assessments. • IT personnel perform internal assessments of cybersecurity & data privacy controls to determine compliance status.

Compliance (CPL) 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: • Compliance activities are 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity personnel either use an impartial member of its team or a third-party assessor to perform an independent assessment of cybersecurity & data privacy controls.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • Cybersecurity personnel either use an impartial member of its team or a third-party assessor to perform an independent assessment of cybersecurity & data privacy controls. • Up on completing an assessment, the GRC function generates a formal report that documents the assessment of cybersecurity & data privacy controls to determine the effectiveness of controls and their ability to meet regulatory and company standards requirements.

Compliance (CPL) 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 regularly review technology assets for adherence to the organization’s cybersecurity & data protection policies and standards.

CC4.1

CC7.2-POF4

null

MEA02.01 MEA02.02

Principle 16

A&A-05 CEK-09 IVS-03 STA-11

CCM-07 GVN-04 SAP-10

null

RQ-05-17

null

9.1

null

18.2.3

5.35 5.36 8.8

18.2.3

null

6.15.2.3

null

T1190, T1195, T1195.001, T1195.002, T1210

null

Sec 4(C)(4)

null

PR.PO-P5

null

A-3 A-4

null

CA-2 RA-3

null

CA-2 RA-3

3.4.9

CA-2 RA-3

null

RA-3

CA-2 RA-3

null

ID.IM-02

null

1.2.7 10.7 10.7.1 10.7.2 10.7.3 11.1 12.4.2

null

1.2.7

null

1.2.7 10.7.2 10.7.3

1.2.7 10.7.1 10.7.2 10.7.3 12.4.2

null

L.6.1

null

5.2.5

null

CTRL:SG3.SP1 CTRL:SG4.SP1 RISK:SG3.SP1

null

CA-2 RA-3

null

§ 11.10 § 11.10(a) § 11.10(b) § 11.10(c) § 11.10(d) § 11.10(e) § 11.10(f) § 11.10(g) § 11.10(h) § 11.10(i) § 11.10(j) § 11.10(k) § 11.10(k)(1) § 11.10(k)(2) § 11.300(e)

null

CA-2 RA-3

null

8-610

4.1 4.4

null

5.11

null

Sec 4(2)(b)(ii)(B)(4)

null

38-99-20(C)(4)

null

Sec 11

CA-2 RA-3

RA-3

null

3.3.6(26) 3.3.6(27) 3.4.6(41) 3.4.6(42) 3.4.6(43) 3.4.6(43)(a) 3.4.6(43)(b) 3.4.6(44) 3.4.6(45) 3.4.6(46) 3.4.6(47) 3.4.6(48)

null

Article 21.1

Art 3

null

5.6

COM-01

null

3.1 3.3 12.30

null

Article 11.7 Article 11.8

null

1-4-1

null

1-8-1

null

B3.a

null

Article 54

null

18.2.3

null

6.1.7.C.01 6.1.9.C.01 23.2.18.C.01

null

4.5.1

null

5.7

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-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-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

- renamed control - wordsmithed control

Compliance

Audit Activities

CPL-04

Mechanisms exist to thoughtfully plan audits by including input from operational risk and compliance partners to minimize the impact of audit-related activities on business operations.

- Internal audit program

null

Does the organization thoughtfully plan audits by including input from operational risk and compliance partners to minimize the impact of audit-related activities on business operations?

5

Identify

null

X

null

There is no evidence of a capability to thoughtfully plan audits by including input from operational risk and compliance partners to minimize the impact of audit-related activities on business operations.

Compliance (CPL) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to govern statutory, regulatory and contractual compliance obligations. • IT personnel self-identify a set of controls that are used to conduct cybersecurity & data privacy control assessments. • IT personnel perform internal assessments of cybersecurity & data privacy controls to determine compliance status. • IT personnel use an informal process to notify stakeholders about audit activities to minimize the impact of audit/assessment activities on business operations.

Compliance (CPL) 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: • Compliance activities are 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity personnel use an informal process to notify stakeholders about audit activities to minimize the impact of audit activities on business operations.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • Cybersecurity personnel use an defined process to notify stakeholders about audit activities to minimize the impact of audit activities on business operations.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to thoughtfully plan audits by including input from operational risk and compliance partners to minimize the impact of audit-related activities on business operations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to thoughtfully plan audits by including input from operational risk and compliance partners to minimize the impact of audit-related activities on business operations.

CC4.1

null

Principle 16

A&A-05

null

9.2

null

12.7.1

5.35 8.34

12.7.1

null

6.9.7 6.9.7.1

null

GOVERN 1.5

null

3.4.9

null

ID.IM-04

null

L.8.4.1

null

CIP-014-2 R2

null

IV.C.2.a IV.C.2.b IV.C.2.c IV.C.2.d IV.C.2.e IV.C.2.e.i IV.C.2.e.ii IV.C.2.e.iii IV.C.2.e.iv IV.C.2.f

null

Art 3

null

COM-02 COM-03

null

4.6.1 12.7.1

null

x

null

x

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

null

R-BC-1

null

R-EX-1

R-EX-2

null

R-EX-4

R-EX-5

null

R-GV-1

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

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

Compliance

Legal Assessment of Investigative Inquires

CPL-05

Mechanisms exist to determine whether a government agency has an applicable and valid legal basis to request data from the organization and what further steps need to be taken, if necessary.

null

Does the organization determine whether a government agency has an applicable and valid legal basis to request data from the organization and what further steps need to be taken, if necessary?

2

Respond

null

X

null

There is no evidence of a capability to determine whether a government agency has an applicable and valid legal basis to request data from the organization and what further steps need to be taken, if necessary.

SP-CMM1 is N/A, since a structured process is required to determine whether a government agency has an applicable and valid legal basis to request data from the organization and what further steps need to be taken, if necessary.

Compliance (CPL) 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: • Compliance activities are 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to determine whether a government agency has an applicable and valid legal basis to request data from the organization and what further steps need to be taken, if necessary.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to determine whether a government agency has an applicable and valid legal basis to request data from the organization and what further steps need to be taken, if necessary.

null

DSP-18

null

L.2.5

null

INQ-01

null

Article 41

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 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

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-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

Compliance

Investigation Request Notifications

CPL-05.1

Mechanisms exist to notify customers about investigation request notifications, unless the applicable legal basis for a government agency's action prohibits notification (e.g., potential criminal prosecution).

null

Does the organization notify customers about investigation request notifications, unless the applicable legal basis for a government agency's action prohibits notification (e.g., potential criminal prosecution)?

2

Respond

null

X

null

There is no evidence of a capability to notify customers about investigation request notifications, unless the applicable legal basis for a government agency's action prohibits notification (e.g., potential criminal prosecution).

SP-CMM1 is N/A, since a structured process is required to notify customers about investigation request notifications, unless the applicable legal basis for a government agency's action prohibits notification (e.g., potential criminal prosecution).

Compliance (CPL) 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: • Compliance activities are 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements. • Requests for investigations are handled through a formal, management-approved process. • Legal representation is consulted on an as-needed basis.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • An Integrated Security Incident Response Team (ISIRT) is formed to analyze and respond to government investigation requests, with legal representation being a key stakeholder. • Client or host-nation requests are formally evaluated to determine the risk impact of the request.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to notify customers about investigation request notifications, unless the applicable legal basis for a government agency's action prohibits notification (e.g., potential criminal prosecution).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to notify customers about investigation request notifications, unless the applicable legal basis for a government agency's action prohibits notification (e.g., potential criminal prosecution).

null

DSP-18

null

P.9.7

null

INQ-02

null

Article 18

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 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

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-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

Compliance

Investigation Access Restrictions

CPL-05.2

Mechanisms exist to support official investigations by provisioning government investigators with "least privileges" and "least functionality" to ensure that government investigators only have access to the data and systems needed to perform the investigation.

null

Does the organization support official investigations by provisioning government investigators with "least privileges" and "least functionality" to ensure that government investigators only have access to the data and systems needed to perform the investigation?

2

Protect

null

X

null

There is no evidence of a capability to support official investigations by provisioning government investigators with "least privileges" and "least functionality" to ensure that government investigators only have access to the data and systems needed to perform the investigation.

SP-CMM1 is N/A, since a structured process is required to support official investigations by provisioning government investigators with "least privileges" and "least functionality" to ensure that government investigators only have access to the data and systems needed to perform the investigation.

Compliance (CPL) 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: • Compliance activities are 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for compliance activities. • Cybersecurity personnel use a defined set of controls to conduct cybersecurity & data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements. • Legal representation is consulted on an as-needed basis.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • An Integrated Security Incident Response Team (ISIRT) is formed to analyze and respond to government investigation requests, with legal representation being a key stakeholder. • Client or host-nation requests are formally evaluated to determine the risk impact of the request.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to support official investigations by provisioning government investigators with "least privileges" and "least functionality" to ensure that government investigators only have access to the data and systems needed to perform the investigation.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to support official investigations by provisioning government investigators with "least privileges" and "least functionality" to ensure that government investigators only have access to the data and systems needed to perform the investigation.

null

DSP-18

null

H.2.3

null

IV.C.1 IV.C.2 IV.C.2.a IV.C.2.b IV.C.2.c IV.C.2.d IV.C.2.e IV.C.2.e.i IV.C.2.e.ii IV.C.2.e.iii IV.C.2.e.iv IV.C.2.f

null

INQ-03 INQ-04

null

Article 61(4) Article 63 Article 63(1) Article 63(2) Article 63(3) Article 63(4) Article 64

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 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

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-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

Compliance

Government Surveillance

CPL-06

Mechanisms exist to constrain the host government from having unrestricted and non-monitored access to the organization's systems, applications and services that could potentially violate other applicable statutory, regulatory and/or contractual obligations.

- Board of Directors (Bod) Ethics Committee

null

Does the organization constrain the host government from having unrestricted and non-monitored access to the organization's systems, applications and services that could potentially violate other applicable statutory, regulatory and/or contractual obligations?

10

Protect

X

There is no evidence of a capability to constrain the host government from having unrestricted and non-monitored access to the organization's systems, applications and services that could potentially violate other applicable statutory, regulatory and/ or contractual obligations.

SP-CMM1 is N/A, since a structured process is required to constrain the host government from having unrestricted and non-monitored access to the organization's systems, applications and services that could potentially violate other applicable statutory, regulatory and/ or contractual obligations.

SP-CMM2 is N/A, since a well-defined process is required to constrain the host government from having unrestricted and non-monitored access to the organization's systems, applications and services that could potentially violate other applicable statutory, regulatory and/ or contractual obligations.

Compliance (CPL) 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 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 ensure compliance requirements are identified and documented. • The GRC function, or similar function: o Ensures data/process owners understand their requirements to manage applicable cybersecurity & data privacy controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity & data privacy controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity & data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. • Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts. • An Integrated Security Incident Response Team (ISIRT) is formed to analyze and respond to government investigation requests, with legal representation being a key stakeholder. • Client or host-nation requests are formally evaluated to determine the risk impact of the request. • The CIO/CISO collaborate on methods to prevent a host government from having unrestricted and non-monitored access to the organization's systems, applications and services which could potentially violate other applicable statutory, regulatory and/ or contractual obligations.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to constrain the host government from having unrestricted and non-monitored access to the organization's systems, applications and services that could potentially violate other applicable statutory, regulatory and/ or contractual obligations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to constrain the host government from having unrestricted and non-monitored access to the organization's systems, applications and services that could potentially violate other applicable statutory, regulatory and/ or contractual obligations.

null

L.9.4

null

Article 24 Article 27 Article 31 Article 33 Article 44

null

Article 11 Article 12 Article 26 Article 38(4) Article 40 Article 47(5) Article 60 Article 61(4) Article 63(3) Article 63(4) Article 64

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 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

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-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

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

Configuration Management

Configuration Management Program

CFG-01

Mechanisms exist to facilitate the implementation of configuration management controls.

- NNT Change Tracker (https://www.newnettechnologies.com) - Configuration Management Database (CMDB) - Baseline hardening standards - Formalized DevOps program - Information Assurance Program (IAP) - Security Test & Evaluation (STE)

null

Does the organization facilitate the implementation of configuration management controls?

9

Protect

X

There is no evidence of a capability to facilitate the implementation of configuration management controls.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 secure configuration 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 organization with regards to secure configuration management. • 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 to ensure that secure configuration management are identified and documented. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including secure configuration management to provide clear and authoritative accountability for secure configuration management operations. • The configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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-POF1

null

4.0 4.1

4.1

BAI10.01 BAI10.02 BAI10.03 BAI10.04 BAI10.05 DSS06.06

null

UEM-03 UEM-07

CCM-02 CCM-08

null

CR 7.6 (11.8.1)

null

9.4.1

8.3 8.9 8.12

9.4.1

null

T1001, T1001.001, T1001.002, T1001.003, T1003, T1003.001, T1003.002, T1003.003, T1003.004, T1003.005, T1003.006, T1003.007, T1003.008, T1008, T1011, T1011.001, T1020.001, T1021, T1021.001, T1021.002, T1021.003, T1021.004, T1021.005, T1021.006, T1027, T1029, T1030, T1036, T1036.001, T1036.003, T1036.005, T1036.007, T1037, T1037.002, T1037.003, T1037.004, T1037.005, T1046, T1047, T1048, T1048.001, T1048.002, T1048.003, T1052, T1052.001, T1053, T1053.002, T1053.005, T1055, T1055.008, T1056.003, T1059, T1059.001, T1059.002, T1059.003, T1059.004, T1059.005, T1059.006, T1059.007, T1059.008, T1068, T1070, T1070.001, T1070.002, T1070.003, T1071, T1071.001, T1071.002, T1071.003, T1071.004, T1072, T1078, T1078.002, T1078.003, T1078.004, T1087, T1087.001, T1087.002, T1090, T1090.001, T1090.002, T1090.003, T1091, T1092, T1095, T1098, T1098.001, T1098.002, T1098.003, T1098.004, T1102, T1102.001, T1102.002, T1102.003, T1104, T1105, T1106, T1110, T1110.001, T1110.002, T1110.003, T1110.004, T1111, T1114, T1114.002, T1114.003, T1119, T1127, T1127.001, T1132, T1132.001, T1132.002, T1133, T1134, T1134.001, T1134.002, T1134.003, T1134.005, T1135, T1136, T1136.001, T1136.002, T1136.003, T1137, T1137.001, T1137.002, T1137.003, T1137.004, T1137.005, T1137.006, T1176, T1187, T1189, T1190, T1197, T1199, T1201, T1204, T1204.001, T1204.002, T1204.003, T1205, T1205.001, T1210, T1211, T1212, T1213, T1213.001, T1213.002, T1216, T1216.001, T1218, T1218.001, T1218.002, T1218.003, T1218.004, T1218.005, T1218.007, T1218.008, T1218.009, T1218.012, T1218.013, T1218.014, T1219, T1220, T1221, T1222, T1222.001, T1222.002, T1482, T1484, T1489, T1490, T1495, T1498, T1498.001, T1498.002, T1499, T1499.001, T1499.002, T1499.003, T1499.004, T1505, T1505.001, T1505.002, T1505.003, T1505.004, T1525, T1528, T1530, T1537, T1539, T1542, T1542.001, T1542.003, T1542.004, T1542.005, T1543, T1543.002, T1546, T1546.002, T1546.003, T1546.004, T1546.006, T1546.008, T1546.013, T1546.014, T1547.002, T1547.003, T1547.005, T1547.006, T1547.007, T1547.008, T1547.011, T1547.013, T1548, T1548.001, T1548.002, T1548.003, T1548.004, T1550, T1550.001, T1550.002, T1550.003, T1552, T1552.001, T1552.002, T1552.003, T1552.004, T1552.005, T1552.006, T1552.007, T1553, T1553.001, T1553.003, T1553.004, T1553.005, T1554, T1555.004, T1555.005, T1556, T1556.001, T1556.002, T1556.003, T1556.004, T1557, T1557.001, T1557.002, T1558, T1558.001, T1558.002, T1558.003, T1558.004, T1559, T1559.001, T1559.002, T1562, T1562.001, T1562.002, T1562.003, T1562.004, T1562.006, T1562.009, T1562.010, T1563, T1563.001, T1563.002, T1564.002, T1564.006, T1564.007, T1564.009, T1565, T1565.001, T1565.002, T1565.003, T1566, T1566.001, T1566.002, T1569, T1569.002, T1570, T1571, T1572, T1573, T1573.001, T1573.002, T1574, T1574.001, T1574.004, T1574.005, T1574.006, T1574.007, T1574.008, T1574.009, T1574.010, T1598, T1598.002, T1598.003, T1599, T1599.001, T1601, T1601.001, T1601.002, T1602, T1602.001, T1602.002, T1609, T1610, T1611, T1612, T1613

TS-2.6

null

PR.PO-P1

null

CM-1 CM-9

CM-1

CM-1 CM-9

CM-1

CM-1 CM-9

null

CM-1

CM-1 CM-9

3.3.5 3.4.7 3.4.8

CM-1 CM-9

CM-1

CM-9

CM-1

CM-1 CM-9

NFO - CM-1 NFO - CM-9

null

A.03.04.03.a

null

PR.IP-1

PR.PS PR.PS-01

A05:2021

1.1.5

2.1 8.5

null

D.1.1

null

TM:SG4.SP2

null

CM-1 CM-9

null

CM-1 CM-9

CM-1

CM-1 CM-9

CM-1

CM-1 CM-9

CM-1

CM-1 CM-9

CM-1

null

1.S.A 2.S.A 3.S.A 6.S.B 6.S.C

1.M.A 2.M.A 9.M.A 9.M.B

1.M.A 2.M.A 9.M.A 9.M.B 2.L.A

CM-1 CM-9

null

8-311 8-610

5.1 5.2

null

CM-1

CM-1 CM-9

null

6-1-1305(4)

null

CM-1

CM-1 CM-9

null

Art 9.3(a) Art 9.3(b) Art 9.3(c) Art 9.3(d)

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

6.8

AM-03

null

3.3 9.22 9.23 14.1

null

2-3-1-6

TPC-2

null

1-6-2-2 2-4-4 2-5-4

null

7.3.3 [OP.EXP.3]

null

B4.b

B4

2

null

Principle 1.1

null

9.4.1 9.4.1.8.PB

null

4.3.19.C.01 12.2.5.C.01 12.2.5.C.02 12.2.6.C.01 12.2.6.C.02 18.1.10.C.01 18.1.10.C.02 18.1.10.C.03 18.1.10.C.04

null

4.3(a)

7.2.1 7.2.2 7.3.1 7.3.2 7.3.3

null

6.1

null

3.2.3

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-10 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

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Configuration Management

Assignment of Responsibility

CFG-01.1

Mechanisms exist to implement a segregation of duties for configuration management that prevents developers from performing production configuration management duties.

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

null

Does the organization implement a segregation of duties for configuration management that prevents developers from performing production configuration management duties?

5

Identify

null

X

There is no evidence of a capability to implement a segregation of duties for configuration management that prevents developers from performing production configuration management duties.

SP-CMM1 is N/A, since a structured process is required to implement a segregation of duties for configuration management that prevents developers from performing production configuration management duties.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software. • The Human Resources (HR) department ensures industry-recognized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization. • HR defines terms of employment, including acceptable and unacceptable rules of behavior for the use of technologies, including consequences for unacceptable behavior.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • The Human Resources (HR) department ensures industry-recognized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization. • HR defines terms of employment, including acceptable and unacceptable rules of behavior for the use of technologies, including consequences for unacceptable behavior.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to implement a segregation of duties for configuration management that prevents developers from performing production configuration management duties.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to implement a segregation of duties for configuration management that prevents developers from performing production configuration management duties.

null

8.9

null

CM-9(1)

null

CM-9(1)

null

CM-9(1)

null

2.1

null

G.2.5.1

null

4.3.19.C.01

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-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

Configuration Management

System Hardening Through Baseline Configurations

CFG-02

Mechanisms exist to develop, document and maintain secure baseline configurations for technology platforms that are consistent with industry-accepted system hardening standards.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Defense Information Security Agency (DISA) Secure Technology Implementation Guides (STIGs) - Center for Internet Security (CIS) Benchmarks - NNT Change Tracker (https://www.newnettechnologies.com)

E-AST-12 E-AST-13 E-AST-14 E-AST-15 E-AST-16 E-AST-17 E-AST-18 E-AST-19 E-AST-20 E-AST-21

Does the organization develop, document and maintain secure baseline configurations for technology platforms that are consistent with industry-accepted system hardening standards?

10

Protect

X

There is no evidence of a capability to develop, document and maintain secure baseline configurations for technology platforms that are consistent with industry-accepted system hardening standards.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • The review of any request for deviating from baseline configurations is documented and a risk assessment performed to determine if the deviation is acceptable.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software. • Secure baseline configurations: o Enforce logging to link system access to individual users or service accounts using a non-repudiation capability to protect against an individual falsely denying having performed a particular action. o Generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. o Restrict access to the management of event logs for privileged users to protect event logs and audit tools from unauthorized access, modification and deletion. o Retain security event logs for a time period consistent with records retention requirements to provide support for after-the-fact investigations of security incidents and to meet statutory, regulatory and contractual retention requirements. o Store logs locally and forward logs to a centralized log repository to provide an alternate audit capability in the event of a failure in the primary audit capability. o Use internal system clocks to generate time stamps for security event logs that are synchronized with an authoritative time source.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Secure baseline configurations: o Enforce logging that links system access to individual users or service accounts using non-repudiation to protect against an individual falsely denying having performed a particular action. o Generate logs that contain sufficient information to establish necessary details of activity and allow for forensic analysis. o Prevent sensitive/regulated data from being captured in log files. o Restrict access to the management of event logs for privileged users to protect event logs and audit tools from unauthorized access, modification and deletion. o Retain security event logs for a time period consistent with records retention requirements for investigations of security incidents and to meet statutory, regulatory and contractual retention requirements. o Store logs locally and forward logs to a centralized log repository to provide an alternate audit capability in the event of a failure in primary audit capability. o Use internal system clocks to generate time stamps for security event logs that are synchronized with an authoritative time source. o Verbosely log all traffic (both allowed and blocked) arriving at network boundary devices, including firewalls, Intrusion Detection / Prevention Systems (IDS/IPS) and inbound and outbound proxies.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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 CC8.1

CC7.1-POF1

null

4.1 4.3 4.4 4.5 4.6 4.7 4.8 4.11 10.3 10.4 10.5 16.7

4.1 4.3 4.4 4.5 4.6 4.7 10.3

4.1 4.3 4.4 4.5 4.6 4.7 4.8 4.11 10.3 10.4 10.5 16.7

BAI10.02 DSS06.06

null

AIS-02 CCC-06 IVS-03 IVS-04 UEM-07

CLS-05 IOT-02 IOT-07 SWS-01 SWS-02

null

CR 2.2 (6.4.1) CR 7.6 (11.8.1)

null

9.4.1 14.1.1

8.3 8.5 8.9 8.12 8.25 8.26

9.4.1 CLD.9.5.2 14.1.1

null

6.11 6.11.1 6.11.1.1

null

T1001, T1001.001, T1001.002, T1001.003, T1003, T1003.001, T1003.002, T1003.003, T1003.004, T1003.005, T1003.006, T1003.007, T1003.008, T1008, T1011.001, T1020.001, T1021.001, T1021.002, T1021.003, T1021.004, T1021.005, T1021.006, T1027, T1029, T1030, T1036, T1036.001, T1036.003, T1036.005, T1036.007, T1037, T1037.002, T1037.003, T1037.004, T1037.005, T1046, T1047, T1048, T1048.001, T1048.002, T1048.003, T1052, T1052.001, T1053, T1053.002, T1053.005, T1059, T1059.001, T1059.002, T1059.003, T1059.004, T1059.005, T1059.006, T1059.007, T1059.008, T1068, T1070, T1070.001, T1070.002, T1070.003, T1071, T1071.001, T1071.002, T1071.003, T1071.004, T1072, T1080, T1090, T1090.001, T1090.002, T1091, T1092, T1095, T1098.004, T1102, T1102.001, T1102.002, T1102.003, T1104, T1105, T1106, T1110, T1110.001, T1110.002, T1110.003, T1110.004, T1111, T1114, T1114.002, T1119, T1127, T1127.001, T1129, T1132, T1132.001, T1132.002, T1133, T1134.005, T1137, T1137.001, T1137.002, T1137.003, T1137.004, T1137.005, T1137.006, T1176, T1185, T1187, T1189, T1201, T1204, T1204.001, T1204.002, T1204.003, T1205, T1210, T1211, T1212, T1213, T1213.001, T1213.002, T1216, T1216.001, T1218, T1218.001, T1218.002, T1218.003, T1218.004, T1218.005, T1218.007, T1218.008, T1218.009, T1218.012, T1218.013, T1218.014, T1219, T1220, T1221, T1484, T1485, T1486, T1490, T1491, T1491.001, T1491.002, T1505, T1505.001, T1505.002, T1505.003, T1505.004, T1525, T1528, T1530, T1539, T1542.004, T1542.005, T1543, T1543.001, T1543.002, T1543.003, T1543.004, T1546, T1546.002, T1546.003, T1546.004, T1546.006, T1546.010, T1546.013, T1546.014, T1547.003, T1547.007, T1547.008, T1547.011, T1547.013, T1548, T1548.002, T1548.003, T1548.004, T1550.001, T1550.003, T1552, T1552.001, T1552.004, T1552.006, T1553, T1553.001, T1553.003, T1553.005, T1554, T1555.004, T1555.005, T1556, T1556.004, T1557, T1557.001, T1557.002, T1558, T1558.001, T1558.002, T1558.003, T1558.004, T1559, T1559.001, T1559.002, T1561, T1561.001, T1561.002, T1562, T1562.001, T1562.002, T1562.003, T1562.004, T1562.006, T1562.010, T1563, T1563.001, T1563.002, T1564.006, T1564.007, T1564.009, T1565, T1565.001, T1565.002, T1566, T1566.001, T1566.002, T1569, T1569.002, T1570, T1571, T1572, T1573, T1573.001, T1573.002, T1574, T1574.001, T1574.004, T1574.005, T1574.007, T1574.008, T1574.009, T1574.010, T1598, T1598.002, T1598.003, T1599, T1599.001, T1601, T1601.001, T1601.002, T1602, T1602.001, T1602.002

TS-1.1 TS-2.3 TS-2.11

null

PR.PO-P1

null

I-2

null

CM-2 CM-6 SA-8

CM-2 CM-6

CM-2 CM-6 SA-8

CM-2 CM-6 PL-10 SA-8 SA-15(5)

null

CM-2 CM-6 SA-8 PL-10

SA-15(5)

null

CM-2 CM-6 SA-8 PL-10

3.4.7 3.4.8

CM-2 CM-6 PL-10 SA-8

CM-2 CM-6

SA-8

CM-2 CM-6 PL-10 SA-8

3.4.1 3.4.2

3.1.12.a 3.1.16.a 3.1.18.a 3.1.18.c 3.4.1.a 3.4.2.a 3.4.6.a 3.4.6.b 3.4.6.a 3.4.6.b 3.4.6.d 3.5.7.e 3.5.7.f 3.5.12.d

3.4.1[a] 3.4.1[b] 3.4.1[c] 3.4.2[a] 3.4.2[b]

A.03.01.12.a[03] A.03.01.16.a[03] A.03.01.18.a[02] A.03.03.01.a A.03.03.07.b[01] A.03.04.01.a[01] A.03.04.01.a[02] A.03.04.02.a[01] A.03.04.02.a[02] A.03.04.02.ODP[01] A.03.04.06.ODP[01] A.03.04.06.ODP[02] A.03.04.06.ODP[03] A.03.04.06.ODP[04] A.03.04.06.ODP[05] A.03.04.06.ODP[06] A.03.04.06.ODP[07] A.03.04.06.ODP[08] A.03.04.06.ODP[09] A.03.04.06.ODP[10] A.03.05.07.f

3.4.1e 3.4.2e 3.14.3e

PO.5.2

PR.IP-1 PR.IP-3

PR.AA-05 PR.PS-01 PR.PS-02 PR.PS-03

A01:2021 A02:2021 A03:2021 A04:2021 A05:2021 A06:2021 A07:2021 A08:2021 A09:2021 A10:2021

1.1 1.1.1 2.2 2.2.1 2.2.2 2.2.3 2.2.4

1.1 1.2.1 1.2.6 2.2.1 8.3.2 8.5 10.2 10.2.1 10.2.1.1 10.2.1.2 10.2.1.3 10.2.1.4 10.2.1.5 10.2.1.6 10.2.1.7 10.2.2 10.6 10.6.1 10.6 10.6.1 10.6.2 10.6.3 11.2

null

1.2.1 1.2.6 2.2.1 8.3.2 10.2.1 10.2.1.1 10.2.1.2 10.2.1.3 10.2.1.4 10.2.1.5 10.2.1.6 10.2.1.7 10.2.2 10.6.1 10.6.2 10.6.3

null

1.2.6

2.2.1 8.3.2 10.2.1.2 10.2.1.4 10.2.1.5 10.2.2 10.6.1 10.6.2 10.6.3

null

1.2.1 1.2.6 2.2.1 8.3.2 10.2.1 10.2.1.1 10.2.1.2 10.2.1.3 10.2.1.4 10.2.1.5 10.2.1.6 10.2.1.7 10.2.2 10.6.1 10.6.2 10.6.3

null

N.9

1.3 2.3 2.10 4.1

null

ASSET-3.A.MIL1 ASSET-3.B.MIL2 ASSET-3.C.MIL2 ARCHITECTURE-3.E.MIL2 ARCHITECTURE-3.F.MIL2 ARCHITECTURE-3.G.MIL2 ARCHITECTURE-4.C.MIL2

TM:SG2.SP1 TM:SG4.SP2

2.1 2.2 2.4 2.5

5.13.1.3 5.13.1.4

null

CM.L2-3.4.1 CM.L2-3.4.2

CM.L2-3.4.2 TBD - 3.4.1e TBD - 3.4.2e TBD - 3.14.3e

null

CM.L2-3.4.1 CM.L2-3.4.2

CM.L2-3.4.1 CM.L2-3.4.2 CM.L3-3.4.1e CM.L3-3.4.2e SI.L3-3.14.3e

CM-2 CM-6 SA-8

null

252.204-7008

null

CM-2 CM-6 SA-8

CM-2 CM-6

CM-2 CM-6 SA-8

CM-2 CM-6

CM-2 CM-6 PL-10 SA-8

CM-2 CM-6 PL-10

CM-2 CM-6 PL-10 SA-8

CM-2 CM-6 PL-10

null

D3.PC.Im.B.5 D1.G.IT.B.4

null

1.S.A 2.S.A 3.S.A 6.S.B 6.S.C

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

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

2.D.8 3.3.7 CM-2 CM-6 SA-8

null

8-202 8-311 8-610

1.2 3.1 5.1 5.2

6.10

null

CM-2 CM-6

null

6-1-1305(4)

null

CM-2 CM-6 SA-8

CM-2 CM-6

CM-2 CM-6 SA-8

null

3.4.4(36)(b)

Art 9.3(a) Art 9.3(b) Art 9.3(c) Art 9.3(d)

null

Article 21.5

null

6.8

AM-02 AM-03 OPS-23

null

3.3 4.9 4.12 4.15 6.1 9.21 12.13 12.24 12.29 13.5 13.6 14.2 15.6

null

1-3-2-3 2-3-1-7

TPC-10 TPC-13 TPC-14 TPC-15 TPC-16 TPC-17 TPC-22 TPC-38 TPC-56 TPC-63 TPC-87

null

1-3-3 2-4-1 2-4-2 5-1-3-7

2-2-1-5 2-3-1-1 2-3-1-7

null

7.3.2 [OP.EXP.2]

null

B4.b

B4

2

null

Principle 3.1 Principle 3.2 Principle 3.3 Principle 3.4 Principle 4.1 Principle 4.2 Principle 4.3 Principle 4.4

Principle 3.1 Principle 3.2 Principle 3.3 Principle 3.4 Principle 3.5 Principle 4.1 Principle 4.2 Principle 4.3 Principle 4.4 Principle 4.5 Principle 4.6 Principle 4.7 Principle 4.8 Principle 4.9 Principle 4.10 Principle 4.11 Principle 4.12 Principle 4.13

Principle 1.3 Principle 1.4 Principle 1.7 Principle 3.1 Principle 3.2 Principle 3.3 Principle 3.4 Principle 3.5 Principle 3.6 Principle 3.7 Principle 3.8 Principle 3.9 Principle 3.10 Principle 3.11 Principle 4.1 Principle 4.2 Principle 4.3 Principle 4.4 Principle 4.5 Principle 4.6 Principle 4.7 Principle 4.8 Principle 4.9 Principle 4.10 Principle 4.11 Principle 4.12 Principle 4.13 Principle 4.14 Principle 4.15 Principle 4.16 Principle 4.17 Principle 5.13

null

1562 0341 0343 1406 1608 1407 1408 1409 0383 0380 1584 1491 1492 1621 1622 1623 1624 1418 0345 1604 1745 1709 1710

null

9.4.1 9.4.1.8.PB 14.1.1

null

14.1.8.C.01 14.1.9.C.01 14.1.9.C.02 14.1.10.C.01 14.1.10.C.02 14.3.7.C.01 23.2.21.C.01

null

4.3(a)

11.2.5 11.3.1 11.3.2

null

4.16 4.20

3.2.3 3.2.8

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-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

Configuration Management

Reviews & Updates

CFG-02.1

Mechanisms exist to review and update baseline configurations: ▪ At least annually; ▪ When required due to so; or ▪ As part of system component installations and upgrades.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Defense Information Security Agency (DISA) Secure Technology Implementation Guides (STIGs) - Center for Internet Security (CIS) Benchmarks - NNT Change Tracker (https://www.newnettechnologies.com)

null

Does the organization review and update baseline configurations: ▪ At least annually; ▪ When required due to so; or ▪ As part of system component installations and upgrades?

8

Detect

null

X

There is no evidence of a capability to review and update baseline configurations: ▪ At least annually; ▪ When required due to so; or ▪ As part of system component installations and upgrades.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • Configurations are reviewed only when new operating systems or versions of applications are released.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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.

CC8.1

null

4.1 4.2

BAI10.03 BAI10.05

null

CCC-06 IVS-03 IVS-04

null

8.9

null

T1001, T1001.001, T1001.002, T1001.003, T1003, T1003.001, T1003.002, T1003.003, T1003.004, T1003.005, T1003.006, T1003.007, T1003.008, T1008, T1011.001, T1020.001, T1021.001, T1021.002, T1021.003, T1021.004, T1021.005, T1021.006, T1027, T1029, T1030, T1036, T1036.001, T1036.003, T1036.005, T1036.007, T1037, T1037.002, T1037.003, T1037.004, T1037.005, T1046, T1047, T1048, T1048.001, T1048.002, T1048.003, T1052, T1052.001, T1053, T1053.002, T1053.005, T1059, T1059.001, T1059.002, T1059.003, T1059.004, T1059.005, T1059.006, T1059.007, T1059.008, T1068, T1070, T1070.001, T1070.002, T1070.003, T1071, T1071.001, T1071.002, T1071.003, T1071.004, T1072, T1080, T1090, T1090.001, T1090.002, T1091, T1092, T1095, T1098.004, T1102, T1102.001, T1102.002, T1102.003, T1104, T1105, T1106, T1110, T1110.001, T1110.002, T1110.003, T1110.004, T1111, T1114, T1114.002, T1119, T1127, T1127.001, T1129, T1132, T1132.001, T1132.002, T1133, T1134.005, T1137, T1137.001, T1137.002, T1137.003, T1137.004, T1137.005, T1137.006, T1176, T1185, T1187, T1189, T1201, T1204, T1204.001, T1204.002, T1204.003, T1205, T1210, T1211, T1212, T1213, T1213.001, T1213.002, T1216, T1216.001, T1218, T1218.001, T1218.002, T1218.003, T1218.004, T1218.005, T1218.007, T1218.008, T1218.009, T1218.012, T1218.013, T1218.014, T1219, T1220, T1221, T1484, T1485, T1486, T1490, T1491, T1491.001, T1491.002, T1505, T1505.001, T1505.002, T1505.003, T1505.004, T1525, T1528, T1530, T1539, T1542.004, T1542.005, T1543, T1543.001, T1543.002, T1543.003, T1543.004, T1546, T1546.002, T1546.003, T1546.004, T1546.006, T1546.010, T1546.013, T1546.014, T1547.003, T1547.007, T1547.008, T1547.011, T1547.013, T1548, T1548.002, T1548.003, T1548.004, T1550.001, T1550.003, T1552, T1552.001, T1552.004, T1552.006, T1553, T1553.001, T1553.003, T1553.005, T1554, T1555.004, T1555.005, T1556, T1556.004, T1557, T1557.001, T1557.002, T1558, T1558.001, T1558.002, T1558.003, T1558.004, T1559, T1559.001, T1559.002, T1561, T1561.001, T1561.002, T1562, T1562.001, T1562.002, T1562.003, T1562.004, T1562.006, T1562.010, T1563, T1563.001, T1563.002, T1564.006, T1564.007, T1564.009, T1565, T1565.001, T1565.002, T1566, T1566.001, T1566.002, T1569, T1569.002, T1570, T1571, T1572, T1573, T1573.001, T1573.002, T1574, T1574.001, T1574.004, T1574.005, T1574.007, T1574.008, T1574.009, T1574.010, T1598, T1598.002, T1598.003, T1599, T1599.001, T1601, T1601.001, T1601.002, T1602, T1602.001, T1602.002

TS-1.1

null

CM-2(1)

null

CM-2(1)

CM-2

null

CM-2

null

CM-2

null

CM-2

null

CM-2

NFO - CM-2(1)

3.4.1.b

null

A.03.04.01.b[01] A.03.04.01.b[02] A.03.04.01.b[03] A.03.04.01.b[04]

null

M.1.8.1

null

ASSET-3.D.MIL2 ASSET-3.E.MIL3

null

CM-2(1)

null

CM-2(1)

null

CM-2(1)

null

CM-2

null

CM-2(1)

null

CM-2

null

CM-2(1)

null

3.3 14.3

null

2-3-1-6

null

1-6-2-2

2-3-1-2

null

B4.b

null

Principle 1.5

null

1588 1407

null

11.2.5

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-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

Configuration Management

Automated Central Management & Verification

CFG-02.2

Automated mechanisms exist to govern and report on baseline configurations of the systems.

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

null

Does the organization use automated mechanisms to govern and report on baseline configurations of the systems?

7

Detect

null

X

There is no evidence of a capability to govern and report on baseline configurations of the systems.

SP-CMM1 is N/A, since a structured process is required to govern and report on baseline configurations of the systems.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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.

CC8.1

null

DSS06.06

null

CCC-06 CCC-07 CCC-08 UEM-04

CCM-03

null

CR 7.6 (11.8.3(1))

null

CM-2(2) CM-6(1)

null

CM-2(2) CM-6(1)

null

CM-2(2)

CM-2(2) CM-6(1)

null

CM-2(2)

CM-2(2) CM-6(1)

null

CM-6(1)

null

CM-6(1)

null

3.4.3e

null

D.1.1

null

TBD - 3.4.3e

null

CM.L3-3.4.3e

CM-6(1)

null

CM-2(2) CM-6(1)

null

CM-2(2) CM-6(1)

null

CM-2(2) CM-6(1)

null

CM-2(2) CM-6(1)

null

2.L.A

CM-2(2)

null

CIP-010-2 R2

null

CM-6(1)

CM-2(2) CM-6(1)

null

CM-2(2) CM-6(1)

null

3.3 6.2 6.4 9.22 9.23 14.3 14.4

null

B4.b

null

4.3(a) 4.3(b)

11.3.2

null

x

null

x

R-AM-3 R-BC-3 R-GV-1 R-GV-6 R-GV-7 R-SA-1

null

R-AM-3

null

R-BC-3

null

R-GV-1

null

R-GV-6

R-GV-7

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

Configuration Management

Retention Of Previous Configurations

CFG-02.3

Mechanisms exist to retain previous versions of baseline configuration to support roll back.

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

null

Does the organization retain previous versions of baseline configuration to support roll back?

3

Identify

null

X

There is no evidence of a capability to retain previous versions of baseline configuration to support roll back.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Historical versions of configurations are maintained for troubleshooting and forensics reasons.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to retain previous versions of baseline configuration to support roll back.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to retain previous versions of baseline configuration to support roll back.

null

CM-2(3)

null

CM-2(3)

null

CM-2(3)

null

CM-2(3)

null

G.2.10

null

CM-2(3)

null

CM-2(3)

null

CM-2(3)

null

CM-2(3)

null

CM-2(3)

null

CM-2(3)

null

CM-2(3)

null

CM-2(3)

null

14.5

null

1510

null

x

null

x

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

null

R-AM-3

R-BC-1

null

R-BC-3

null

R-EX-5

null

R-GV-1

null

R-GV-4

null

R-GV-6

R-GV-7

null

R-IR-1

null

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

Configuration Management

Development & Test Environment Configurations

CFG-02.4

Mechanisms exist to manage baseline configurations for development and test environments separately from operational baseline configurations to minimize the risk of unintentional changes.

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

null

Does the organization manage baseline configurations for development and test environments separately from operational baseline configurations to minimize the risk of unintentional changes?

5

Protect

null

X

There is no evidence of a capability to manage baseline configurations for development and test environments separately from operational baseline configurations to minimize the risk of unintentional changes.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

AIS-02 IVS-05

null

8.25

null

TS-2.5

null

CM-2(6)

null

CM-2(6)

null

CM-2(6)

null

CM-2(6)

null

CM-2(6)

null

PO.5 PO.5.1 PO.5.2

null

6.4.1

6.5.6

null

6.5.6

null

I.1.1

null

5.2.2

null

6.S.A

null

10.1 10.2

null

0292

null

18.1.10.C.01 18.1.10.C.02 18.1.10.C.03 18.1.10.C.04

null

5.7.3

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 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

Configuration Management

Configure Systems, Components or Services for High-Risk Areas

CFG-02.5

Mechanisms exist to configure systems utilized in high-risk areas with more restrictive baseline configurations.

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

E-AST-12 E-AST-13 E-AST-14 E-AST-15 E-AST-16 E-AST-17 E-AST-18 E-AST-19 E-AST-20 E-AST-21

Does the organization configure systems utilized in high-risk areas with more restrictive baseline configurations?

8

Protect

null

X

There is no evidence of a capability to configure systems utilized in high-risk areas with more restrictive baseline configurations.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

16.7

null

16.7

DSS06.06

null

AIS-02 IVS-03 IVS-04 UEM-14

CLS-05 IOT-02 IOT-07 SAP-09 SWS-01 SWS-02 SWS-03

null

CR 2.2 (6.4.1) CR 7.6 (11.8.1)

null

8.12

CLD.9.5.2

null

TS-1.1 TS-2.3 TS-2.11

null

P-6

null

CM-2(7)

null

CM-2(7)

CM-2(7) CM-7(6) CM-7(7) CM-7(9)

null

CM-2(7)

null

CM-2(7)

null

CM-7(6) CM-7(7) CM-7(9)

null

CM-7(6) CM-7(9)

CM-7(6) CM-7(7) CM-7(9)

NFO - CM-2(7)

3.4.1.a 3.4.12.a 3.4.12.b

null

A.03.04.12.ODP[01] A.03.04.12.ODP[02]

null

PO.5 PO.5.1 PO.5.2

null

1.2.1 1.5 1.5.1 8.5 10.2 10.2.1 10.2.1.1 10.2.1.2 10.2.1.3 10.2.1.4 10.2.1.5 10.2.1.6 10.2.1.7 10.2.2 10.6 10.6.1 10.6.2 10.6.3

null

1.2.1 1.2.6 1.5.1 10.2.1 10.2.1.1 10.2.1.2 10.2.1.3 10.2.1.4 10.2.1.5 10.2.1.6 10.2.1.7 10.2.2 10.6.1 10.6.2 10.6.3

null

1.2.6

10.2.1.2 10.2.1.4 10.2.1.5 10.2.2 10.6.1 10.6.2 10.6.3

1.5.1

1.2.1 1.2.6 1.5.1 10.2.1 10.2.1.1 10.2.1.2 10.2.1.3 10.2.1.4 10.2.1.5 10.2.1.6 10.2.1.7 10.2.2 10.6.1 10.6.2 10.6.3

null

I.1.7.6

1.3 2.3 2.6 2.10 4.1

null

ARCHITECTURE-3.G.MIL2 ARCHITECTURE-3.K.MIL2

OPD:SG1.SP2

2.4 2.5

null

CM-2(7)

null

CM-2(7)

null

CM-2(7)

null

CM-2(7)

null

6.S.A

null

3.3.7 CM-2(7) CM-7(9)

null

1.2 5.1 5.2

null

CM-2(7)

null

CM-2(7)

null

4.12 9.21 10.7

null

1-3-2-3 2-3-1-7

TPC-10 TPC-13 TPC-14 TPC-15 TPC-16 TPC-17 TPC-22 TPC-38 TPC-56 TPC-63 TPC-87

null

5-1-3-7

2-2-1-5 2-3-1-7

null

B4.b

B4

null

1656 1657 1658 1659 1666 1667 1668 1669 1670 1748 1671 1672 1673 1674 1675 1676 1677 1678 1749 1800 0534

null

18.1.10.C.01 18.1.10.C.02 18.1.10.C.03 18.1.10.C.04 23.2.21.C.01

null

3.2.3

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-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

Configuration Management

Network Device Configuration File Synchronization

CFG-02.6

Mechanisms exist to configure network devices to synchronize startup and running configuration files.

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

null

Does the organization configure network devices to synchronize startup and running configuration files?

7

Protect

null

X

There is no evidence of a capability to configure network devices to synchronize startup and running configuration files.

SP-CMM1 is N/A, since a structured process is required to configure network devices to synchronize startup and running configuration files.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software. • IT infrastructure personnel configure network devices to synchronize startup and running configuration files.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • IT infrastructure personnel configure network devices to synchronize startup and running configuration files.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to configure network devices to synchronize startup and running configuration files.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to configure network devices to synchronize startup and running configuration files.

null

IVS-03

null

CR 7.6 (11.8.1)

null

1.2.2

1.2.8

null

1.2.8

null

1.2.8

null

M.1.8

null

9.22

null

18.1.10.C.01 18.1.10.C.02 18.1.10.C.03 18.1.10.C.04

null

x

null

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

null

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

null

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

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-3

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 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

Configuration Management

Approved Configuration Deviations

CFG-02.7

Mechanisms exist to document, assess risk and approve or deny deviations to standardized configurations.

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

null

Does the organization document, assess risk and approve or deny deviations to standardized configurations?

9

Protect

null

X

There is no evidence of a capability to document, assess risk and approve or deny deviations to standardized configurations.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • The review of any request for deviating from baseline configurations is documented and a risk assessment performed to determine if the deviation is acceptable.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software. • Deviations to baseline for embedded technologies configurations are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Deviations to baseline for embedded technologies configurations are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes are immediately reverted to approved configurations.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

AIS-02 CCC-08

null

CM-6

null

CM-6

null

CM-6

null

CM-6

null

CM-6

null

CM-6

null

3.4.2.b

null

PO.5.2

null

M.1.42

null

CM-6

null

CM-6

null

CM-6

null

B4.b

null

4.3(c)

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-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

Configuration Management

Respond To Unauthorized Changes

CFG-02.8

Mechanisms exist to respond to unauthorized changes to configuration settings as security incidents.

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

null

Does the organization respond to unauthorized changes to configuration settings as security incidents?

9

Respond

null

X

There is no evidence of a capability to respond to unauthorized changes to configuration settings as security incidents.

SP-CMM1 is N/A, since a structured process is required to respond to unauthorized changes to configuration settings as security incidents.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Unauthorized configuration changes are immediately reverted to approved configurations.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

2.3

null

CCC-09

null

CM-6(2)

null

CM-6(2)

null

CM-6(2)

null

CM-6(2)

null

CM-6(2)

null

CM-6(2)

null

A.03.04.02.b[01] A.03.04.02.b[02]

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

J.2.31

null

CM-6(2)

null

CM-6(2)

null

CM-6(2)

null

CM-6(2)

null

8.6

null

2-3-1-11

null

4.19 4.20

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-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

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-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

Configuration Management

Baseline Tailoring

CFG-02.9

Mechanisms exist to allow baseline controls to be specialized or customized by applying a defined set of tailoring actions that are specific to: ▪ Mission / business functions; ▪ Operational environment; ▪ Specific threats or vulnerabilities; or ▪ Other conditions or situations that could affect mission / business success.

- DISA STIGs - CIS Benchmarks

null

Does the organization allow baseline controls to be specialized or customized by applying a defined set of tailoring actions that are specific to: ▪ Mission / business functions; ▪ Operational environment; ▪ Specific threats or vulnerabilities; or ▪ Other conditions or situations that could affect mission / business success?

9

Protect

null

X

There is no evidence of a capability to allow baseline controls to be specialized or customized by applying a defined set of tailoring actions that are specific to: ▪ Mission / business functions; ▪ Operational environment; ▪ Specific threats or vulnerabilities; or ▪ Other conditions or situations that could affect mission / business success.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

AIS-02 IVS-03

null

PM-06-13 RQ-06-14

null

P-4

null

PL-11

null

PL-11

null

PL-11

null

A01:2021 A05:2021

null

N.9

null

2.5

null

PL-11

null

1.S.A

1.M.A

null

10.7

null

2-3-1-7

null

16.1.50.C.01 16.1.50.C.02

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-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-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

Configuration Management

Least Functionality

CFG-03

Mechanisms exist to configure systems to provide only essential capabilities by specifically prohibiting or restricting the use of ports, protocols, and/or services.

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

null

Does the organization configure systems to provide only essential capabilities by specifically prohibiting or restricting the use of ports, protocols, and/or services?

10

Protect

null

X

There is no evidence of a capability to configure systems to provide only essential capabilities by specifically prohibiting or restricting the use of ports, protocols, and/ or services.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software. • Administrative processes exist to prevent unauthorized access by limiting and reviewing permissions to change hardware, software and firmware components within a production/operational environment

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Administrative processes exist to prevent unauthorized access by limiting and reviewing permissions to change hardware, software and firmware components within a production/operational environment.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

CC6.1-POF6

null

4.8

null

4.8

null

AIS-02 UEM-02

null

CR 2.2 (6.4.1) CR 7.7 (11.9.1)

null

9.4.1

8.3 8.9 8.12

9.4.1

null

T1003, T1003.001, T1003.002, T1003.005, T1008, T1011, T1011.001, T1021.001, T1021.002, T1021.003, T1021.005, T1021.006, T1036, T1036.005, T1036.007, T1037, T1037.001, T1046, T1047, T1048, T1048.001, T1048.002, T1048.003, T1052, T1052.001, T1053, T1053.002, T1053.005, T1059, T1059.005, T1059.007, T1068, T1071, T1071.001, T1071.002, T1071.003, T1071.004, T1072, T1080, T1087, T1087.001, T1087.002, T1090, T1090.001, T1090.002, T1090.003, T1092, T1095, T1098, T1098.001, T1098.004, T1102, T1102.001, T1102.002, T1102.003, T1104, T1105, T1106, T1112, T1127, T1129, T1133, T1135, T1136, T1136.002, T1136.003, T1176, T1187, T1190, T1195, T1195.001, T1195.002, T1197, T1199, T1204, T1204.001, T1204.002, T1204.003, T1205, T1205.001, T1210, T1213, T1213.001, T1213.002, T1216, T1216.001, T1218, T1218.001, T1218.002, T1218.003, T1218.004, T1218.005, T1218.007, T1218.008, T1218.009, T1218.012, T1218.013, T1218.014, T1219, T1220, T1221, T1482, T1484, T1489, T1490, T1498, T1498.001, T1498.002, T1499, T1499.001, T1499.002, T1499.003, T1499.004, T1505.004, T1525, T1530, T1537, T1542.004, T1542.005, T1543, T1546.002, T1546.006, T1546.008, T1546.009, T1546.010, T1547.004, T1547.006, T1547.007, T1547.011, T1548, T1548.001, T1548.003, T1548.004, T1552, T1552.003, T1552.005, T1552.007, T1553, T1553.001, T1553.003, T1553.004, T1553.005, T1553.006, T1555.004, T1556, T1556.002, T1557, T1557.001, T1557.002, T1559, T1559.002, T1562, T1562.001, T1562.002, T1562.003, T1562.004, T1562.006, T1562.009, T1563, T1563.001, T1563.002, T1564.002, T1564.003, T1564.006, T1564.008, T1564.009, T1565, T1565.003, T1569, T1569.002, T1570, T1571, T1572, T1573, T1573.001, T1573.002, T1574, T1574.001, T1574.006, T1574.007, T1574.008, T1574.009, T1574.012, T1599, T1599.001, T1601, T1601.001, T1601.002, T1602, T1602.001, T1602.002, T1609, T1610, T1611, T1612, T1613

TS-1.1 TS-2.3

null

PR.PT-P2

null

CM-7

null

CM-7

null

CM-7

null

CM-7

null

CM-7

3.4.6

3.4.2.a 3.4.6.a 3.4.6.b 3.4.6.d

3.4.6[a] 3.4.6[b]

A.03.04.06.a A.03.04.06.b[01] A.03.04.06.b[02] A.03.04.06.b[03] A.03.04.06.b[04] A.03.04.06.b[05] A.03.04.06.c A.03.04.06.d[01] A.03.04.06.d[02] A.03.04.06.d[03] A.03.04.06.d[04] A.03.04.06.d[05] A.03.04.06.ODP[01] A.03.04.06.ODP[02] A.03.04.06.ODP[03] A.03.04.06.ODP[04] A.03.04.06.ODP[05] A.03.04.06.ODP[06] A.03.04.06.ODP[07] A.03.04.06.ODP[08] A.03.04.06.ODP[09] A.03.04.06.ODP[10]

null

PR.PT-3

null

A05:2021

1.1.5 1.2.1 2.2.2 2.2.4 2.2.5

1.2.6 1.4 1.4.1 1.4.2 2.2.4

null

1.4.1 1.4.2 2.2.4

null

2.2.4

1.4.1 1.4.2 2.2.4

null

M.2.3

2.10

null

ARCHITECTURE-2.E.MIL2 ARCHITECTURE-3.D.MIL2

TM:SG2.SP1 TM:SG2.SP2

null

5.7.1.1

null

CM.L2-3.4.6

AC.L1-b.1.ii

CM.L2-3.4.6

CM-7

null

52.204-21(b)(1)(ii)

null

CM-7

null

D3.PC.Am.B.7 D3.PC.Am.B.4 D3.PC.Am.B.3 D4.RM.Om.Int.1

null

1.S.A 6.S.A 6.S.B

1.M.A

CM-7

null

1.2

6.3

null

5.3

CM-7

null

17.03(2)(a) 17.03(2)(g)

null

CM-7

null

4.8 4.9 12.9 12.13

null

2-5-3-5

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

null

B4.b

null

1487 1488 1489 0385 1479 1006 1311 1312

null

9.4.1 9.4.1.8.PB

null

18.1.15.C.01 18.1.15.C.02 18.1.15.C.03 18.1.15.C.04

null

x

FAR 52.204-21 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-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-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

Configuration Management

Periodic Review

CFG-03.1

Mechanisms exist to periodically review system configurations to identify and disable unnecessary and/or non-secure functions, ports, protocols and services.

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

null

Does the organization periodically review system configurations to identify and disable unnecessary and/or non-secure functions, ports, protocols and services?

8

Detect

null

X

There is no evidence of a capability to periodically review system configurations to identify and disable unnecessary and/ or non-secure functions, ports, protocols and services.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software. • Cybersecurity personnel perform an annual review of existing configurations to ensure security objectives are still being met.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Cybersecurity personnel perform an annual review of existing configurations to ensure security objectives are still being accomplished, or up on the release of a new application or service that requires additional configuration settings.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

AIS-02 IVS-03 IVS-04

null

9.2.5 9.2.6 12.6.1 14.2.5

5.18 8.8 8.27

9.2.5 9.2.6 12.6.1 14.2.5

null

6.6.2.5 6.6.2.6

null

CM-7(1)

null

CM-7(1)

null

CM-7(1)

null

CM-7(1)

null

CM-7(1)

null

CM-7(1)

3.4.7

3.4.6.c

3.4.7[a] 3.4.7[b] 3.4.7[c] 3.4.7[d] 3.4.7[e] 3.4.7[f] 3.4.7[g] 3.4.7[h] 3.4.7[i] 3.4.7[j] 3.4.7[k] 3.4.7[l] 3.4.7[m] 3.4.7[n] 3.4.7[o]

null

1.2.7

null

1.2.7

null

1.2.7

null

N.2.2

2.2

null

CM.L2-3.4.7

null

CM.L2-3.4.7

CM-7(1)

null

CM-7(1)

null

CM-7(1)

null

CM-7(1)

null

CM-7(1)

null

CM-7(1)

null

CM-7(1)

null

CM-7(1)

null

B4.b

null

9.2.5 9.2.6 12.6.1 12.6.1.18.PB 14.2.5

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-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

Configuration Management

Prevent Unauthorized Software Execution

CFG-03.2

Mechanisms exist to configure systems to prevent the execution of unauthorized software programs.

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

null

Does the organization configure systems to prevent the execution of unauthorized software programs?

7

Protect

null

X

There is no evidence of a capability to configure systems to prevent the execution of unauthorized software programs.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • Terms of employment and rules of behavior address the requirement for users to comply with applicable software usage requirements and copyright laws.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software. • An “acceptable use policy”, or similar control, addresses the requirement for users to comply with applicable software usage requirements and copyright laws.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Administrative processes exist to prevent unauthorized access by limiting and reviewing developer permissions to change hardware, software and firmware components within a production/operational environment.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

UEM-02

null

CM-7(2)

null

CM-7(2)

null

CM-7(2)

null

CM-7(2)

null

3.4.7

3.4.8.a 3.4.8.b 3.4.8.c

null

M.1.37

null

CM.L2-3.4.7

null

CM.L2-3.4.7

CM-7(2)

null

CM-7(2)

null

CM-7(2)

null

CM-7(2)

null

CM-7(2)

null

CM-7(2)

null

2-3-1-11

null

B4.b

null

Principle 1.1

Principle 1.1 Principle 1.2

null

4.19 4.20

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-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

Configuration Management

Unauthorized or Authorized Software (Blacklisting or Whitelisting)

CFG-03.3

Mechanisms exist to whitelist or blacklist applications in an order to limit what is authorized to execute on systems.

- Microsoft Windows Defender Application Control (WDAC) (replaced AppLocker) - CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - NNT Change Tracker (https://www.newnettechnologies.com)

null

Does the organization whitelist or blacklist applications in an order to limit what is authorized to execute on systems?

5

Protect

null

X

There is no evidence of a capability to whitelist or blacklist applications in an order to limit what is authorized to execute on systems.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • Terms of employment and rules of behavior address the requirement for users to comply with applicable software usage requirements and copyright laws.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Software Asset Management (SWAM) solution is used to provide oversight of unmanaged or unauthorized software executables that are on a network.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

2.3 2.5 2.6 2.7

2.3

2.3 2.5 2.6

2.3 2.5 2.6 2.7

null

UEM-02

CLS-02

null

CM-7(4) CM-7(5) SC-18(4)

null

CM-7(4)

CM-7(5)

CM-7(4) CM-7(5) SC-18(4)

null

CM-7(5)

CM-7(4) SC-18(4)

null

CM-7(5)

null

CM-7(4) CM-7(5)

null

CM-7(4)

CM-7(4) CM-7(5)

3.4.8

3.4.8.a 3.4.8.b 3.4.8.c 3.13.13.a 3.13.13.b

3.4.8[a] 3.4.8[b] 3.4.8[c]

A.03.04.08.a A.03.04.08.b A.03.04.08.c[01] A.03.04.08.c[02]

null

M.1.45

null

8.5

null

ARCHITECTURE-3.M.MIL3

null

CM.L2-3.4.8

null

CM.L2-3.4.8

CM-7(4)

null

CM-7(5)

null

CM-7(5)

null

CM-7(5)

null

CM-7(5)

null

9.M.B

9.M.B 2.L.E

CM-7(5)

null

CM-7(5)

null

CM-7(5)

null

AM-02

null

6.7

null

2-3-1-1

null

2-3-1-6

null

4

null

Principle 1.3

Principle 1.3 Principle 1.4 Principle 1.6

null

14.2.4.C.01 14.2.5.C.01 14.2.5.C.02 14.2.5.C.03 14.2.5.C.04 14.2.6.C.01 14.2.7.C.01 14.2.7.C.02 14.2.7.C.03 14.2.7.C.04 14.2.7.C.05 14.2.7.C.06 14.2.7.C.07

null

11.3.6

null

4.19 4.20

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-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

Configuration Management

Split Tunneling

CFG-03.4

Mechanisms exist to prevent split tunneling for remote devices unless the split tunnel is securely provisioned using organization-defined safeguards.

null

Does the organization prevent split tunneling for remote devices unless the split tunnel is securely provisioned using organization-defined safeguards? Prevent split tunneling for remote devices unless the split tunnel is securely provisioned using organization-defined safeguards?

8

Protect

null

X

There is no evidence of a capability to prevent split tunneling for remote devices unless the split tunnel is securely provisioned using organization-defined safeguards.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

TS-1.15 TS-2.5

null

SC-7(7)

null

SC-7(7)

null

SC-7(7)

null

SC-7(7)

null

CM-7(7)

null

CM-7(7)

3.13.7

null

3.13.7

null

1.5.1

null

1.5.1

null

1.5.1

null

N.4.3

null

SC.L2-3.13.7

null

SC.L2-3.13.7

SC-7(7)

null

SC-7(7)

null

SC-7(7)

null

SC-7(7)

null

SC-7(7)

null

SC-7(7)

null

SC-7(7)

null

SC-7(7)

null

4.15 9.13

null

0705

null

18.7.14.C.01 18.7.14.C.02

null

x

null

x

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

null

R-AC-4

R-AM-1

null

R-AM-3

null

R-BC-2

null

R-BC-4

null

R-EX-7

null

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

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

- wordsmithed control

Configuration Management

Software Usage Restrictions

CFG-04

Mechanisms exist to enforce software usage restrictions to comply with applicable contract agreements and copyright laws.

null

Does the organization enforce software usage restrictions to comply with applicable contract agreements and copyright laws?

9

Protect

null

X

There is no evidence of a capability to enforce software usage restrictions to comply with applicable contract agreements and copyright laws.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • Terms of employment and rules of behavior address the requirement for users to comply with applicable software usage requirements and copyright laws.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

UEM-03

null

T1546.008, T1546.013, T1550.001, T1553, T1553.004, T1559, T1559.002, T1562.006, T1562.009

null

CM-10

null

CM-10

null

CM-10

null

CM-10

null

CM-10

null

3.13.13.a 3.13.13.b

null

M.1.49

null

COMP:SG2.SP1 COMP:SG2.SP2 COMP:SG3.SP1

null

CM-10

null

CM-10

null

CM-10

null

CM-10

null

CM-10

null

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-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-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

Configuration Management

Open Source Software

CFG-04.1

Mechanisms exist to establish parameters for the secure use of open source software.

- Acceptable Use Policy (AUP)

null

Does the organization establish parameters for the secure use of open source software?

9

Protect

null

X

There is no evidence of a capability to establish parameters for the secure use of open source software.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • Terms of employment and rules of behavior address the requirement for users to comply with applicable software usage requirements and copyright laws.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

CM-10(1)

null

CM-10(1)

null

CM-10(1)

null

CM-10(1)

null

CM-10(1)

null

3.13.13.a 3.13.13.b

null

M.1.47

null

CM-10(1)

null

CM-10(1)

null

CM-10(1)

null

CM-10(1)

null

CM-10(1)

null

6.1.3

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-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

Configuration Management

Unsupported Internet Browsers & Email Clients

CFG-04.2

Mechanisms exist to allow only approved Internet browsers and email clients to run on systems.

null

Does the organization allow only approved Internet browsers and email clients to run on systems?

7

Protect

null

X

There is no evidence of a capability to allow only approved Internet browsers and email clients to run on systems.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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.

CC6.7

null

9.0 9.1 9.4

9.1

9.1 9.4

null

M.1.49

null

1.S.A

1.M.A

null

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

null

0824 1412 1485 1486 1542 1470 1235 1601 1585 1654 1655

null

4.6 4.9

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-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-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

Configuration Management

User-Installed Software

CFG-05

Mechanisms exist to restrict the ability of non-privileged users to install unauthorized software.

- Privileged Account Management (PAM)

null

Does the organization restrict the ability of non-privileged users to install unauthorized software?

10

Protect

X

There is no evidence of a capability to restrict the ability of non-privileged users to install unauthorized software.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • Terms of employment and rules of behavior address the requirement for users to comply with applicable software usage requirements and copyright laws.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

CC6.8-POF1

null

T1021.005, T1059, T1059.006, T1176, T1195, T1195.001, T1195.002, T1218, T1218.001, T1218.002, T1218.003, T1218.004, T1218.005, T1218.008, T1218.009, T1218.012, T1218.013, T1218.014, T1505, T1505.001, T1505.002, T1505.004, T1543, T1543.001, T1543.002, T1543.003, T1543.004, T1547.013, T1550.001, T1564.009, T1569, T1569.001

null

CM-11

CM-11 CM-11(2)

null

CM-11

CM-11(2)

null

CM-11

null

CM-11

null

CM-11

3.4.9

3.13.13.b

3.4.9[b] 3.4.9[c]

null

PR.PS-05

null

M.1.31

null

AM:SG1.SP1 COMP:SG3.SP2 MON:SG2.SP3

null

CM.L2-3.4.9

null

CM.L2-3.4.9

CM-11

null

CM-11

null

2.M.A

CM-11

null

CM-11

null

CM-11

null

6.3

null

B4.b

null

3

null

1592 0382 1655

null

4.19 4.20

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-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

Configuration Management

Unauthorized Installation Alerts

CFG-05.1

Mechanisms exist to configure systems to generate an alert when the unauthorized installation of software is detected.

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

null

Does the organization configure systems to generate an alert when the unauthorized installation of software is detected?

8

Detect

null

X

There is no evidence of a capability to configure systems to generate an alert when the unauthorized installation of software is detected.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

CC6.8-POF2

null

2.3

null

CM-11(1)

null

CM-8(3) CM-11(3)

null

CM-8(3)

CM-11(3)

null

CM-8(3)

null

N.19

null

CM-11(1)

null

CM-11(1)

null

III.D.2.c

null

2-3-1-11

null

4.19 4.20

null

x

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

null

R-AC-4

R-AM-1

null

R-AM-3

null

R-BC-2

null

R-BC-4

null

R-EX-7

null

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

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

Configuration Management

Restrict Roles Permitted To Install Software

CFG-05.2

Mechanisms exist to configure systems to prevent the installation of software, unless the action is performed by a privileged user or service.

null

Does the organization configure systems to prevent the installation of software, unless the action is performed by a privileged user or service?

9

Protect

null

X

There is no evidence of a capability to configure systems to prevent the installation of software, unless the action is performed by a privileged user or service.

Configuration Management (CFG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments. • Secure configurations are not: o Standardized across the organization. o Consistently aligned with industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Configuration Management (CFG) 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.

Configuration Management (CFG) 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

CC6.8-POF1

null

9.4

null

9.4

null

IAM-09

null

CM-11(2)

null

CM-11(2)

null

CM-11(2)

null

PR.PS-05

null

M.1.14

null

2.1 2.2

null

1.2

null

6.3

null

1592 0382

null

4.19 4.20

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-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

Configuration Management

Configuration Enforcement

CFG-06

Automated mechanisms exist to monitor, enforce and report on configurations for endpoint devices.

null

Does the organization use automated mechanisms to monitor, enforce and report on configurations for endpoint devices?

7

Protect

null

X

There is no evidence of a capability to monitor, enforce and report on configurations for endpoint devices.

SP-CMM1 is N/A, since a structured process is required to monitor, enforce and report on configurations for endpoint devices.

SP-CMM2 is N/A, since a well-defined process is required to monitor, enforce and report on configurations for endpoint devices.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Unauthorized configuration changes are immediately reverted to approved configurations. • Configuration monitoring software monitors, reports on and enforces configurations for endpoint devices. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices the management of user, group and system accounts, including privileged accounts. • ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A formal Change Management (CM) program ensures that no unauthorized changes are made, all changes are documented, services are not disrupted and that resources are used efficiently.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to monitor, enforce and report on configurations for endpoint devices.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to monitor, enforce and report on configurations for endpoint devices.

null

CCM-03

null

CM-3(8) CM-11(3)

null

CM-3(8) CM-11(3)

null

CM-3(8)

null

CM-3(8)

null

3.4.2.a 3.4.3.a 3.4.3.b 3.4.3.c 3.4.3.d

null

A.03.04.03.d[01] A.03.04.03.d[02]

null

M.1.43

null

0843 1490 0955 1582 1471 1392 1544 0846

null

4.19 4.20

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-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

Configuration Management

Zero-Touch Provisioning (ZTP)

CFG-07

Mechanisms exist to implement Zero-Touch Provisioning (ZTP), or similar technology, to automatically and securely configure devices upon being added to a network.

null

Does the organization implement Zero-Touch Provisioning (ZTP), or similar technology, to automatically and securely configure devices upon being added to a network?

8

Protect

null

X

There is no evidence of a capability to implement Zero-Touch Provisioning (ZTP), or similar technology, to automatically and securely configure devices up on being added to a network.

SP-CMM1 is N/A, since a structured process is required to implement Zero-Touch Provisioning (ZTP), or similar technology, to automatically and securely configure devices up on being added to a network.

SP-CMM2 is N/A, since a well-defined process is required to implement Zero-Touch Provisioning (ZTP), or similar technology, to automatically and securely configure devices up on being added to a network.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Zero-Touch Provisioning (ZTP), or similar technology, is used to automatically and securely configure devices up on being added to a network.

Configuration Management (CFG) 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 Zero-Touch Provisioning (ZTP), or similar technology, to automatically and securely configure devices up on being added to a network.

null

IAM-07

null

EDR 3.13 (13.8.1(b)) HDR 3.13 (14.8.1(b)) NDR 3.13 (15.10.1(b))

null

N.11

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-6 R-EX-7 R-GV-1 R-GV-4

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

null

R-EX-6

R-EX-7

R-GV-1

null

R-GV-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

Configuration Management

Sensitive / Regulated Data Access Enforcement

CFG-08

Mechanisms exist to configure systems, applications and processes to restrict access to sensitive/regulated data.

null

E-DCH-08

Does the organization configure systems, applications and processes to restrict access to sensitive/regulated data?

7

Protect

null

X

There is no evidence of a capability to configure systems, applications and processes to restrict access to sensitive/regulated data.

SP-CMM1 is N/A, since a structured process is required to configure systems, applications and processes to restrict access to sensitive/regulated data.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to configure systems, applications and processes to restrict access to sensitive/regulated data.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to configure systems, applications and processes to restrict access to sensitive/regulated data.

null

AC-3(11)

null

AC-3(11)

null

AC-3(11)

null

3.1.2

null

AC-3(11)

null

AC-3(11)

null

1733

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-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

- Added NIST 800-53 R5 mapping for AC-3(11)

Configuration Management

Sensitive / Regulated Data Actions

CFG-08.1

Automated mechanisms exist to generate event logs whenever sensitive/regulated data is collected, created, updated, deleted and/or archived.

null

Does the organization use automated mechanisms to generate event logs whenever sensitive/regulated data is collected, created, updated, deleted and/or archived?

7

Protect

null

X

There is no evidence of a capability to generate event logs whenever sensitive/regulated data is collected, created, updated, deleted and/ or archived.

SP-CMM1 is N/A, since a structured process is required to generate event logs whenever sensitive/regulated data is collected, created, updated, deleted and/ or archived.

Configuration Management (CFG) 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: • Configuration 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 that are appropriate to address applicable statutory, regulatory and contractual requirements for configuration management. • 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. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • Apart from workstation and server operating system baselines, configuration management is decentralized. • Cybersecurity personnel use a structured process to design, build and maintain secure configurations for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and the business process owner acceptance of the risk(s) associated with the deviation. • Unauthorized configuration changes are investigated to determine if the unauthorized configuration is malicious in nature. • Logical Access Control (LAC) is enforced to prohibit non-administrative users from being able to install unauthorized software.

Configuration Management (CFG) 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 configuration management function is formally assigned with defined roles and responsibilities. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations are designed, built and maintained. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Deviations to baseline configurations are required to have a risk assessment and business process owner approval of the risk(s) associated with the deviation. • Special baseline configurations are created for higher-risk environments or for systems, applications and services that store, process or transmit sensitive/regulated data. • An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management. • Logical Access Control (LAC) is used to limit the ability of non-administrators from making configuration changes to systems, applications and services, including the of installation of unauthorized software. • A Security Incident Event Manager (SIEM), or similar automated tool, monitors for unauthorized activities, accounts, connections, devices and software. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to generate event logs whenever sensitive/regulated data is collected, created, updated, deleted and/ or archived.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to generate event logs whenever sensitive/regulated data is collected, created, updated, deleted and/ or archived.

null

DM-2(1)

null

DM-2(1)

null

7101(a) 7101(b) 7101(c) 7101(d) 7101(e)

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-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

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

null

Continuous Monitoring

MON-01

Mechanisms exist to facilitate the implementation of enterprise-wide monitoring controls.

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

null

Does the organization facilitate the implementation of enterprise-wide monitoring controls?

10

Detect

X

There is no evidence of a capability to facilitate the implementation of enterprise-wide monitoring controls.

Continuous Monitoring (MON) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Generating event logs and the review of event logs is narrowly-focused to business-critical systems and/ or systems that store, processes and/ or transmit sensitive/regulated data. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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 continuous monitoring (e.g., event log collection and analysis) practices, within the broader scope of cybersecurity and data protection operations. • 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 organization for security monitoring. • 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 for continuous security monitoring. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including continuous monitoring. • An IT Asset Management (ITAM) function, or similar function: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • A Security Operations Center (SOC), or similar function, enables incident management operations covering preparation, detection and analysis, containment, eradication and recovery. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

Continuous Monitoring (MON) 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 enterprise-wide monitoring controls.

CC7.2

CC7.2-POF1

null

8.0 8.2 8.4 13.0 13.6

8.2

8.2 8.4 13.6

DSS01.03 DSS05.07 DSS06.05 MEA01.01

null

LOG-01 LOG-07

CLS-08 MON-01 MON-03 MON-05 MON-07 SNT-03

SO21

null

CR 2.8 (6.10.1) CR 6.2 (10.4.1)

RQ-08-03 RQ-08-04

null

12.4.1

8.15 8.16

12.4.1 CLD.12.4.5

null

6.9.4 6.9.4.1

null

T1001, T1001.001, T1001.002, T1001.003, T1003, T1003.001, T1003.002, T1003.003, T1003.004, T1003.005, T1003.006, T1003.007, T1003.008, T1005, T1008, T1011, T1011.001, T1020.001, T1021, T1021.001, T1021.002, T1021.003, T1021.004, T1021.005, T1021.006, T1025, T1027, T1027.002, T1029, T1030, T1036, T1036.001, T1036.003, T1036.005, T1036.007, T1037, T1037.002, T1037.003, T1037.004, T1037.005, T1040, T1041, T1046, T1047, T1048, T1048.001, T1048.002, T1048.003, T1052, T1052.001, T1053, T1053.001, T1053.002, T1053.003, T1053.005, T1053.006, T1055, T1055.001, T1055.002, T1055.003, T1055.004, T1055.005, T1055.008, T1055.009, T1055.011, T1055.012, T1055.013, T1055.014, T1056.002, T1059, T1059.001, T1059.002, T1059.003, T1059.004, T1059.005, T1059.006, T1059.007, T1059.008, T1068, T1070, T1070.001, T1070.002, T1070.003, T1071, T1071.001, T1071.002, T1071.003, T1071.004, T1072, T1078, T1078.001, T1078.002, T1078.003, T1078.004, T1080, T1087, T1087.001, T1087.002, T1090, T1090.001, T1090.002, T1091, T1092, T1095, T1098, T1098.001, T1098.002, T1098.003, T1098.004, T1102, T1102.001, T1102.002, T1102.003, T1104, T1105, T1106, T1110, T1110.001, T1110.002, T1110.003, T1110.004, T1111, T1114, T1114.001, T1114.002, T1114.003, T1119, T1127, T1127.001, T1129, T1132, T1132.001, T1132.002, T1133, T1135, T1136, T1136.001, T1136.002, T1136.003, T1137, T1137.001, T1176, T1185, T1187, T1189, T1190, T1197, T1201, T1203, T1204, T1204.001, T1204.002, T1204.003, T1205, T1205.001, T1210, T1211, T1212, T1213, T1213.001, T1213.002, T1216, T1216.001, T1218, T1218.001, T1218.002, T1218.003, T1218.004, T1218.005, T1218.008, T1218.009, T1218.010, T1218.011, T1218.012, T1218.013, T1218.014, T1219, T1220, T1221, T1222, T1222.001, T1222.002, T1484, T1485, T1486, T1489, T1490, T1491, T1491.001, T1491.002, T1499, T1499.001, T1499.002, T1499.003, T1499.004, T1505, T1505.002, T1505.003, T1505.004, T1525, T1528, T1530, T1537, T1539, T1542.004, T1542.005, T1543, T1543.002, T1546.002, T1546.003, T1546.004, T1546.006, T1546.008, T1546.013, T1546.014, T1547.002, T1547.003, T1547.004, T1547.005, T1547.006, T1547.007, T1547.008, T1547.009, T1547.011, T1547.012, T1547.013, T1548, T1548.001, T1548.002, T1548.003, T1548.004, T1550.001, T1550.003, T1552, T1552.001, T1552.002, T1552.003, T1552.004, T1552.005, T1552.006, T1553, T1553.001, T1553.003, T1553.004, T1553.005, T1555, T1555.001, T1555.002, T1555.004, T1555.005, T1556, T1556.001, T1556.002, T1556.003, T1556.004, T1557, T1557.001, T1557.002, T1558, T1558.002, T1558.003, T1558.004, T1559, T1559.002, T1560, T1560.001, T1561, T1561.001, T1561.002, T1562, T1562.001, T1562.002, T1562.003, T1562.004, T1562.006, T1562.010, T1563, T1563.001, T1563.002, T1564.002, T1564.004, T1564.006, T1564.007, T1564.008, T1564.009, T1565, T1565.001, T1565.002, T1565.003, T1566, T1566.001, T1566.002, T1566.003, T1567, T1568, T1568.002, T1569, T1569.002, T1570, T1571, T1572, T1573, T1573.001, T1573.002, T1574, T1574.001, T1574.004, T1574.005, T1574.007, T1574.008, T1574.009, T1574.010, T1578, T1578.001, T1578.002, T1578.003, T1598, T1598.001, T1598.002, T1598.003, T1599, T1599.001, T1601, T1601.001, T1601.002, T1602, T1602.001, T1602.002, T1610, T1611, T1612, T1613

null

Sec 4(D)(2)(h) Sec 4(D)(2)(i)

null

CT.DM-P8

null

P-7 S-5

null

AU-1 SI-4

AU-1 PM-31 SI-4

AU-1 PM-31

AU-1 SI-4

null

AU-1 SI-4

null

AU-1 PM-31 SI-4

AU-1 SI-4

SI-4

AU-1 PM-31 SI-4

NFO - AU-1

3.3.1.a 3.3.1.b 3.12.3

null

A.03.03.05.a A.03.12.03[01] A.03.12.03[02] A.03.12.03[03] A.03.14.06.a.01

null

DE.CM-1 DE.DP-1 DE.DP-2 PR.PT-1

DE.CM DE.CM-01 DE.CM-03 DE.AE

A01:2021 A07:2021 A09:2021

10.1 10.6 10.6.1 10.6.2 10.6.3 10.8 10.8.1

10.1 10.4.3 10.7 10.7.1 10.7.2 10.7.3 A3.3.1

null

10.4.3

null

10.4.3

null

10.4.3 10.7.2 10.7.3

10.4.3 10.7.1 10.7.2 10.7.3

null

J.3.3

6.4

5.2.4

null

SITUATION-1.A.MIL1 SITUATION-3.G.MIL3

COMP:SG1.SP2 MON:SG1.SP3 COMP:SG2.SP1 MON:SG2.SP3 MON:SG2.SP4

8.2

5.4 5.4.3

null

AU-1 SI-4

null

§ 11.10 § 11.10(e)

AU-1 SI-4

null

D3.DC.An.B.2 D3.DC.An.B.3 D1.G.SP.B.3 D2.MA.Ma.B.1 D2.MA.Ma.B.2 D3.DC.Ev.B.4 D1.G.Ov.E.2

null

164.312(b)

null

6.M.C

6.M.C 6.L.B 8.L.E 9.L.B

AU-1 SI-4

null

CIP-007-6 R4

8-602

3.1

null

5.4 5.6

AU-1 SI-4

III.D III.D.3.a III.D.3.b

null

500.06

Sec 4(2)(b)(ii)(C)(2)

null

38-99-20(D)(2)(h) 38-99-20(D)(2)(i)

null

AU-1 SI-4

null

§ 2447(b)(2)(C) § 2447(b)(8) § 2447(b)(8)(A)

3.4.5(39) 3.4.5(40) 3.5(52)

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

5.5 6.3 6.7

OPS-10

null

4.6 6.8 9.10 11.11 12.31 13.9 21.1

null

2-11

TPC-40 TPC-80

3.3.14

2-3-4 2-12-1 2-12-2 2-12-3 2-12-4 5-1-3-3

2-11 2-11-1 2-11-2

null

Sec 19.1 Sec 19.2

null

7.3.8 [OP.EXP.8]

null

B2.d C1.a C1.e C2.a

C1

null

0120 1163 0580 0109 1586 1294 0660

null

12.4.1 12.4.1.15.PB 12.4.5.P

null

16.6.6.C.01 16.6.6.C.02 16.6.8.C.01 16.6.10.C.01 16.6.10.C.02

null

12.2.1 12.2.2 12.2.3

null

6.21

null

3.5

3.3 3.3.1

null

x

NAIC

x

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

null

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-10 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

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Continuous Monitoring

Intrusion Detection & Prevention Systems (IDS & IPS)

MON-01.1

Mechanisms exist to implement Intrusion Detection / Prevention Systems (IDS / IPS) technologies on critical systems, key network segments and network choke points.

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

null

Does the organization implement Intrusion Detection / Prevention Systems (IDS / IPS) technologies on critical systems, key network segments and network choke points?

9

Detect

null

X

There is no evidence of a capability to implement Intrusion Detection / Prevention Systems (IDS / IPS) technologies on critical systems, key network segments and network choke points.

Continuous Monitoring (MON) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Generating event logs and the review of event logs is narrowly-focused to business-critical systems and/ or systems that store, processes and/ or transmit sensitive/regulated data. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to implement Intrusion Detection / Prevention Systems (IDS / IPS) technologies on critical systems, key network segments and network choke points.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to implement Intrusion Detection / Prevention Systems (IDS / IPS) technologies on critical systems, key network segments and network choke points.

CC7.2

CC7.2-POF2 CC7.2-POF3

null

DSS05.07

null

OPA-04

null

NDR 3.2 (15.6.1)

null

8.16

null

TS-2.7

Sec 4(D)(2)(h)

null

SI-4(1)

null

SI-4(1) SI-4(25)

null

SI-4(1) SI-4(25)

null

A01:2021 A07:2021 A09:2021

null

1.4.3 11.5 11.5.1 11.5.1.1

null

1.4.3 11.5.1

null

1.4.3

null

1.4.3 11.5.1

1.4.3 11.5.1 11.5.1.1

null

N.6

6.5A

null

5.10.1.3

null

SI-4(1)

null

SI-4(1)

null

SI-4(1)

null

SI-4(1)

null

SI-4(1)

null

6.S.C

6.M.C

6.M.C 1.L.A

SI-4(1)

null

5.6

null

SI-4(1)

null

38-99-20(D)(2)(h)

null

SI-4(1)

null

7.4 11.11 12.18 23.6

null

2-5-3-6

null

7.6.1 [OP.MON.1]

null

C1.a C1.c

null

0576

null

16.6.10.C.01 16.6.10.C.02 18.4.7.C.01 18.4.7.C.02 18.4.7.C.03 18.4.8.C.01 18.4.8.C.02 18.4.8.C.03 18.4.9.C.01 18.4.9.C.02 18.4.10.C.01 18.4.11.C.01 18.4.11.C.02 18.4.11.C.03 18.4.12.C.01 18.4.14.C.01

null

3.3 4.3 4.4

null

x

NAIC

x

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

null

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-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

Continuous Monitoring

Automated Tools for Real-Time Analysis

MON-01.2

Mechanisms exist to utilize a Security Incident Event Manager (SIEM), or similar automated tool, to support near real-time analysis and incident escalation.

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

E-MON-01 E-MON-05

Does the organization utilize a Security Incident Event Manager (SIEM), or similar automated tool, to support near real-time analysis and incident escalation?

9

Detect

null

X

There is no evidence of a capability to utilize a Security Incident Event Manager (SIEM), or similar automated tool, to support near real-time analysis and incident escalation.

SP-CMM1 is N/A, since a structured process is required to utilize a Security Incident Event Manager (SIEM), or similar automated tool, to support near real-time analysis and incident escalation.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems. • A Security Operations Center (SOC), or similar function, enables cybersecurity operations covering preparation, detection and analysis, containment, eradication and recovery.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to utilize a Security Incident Event Manager (SIEM), or similar automated tool, to support near real-time analysis and incident escalation.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize a Security Incident Event Manager (SIEM), or similar automated tool, to support near real-time analysis and incident escalation.

CC7.2

null

DSS06.05

null

LOG-03

MON-03 OPA-04

null

8.16

null

SI-4(2)

null

SI-4(2)

SI-4(2) SC-48

null

SI-4(2)

SC-48

null

SI-4(2)

null

A01:2021 A07:2021 A09:2021

10.6 10.6.1 10.6.2 10.6.3

10.4 10.4.1 10.4.1.1

null

10.4.1 10.4.1.1

null

10.4.1 10.4.1.1

null

10.4.1 10.4.1.1

null

J.3.2

null

5.4.1

null

SI-4(2)

null

SI-4(2)

null

SI-4(2)

null

SI-4(2)

null

SI-4(2)

null

SI-4(2)

null

5.6

null

SI-4(2)

null

SI-4(2)

null

3.4.5(39) 3.4.5(40)

null

OPS-13

null

11.11 12.31

null

2-11-1-3 2-11-1-4

null

3.3.14

2-12-3-3 5-1-3-3

null

C1.a C1.c

null

Principle 5.17

null

12.4.5.P

null

3.4

null

x

null

x

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

null

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-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

Continuous Monitoring

Inbound & Outbound Communications Traffic

MON-01.3

Mechanisms exist to continuously monitor inbound and outbound communications traffic for unusual or unauthorized activities or conditions.

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

null

Does the organization continuously monitor inbound and outbound communications traffic for unusual or unauthorized activities or conditions?

9

Detect

null

X

There is no evidence of a capability to continuously monitor inbound and outbound communications traffic for unusual or unauthorized activities or conditions.

SP-CMM1 is N/A, since a structured process is required to continuously monitor inbound and outbound communications traffic for unusual or unauthorized activities or conditions.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems. • A Security Operations Center (SOC), or similar function, enables cybersecurity operations covering preparation, detection and analysis, containment, eradication and recovery.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to continuously monitor inbound and outbound communications traffic for unusual or unauthorized activities or conditions.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to continuously monitor inbound and outbound communications traffic for unusual or unauthorized activities or conditions.

CC7.2

null

OPA-04

null

8.16

null

SI-4(4)

null

SI-4(4)

null

SI-4(4)

null

SI-4(4)

null

3.14.6

3.14.6.c

3.14.6[a] 3.14.6[b] 3.14.6[c]

null

3.14.2e

null

DE.AE-1

DE.CM-01 DE.CM-03 DE.CM-06

A01:2021 A07:2021 A09:2021

null

J.7

null

5.4.1

null

SI.L2-3.14.6

SI.L2-3.14.6 TBD - 3.14.2e

null

SI.L2-3.14.6

SI-4(4)

null

SI-4(4)

null

SI-4(4)

null

SI-4(4)

null

SI-4(4)

null

SI-4(4)

null

SI-4(4)

III.D.2.b

null

SI-4(4)

null

9.9 9.10 10.9

null

TPC-40

null

C1.a C1.c C2.a

null

16.6.10.C.01 16.6.10.C.02 18.4.8.C.01 18.4.8.C.02 18.4.8.C.03

null

x

null

x

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

null

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-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

Continuous Monitoring

System Generated Alerts

MON-01.4

Mechanisms exist to monitor, correlate and respond to alerts from physical, cybersecurity, data privacy and supply chain activities to achieve integrated situational awareness.

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

null

Does the organization monitor, correlate and respond to alerts from physical, cybersecurity, data privacy and supply chain activities to achieve integrated situational awareness?

7

Detect

null

X

There is no evidence of a capability to monitor, correlate and respond to alerts from physical, cybersecurity, data privacy and supply chain activities to achieve integrated situational awareness.

Continuous Monitoring (MON) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Generating event logs and the review of event logs is narrowly-focused to business-critical systems and/ or systems that store, processes and/ or transmit sensitive/regulated data. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to monitor, correlate and respond to alerts from physical, cybersecurity, data privacy and supply chain activities to achieve integrated situational awareness.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to monitor, correlate and respond to alerts from physical, cybersecurity, data privacy and supply chain activities to achieve integrated situational awareness.

CC7.2

null

8.4

null

8.4

DSS06.05

null

LOG-03

CLS-08 MON-03

null

CR 2.8 (6.10.1)

null

12.4.1

8.15

12.4.1

null

SI-4(5)

null

SI-4(5)

null

SI-4(5)

null

SI-4(5)

null

NFO - SI-4(5)

3.3.1.a 3.14.6.a 3.14.6.a.1 3.14.6.a.2 3.14.6.b 3.14.6.c

null

A.03.03.01.ODP[01] A.03.03.02.a.01 A.03.03.02.a.02 A.03.03.02.a.03 A.03.03.02.a.04 A.03.03.02.a.05 A.03.03.02.a.06 A.03.03.02.b.07 A.03.03.03.a

null

PR.PS-04 DE.CM-02 DE.CM-03 DE.CM-09

A01:2021 A07:2021 A09:2021

null

10.2 10.4 10.4.1 10.4.1.1 10.4.3

null

10.4.1 10.4.1.1 10.4.3

null

10.4.1 10.4.1.1 10.4.3

null

10.4.1 10.4.1.1 10.4.3

null

J.2.10

null

5.2.4

null

SITUATION-1.A.MIL1 SITUATION-1.B.MIL2 SITUATION-1.C.MIL2 SITUATION-1.D.MIL2 SITUATION-1.F.MIL3

null

5.4.1 5.4.1.1 5.4.1.1.1

null

SI-4(5)

null

SI-4(5)

null

SI-4(5)

null

SI-4(5)

null

SI-4(5)

null

164.312(b)

null

SI-4(5)

null

5.4 5.6

null

SI-4(5)

III.D.3.a

null

SI-4(5)

null

OPS-13

null

21.2 21.4

null

2-11-1-1

TPC-80 TPC-87

null

2-12-3-1

null

7.3.8 [OP.EXP.8]

null

B2.d C1.a C1.c

null

Principle 1.7 Principle 7.8

null

12.4.1 12.4.1.15.PB

null

3.6

null

x

null

x

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

null

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-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

Continuous Monitoring

Wireless Intrusion Detection System (WIDS)

MON-01.5

Mechanisms exist to utilize Wireless Intrusion Detection / Protection Systems (WIDS / WIPS) to identify rogue wireless devices and to detect attack attempts via wireless networks.

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

null

Does the organization utilize Wireless Intrusion Detection / Protection Systems (WIDS / WIPS) to identify rogue wireless devices and to detect attack attempts via wireless networks?

5

Detect

null

X

There is no evidence of a capability to utilize Wireless Intrusion Detection / Protection Systems (WIDS / WIPS) to identify rogue wireless devices and to detect attack attempts via wireless networks.

SP-CMM1 is N/A, since a structured process is required to utilize Wireless Intrusion Detection / Protection Systems (WIDS / WIPS) to identify rogue wireless devices and to detect attack attempts via wireless networks.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to utilize Wireless Intrusion Detection / Protection Systems (WIDS / WIPS) to identify rogue wireless devices and to detect attack attempts via wireless networks.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize Wireless Intrusion Detection / Protection Systems (WIDS / WIPS) to identify rogue wireless devices and to detect attack attempts via wireless networks.

CC7.2

null

MON-08 MON-10

null

SI-4(14) SI-4(15)

null

SI-4(14) SI-4(15)

null

SI-4(14)

SI-4(15)

null

SI-4(14)

null

11.1

11.2

null

N.8.5

6.5A

null

SI-4(14)

null

SI-4(14)

null

SI-4(14)

null

SI-4(14)

null

SI-4(14)

null

6.M.C

null

SI-4(14)

null

SI-4(14)

null

7.6

null

C1.a C1.c

null

16.6.10.C.01 16.6.10.C.02 18.4.8.C.01 18.4.8.C.02 18.4.8.C.03

null

x

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

null

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-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

Continuous Monitoring

Host-Based Devices

MON-01.6

Mechanisms exist to utilize Host-based Intrusion Detection / Prevention Systems (HIDS / HIPS) to actively alert on or block unwanted activities and send logs to a Security Incident Event Manager (SIEM), or similar automated tool, to maintain situational awareness.

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

null

Does the organization utilize Host-based Intrusion Detection / Prevention Systems (HIDS / HIPS) to actively alert on or block unwanted activities and send logs to a Security Incident Event Manager (SIEM), or similar automated tool, to maintain situational awareness?

8

Detect

null

X

There is no evidence of a capability to utilize Host-based Intrusion Detection / Prevention Systems (HIDS / HIPS) to actively alert on or block unwanted activities and send logs to a Security Incident Event Manager (SIEM), or similar automated tool, to maintain situational awareness.

Continuous Monitoring (MON) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Generating event logs and the review of event logs is narrowly-focused to business-critical systems and/ or systems that store, processes and/ or transmit sensitive/regulated data. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to utilize Host-based Intrusion Detection / Prevention Systems (HIDS / HIPS) to actively alert on or block unwanted activities and send logs to a Security Incident Event Manager (SIEM), or similar automated tool, to maintain situational awareness.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize Host-based Intrusion Detection / Prevention Systems (HIDS / HIPS) to actively alert on or block unwanted activities and send logs to a Security Incident Event Manager (SIEM), or similar automated tool, to maintain situational awareness.

CC7.2

null

SI-4(23)

null

SI-4(23)

null

SI-4(23)

null

N.6.2

null

SI-4(23)

null

SI-4(23)

null

SI-4(23)

null

SI-4(23)

null

SI-4(23)

null

SI-4(23)

null

C1.a C1.c

null

x

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

null

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-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

Continuous Monitoring

File Integrity Monitoring (FIM)

MON-01.7

Mechanisms exist to utilize a File Integrity Monitor (FIM), or similar change-detection technology, on critical assets to generate alerts for unauthorized modifications.

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

null

Does the organization utilize a File Integrity Monitor (FIM), or similar change-detection technology, on critical assets to generate alerts for unauthorized modifications?

9

Detect

null

X

There is no evidence of a capability to utilize a File Integrity monitor (FIM), or similar change-detection technology, on critical assets to generate alerts for unauthorized modifications.

Continuous Monitoring (MON) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Generating event logs and the review of event logs is narrowly-focused to business-critical systems and/ or systems that store, processes and/ or transmit sensitive/regulated data. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to utilize a File Integrity monitor (FIM), or similar change-detection technology, on critical assets to generate alerts for unauthorized modifications.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize a File Integrity monitor (FIM), or similar change-detection technology, on critical assets to generate alerts for unauthorized modifications.

CC6.8 CC7.1

CC7.1-POF2 CC7.1-POF3 CC7.1-POF4

null

SAP-06

SO12

null

FR 3 (7.1) CR 3.4 (7.6.3(2))

null

T1003, T1003.003, T1020.001, T1027, T1027.002, T1036, T1036.001, T1036.005, T1037, T1037.002, T1037.003, T1037.004, T1037.005, T1040, T1047, T1053.006, T1056.002, T1059, T1059.001, T1059.002, T1059.003, T1059.004, T1059.005, T1059.006, T1059.007, T1059.008, T1068, T1070, T1070.001, T1070.002, T1070.003, T1072, T1080, T1098.001, T1098.002, T1098.003, T1114, T1114.001, T1114.002, T1114.003, T1119, T1127, T1129, T1133, T1136, T1136.001, T1136.002, T1136.003, T1176, T1185, T1189, T1190, T1195.003, T1203, T1204, T1204.002, T1204.003, T1210, T1211, T1212, T1213, T1213.001, T1213.002, T1216, T1216.001, T1218, T1218.001, T1218.002, T1218.003, T1218.004, T1218.005, T1218.008, T1218.009, T1218.010, T1218.011, T1218.012, T1218.013, T1218.014, T1219, T1220, T1221, T1222, T1222.001, T1222.002, T1485, T1486, T1490, T1491, T1491.001, T1491.002, T1495, T1505, T1505.001, T1505.002, T1505.004, T1525, T1530, T1542, T1542.001, T1542.003, T1542.004, T1542.005, T1543, T1543.002, T1546, T1546.002, T1546.004, T1546.006, T1546.008, T1546.009, T1546.010, T1546.013, T1547.002, T1547.003, T1547.004, T1547.005, T1547.006, T1547.008, T1547.011, T1547.013, T1548, T1548.004, T1550.001, T1550.004, T1552, T1552.004, T1553, T1553.001, T1553.003, T1553.005, T1553.006, T1554, T1556, T1556.001, T1556.003, T1556.004, T1557, T1557.002, T1558, T1558.002, T1558.003, T1558.004, T1561, T1561.001, T1561.002, T1562, T1562.001, T1562.002, T1562.004, T1562.006, T1562.009, T1564.003, T1564.004, T1564.006, T1564.008, T1564.009, T1565, T1565.001, T1565.002, T1569, T1569.002, T1574, T1574.001, T1574.004, T1574.006, T1574.007, T1574.008, T1574.009, T1574.012, T1599, T1599.001, T1601, T1601.001, T1601.002, T1602, T1602.001, T1602.002, T1609, T1611

TS-2.6

null

PR.DS-P6

null

SI-4(24)

null

SI-4(24)

null

PR.DS-8

DE.CM-09

A01:2021 A02:2021 A05:2021 A08:2021 A09:2021

11.5 11.5.1

10.3.4 11.5 11.5.2

null

10.3.4 11.5.2

null

10.3.4 11.5.2

null

10.3.4 11.5.2

null

1.2.5.11

6.2

null

164.312(c) 164.312(c)(1) 164.312(c)(2)

null

2.L.D

SI-4(24)

null

8-613

null

3.4.4(36)(e)

null

6.4 12.19

null

1-5-4

null

C1.a C1.c

null

16.6.10.C.01 16.6.10.C.02

null

x

null

x

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

null

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-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

Continuous Monitoring

Reviews & Updates

MON-01.8

Mechanisms exist to review event logs on an ongoing basis and escalate incidents in accordance with established timelines and procedures.

- Security Incident Event Manager (SIEM) - Splunk

E-MON-01 E-MON-02 E-MON-05

Does the organization review event logs on an ongoing basis and escalate incidents in accordance with established timelines and procedures?

10

Detect

X

There is no evidence of a capability to review event logs on an ongoing basis and escalate incidents in accordance with established timelines and procedures.

Continuous Monitoring (MON) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Generating event logs and the review of event logs is narrowly-focused to business-critical systems and/ or systems that store, processes and/ or transmit sensitive/regulated data. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to review event logs on an ongoing basis and escalate incidents in accordance with established timelines and procedures.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to review event logs on an ongoing basis and escalate incidents in accordance with established timelines and procedures.

CC7.2

CC7.2-POF4

null

8.1

null

LOG-03

CLS-08 MON-04

null

8.16

null

AU-2(3)

null

AU-2

null

AU-2

null

AU-2

3.3.3 3.14.3

null

3.3.3[a] 3.3.3[b] 3.3.3[c] 3.14.3[a] 3.14.3[b] 3.14.3[c]

A.03.03.05.a

null

PR.PT-1

DE.AE-02

A01:2021 A07:2021 A09:2021

null

10.4 10.4.1 10.4.1.1 10.4.2 10.4.2.1 10.4.3

null

10.4.1 10.4.1.1 10.4.2 10.4.2.1 10.4.3

null

10.4.1 10.4.1.1 10.4.2 10.4.2.1 10.4.3

null

10.4.1 10.4.1.1 10.4.2 10.4.2.1 10.4.3

null

J.3

null

5.2.4

null

SITUATION-2.A.MIL1 SITUATION-2.B.MIL1 SITUATION-2.C.MIL2

null

AU.L2-3.3.3 SI.L2-3.14.3

null

AU.L2-3.3.3 SI.L2-3.14.3

null

AU-2(3)

null

AU-2(3)

null

164.312(b)

null

AU-2

null

5.6 5.7

null

AU-2(3)

III.D.3.a

null

Sec 4(2)(b)(ii)(C)(2)

null

3.4.5(39) 3.4.5(40)

null

5.5

null

12.31 21.3 21.11

null

2-11-1-2

TPC-40

null

2-12-3-4

null

B2.d C1.a C1.e

C1 C2

null

Principle 1.8 Principle 3.12 Principle 4.18

null

0109

null

12.2.2

null

3.5

3.3.1 3.3.2

null

x

null

x

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

null

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-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

Continuous Monitoring

Proxy Logging

MON-01.9

Mechanisms exist to log all Internet-bound requests, in order to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

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

null

Does the organization log all Internet-bound requests, in order to identify prohibited activities and assist incident handlers with identifying potentially compromised systems?

8

Detect

null

X

There is no evidence of a capability to log all Internet-bound requests, in order to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

Continuous Monitoring (MON) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Generating event logs and the review of event logs is narrowly-focused to business-critical systems and/ or systems that store, processes and/ or transmit sensitive/regulated data. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to log all Internet-bound requests, in order to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to log all Internet-bound requests, in order to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

null

J.7.3

null

6.M.D

null

9.14 21.20

null

C1.a C1.c

null

0261

null

14.3.6.C.02 16.6.10.C.01 16.6.10.C.02

null

x

null

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

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 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

Continuous Monitoring

Deactivated Account Activity

MON-01.10

Mechanisms exist to monitor deactivated accounts for attempted usage.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Security Incident Event Manager (SIEM) - Splunk - NNT Change Tracker (https://www.newnettechnologies.com)

null

Does the organization monitor deactivated accounts for attempted usage?

9

Detect

null

X

There is no evidence of a capability to monitor deactivated accounts for attempted usage.

Continuous Monitoring (MON) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Generating event logs and the review of event logs is narrowly-focused to business-critical systems and/ or systems that store, processes and/ or transmit sensitive/regulated data. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to monitor deactivated accounts for attempted usage.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to monitor deactivated accounts for attempted usage.

null

A09:2021

null

I.1.9

null

C1.a C1.c

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-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-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

Continuous Monitoring

Automated Response to Suspicious Events

MON-01.11

Mechanisms exist to automatically implement pre-determined corrective actions in response to detected events that have security incident implications.

null

Does the organization automatically implement pre-determined corrective actions in response to detected events that have security incident implications?

5

Detect

null

X

There is no evidence of a capability to automatically implement pre-determined corrective actions in response to detected events that have security incident implications.

SP-CMM1 is N/A, since a structured process is required to automatically implement pre-determined corrective actions in response to detected events that have security incident implications.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

Continuous Monitoring (MON) 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.

Continuous Monitoring (MON) 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

CLS-08

null

SI-4(7)

null

IR-4(5) SI-4(7)

null

IR-4(5) SI-4(7)

null

3.14.2e

null

A3.2.6.1

null

M.1.44

null

TBD - 3.14.2e

null

x

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

null

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-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

Continuous Monitoring

Automated Alerts

MON-01.12

Mechanisms exist to automatically alert incident response personnel to inappropriate or anomalous activities that have potential security incident implications.

null

Does the organization automatically alert incident response personnel to inappropriate or anomalous activities that have potential security incident implications?

5

Detect

null

X

There is no evidence of a capability to automatically alert incident response personnel to inappropriate or anomalous activities that have potential security incident implications.

SP-CMM1 is N/A, since a structured process is required to automatically alert incident response personnel to inappropriate or anomalous activities that have potential security incident implications.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to automatically alert incident response personnel to inappropriate or anomalous activities that have potential security incident implications.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to automatically alert incident response personnel to inappropriate or anomalous activities that have potential security incident implications.

null

LOG-03

MON-03

null

SI-4(12)

null

SI-4(12)

null

SI-4(12)

null

SI-4(12)

null

3.3.4.a

null

A3.2.6.1

null

J.2.10

null

SI-4(12)

null

SI-4(12)

null

2-12-3-1

null

B2.d C1.c

null

x

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

null

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-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

Continuous Monitoring

Alert Threshold Tuning

MON-01.13

Mechanisms exist to "tune" event monitoring technologies through analyzing communications traffic/event patterns and developing profiles representing common traffic patterns and/or events.

null

Does the organization "tune" event monitoring technologies through analyzing communications traffic/event patterns and developing profiles representing common traffic patterns and/or events?

5

Detect

null

X

There is no evidence of a capability to "tune" event monitoring technologies through analyzing communications traffic/event patterns and developing profiles representing common traffic patterns and/ or events.

SP-CMM1 is N/A, since a structured process is required to "tune" event monitoring technologies through analyzing communications traffic/event patterns and developing profiles representing common traffic patterns and/ or events.

Continuous Monitoring (MON) 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: • Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs. • A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

Continuous Monitoring (MON) 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: o Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. • A Security Incident Event Manager (SIEM), or similar automated tool: o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events. • Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems. • A Security Operations Center (SOC), or similar function, enables cybersecurity operations covering preparation, detection and analysis, containment, eradication and recovery. • Administrative processes exist and a SIEM, or similar automated tool, is configured to perform trend analysis to assist in the determination if security control implementations, the frequency of continuous monitoring activities, and/ or the types of activities used in the continuous monitoring process need to be modified based on empirical data.

Continuous Monitoring (MON) 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.

Continuous Monitoring (MON) 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

13.6 13.11

null

13.6

13.6 13.11

null

LOG-05

OPA-04

null

SI-4(13)

null

SI-4(13)

null

SI-4(13)

null

3.14.2e

null

J.3.2

null

5.4 5.4.1 5.4.3

null

TBD - 3.14.2e

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-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

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 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