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

Continuous Monitoring

Individuals Posing Greater Risk

MON-01.14

Mechanisms exist to implement enhanced activity monitoring for individuals who have been identified as posing an increased level of risk.

null

E-MON-03

Does the organization implement enhanced activity monitoring for individuals who have been identified as posing an increased level of risk?

5

Detect

null

X

There is no evidence of a capability to implement enhanced activity monitoring for individuals who have been identified as posing an increased level of risk.

SP-CMM1 is N/A, since a structured process is required to implement enhanced activity monitoring for individuals who have been identified as posing an increased level of risk.

SP-CMM2 is N/A, since a well-defined process is required to implement enhanced activity monitoring for individuals who have been identified as posing an increased level of risk.

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. • Human Resources (HR) and Legal departments determine what is legally-allowable to support enhanced monitoring for individuals who pose a greater risk to the organization, including privileged users. • A Security Operations Center (SOC), or similar capability, configures monitoring technologies to implement the enhanced monitoring profiles for selected users and establish a reporting capability to designated personnel.

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

SI-4(19)

null

SI-4(19)

null

SI-4(19)

null

SI-4(19)

null

SI-4(19)

null

3.14.2e

null

B.1.1.6

null

TBD - 3.14.2e

null

SI-4(19)

null

SI-4(19)

null

SI-4(19)

null

SI-4(19)

null

6.7

null

2-12-3-2

null

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

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

Privileged User Oversight

MON-01.15

Mechanisms exist to implement enhanced activity monitoring for privileged users.

null

E-MON-03

Does the organization implement enhanced activity monitoring for privileged users?

5

Detect

null

X

null

There is no evidence of a capability to implement enhanced activity monitoring for privileged users.

SP-CMM1 is N/A, since a structured process is required to implement enhanced activity monitoring for privileged users.

SP-CMM2 is N/A, since a well-defined process is required to implement enhanced activity monitoring for privileged users.

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. • Human Resources (HR) and Legal departments determine what is legally-allowable to support enhanced monitoring for individuals who pose a greater risk to the organization, including privileged users. • A Security Operations Center (SOC), or similar capability, configures monitoring technologies to implement the enhanced monitoring profiles for selected users and establish a reporting capability to designated personnel.

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

3.14

null

3.14

null

IAM-09 IAM-10 IAM-11 LOG-11

CLS-07

null

SI-4(20)

null

SI-4(20)

null

SI-4(20)

null

SI-4(20)

null

3.1.7.b

null

3.14.2e

null

D.21

null

TBD - 3.14.2e

null

SI-4(20)

null

SI-4(20)

null

SI-4(20)

null

SI-4(20)

null

6.7

null

TPC-83

null

2-12-3-2

null

B2.c C1.a C1.c

null

Principle 5.11 Principle 5.12

Principle 5.15

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

Continuous Monitoring

Analyze and Prioritize Monitoring Requirements

MON-01.16

Mechanisms exist to assess the organization's needs for monitoring and prioritize the monitoring of assets, based on asset criticality and the sensitivity of the data it stores, transmits and processes.

null

Does the organization assess the organization's needs for monitoring and prioritize the monitoring of assets, based on asset criticality and the sensitivity of the data it stores, transmits and processes?

5

Detect

null

X

null

There is no evidence of a capability to assess the organization's needs for monitoring and prioritize the monitoring of assets, based on asset criticality and the sensitivity of the data it stores, transmits and processes.

SP-CMM1 is N/A, since a structured process is required to assess the organization's needs for monitoring and prioritize the monitoring of assets, based on asset criticality and the sensitivity of the data it stores, transmits and processes.

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 assess the organization's needs for monitoring and prioritize the monitoring of assets, based on asset criticality and the sensitivity of the data it stores, transmits and processes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to assess the organization's needs for monitoring and prioritize the monitoring of assets, based on asset criticality and the sensitivity of the data it stores, transmits and processes.

null

LOG-11

CLS-07 CLS-08

null

TS-1.11

null

G.3.8.1

null

SITUATION-1.E.MIL2

MON:SG1.SP4

null

5.4 5.4.1 5.4.3

null

B2.d C1.e

null

3.3.1 3.3.2

null

R-AC-1 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

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

Real-Time Session Monitoring

MON-01.17

Mechanisms exist to enable authorized personnel the ability to remotely view and hear content related to an established user session in real time, in accordance with organizational standards, as well as statutory, regulatory and contractual obligations.

null

Does the organization enable authorized personnel the ability to remotely view and hear content related to an established user session in real time, in accordance with organizational standards, as well as statutory, regulatory and contractual obligations?

4

Detect

null

X

There is no evidence of a capability to enable authorized personnel the ability to remotely view and hear content related to an established user session in real time, in accordance with organizational standards, as well as statutory, regulatory and contractual obligations.

SP-CMM1 is N/A, since a structured process is required to enable authorized personnel the ability to remotely view and hear content related to an established user session in real time, in accordance with organizational standards, as well as statutory, regulatory and contractual obligations.

SP-CMM2 is N/A, since a well-defined process is required to enable authorized personnel the ability to remotely view and hear content related to an established user session in real time, in accordance with organizational standards, as well as statutory, regulatory and contractual obligations.

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 enable authorized personnel the ability to remotely view and hear content related to an established user session in real time, in accordance with 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 enable authorized personnel the ability to remotely view and hear content related to an established user session in real time, in accordance with organizational standards, as well as statutory, regulatory and contractual obligations.

null

AU-14(3)

null

AU-14(3)

null

N.27.4

null

B2.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-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

Centralized Collection of Security Event Logs

MON-02

Mechanisms exist to utilize a Security Incident Event Manager (SIEM) or similar automated tool, to support the centralized collection of security-related event logs.

- Security Incident Event Manager (SIEM) - Splunk

E-MON-01 E-MON-05

Does the organization utilize a Security Incident Event Manager (SIEM) or similar automated tool, to support the centralized collection of security-related event logs?

10

Detect

X

There is no evidence of a capability to utilize a Security Incident Event Manager (SIEM) or similar automated tool, to support the centralized collection of security-related event logs.

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 the centralized collection of security-related event logs.

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.

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 the centralized collection of security-related event logs.

CC7.2 CC7.3

null

3.14 8.1 8.2 8.3 8.4 8.5 8.6 8.7 8.8 8.9 8.12 13.1

8.1 8.2 8.3

8.1 8.2 8.3 8.4 8.5 8.6 8.7 8.8 8.9 13.1

3.14 8.1 8.2 8.3 8.4 8.5 8.6 8.7 8.8 8.9 8.12 13.1

DSS06.05

null

LOG-03

CLS-08 MON-07

SO17 SO20 SO21

null

8.15

null

TS-1.5 TS-1.11

null

AU-2 AU-2(3) AU-6 IR-4(4) SI-4

AU-2 AU-6 SI-4

AU-2 AU-2(3) AU-6 SI-4

AU-2 AU-6 IR-4(4) SI-4

AU-2

AU-2 AU-6 SI-4

AU-2 AU-6 IR-4(4) SI-4

null

AU-2 AU-6 SI-4

AU-2 AU-6 IR-4(4) SI-4

null

AU-2 AU-6 SI-4

AU-2 SI-4

AU-2 AU-6 SI-4

3.3.1 3.3.3 3.3.5 3.3.6 3.3.8 3.3.9

3.3.5.a

null

A.03.03.05.c A.03.03.06.a

null

DE.AE-3

null

A09:2021

10.2.1 10.2.2 10.2.3 10.2.4 10.2.5 10.2.6 10.2.7 11.4

10.3.3 10.4 10.4.1 10.4.1.1

null

10.3.3 10.4.1 10.4.1.1

null

10.3.3 10.4.1 10.4.1.1

null

10.3.3 10.4.1 10.4.1.1

null

J.3.2

6.1 6.2 6.3 6.4

null

SITUATION-1.E.MIL2

COMP:SG2.SP1 COMP:SG3.SP1 MON:SG1.SP3 MON:SG2.SP3 MON:SG2.SP4

3.1

5.4 5.4.1 5.4.3

null

AU.L2-3.3.1 AU.L2-3.3.3 AU.L2-3.3.5 AU.L2-3.3.6 AU.L2-3.3.8 AU.L2-3.3.9

null

AU.L2-3.3.1 AU.L2-3.3.3 AU.L2-3.3.5 AU.L2-3.3.6 AU.L2-3.3.8 AU.L2-3.3.9

AU-2 AU-2(3) AU-6 SI-4

null

§ 11.10 § 11.10(b) § 11.10(c) § 11.10(e)

AU-2 AU-6 SI-4

null

AU-2 AU-6 SI-4

null

8-602

null

5.4

AU-2 AU-6

null

17.03(2)(b)(3) 17.04(4)

null

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

null

AU-2 AU-6 SI-4

AU-2 AU-2(3) AU-6 SI-4

null

3.5(52)

null

OPS-14

null

4.6 12.17 21.3 21.4 21.6 21.12

null

2-11-1-3 2-11-1-4

TPC-81

3.3.14

null

2-11-1-3 2-11-1-9

null

C1.a C1.c

C1 C2

null

Principle 5.14

null

1566 1405 0109 1228

null

16.6.11.C.01 16.6.11.C.02 16.6.11.C.03 16.6.12.C.01 16.6.12.C.02 16.6.12.C.03

null

9.1.3

null

6.21

null

3.2

3.3.1 3.3.2

null

x

MA 201 CMR 17 OR 6464A

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

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

Correlate Monitoring Information

MON-02.1

Automated mechanisms exist to correlate both technical and non-technical information from across the enterprise by a Security Incident Event Manager (SIEM) or similar automated tool, to enhance organization-wide situational awareness.

- 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 use automated mechanisms to correlate both technical and non-technical information from across the enterprise by a Security Incident Event Manager (SIEM) or similar automated tool, to enhance organization-wide situational awareness?

9

Detect

null

X

There is no evidence of a capability to correlate both technical and non-technical information from across the enterprise by a Security Incident Event Manager (SIEM) or similar automated tool, to enhance organization-wide situational awareness.

SP-CMM1 is N/A, since a structured process is required to correlate both technical and non-technical information from across the enterprise by a Security Incident Event Manager (SIEM) or similar automated tool, to enhance organization-wide situational awareness.

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 correlate both technical and non-technical information from across the enterprise by a Security Incident Event Manager (SIEM) or similar automated tool, to enhance organization-wide situational awareness.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to correlate both technical and non-technical information from across the enterprise by a Security Incident Event Manager (SIEM) or similar automated tool, to enhance organization-wide situational awareness.

CC7.2 CC7.3

null

3.14 8.12 13.6

null

13.6

3.14 8.12 13.6

DSS06.05

null

LOG-03 LOG-12

null

8.15

null

TS-1.5 TS-1.11

null

AU-6(3) IR-4(4) SI-4(16)

null

AU-6(3)

AU-6(3) IR-4(4)

AU-6(3) AU-6(9) IR-4(4) SI-4(16)

null

AU-6(3)

AU-6(3) IR-4(4)

SI-4(16)

null

AU-6(3)

AU-6(3) IR-4(4)

null

AU-6(9)

null

AU-6(9)

3.3.5 3.14.7

3.3.5.c

3.3.5[a] 3.3.5[b] 3.14.7[a] 3.14.7[b]

A.03.03.05.c

null

DE.AE-3

DE.AE-03

A09:2021

null

10.4.1.1 12.10.5

null

10.4.1.1

null

10.4.1.1

null

10.4.1.1 12.10.5

null

J.3.2

null

SITUATION-1.E.MIL2 SITUATION-3.E.MIL3 SITUATION-3.F.MIL3

null

3.1

5.4 5.4.1 5.4.3

null

AU.L2-3.3.5 SI.L2-3.14.7

null

AU.L2-3.3.5 SI.L2-3.14.7

AU-6(3)

null

AU-6(3) IR-4(4) SI-4(16)

null

AU-6(3) SI-4(16)

AU-6(3) IR-4(4) SI-4(16)

null

AU-6(3) IR-4(4) SI-4(16)

null

AU-6(3) SI-4(16)

AU-6(3) IR-4(4) SI-4(16)

null

AU-6(3) AU-6(9)

null

5.6

null

AU-6(3) SI-4(16)

null

AU-6(3) SI-4(16)

null

OPS-13

null

4.6 12.17 21.6 21.12 21.13 21.19

null

2-11-1-3 2-11-1-4

TPC-81

3.3.14

null

2-11-1-4 2-11-1-5 2-11-1-6 2-11-1-7 2-11-1-8 2-11-1-10

null

C1.a C1.c

null

Principle 5.17

null

1228

null

16.6.14.C.01 18.4.12.C.01

null

12.2.5

null

3.6

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-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

Central Review & Analysis

MON-02.2

Automated mechanisms exist to centrally collect, review and analyze audit records from multiple sources.

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

E-MON-01 E-MON-02 E-MON-05

Does the organization use automated mechanisms to centrally collect, review and analyze audit records from multiple sources?

5

Detect

X

There is no evidence of a capability to centrally collect, review and analyze audit records from multiple sources.

SP-CMM1 is N/A, since a structured process is required to centrally collect, review and analyze audit records from multiple sources.

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

8.11

null

8.11

null

LOG-03

CLS-08 MON-07

null

12.4.1

6.8 8.15 8.16

12.4.1

null

TS-1.5 TS-1.11

null

CT.DM-P8

null

AU-6(4)

null

AU-6(4)

null

AU-6(4)

null

3.3.1.b 3.3.5.a 3.3.5.b 3.3.5.c

null

A.03.03.05.a

null

10.3.3 10.4 10.4.1 10.4.1.1

null

10.3.3 10.4.1 10.4.1.1

null

10.3.3 10.4.1 10.4.1.1

null

10.3.3 10.4.1 10.4.1.1

null

J.1.2

6.1 6.2 6.3 6.4

null

SITUATION-3.A.MIL2

null

3.1

null

AU-6(4)

null

AU-6(4)

null

AU-6(4)

null

AU-6(4)

null

3.1

null

3.5(52)

null

OPS-13

null

2-11-1-3

TPC-81

null

2-12-3-4

2-11-1-9 2-11-2

null

7.3.8 [OP.EXP.8]

null

C1.a C1.c C1.e

C1 C2

null

Principle 5.17 Principle 7.10

null

1228

null

12.4.1 12.4.1.15.PB

null

16.6.11.C.01 16.6.11.C.02 16.6.11.C.03 16.6.12.C.01 16.6.12.C.02 16.6.12.C.03

null

12.2.6

null

6.21

null

3.3.1 3.3.2

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

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

Integration of Scanning & Other Monitoring Information

MON-02.3

Automated mechanisms exist to integrate the analysis of audit records with analysis of vulnerability scanners, network performance, system monitoring and other sources to further enhance the ability to identify inappropriate or unusual activity.

null

Does the organization use automated mechanisms to integrate the analysis of audit records with analysis of vulnerability scanners, network performance, system monitoring and other sources to further enhance the ability to identify inappropriate or unusual activity?

5

Detect

null

X

There is no evidence of a capability to integrate the analysis of audit records with analysis of vulnerability scanners, network performance, system monitoring and other sources to further enhance the ability to identify inappropriate or unusual activity.

SP-CMM1 is N/A, since a structured process is required to integrate the analysis of audit records with analysis of vulnerability scanners, network performance, system monitoring and other sources to further enhance the ability to identify inappropriate or unusual activity.

SP-CMM2 is N/A, since a well-defined process is required to integrate the analysis of audit records with analysis of vulnerability scanners, network performance, system monitoring and other sources to further enhance the ability to identify inappropriate or unusual activity.

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

3.14 8.6 8.7 8.12 13.6

null

8.6 8.7 13.6

3.14 8.6 8.7 8.12 13.6

null

LOG-11

null

TS-1.11

null

AU-6(5)

null

AU-6(5)

AU-6(5) SI-4(17)

null

AU-6(5)

SI-4(17)

null

AU-6(5)

null

SI-4(17)

null

SI-4(17)

null

3.3.5.c

null

DE.CM-02

null

J.3

null

AU-6(5)

null

AU-6(5)

null

AU-6(5)

null

AU-6(5)

null

2-11-1-4 2-11-1-5 2-11-1-6 2-11-1-7 2-11-1-8 2-11-1-10

null

C1.a C1.c

C1 C2

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

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

Correlation with Physical Monitoring

MON-02.4

Automated mechanisms exist to correlate information from audit records with information obtained from monitoring physical access to further enhance the ability to identify suspicious, inappropriate, unusual or malevolent activity.

null

Does the organization use automated mechanisms to correlate information from audit records with information obtained from monitoring physical access to further enhance the ability to identify suspicious, inappropriate, unusual or malevolent activity?

5

Detect

null

X

There is no evidence of a capability to correlate information from audit records with information obtained from monitoring physical access to further enhance the ability to identify suspicious, inappropriate, unusual or malevolent activity.

SP-CMM1 is N/A, since a structured process is required to correlate information from audit records with information obtained from monitoring physical access to further enhance the ability to identify suspicious, inappropriate, unusual or malevolent activity.

SP-CMM2 is N/A, since a well-defined process is required to correlate information from audit records with information obtained from monitoring physical access to further enhance the ability to identify suspicious, inappropriate, unusual or malevolent activity.

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

LOG-12

null

AU-6(6)

null

AU-6(6)

null

AU-6(6)

null

AU-6(6)

null

3.14.2e

null

DE.CM-02 DE.AE-03

null

J.3

null

TBD - 3.14.2e

null

AU-6(6)

null

AU-6(6)

null

AU-6(6)

null

AU-6(6)

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

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

Permitted Actions

MON-02.5

Mechanisms exist to specify the permitted actions for both users and systems associated with the review, analysis and reporting of audit information.

null

Does the organization specify the permitted actions for both users and systems associated with the review, analysis and reporting of audit information?

5

Protect

null

X

There is no evidence of a capability to specify the permitted actions for both users and systems associated with the review, analysis and reporting of audit information.

SP-CMM1 is N/A, since a structured process is required to specify the permitted actions for both users and systems associated with the review, analysis and reporting of audit information.

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 specify the permitted actions for both users and systems associated with the review, analysis and reporting of audit information.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to specify the permitted actions for both users and systems associated with the review, analysis and reporting of audit information.

null

LOG-09

MON-04

null

AU-6(7)

null

AU-6(7)

null

AU-6(7)

null

J.2.10

null

AU-6(7)

null

AU-6(7)

null

AU-6(7)

null

AU-6(7)

null

AU-6(7)

null

2-3-1-8

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

Audit Level Adjustments

MON-02.6

Mechanisms exist to adjust the level of audit review, analysis and reporting based on evolving threat information from law enforcement, industry associations or other credible sources of threat intelligence.

null

Does the organization adjust the level of audit review, analysis and reporting based on evolving threat information from law enforcement, industry associations or other credible sources of threat intelligence?

5

Detect

null

X

There is no evidence of a capability to adjust the level of audit review, analysis and reporting based on evolving threat information from law enforcement, industry associations or other credible sources of threat intelligence.

SP-CMM1 is N/A, since a structured process is required to adjust the level of audit review, analysis and reporting based on evolving threat information from law enforcement, industry associations or other credible sources of threat intelligence.

SP-CMM2 is N/A, since a well-defined process is required to adjust the level of audit review, analysis and reporting based on evolving threat information from law enforcement, industry associations or other credible sources of threat intelligence.

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 capability, configures monitoring technologies to implement the enhanced monitoring profiles for selected users and establish a reporting capability to designated personnel.

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 adjust the level of audit review, analysis and reporting based on evolving threat information from law enforcement, industry associations or other credible sources of threat intelligence.

null

AU-6(10)

null

AU-6

null

AU-6

null

AU-6

null

AU-6

null

AU-6

null

J.1.2

null

AU-6(10)

null

AU-6(10)

null

AU-6

null

AU-6

null

OIS-05

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-Wide / Time-Correlated Audit Trail

MON-02.7

Automated mechanisms exist to compile audit records into an organization-wide audit trail that is time-correlated.

null

Does the organization use automated mechanisms to compile audit records into an organization-wide audit trail that is time-correlated?

5

Detect

null

X

There is no evidence of a capability to compile audit records into an organization-wide audit trail that is time-correlated.

SP-CMM1 is N/A, since a structured process is required to compile audit records into an organization-wide audit trail that is time-correlated.

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

8.2

null

LOG-03

MON-07

null

AU-12(1)

null

AU-12(1)

null

AU-12(1)

null

AU-12(1)

null

3.3.1.a

null

DE.AE-03

null

10.6 10.6.1 10.6.2 10.6.3

null

10.6.1 10.6.2 10.6.3

null

10.6.1 10.6.2 10.6.3

null

10.6.1 10.6.2 10.6.3

null

G.6.1

null

3.1

null

AU-12(1)

null

AU-12(1)

null

AU-12(1)

null

AU-12(1)

null

AU-12(1)

null

AU-12(1)

null

2-11-1-1 2-11-1-2 2-11-1-3

null

C1.a C1.c

null

0988

null

16.6.11.C.02

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-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

Changes by Authorized Individuals

MON-02.8

Mechanisms exist to provide privileged users or roles the capability to change the auditing to be performed on specified information system components, based on specific event criteria within specified time thresholds.

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

null

Does the organization provide privileged users or roles the capability to change the auditing to be performed on specified information system components, based on specific event criteria within specified time thresholds?

5

Detect

null

X

There is no evidence of a capability to provide privileged users or roles the capability to change the auditing to be performed on specified information system components, based on specific event criteria within specified time thresholds.

SP-CMM1 is N/A, since a structured process is required to provide privileged users or roles the capability to change the auditing to be performed on specified information system components, based on specific event criteria within specified time thresholds.

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 provide privileged users or roles the capability to change the auditing to be performed on specified information system components, based on specific event criteria within specified time thresholds.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide privileged users or roles the capability to change the auditing to be performed on specified information system components, based on specific event criteria within specified time thresholds.

null

LOG-09

MON-04

null

TS-1.5

null

AU-12(3)

null

AU-12(3)

null

AU-12(3)

null

AU-12(3)

null

H.2.5

null

AU-12(3)

null

AU-12(3)

null

AU-12(3)

null

AU-12(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

Continuous Monitoring

Content of Event Logs

MON-03

Mechanisms exist to configure systems to produce event logs that contain sufficient information to, at a minimum: ▪ Establish what type of event occurred; ▪ When (date and time) the event occurred; ▪ Where the event occurred; ▪ The source of the event; ▪ The outcome (success or failure) of the event; and ▪ The identity of any user/subject associated with the event.

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

null

Does the organization configure systems to produce event logs that contain sufficient information to, at a minimum: ▪ Establish what type of event occurred; ▪ When (date and time) the event occurred; ▪ Where the event occurred; ▪ The source of the event; ▪ The outcome (success or failure) of the event; and ▪ The identity of any user/subject associated with the event?

10

Detect

X

There is no evidence of a capability to configure systems to produce event logs that contain sufficient information to, at a minimum: ▪ Establish what type of event occurred; ▪ When (date and time) the event occurred; ▪ Where the event occurred; ▪ The source of the event; ▪ The outcome (success or failure) of the event; and ▪ The identity of any user/subject associated with the event.

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 configure systems to produce event logs that contain sufficient information to, at a minimum: ▪ Establish what type of event occurred; ▪ When (date and time) the event occurred; ▪ Where the event occurred; ▪ The source of the event; ▪ The outcome (success or failure) of the event; and ▪ The identity of any user/subject associated with the event.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to configure systems to produce event logs that contain sufficient information to, at a minimum: ▪ Establish what type of event occurred; ▪ When (date and time) the event occurred; ▪ Where the event occurred; ▪ The source of the event; ▪ The outcome (success or failure) of the event; and ▪ The identity of any user/subject associated with the event.

PI1.4

null

3.14 8.2

8.2

3.14 8.2

null

LOG-08

MON-03 MON-06

null

CR 2.8 (6.10.1)

null

12.4.1

8.15

12.4.1

null

Sec 4(D)(2)(i)

null

AU-3 DM-2(1)

AU-3

null

AU-3

null

AU-3

null

AU-3

3.3.2

3.3.1.a 3.3.2.a 3.3.2.a.1 3.3.2.a.2 3.3.2.a.3 3.3.2.a.4 3.3.2.a.5 3.3.2.a.6 3.3.2.b 3.3.3.a

3.3.1[a] 3.3.1[b] 3.3.1[d] 3.3.2[a] 3.3.2[b]

A.03.03.01.b[01] A.03.03.01.b[02] 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

A09:2021

10.3 10.3.1 10.3.2 10.3.3 10.3.4 10.3.5 10.3.6

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

null

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

null

10.2.1.2 10.2.1.4 10.2.1.5 10.2.2

null

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

null

N.15

null

COMP:SG1.SP3 COMP:SG3.SP1 TM:SG2.SP2

3.1

5.4.1 5.4.1.1 5.4.1.1.1

null

AU.L2-3.3.2

null

AU.L2-3.3.2

AU-3

null

§ 11.10 § 11.10(b) § 11.10(c) § 11.10(e)

AU-3

null

AU-3

null

8-602

3.1 3.2 7.1

null

AU-3

III.D.3.a

null

500.06

null

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

null

AU-3

null

3.5(52)

null

6.3

OPS-15

null

4.6 12.17 21.2 21.5 21.7 21.10

null

2-11-1-5

null

7.3.8 [OP.EXP.8]

null

C1.a C1.c

null

0582 1536 1537 0585

null

12.4.1 12.4.1.15.PB

null

16.6.7.C.01 16.6.9.C.01 16.6.10.C.01 16.6.10.C.02

null

6.21

null

x

NAIC

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-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

Continuous Monitoring

Sensitive Audit Information

MON-03.1

Mechanisms exist to protect sensitive/regulated data contained in log files.

null

Does the organization protect sensitive/regulated data contained in log files?

8

Detect

null

X

There is no evidence of a capability to protect sensitive/regulated data contained in log files.

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 protect sensitive/regulated data contained in log files.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to protect sensitive/regulated data contained in log files.

null

3.14

null

3.14

null

LOG-02

null

AU-3(1) AU-6(1)

null

AU-3(1) AU-6(1)

null

AU-3(1) AU-6(1)

null

AU-3(1) AU-6(1)

null

3.3.8

null

N.15.1

null

AU.L2-3.3.8

null

AU.L2-3.3.8

AU-3(1) AU-6(1)

null

AU-3(1) AU-6(1)

null

AU-3(1) AU-6(1)

null

AU-3(1) AU-6(1)

null

AU-3(1) AU-6(1)

null

AU-3(1) AU-6(1)

null

5.4 5.6

null

AU-3(1) AU-6(1)

null

AU-3(1) AU-6(1)

null

21.4

null

x

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-GV-2 R-GV-4 R-GV-5 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

null

R-GV-2

null

R-GV-4

R-GV-5

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

Continuous Monitoring

Audit Trails

MON-03.2

Mechanisms exist to link system access to individual users or service accounts.

null

Does the organization link system access to individual users or service accounts?

10

Detect

null

X

There is no evidence of a capability to link system access to individual users or service accounts.

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. • Secure baseline configurations restrict access to event logs from privileged users to protect event logs and audit tools from unauthorized access, modification and deletion.

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 link system access to individual users or service accounts.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to link system access to individual users or service accounts.

null

LOG-02

null

3.3.1.a

3.3.2[a] 3.3.1[c]

null

A09:2021

10.1

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

null

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

null

10.2.1.2 10.2.1.4 10.2.1.5 10.2.2

null

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

null

H.2.2

null

3.1

null

§ 11.10 § 11.10(b) § 11.10(c) § 11.10(e)

null

3.1 3.2 7.1

null

5.4

null

III.D.3.b

null

12.17

null

2-11-1-3

null

C1.a C1.c

null

16.6.8.C.01 16.6.9.C.01 16.6.10.C.01 16.6.10.C.02

null

9.2.2

null

x

null

x

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-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

Privileged Functions Logging

MON-03.3

Mechanisms exist to log and review the actions of users and/or services with elevated privileges.

- Security Incident Event Manager (SIEM) - Splunk

null

Does the organization log and review the actions of users and/or services with elevated privileges?

8

Detect

null

X

There is no evidence of a capability to log and review the actions of users and/ or services with elevated privileges.

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. • Logs of privileged functions (e.g., administrator or root actions) are reviewed for evidence of unauthorized activities.

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. • Human Resources (HR) and Legal departments determine what is legally-allowable to support enhanced monitoring for individuals who pose a greater risk to the organization, including privileged users. • A Security Operations Center (SOC), or similar capability, configures monitoring technologies to implement the enhanced monitoring profiles for selected users and establish a reporting capability to designated personnel. • Logs of privileged functions (e.g., administrator or root actions) are reviewed for evidence of unauthorized activities.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to log and review the actions of users and/ or services with elevated privileges.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to log and review the actions of users and/ or services with elevated privileges.

null

8.8

null

8.8

null

IAM-09 IAM-10 IAM-11

null

12.4.3

8.15

12.4.3

null

6.9.4.3

null

AU-6(8)

null

AU-6(8)

null

AU-6(8)

null

3.1.7.b

null

A.03.01.07.b

null

A09:2021

10.2 10.2.1 10.2.2 10.2.3 10.2.4 10.2.5 10.2.6 10.2.7

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

null

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

null

10.2.1.2 10.2.1.4 10.2.1.5

null

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

null

H.2.8

null

5.3

null

OPS-16

null

21.10 21.21

null

2-12-3-2

null

B2.c C1.a C1.c

null

Principle 5.11 Principle 5.12

Principle 5.15

null

1537

null

12.4.3

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

Continuous Monitoring

Verbosity Logging for Boundary Devices

MON-03.4

Mechanisms exist to 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.

null

Does the organization 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?

5

Detect

null

X

There is no evidence of a capability to 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.

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 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.

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

null

A09:2021

null

N.6.2

null

21.5 21.21

null

x

null

x

null

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

null

R-AC-4

null

R-AM-3

null

R-GV-1

null

R-IR-1

null

R-SA-1

null

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

Limit Personal Data (PD) In Audit Records

MON-03.5

Mechanisms exist to limit Personal Data (PD) contained in audit records to the elements identified in the data privacy risk assessment.

- Data Protection Impact Assessment (DPIA)

null

Does the organization limit Personal Data (PD) contained in audit records to the elements identified in the data privacy risk assessment?

8

Detect

null

X

There is no evidence of a capability to limit Personal Data (PD) contained in audit records to the elements identified in the data privacy risk assessment.

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 limit Personal Data (PD) contained in audit records to the elements identified in the data privacy risk assessment.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to limit Personal Data (PD) contained in audit records to the elements identified in the data privacy risk assessment.

null

AU-3(3)

null

P.5

null

AU-3(3)

null

C1.c

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-GV-2 R-GV-4 R-GV-5 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

null

R-GV-2

null

R-GV-4

R-GV-5

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

Continuous Monitoring

Centralized Management of Planned Audit Record Content

MON-03.6

Mechanisms exist to centrally manage and configure the content required to be captured in audit records generated by organization-defined information system components.

null

Does the organization centrally manage and configure the content required to be captured in audit records generated by organization-defined information system components?

5

Detect

X

There is no evidence of a capability to centrally manage and configure the content required to be captured in audit records generated by organization-defined information system components.

SP-CMM1 is N/A, since a structured process is required to centrally manage and configure the content required to be captured in audit records generated by organization-defined information system components.

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 centrally manage and configure the content required to be captured in audit records generated by organization-defined information system components.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to centrally manage and configure the content required to be captured in audit records generated by organization-defined information system components.

null

AU-3(2)

null

AU-3(2)

PL-9

null

PL-9

null

PL-9

null

M.1.43

null

AU-3(2)

null

AU-3(2)

null

2-12-4

null

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

null

R-AM-3

null

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

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

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

Continuous Monitoring

Database Logging

MON-03.7

Mechanisms exist to ensure databases produce audit records that contain sufficient information to monitor database activities.

null

Does the organization ensure databases produce audit records that contain sufficient information to monitor database activities?

8

Detect

null

X

There is no evidence of a capability to ensure databases produce audit records that contain sufficient information to monitor database activities.

SP-CMM1 is N/A, since a structured process is required to ensure databases produce audit records that contain sufficient information to monitor database activities.

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 ensure databases produce audit records that contain sufficient information to monitor database activities.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure databases produce audit records that contain sufficient information to monitor database activities.

null

3.3.2[a]

null

7.2.6

null

7.2.6

null

U.1.11

null

1537

null

16.6.7.C.01 16.6.9.C.01 16.6.10.C.01 16.6.10.C.02

null

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

R-AC-1

null

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

null

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

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

Continuous Monitoring

Event Log Storage Capacity

MON-04

Mechanisms exist to allocate and proactively manage sufficient event log storage capacity to reduce the likelihood of such capacity being exceeded.

null

Does the organization allocate and proactively manage sufficient event log storage capacity to reduce the likelihood of such capacity being exceeded?

8

Detect

null

X

There is no evidence of a capability to allocate and proactively manage sufficient event log storage capacity to reduce the likelihood of such capacity being exceeded.

SP-CMM1 is N/A, since a structured process is required to allocate and proactively manage sufficient event log storage capacity to reduce the likelihood of such capacity being exceeded.

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.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to allocate and proactively manage sufficient event log storage capacity to reduce the likelihood of such capacity being exceeded.

null

8.10

null

8.10

null

CR 2.9 (6.11.1)

null

AU-4

AU-4 AU-5(1)

AU-4

null

AU-4

null

AU-4

null

I.3.15.5

null

TM:SG5.SP3

null

AU-4

null

AU-4 AU-5(1)

AU-4

AU-4 AU-5(1)

AU-4

AU-4 AU-5(1)

AU-4

AU-4 AU-5(1)

AU-4

null

AU-4

null

8-602

null

AU-4

null

AU-4

null

21.8

null

2-12-3-5

null

16.6.13.C.01 16.6.13.C.02 16.6.13.C.03 16.6.13.C.04

null

x

null

x

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

null

R-AM-3

null

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

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

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

Continuous Monitoring

Response To Event Log Processing Failures

MON-05

Mechanisms exist to alert appropriate personnel in the event of a log processing failure and take actions to remedy the disruption.

- 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 alert appropriate personnel in the event of a log processing failure and take actions to remedy the disruption?

8

Detect

null

X

There is no evidence of a capability to alert appropriate personnel in the event of a log processing failure and take actions to remedy the disruption.

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.

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 alert appropriate personnel in the event of a log processing failure and take actions to remedy the disruption.

null

LOG-13

null

CR 2.10 (6.12.1)

null

AU-5

null

AU-5

null

AU-5

null

3.3.4

3.3.4.a 3.3.4.b

3.3.4[a] 3.3.4[b] 3.3.4[c]

A.03.03.04.a A.03.03.04.b A.03.03.04.ODP[01] A.03.03.04.ODP[02]

null

A09:2021

null

I.1.17

null

COMP:SG1.SP3 TM:SG5.SP2

null

5.4.2

null

AU.L2-3.3.4

null

AU.L2-3.3.4

AU-5

null

AU-5

null

AU-5

null

8-602

null

AU-5

null

AU-5

null

OPS-17

null

21.9

null

2-11-1-2

null

x

null

x

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

null

R-AM-3

R-BC-1

R-BC-2

null

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

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

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

Continuous Monitoring

Real-Time Alerts of Event Logging Failure

MON-05.1

Mechanisms exist to provide 24x7x365 near real-time alerting capability when an event log processing failure occurs.

- 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 provide 24x7x365 near real-time alerting capability when an event log processing failure occurs?

6

Detect

null

X

There is no evidence of a capability to provide 24x7x365 near real-time alerting capability when an event log processing failure occurs.

SP-CMM1 is N/A, since a structured process is required to provide 24x7x365 near real-time alerting capability when an event log processing failure occurs.

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 provide 24x7x365 near real-time alerting capability when an event log processing failure occurs.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide 24x7x365 near real-time alerting capability when an event log processing failure occurs.

null

LOG-13

null

AU-5(2) SI-4(12)

null

AU-5(2)

AU-5(2) SI-4(12)

null

AU-5(2) SI-4(12)

null

AU-5(2) SI-4(12)

null

I.1.17

null

AU-5(2)

null

AU-5(2)

null

AU-5(2) SI-4(12)

null

AU-5(2) SI-4(12)

null

SI-4(12)

null

OPS-17

null

21.9

null

x

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

null

R-AM-3

R-BC-1

R-BC-2

null

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

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

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

Continuous Monitoring

Event Log Storage Capacity Alerting

MON-05.2

Automated mechanisms exist to alert appropriate personnel when the allocated volume reaches an organization-defined percentage of maximum event log storage capacity.

null

Does the organization use automated mechanisms to alert appropriate personnel when the allocated volume reaches an organization-defined percentage of maximum event log storage capacity?

5

Detect

null

X

There is no evidence of a capability to alert appropriate personnel when the allocated volume reaches an organization-defined percentage of maximum event log storage capacity.

SP-CMM1 is N/A, since a structured process is required to alert appropriate personnel when the allocated volume reaches an organization-defined percentage of maximum event log storage capacity.

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.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to alert appropriate personnel when the allocated volume reaches an organization-defined percentage of maximum event log storage capacity.

null

CR 2.9 (6.11.3(1))

null

AU-5(1)

null

AU-5(1)

null

AU-5(1)

null

AU-5(1)

null

I.3.15.5

null

AU-5(1)

null

AU-5(1)

null

x

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

R-AC-1

null

R-AM-3

R-BC-1

R-BC-2

null

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

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

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

Continuous Monitoring

Monitoring Reporting

MON-06

Mechanisms exist to provide an event log report generation capability to aid in detecting and assessing anomalous activities.

- 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 provide an event log report generation capability to aid in detecting and assessing anomalous activities?

7

Detect

null

X

There is no evidence of a capability to provide an event log report generation capability to aid in detecting and assessing anomalous activities.

SP-CMM1 is N/A, since a structured process is required to provide an event log report generation capability to aid in detecting and assessing anomalous activities.

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 provide an event log report generation capability to aid in detecting and assessing anomalous activities.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide an event log report generation capability to aid in detecting and assessing anomalous activities.

CC7.2 CC7.3

null

LOG-13

null

6.8 8.15

null

AU-7 AU-7(1) AU-12

AU-12

AU-7 AU-7(1) AU-12

null

AU-12

AU-7 AU-7(1) AU-12

null

AU-12

AU-7 AU-7(1) AU-12

null

AU-12

null

AU-12

3.3.6

3.3.3.a 3.3.5.b 3.3.6.a

3.3.6[a] 3.3.6[b]

A.03.03.05.b A.03.03.06.a

null

DE.DP-4

null

J.3.2

null

SITUATION-3.B.MIL2 SITUATION-3.C.MIL2

COMP:SG3.SP2 TM:SG2.SP2

null

AU.L2-3.3.6

null

AU.L2-3.3.6

AU-7 AU-7(1) AU-12

null

AU-7 AU-7(1) AU-12

AU-12

AU-7 AU-7(1) AU-12

AU-12

AU-7 AU-7(1) AU-12

AU-12

AU-7 AU-7(1) AU-12

AU-12

null

D3.DC.Ev.B.2 D5.ER.Is.B.1 D5.ER.Is.E.1

null

AU-7 AU-7(1) AU-12

null

8-602

null

5.6

null

AU-7 AU-7(1)

null

AU-12

AU-7 AU-7(1) AU-12

null

21.3 21.11 21.19 21.20

null

C1.a

null

12.2.6

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

Continuous Monitoring

Query Parameter Audits of Personal Data (PD)

MON-06.1

Mechanisms exist to provide and implement the capability for auditing the parameters of user query events for data sets containing Personal Data (PD).

null

Does the organization provide and implement the capability for auditing the parameters of user query events for data sets containing Personal Data (PD)?

3

Detect

null

X

There is no evidence of a capability to provide and implement the capability for auditing the parameters of user query events for data sets containing Personal Data (PD).

SP-CMM1 is N/A, since a structured process is required to provide and implement the capability for auditing the parameters of user query events for data sets containing Personal Data (PD).

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.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide and implement the capability for auditing the parameters of user query events for data sets containing Personal Data (PD).

null

AU-12(4)

null

AU-12(4)

null

A09:2021

null

P.9.6

null

x

null

x

null

R-AM-3 R-EX-5 R-GV-3 R-GV-6 R-GV-7

null

R-AM-3

null

R-EX-5

null

R-GV-3

null

R-GV-6

R-GV-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

Continuous Monitoring

Trend Analysis Reporting

MON-06.2

Mechanisms exist to employ trend analyses to determine 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.

null

Does the organization employ trend analyses to determine 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?

5

Detect

null

X

There is no evidence of a capability to employ trend analyses to determine 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.

SP-CMM1 is N/A, since a structured process is required to employ trend analyses to determine 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.

SP-CMM2 is N/A, since a well-defined process is required to employ trend analyses to determine 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 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. • 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. • The organization sets specific parameters on what type of audit information is permitted to be shared and what cannot be shared with third-parties, even with a NDA in place.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to employ trend analyses to determine 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.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to employ trend analyses to determine 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.

null

CA-7(3)

null

CA-7(3)

null

CA-7(3)

null

CA-7(3)

null

CA-7(3)

null

C.1.9

null

SITUATION-3.B.MIL2 SITUATION-3.C.MIL2 SITUATION-3.D.MIL3

null

CA-7(3)

null

CA-7(3)

null

x

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

null

R-AM-3

R-BC-1

R-BC-2

null

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

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

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

Continuous Monitoring

Time Stamps

MON-07

Mechanisms exist to configure systems to use an authoritative time source to generate time stamps for event logs.

null

Does the organization configure systems to use an authoritative time source to generate time stamps for event logs?

10

Detect

null

X

There is no evidence of a capability to configure systems to use an authoritative time source to generate time stamps for event logs.

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. • Secure baseline configurations use internal system clocks to generate time stamps for security event logs that are synchronized with an authoritative time source.

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. • Secure baseline configurations use internal system clocks to generate time stamps for security event logs that are synchronized with an authoritative time source.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to configure systems to use an authoritative time source to generate time stamps for event logs.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to configure systems to use an authoritative time source to generate time stamps for event logs.

null

LOG-06

null

CR 2.11 (6.13.1)

null

TS-1.5

null

AU-8

null

AU-8

null

AU-8

null

3.3.2.a.2 3.3.7.a 3.3.7.b 3.3.7.b.1 3.3.7.b.2 3.3.7.b.3

3.3.7[a] 3.3.7[b]

A.03.03.07.b[01] A.03.03.07.b[02] A.03.03.07.ODP[01]

null

A09:2021

10.4 10.4.1 10.4.2 10.4.3

10.2 10.6 10.6.1 10.6.2 10.6.3

null

10.6.1 10.6.2 10.6.3

null

10.6.1 10.6.2 10.6.3

null

10.6.1 10.6.2 10.6.3

null

G.6.1

null

TM:SG2.SP2

null

5.4.4

null

AU-8

null

§ 11.10 § 11.10(b) § 11.10(c) § 11.10(e)

AU-8

null

AU-8

null

8-602

null

AU-8

null

AU-8

null

2-3-3-4

null

8.7.5 [MP.INFO.5]

null

C1.a C1.b

null

x

null

x

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

R-AC-1

null

R-AM-3

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

R-EX-7

null

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-1

null

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

Synchronization With Authoritative Time Source

MON-07.1

Mechanisms exist to synchronize internal system clocks with an authoritative time source.

- Network Time Protocol (NTP)

null

Does the organization synchronize internal system clocks with an authoritative time source?

8

Detect

null

X

There is no evidence of a capability to synchronize internal system clocks with an authoritative time source.

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 synchronize internal system clocks with an authoritative time source.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to synchronize internal system clocks with an authoritative time source.

null

8.4

null

8.4

null

LOG-06

null

CR 2.11 (6.13.3(1)) CR 2.11 (6.13.3(2))

null

TS-1.5

null

AU-8(1)

null

AU-8(1)

SC-45 SC-45(1)

null

SC-45 SC-45(1)

null

SC-45

null

3.3.7

3.3.7.a 3.3.7.b 3.3.7.b.1 3.3.7.b.2 3.3.7.b.3

3.3.7[b] 3.3.7[c]

A.03.03.07.a

null

A09:2021

null

10.6 10.6.1 10.6.2 10.6.3

null

10.6.1 10.6.2 10.6.3

null

10.6.1 10.6.2 10.6.3

null

10.6.1 10.6.2 10.6.3

null

G.6

null

AU.L2-3.3.7

null

AU.L2-3.3.7

AU-8(1)

null

§ 11.10 § 11.10(b) § 11.10(c) § 11.10(e)

AU-8(1)

null

AU-8(1)

null

SC-45 SC-45(1)

null

SC-45 SC-45(1)

null

SC-45 SC-45(1)

null

AU-8(1)

null

AU-8(1)

null

2-3-3-4

null

C1.b

null

x

null

x

null

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

R-AC-1

null

R-AM-3

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

R-EX-7

null

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-1

null

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

- Added NIST 800-53 R5 mapping for SC-45

Continuous Monitoring

Protection of Event Logs

MON-08

Mechanisms exist to protect event logs and audit tools from unauthorized access, modification and deletion.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Security Incident Event Manager (SIEM) - Splunk

null

Does the organization protect event logs and audit tools from unauthorized access, modification and deletion?

10

Detect

null

X

There is no evidence of a capability to protect event logs and audit tools from unauthorized access, modification and deletion.

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. • Secure baseline configurations restrict access to event logs from privileged users to protect event logs and audit tools from unauthorized access, modification and deletion.

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 protect event logs and audit tools from unauthorized access, modification and deletion.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to protect event logs and audit tools from unauthorized access, modification and deletion.

PI1.4 PI1.5

null

IAM-12 LOG-02 LOG-09

MON-04 MON-05

null

CR 3.9 (7.11.1) CR 6.1 (10.3.3(1))

null

12.4.2

8.15

12.4.2

null

6.9.4.2

null

TS-1.5

null

AU-9

null

AU-9

null

AU-9

null

3.3.8

3.3.3.b 3.3.6.b 3.3.8.a 3.3.8.b

3.3.8[a] 3.3.8[b] 3.3.8[c] 3.3.8[d] 3.3.8[e] 3.3.8[f]

A.03.03.03.b A.03.03.06.b A.03.03.08.a A.03.03.08.b

null

A01:2021 A09:2021

10.5 10.5.1 10.5.2 10.5.3 10.5.4 10.5.5

10.3 10.3.1 10.3.2

null

10.3.1 10.3.2

null

10.3.1 10.3.2

null

10.3.1 10.3.2

null

M.1.59

null

TM:SG2.SP2

3.2

5.4.5

null

AU.L2-3.3.8

null

AU.L2-3.3.8

AU-9

null

§ 11.10 § 11.10(b) § 11.10(c) § 11.10(e)

AU-9

null

AU-9

null

8-602

3.1

null

5.4

AU-9

null

AU-9

null

OPS-16

null

21.4 21.14 21.16

null

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

null

2-12-3-5 2-14-3-3

2-3-1-10

null

7.3.10 [OP.EXP.10]

null

C1.b

null

Principle 5.16 Principle 7.9

null

0859 0991 1714 1715 1663 1747 1758 1775 1776 1777 1815

null

12.4.2

null

16.6.13.C.01 16.6.13.C.02 16.6.13.C.03 16.6.13.C.04

null

6.21

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

Continuous Monitoring

Event Log Backup on Separate Physical Systems / Components

MON-08.1

Mechanisms exist to back up event logs onto a physically different system or system component than the Security Incident Event Manager (SIEM) or similar automated tool.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Security Incident Event Manager (SIEM) - Splunk

null

Does the organization back up event logs onto a physically different system or system component than the Security Incident Event Manager (SIEM) or similar automated tool?

5

Detect

null

X

There is no evidence of a capability to back up event logs onto a physically different system or system component than the Security Incident Event Manager (SIEM) or similar automated tool.

SP-CMM1 is N/A, since a structured process is required to back up event logs onto a physically different system or system component than the Security Incident Event Manager (SIEM) or similar automated tool.

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 back up event logs onto a physically different system or system component than the Security Incident Event Manager (SIEM) or similar automated tool.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to back up event logs onto a physically different system or system component than the Security Incident Event Manager (SIEM) or similar automated tool.

null

LOG-09

MON-06

null

CR 3.9 (7.11.3(1))

null

AU-4(1) AU-9(2)

null

AU-9(2)

AU-4(1) AU-9(2)

null

AU-9(2)

AU-4(1)

null

AU-4(1)

AU-4(1) AU-9(2)

null

A09:2021

null

10.3.3

null

10.3.3

null

10.3.3

null

10.3.3

null

M.1.57

null

AU-9(2)

null

AU-9(2)

null

AU-9(2)

null

AU-9(2)

null

AU-9(2)

null

AU-9(2)

null

21.14 21.15 21.17

null

2-11-1-5 2-11-2

null

C1.b

null

16.6.13.C.01 16.6.13.C.02 16.6.13.C.03 16.6.13.C.04

null

x

null

x

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

null

R-AM-3

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

R-EX-7

null

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-1

null

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

- Added NIST 800-53 R5 mapping for AU-4(1)

Continuous Monitoring

Access by Subset of Privileged Users

MON-08.2

Mechanisms exist to restrict access to the management of event logs to privileged users with a specific business need.

- Security Incident Event Manager (SIEM) - Splunk

null

Does the organization restrict access to the management of event logs to privileged users with a specific business need?

8

Detect

null

X

There is no evidence of a capability to restrict access to the management of event logs to privileged users with a specific business need.

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. • Secure baseline configurations restrict access to event logs from privileged users to protect event logs and audit tools from unauthorized access, modification and deletion.

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 restrict access to the management of event logs to privileged users with a specific business need.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to restrict access to the management of event logs to privileged users with a specific business need.

null

LOG-04

MON-04 MON-05

null

CR 6.1 (10.3.1)

null

AU-9(4)

null

AU-9(4)

null

AU-9(4)

null

AU-9(4)

null

3.3.9

3.3.8.b

3.3.9[a] 3.3.9[b]

null

A09:2021

null

10.3 10.3.1 10.3.2

null

10.3.1 10.3.2

null

10.3.1 10.3.2

null

10.3.1 10.3.2

null

U.1.11.2

null

AU.L2-3.3.9

null

AU.L2-3.3.9

AU-9(4)

null

AU-9(4)

null

AU-9(4)

null

AU-9(4)

null

AU-9(4)

null

AU-9(4)

null

5.4

null

AU-9(4)

null

AU-9(4)

null

OPS-16

null

21.14

null

C1.b

null

x

null

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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

Continuous Monitoring

Cryptographic Protection of Event Log Information

MON-08.3

Cryptographic mechanisms exist to protect the integrity of event logs and audit tools.

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

null

Are cryptographic mechanisms utilized to protect the integrity of event logs and audit tools?

5

Protect

null

X

There is no evidence of a capability to Cryptographic protect the integrity of event logs and audit tools.

SP-CMM1 is N/A, since a structured process is required to Cryptographic protect the integrity of event logs and audit tools.

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 Cryptographic protect the integrity of event logs and audit tools.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to Cryptographic protect the integrity of event logs and audit tools.

null

LOG-04 LOG-09

MON-05

null

AU-9(3)

null

AU-9(3)

null

AU-9(3)

null

AU-9(3)

null

3.3.8.a

null

M.1.59

null

AU-9(3)

null

AU-9(3)

null

AU-9(3)

null

AU-9(3)

null

C1.b

null

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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

Continuous Monitoring

Dual Authorization for Event Log Movement

MON-08.4

Automated mechanisms exist to enforce dual authorization for the movement or deletion of event logs.

null

Does the organization use automated mechanisms to enforce dual authorization for the movement or deletion of event logs?

5

Protect

null

X

There is no evidence of a capability to enforce dual authorization for the movement or deletion of event logs.

SP-CMM1 is N/A, since a structured process is required to enforce dual authorization for the movement or deletion of event logs.

SP-CMM2 is N/A, since a well-defined process is required to enforce dual authorization for the movement or deletion of event logs.

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.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to enforce dual authorization for the movement or deletion of event logs.

null

AU-9(5)

null

AU-9(5)

null

AU-9(5)

null

3.1.1e

null

D.4.3.4

null

TBD - 3.1.1e

null

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-1

null

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

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

Non-Repudiation

MON-09

Mechanisms exist to utilize a non-repudiation capability to protect against an individual falsely denying having performed a particular action.

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

null

Does the organization utilize a non-repudiation capability to protect against an individual falsely denying having performed a particular action?

8

Protect

null

X

There is no evidence of a capability to utilize a non-repudiation capability to protect against an individual falsely denying having performed a particular action.

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 non-repudiation capability to protect against an individual falsely denying having performed a particular action.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize a non-repudiation capability to protect against an individual falsely denying having performed a particular action.

null

CR 2.12 (6.14.1) CR 2.12 (6.14.3(1))

null

AU-10

null

AU-10

null

AU-10

null

AU-10

null

AU-10

null

AU-10

null

L.24.5.2

null

TM:SG2.SP2

null

AU-10

null

AU-10

null

AU-10

null

AU-10

null

AU-10

null

8-602

null

Art 26

null

21.14

null

14.2.1 14.2.2 14.2.3 14.2.4 14.2.5 14.2.6 14.2.7 14.2.8 14.2.9 14.2.10 14.2.11

null

x

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

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

Identity Binding

MON-09.1

Mechanisms exist to bind the identity of the information producer to the information generated.

null

Does the organization bind the identity of the information producer to the information generated?

4

Protect

null

X

There is no evidence of a capability to bind the identity of the information producer to the information generated.

SP-CMM1 is N/A, since a structured process is required to bind the identity of the information producer to the information generated.

SP-CMM2 is N/A, since a well-defined process is required to bind the identity of the information producer to the information generated.

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 bind the identity of the information producer to the information generated.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to bind the identity of the information producer to the information generated.

null

AU-10(1) AU-10(2)

null

AU-10(1) AU-10(2)

null

AU-10(1) AU-10(2)

AU-10(2)

null

P.5.5.6.6

null

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

R-AC-1

null

R-AM-3

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

Continuous Monitoring

Event Log Retention

MON-10

Mechanisms exist to retain 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.

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

E-AST-11

Does the organization retain 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?

10

Detect

null

X

There is no evidence of a capability to retain 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.

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 retain 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.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to retain 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.

C1.2

null

8.10

null

8.10

null

LOG-04 LOG-09

null

PS-1.1 TS-1.5

null

AU-11

null

AU-11

null

3.3.1

3.3.3.b

3.3.1[e] 3.3.1[f]

A.03.03.03.b

null

A09:2021

10.7

10.5 10.5.1

null

10.5.1

null

10.5.1

null

10.5.1

null

U.1.11.1

null

COMP:SG3.SP1 COMP:SG3.SP2

null

5.4.6 5.4.7

null

AU.L2-3.3.1

null

AU.L2-3.3.1

AU-11

null

AU-11

null

AU-11

null

8-602

null

AU-11

III.D.3.b

null

AU-11

null

OPS-14

null

21.4 21.15 21.17

null

2-11-2

TPC-75

null

2-12-3-5 2-14-3-3

null

C1.b

null

0859 0991

null

Article 19

null

x

null

x

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

null

R-AM-3

null

R-EX-6

null

R-GV-1

null

R-GV-3

R-GV-4

R-GV-5

null

R-IR-1

R-IR-2

R-IR-3

null

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

Monitoring For Information Disclosure

MON-11

Mechanisms exist to monitor for evidence of unauthorized exfiltration or disclosure of non-public information.

- Content filtering solution - Review of social media outlets

null

Does the organization monitor for evidence of unauthorized exfiltration or disclosure of non-public information?

8

Detect

null

X

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

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 for evidence of unauthorized exfiltration or disclosure of non-public information.

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

null

5.7

null

AU-13

null

AU-13

null

AU-13

null

AU-13

null

AU-13

null

AU-13

null

3.1.22.b

null

D.10.8

null

IMC:SG2.SP1 KIM:SG4.SP2

null

8-602

null

C1.a

null

x

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

Continuous Monitoring

Analyze Traffic for Covert Exfiltration

MON-11.1

Automated mechanisms exist to analyze network traffic to detect covert data exfiltration.

null

Does the organization use automated mechanisms to analyze network traffic to detect covert data exfiltration?

5

Detect

null

X

There is no evidence of a capability to analyze network traffic to detect covert data exfiltration.

SP-CMM1 is N/A, since a structured process is required to analyze network traffic to detect covert data exfiltration.

SP-CMM2 is N/A, since a well-defined process is required to analyze network traffic to detect covert data exfiltration.

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

SI-4(18)

null

SI-4(18)

null

SI-4(18)

null

3.14.2e

null

11.5.1.1

null

11.5.1.1

null

D.10.17.1

null

ARCHITECTURE-5.F.MIL2

null

TBD - 3.14.2e

null

SI-4(18)

null

SI-4(18)

null

SI-4(18)

null

SI-4(18)

null

SI-4(18)

null

x

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

null

R-AM-1

null

R-AM-3

null

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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

Unauthorized Network Services

MON-11.2

Automated mechanisms exist to detect unauthorized network services and alert incident response personnel.

null

Does the organization use automated mechanisms to detect unauthorized network services and alert incident response personnel?

5

Detect

null

X

There is no evidence of a capability to detect unauthorized network services and alert incident response personnel.

SP-CMM1 is N/A, since a structured process is required to detect unauthorized network services and alert incident response personnel.

SP-CMM2 is N/A, since a well-defined process is required to detect unauthorized network services and alert incident response personnel.

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

LOG-13

null

SI-4(22)

null

SI-4(22)

null

SI-4(22)

null

SI-4(22)

null

3.14.2e

null

D.10.18

null

TBD - 3.14.2e

null

SI-4(22)

null

SI-4(22)

null

SI-4(22)

null

SI-4(22)

null

C1.a

null

x

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

null

R-AM-1

R-AM-2

R-AM-3

null

R-BC-4

null

R-GV-1

null

R-GV-3

R-GV-4

R-GV-5

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

Monitoring for Indicators of Compromise (IOC)

MON-11.3

Automated mechanisms exist to identify and alert on Indicators of Compromise (IoC).

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

null

Does the organization use automated mechanisms to identify and alert on Indicators of Compromise (IoC)?

5

Detect

null

X

There is no evidence of a capability to identify and alert on Indicators of Compromise (IoC).

SP-CMM1 is N/A, since a structured process is required to identify and alert on Indicators of Compromise (IoC).

SP-CMM2 is N/A, since a well-defined process is required to identify and alert on Indicators of Compromise (IoC).

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

LOG-11 LOG-13

IAM-08 MON-01 MON-09

null

RQ-08-03

null

5.7

null

SI-4(24)

null

SI-4(24)

null

SI-4(24)

null

3.14.6.a 3.14.6.a.1 3.14.6.a.2 3.14.6.b 3.14.6.c

null

3.11.2e 3.11.3e 3.14.6e

null

DE.AE-07

null

D.10.4

null

SITUATION-2.D.MIL2 SITUATION-2.E.MIL2 SITUATION-2.F.MIL2 SITUATION-2.G.MIL3 SITUATION-2.H.MIL3 SITUATION-2.I.MIL3 RESPONSE-1.D.MIL3 RESPONSE-1.E.MIL3 RESPONSE-1.F.MIL3

null

TBD - 3.11.2e TBD - 3.11.3e TBD - 3.14.6e

null

RA.L3-3.11.2e RA.L3-3.11.3e SI.L3-3.14.6e

null

SI-4(24)

null

SI-4(24)

null

SI-4(24)

null

3.4.5(38) 3.4.5(38)(a) 3.4.5(38)(b) 3.4.5(38)(c)

null

5.4

null

C1.a C2.a

null

0120

null

11.3.5

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-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

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

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

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

Session Audit

MON-12

Mechanisms exist to provide session audit capabilities that can: ▪ Capture and log all content related to a user session; and ▪ Remotely view all content related to an established user session in real time.

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

null

Does the organization provide session audit capabilities that can: ▪ Capture and log all content related to a user session; and ▪ Remotely view all content related to an established user session in real time?

7

Detect

null

X

There is no evidence of a capability to provide session audit capabilities that can: ▪ Capture and log all content related to a user session; and ▪ Remotely view all content related to an established user session in real time.

SP-CMM1 is N/A, since a structured process is required to provide session audit capabilities that can: ▪ Capture and log all content related to a user session; and ▪ Remotely view all content related to an established user session in real time.

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 provide session audit capabilities that can: ▪ Capture and log all content related to a user session; and ▪ Remotely view all content related to an established user session in real time.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide session audit capabilities that can: ▪ Capture and log all content related to a user session; and ▪ Remotely view all content related to an established user session in real time.

null

AU-14

null

AU-14

null

AU-14

null

AU-14

null

AU-14

null

AU-14

null

N.27.4

null

TM:SG2.SP2

null

8-602

null

5.4

null

21.10 21.18

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

Continuous Monitoring

Alternate Event Logging Capability

MON-13

Mechanisms exist to provide an alternate event logging capability in the event of a failure in primary audit capability.

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

null

Does the organization provide an alternate event logging capability in the event of a failure in primary audit capability?

3

Detect

null

X

There is no evidence of a capability to provide an alternate event logging capability in the event of a failure in primary audit capability.

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 provide an alternate event logging capability in the event of a failure in primary audit capability.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide an alternate event logging capability in the event of a failure in primary audit capability.

null

AU-15

null

AU-5(5)

null

AU-5(5)

null

L.3.4.1

null

CTRL:SG2.SP1 TM:SG5.SP1

null

8-602

null

21.15

null

x

R-AC-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-GV-1 R-GV-2 R-GV-4 R-GV-5 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-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

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

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

Cross-Organizational Monitoring

MON-14

Mechanisms exist to coordinate sanitized event logs among external organizations to identify anomalous events when event logs are shared across organizational boundaries, without giving away sensitive or critical business data.

null

Does the organization coordinate sanitized event logs among external organizations to identify anomalous events when event logs are shared across organizational boundaries, without giving away sensitive or critical business data?

3

Detect

null

X

There is no evidence of a capability to coordinate sanitized event logs among external organizations to identify anomalous events when event logs are shared across organizational boundaries, without giving away sensitive or critical business data.

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. • A formal agreement exists between the organization and applicable third-parties that includes a Non-Disclosure Agreement (NDA) addressing shared sensitive data. • the organization sets specific parameters on what type of audit information is permitted to be shared and what cannot be shared with third-parties, even with a NDA in place.

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 formal agreement exists between the organization and applicable third-parties that includes a Non-Disclosure Agreement (NDA) addressing shared sensitive data. • The organization sets specific parameters on what type of audit information is permitted to be shared and what cannot be shared with third-parties, even with a NDA in place.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to coordinate sanitized event logs among external organizations to identify anomalous events when event logs are shared across organizational boundaries, without giving away sensitive or critical business data.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to coordinate sanitized event logs among external organizations to identify anomalous events when event logs are shared across organizational boundaries, without giving away sensitive or critical business data.

null

AU-16 AU-16(1)

null

AU-16 AU-16(1)

null

AU-16

null

AU-16

null

AU-16

null

L.1.4

null

COMP:SG3.SP1 EXD:SG3.SP4

null

AU-16

null

AU-16 AU-16(1)

null

8-602

null

x

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

R-AC-1

null

R-AM-3

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-1

R-IR-2

R-IR-3

null

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

Sharing of Event Logs

MON-14.1

Mechanisms exist to share event logs with third-party organizations based on specific cross-organizational sharing agreements.

- Veris (incident sharing) (http://veriscommunity.net)

null

Does the organization share event logs with third-party organizations based on specific cross-organizational sharing agreements?

5

Detect

null

X

There is no evidence of a capability to share event logs with third-party organizations based on specific cross-organizational sharing agreements.

SP-CMM1 is N/A, since a structured process is required to share event logs with third-party organizations based on specific cross-organizational sharing agreements.

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. • A formal agreement exists between the organization and applicable third-parties that includes a Non-Disclosure Agreement (NDA) addressing shared sensitive data. • the organization sets specific parameters on what type of audit information is permitted to be shared and what cannot be shared with third-parties, even with a NDA in place.

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 formal agreement exists between the organization and applicable third-parties that includes a Non-Disclosure Agreement (NDA) addressing shared sensitive data. • The organization sets specific parameters on what type of audit information is permitted to be shared and what cannot be shared with third-parties, even with a NDA in place.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to share event logs with third-party organizations based on specific cross-organizational sharing agreements.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to share event logs with third-party organizations based on specific cross-organizational sharing agreements.

null

AU-16(2)

null

AU-16(2)

null

AU-16(2)

null

AU-16(2)

null

AU-16(2)

null

AU-16(2)

null

L.1.4

null

AU-16(2)

null

x

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

R-AC-1

null

R-AM-3

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-1

R-IR-2

R-IR-3

null

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

Covert Channel Analysis

MON-15

Mechanisms exist to conduct covert channel analysis to identify aspects of communications that are potential avenues for covert channels.

null

Does the organization conduct covert channel analysis to identify aspects of communications that are potential avenues for covert channels?

3

Detect

null

X

There is no evidence of a capability to conduct covert channel analysis to identify aspects of communications that are potential avenues for covert channels.

SP-CMM1 is N/A, since a structured process is required to conduct covert channel analysis to identify aspects of communications that are potential avenues for covert channels.

SP-CMM2 is N/A, since a well-defined process is required to conduct covert channel analysis to identify aspects of communications that are potential avenues for covert channels.

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 conduct covert channel analysis to identify aspects of communications that are potential avenues for covert channels.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to conduct covert channel analysis to identify aspects of communications that are potential avenues for covert channels.

null

T1041, T1048, T1048.002, T1048.003, T1071, T1071.001, T1071.002, T1071.003, T1071.004, T1567

null

SC-31

null

SC-31

null

SC-31

null

11.5.1.1

null

11.5.1.1

null

N.2.4

null

8.L.F

null

21.10

null

x

null

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

null

R-AM-1

null

R-AM-3

null

R-BC-2

null

R-BC-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

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

Anomalous Behavior

MON-16

Mechanisms exist to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities.

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

null

Does the organization detect and respond to anomalous behavior that could indicate account compromise or other malicious activities?

10

Detect

null

X

There is no evidence of a capability to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities.

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. • the organization sets specific parameters on what type of audit information is permitted to be shared and what cannot be shared with third-parties, even with a NDA in place.

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. • The organization sets specific parameters on what type of audit information is permitted to be shared and what cannot be shared with third-parties, even with a NDA in place.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities.

CC7.2

CC7.2-POF2 CC7.2-POF3

null

LOG-05

CLS-08 IAM-08 MON-10 MON-11

null

AC-2(12) SI-4(11)

null

AC-2(12)

AC-2(12) IR-4(13) SI-4(11)

null

AC-2(12)

IR-4(13) SI-4(11)

null

AC-2(12)

null

3.3.5.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.03.14.06.a.01 A.03.14.06.a.02 A.03.14.06.b

3.14.2e

null

DE.AE-1

DE.CM-03 DE.CM-06 DE.CM-09 DE.AE-02

null

10.6 10.6.1 10.6.2

15.1 A3.2.6.1

null

J.1.3

2.9

null

ACCESS-2.I.MIL3 SITUATION-2.D.MIL2 SITUATION-2.E.MIL2 SITUATION-2.F.MIL2 SITUATION-2.G.MIL3 SITUATION-2.H.MIL3 SITUATION-2.I.MIL3

null

TBD - 3.14.2e

null

AC-2(12) SI-4(11)

null

AC-2(12)

AC-2(12) SI-4(11)

null

AC-2(12) SI-4(11)

null

AC-2(12)

AC-2(12) SI-4(11)

null

D3.DC.Ev.B.1 D4.C.Co.B.4

null

3.M.C

3.M.C 1.L.C 4.L.B 6.L.B 8.L.D 8.L.E

AC-2(12) SI-4(11)

null

5.6 5.7

null

AC-2(12)

III.D III.D.2.b

null

Sec 4(2)(b)(ii)(C)(2)

null

AC-2(12)

null

§ 2447(c)(4)

3.4.5(38) 3.4.5(38)(a) 3.4.5(38)(b) 3.4.5(38)(c)

null

5.5

null

4.7 21.10 21.20

null

TPC-80

null

2-3-1-12

null

C1.a C2.a

C1 C2

null

1660 1661 1662 1664 1665 1757

null

9.2.2 11.5.5 12.2.4

null

3.3.2

null

x

null

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

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

Insider Threats

MON-16.1

Mechanisms exist to monitor internal personnel activity for potential security incidents.

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

null

Does the organization monitor internal personnel activity for potential security incidents?

8

Detect

null

X

There is no evidence of a capability to monitor internal personnel activity for potential security incidents.

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 internal personnel activity for potential security incidents.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to monitor internal personnel activity for potential security incidents.

null

DE.CM-3

null

A3.2.6.1

null

J.3

null

D3.DC.An.A.3

null

1.L.C

null

5.6 5.7

null

21.10

null

1625

null

3.5.2

null

x

null

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

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

Third-Party Threats

MON-16.2

Mechanisms exist to monitor third-party personnel activity for potential security incidents.

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

null

Does the organization monitor third-party personnel activity for potential security incidents?

8

Detect

null

X

There is no evidence of a capability to monitor third-party personnel activity for potential security incidents.

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 third-party personnel activity for potential security incidents.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to monitor third-party personnel activity for potential security incidents.

null

DE.CM-6

null

J.3

null

D4.RM.Om.Int.1

null

1.L.C

null

5.6

null

21.10

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-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

Unauthorized Activities

MON-16.3

Mechanisms exist to monitor for unauthorized activities, accounts, connections, devices and software.

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

null

Does the organization monitor for unauthorized activities, accounts, connections, devices and software?

8

Detect

null

X

There is no evidence of a capability to monitor for unauthorized activities, accounts, connections, devices and software.

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 for unauthorized activities, accounts, connections, devices and software.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to monitor for unauthorized activities, accounts, connections, devices and software.

null

2.3

null

LOG-11 LOG-13

null

A.03.14.06.a.02

null

DE.CM-7

null

A3.2.6.1

null

J.3.3

null

D3.DC.Ev.B.3

null

1.L.A 6.L.B 6.L.D 9.L.B

null

5.6

null

21.10

null

2-3-1-11 2-3-1-12

null

C1.a

null

x

null

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-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

Account Creation and Modification Logging

MON-16.4

Automated mechanisms exist to generate event logs for permissions changes to privileged accounts and/or groups.

null

Does the organization use automated mechanisms to generate event logs for permissions changes to privileged accounts and/or groups?

7

Detect

null

X

There is no evidence of a capability to generate event logs for permissions changes to privileged accounts and/ or groups.

SP-CMM1 is N/A, since a structured process is required to generate event logs for permissions changes to privileged accounts and/ or groups.

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 generate event logs for permissions changes to privileged accounts and/ or groups.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to generate event logs for permissions changes to privileged accounts and/ or groups.

null

1650 1651 1652

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-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

Cryptographic Protections

Use of Cryptographic Controls

CRY-01

Mechanisms exist to facilitate the implementation of cryptographic protections controls using known public standards and trusted cryptographic technologies.

- Key and certificate management solutions - Microsoft BitLocker (https://www.microsoft.com/en-us/download/details.aspx?id=53006) - Symantec Endpoint Encryption (https://www.symantec.com/products/endpoint-protection) - Vormetric Transparent Encryption (https://www.thalesesecurity.com/products/data-encryption/vormetric-transparent-encryption)

null

Does the organization facilitate the implementation of cryptographic protections controls using known public standards and trusted cryptographic technologies?

10

Protect

X

There is no evidence of a capability to facilitate the implementation of cryptographic protections controls using known public standards and trusted cryptographic technologies.

Cryptographic Protections (CRY) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • IT/cybersecurity personnel perform an annual review of deployed cryptographic cipher suites and protocols to identify and replace weak cryptographic cipher suites and protocols.

Cryptographic Protections (CRY) 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 cryptographic protections. • The CISO, or similar function, develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures for cryptographic protections. • 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 using cryptographic protections. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including cryptographic protections. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • IT/cybersecurity personnel perform an annual review of deployed cryptographic cipher suites and protocols to identify and replace weak cryptographic cipher suites and protocols.

Cryptographic Protections (CRY) 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 cryptographic protections controls using known public standards and trusted cryptographic technologies.

CC6.1

CC6.1-POF9

null

3.6 3.9 3.10

3.6

3.6 3.9 3.10

null

CEK-01 CEK-02 CEK-03 CEK-04 DSP-10 LOG-10 LOG-11

CLS-01 IAM-12 IOT-10 SAP-07 SWS-08

null

CR 4.1 (8.3.1(a)) CR 4.3 (8.5.1)

null

10.1.1 14.1.2

8.24 8.26

10.1.1 14.1.2

null

6.7 6.7.1 6.7.1.1

null

T1005, T1025, T1041, T1048.003

TS-1.0 TS-1.9 TS-1.15 TS-3.0

Sec 4(D)(2)(d)

null

PR.DS-P1 PR.DS-P2

null

SC-8(1) SC-8(2) SC-13 SC-13(1) SI-7(6)

SC-13

SC-8(1) SC-13

SC-8(1) SC-8(2) SC-13 SI-7(6)

null

SC-13

SC-8(1) SC-13

SC-8(2) SI-7(6)

null

SC-13

SC-8(1) SC-13

null

3.13.11

3.13.8 3.13.11

3.13.8[a] 3.13.11

A.03.13.11 A.03.13.11.ODP[01]

3.14.1e

null

PR.DS-1 PR.DS-2

PR.DS-01 PR.DS-02

A02:2021

2.2.3 4.1

3.3.2 8.3.2 12.3.3

null

8.3.2

null

8.3.2

null

3.3.2 8.3.2 12.3.3

null

I.3.6.1

2.1 2.4A 2.6 5.2

5.1 5.1.1 5.1.2

10.3

7.3.8

ARCHITECTURE-5.B.MIL2 ARCHITECTURE-5.C.MIL2 ARCHITECTURE-5.D.MIL2 ARCHITECTURE-5.G.MIL3

KIM:SG4.SP1

3.3 3.4

5.10.1.2 5.10.1.2.1

null

SC.L2-3.13.11

SC.L2-3.13.11 TBD - 3.14.1e

null

SC.L2-3.13.11

SC.L2-3.13.11 SI.L3-3.14.1e

SC-8(2) SC-13

null

§ 11.10 § 11.10(c)

SC-8(1) SC-13

SC-13

SC-8(1) SC-13

SC-13

SC-8(1) SC-13

null

314.4(c)(3)

164.312(a)(2)(iv)

null

1.M.C 2.M.A 4.M.C 9.M.B

1.M.C 2.M.A 4.M.C 9.M.B 1.L.A 1.L.B

2.E.3 SC-13

120.54(a)(5)

null

9-400

18.1 18.2 18.3 19.1 19.2 19.3

null

5.8

SC-13

null

500.15

null

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

null

SC-13

null

SC-13

null

§ 2447(c)(3) § 2447(c)(5)

3.4.4(36)(f)

null

Art 5

Art 5.1 Art 32.1 Art 32.2

Article 21.2(h)

Art 20 Art 30

null

Sec 14 Sec 15

Art 16

null

CRY-01

null

8.1 8.8 15.7 21.16

null

2-7 2-7-1-3

TPC-52 TPC-54

3.3.9

2-8-1 2-8-2 2-8-3 2-8-3-1 2-8-4

2-2-1-4 2-7 2-7-1 2-7-2

null

Sec 14.1 Sec 19.1 Sec 19.2

null

8.4.2 [MP.COM.2] 8.4.3 [MP.COM.3] 8.5.2 [MP.SI.2] 8.7.3 [MP.INFO.3] 8.7.4 [MP.INFO.4]

null

B3.b B3.c

null

0457 0460 0471 0994 0472 0473 1146 0474 0475 0476 0477 0479 0481 0501 0142 1091 0499 1759 1629 1630 1760 1446 1761 1762 1763 1764 1765 1766 1767 1768 1769 1770 1771 1772

null

10.1.1 10.1.1.9.PB 14.1.2

null

15.1

8.4.13.C.01 17.1.52.C.01 17.1.52.C.02 17.1.53.C.01 17.1.53.C.02 17.1.53.C.03 17.1.53.C.04 17.1.54.C.01 17.1.55.C.01 17.1.55.C.02 17.1.55.C.03 17.1.55.C.04 17.1.56.C.01 17.1.56.C.02 17.1.57.C.01 17.2.17.C.01 17.2.18.C.01 17.2.19.C.01 17.2.20.C.01 17.2.20.C.02 17.2.21.C.01 17.2.22.C.01 17.2.22.C.02 17.2.23.C.01 17.2.24.C.01 17.2.24.C.02 17.2.24.C.03 17.2.25.C.01 17.2.26.C.01 17.2.26.C.02 17.2.26.C.03 17.2.27.C.01 17.2.27.C.02 17.2.27.C.03 17.2.28.C.01 17.3.6.C.01 17.4.16.C.01 17.4.16.C.02 17.5.6.C.01 17.6.6.C.01 17.6.7.C.01 17.7.6.C.01 17.8.10.C.01 17.8.10.C.02 17.8.11.C.01 17.8.12.C.01 17.8.13.C.01 17.8.14.C.01 17.8.15.C.01 17.8.16.C.01 17.8.17.C.01 17.9.24.C.01 17.9.24.C.02 17.9.24.C.03 17.9.25.C.01 17.9.26.C.01 17.9.26.C.02 17.9.27.C.01 17.9.27.C.02 17.9.27.C.03 17.9.28.C.01 17.9.29.C.01 17.9.30.C.01 17.9.30.C.02 17.9.31.C.01 17.9.32.C.01 17.9.32.C.02 17.9.32.C.03

null

10.1.1 10.1.2 10.1.3 10.1.4 10.1.5

null

6.22

null

3.2.2

null

x

NAIC Lockton

x

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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 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

Cryptographic Protections

Alternate Physical Protection

CRY-01.1

Cryptographic mechanisms exist to prevent unauthorized disclosure of information as an alternative to physical safeguards.

null

Are cryptographic mechanisms utilized to prevent unauthorized disclosure of information as an alternative to physical safeguards?

5

Protect

null

X

null

There is no evidence of a capability to Cryptographic prevent unauthorized disclosure of information as an alternative to physical safeguards.

Cryptographic Protections (CRY) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to Cryptographic prevent unauthorized disclosure of information as an alternative to physical safeguards.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to Cryptographic prevent unauthorized disclosure of information as an alternative to physical safeguards.

null

SC-8(1)

null

SC-8(1)

null

SC-8(1)

null

SC-8(1)

null

3.13.8

3.13.8[b] 3.13.8[c]

null

I.3.6.1

null

ARCHITECTURE-5.G.MIL3

null

SC.L2-3.13.8

null

SC.L2-3.13.8

SC-8(1)

null

SC-8(1)

null

SC-8(1)

null

SC-8(1)

null

2.M.A 4.M.C 5.M.C

null

SC-8(1)

null

17.04(3)

null

622(2)(d)(C)(iii)

null

SC-8(1)

null

15.7

null

B3.b B3.c

null

MA 201 CMR 17 OR 6464A

null

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-1

null

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-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

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Export-Controlled Technology

CRY-01.2

Mechanisms exist to address the exporting of cryptographic technologies in compliance with relevant statutory and regulatory requirements.

null

Does the organization address the exporting of cryptographic technologies in compliance with relevant statutory and regulatory requirements?

5

Protect

null

X

null

There is no evidence of a capability to address the exporting of cryptographic technologies in compliance with relevant statutory and regulatory requirements.

SP-CMM1 is N/A, since a structured process is required to address the exporting of cryptographic technologies in compliance with relevant statutory and regulatory requirements.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • Systems, applications and services that include cryptographic mechanisms are controlled to ensure the exporting of cryptographic technologies is in compliance with relevant statutory and regulatory requirements.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to address the exporting of cryptographic technologies in compliance with relevant statutory and regulatory requirements.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to address the exporting of cryptographic technologies in compliance with relevant statutory and regulatory requirements.

null

18.1.5

5.31

18.1.5

null

6.15.1.5

null

SC-13

null

SC-13

null

SC-13

null

L.6.2

null

KIM:SG4.SP1

null

SC-13

null

SC-13

null

SC-13

120.54(a)(5)

null

9-400

null

SC-13

null

SC-13

null

SC-13

null

18.1.5 18.1.5.7.PB

null

x

null

R-AM-3 R-EX-5

null

R-AM-3

null

R-EX-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 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

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Pre/Post Transmission Handling

CRY-01.3

Cryptographic mechanisms exist to ensure the confidentiality and integrity of information during preparation for transmission and during reception.

null

Are cryptographic mechanisms utilized to ensure the confidentiality and integrity of information during preparation for transmission and during reception?

5

Protect

null

X

There is no evidence of a capability to Cryptographic ensure the confidentiality and integrity of information during preparation for transmission and during reception.

SP-CMM1 is N/A, since a structured process is required to Cryptographic ensure the confidentiality and integrity of information during preparation for transmission and during reception.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to Cryptographic ensure the confidentiality and integrity of information during preparation for transmission and during reception.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to Cryptographic ensure the confidentiality and integrity of information during preparation for transmission and during reception.

null

COM-07 COM-08 COM-09

null

SC-8(2)

null

SC-8(2)

null

SC-8(2)

null

D.6

null

SC-8(2)

null

0548

null

R-AC-4 R-AM-2 R-AM-3 R-BC-1 R-BC-2 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-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-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Conceal / Randomize Communications

CRY-01.4

Cryptographic mechanisms exist to conceal or randomize communication patterns.

null

Are cryptographic mechanisms utilized to conceal or randomize communication patterns?

5

Protect

null

X

There is no evidence of a capability to Cryptographic conceal or randomize communication patterns.

SP-CMM1 is N/A, since a structured process is required to Cryptographic conceal or randomize communication patterns.

SP-CMM2 is N/A, since a well-defined process is required to Cryptographic conceal or randomize communication patterns.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • IT/cybersecurity personnel perform an annual review of deployed cryptographic cipher suites and protocols to identify and replace weak cryptographic cipher suites and protocols.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to Cryptographic conceal or randomize communication patterns.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to Cryptographic conceal or randomize communication patterns.

null

SC-8(4)

null

SC-8(4)

null

SC-8(4)

null

3.13.3e

null

D.13.1

null

TBD - 3.13.3e

null

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

null

R-AM-3

R-BC-1

R-BC-2

null

R-GV-1

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-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Cryptographic Cipher Suites and Protocols Inventory

CRY-01.5

Mechanisms exist to identify, document and review deployed cryptographic cipher suites and protocols to proactively respond to industry trends regarding the continued viability of utilized cryptographic cipher suites and protocols.

null

Does the organization identify, document and review deployed cryptographic cipher suites and protocols to proactively respond to industry trends regarding the continued viability of utilized cryptographic cipher suites and protocols?

9

Protect

X

There is no evidence of a capability to identify, document and review deployed cryptographic cipher suites and protocols to proactively respond to industry trends regarding the continued viability of utilized cryptographic cipher suites and protocols.

SP-CMM1 is N/A, since a structured process is required to identify, document and review deployed cryptographic cipher suites and protocols to proactively respond to industry trends regarding the continued viability of utilized cryptographic cipher suites and protocols.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • IT/cybersecurity personnel perform an annual review of deployed cryptographic cipher suites and protocols to identify and replace weak cryptographic cipher suites and protocols.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • IT/cybersecurity personnel perform an annual review of deployed cryptographic cipher suites and protocols to identify and replace weak cryptographic cipher suites and protocols.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to identify, document and review deployed cryptographic cipher suites and protocols to proactively respond to industry trends regarding the continued viability of utilized cryptographic cipher suites and protocols.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify, document and review deployed cryptographic cipher suites and protocols to proactively respond to industry trends regarding the continued viability of utilized cryptographic cipher suites and protocols.

null

12.3.3

null

12.3.3

null

I.3.4

null

2-7-1-3

null

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

R-AC-1

null

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-GV-1

null

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

null

MT-8

MT-9

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Cryptographic Module Authentication

CRY-02

Automated mechanisms exist to enable systems to authenticate to a cryptographic module.

- Yubico (https://www.yubico.com)

null

Does the organization use automated mechanisms to enable systems to authenticate to a cryptographic module?

8

Protect

null

X

There is no evidence of a capability to enable systems to authenticate to a cryptographic module.

SP-CMM1 is N/A, since a structured process is required to enable systems to authenticate to a cryptographic module.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to enable systems to authenticate to a cryptographic module.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to enable systems to authenticate to a cryptographic module.

null

CEK-04

IAM-22

null

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

null

IA-7

null

IA-7

null

IA-7

null

8.2.1

2.2.7 3.6.1.1 3.6.1.2 3.7.3

null

2.2.7

null

2.2.7

2.2.7 3.6.1.2 3.7.3

2.2.7 3.6.1.1 3.6.1.2 3.7.3

null

D.13.5.2

null

TM:SG4.SP1

null

IA-7

null

IA-7

null

IA-7

null

IA-7

120.54(a)(5)

null

IA-7

null

4.37 12.10

null

2-8-3-1

null

x

null

x

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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-13 MT-14

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

null

MT-13

MT-14

null

Cryptographic Protections

Transmission Confidentiality

CRY-03

Cryptographic mechanisms exist to protect the confidentiality of data being transmitted.

- SSL / TLS protocols - IPSEC Tunnels - Native MPLS encrypted tunnel configurations - Custom encrypted payloads

E-CRY-01

Are cryptographic mechanisms utilized to protect the confidentiality of data being transmitted?

10

Protect

null

X

There is no evidence of a capability to Cryptographic protect the confidentiality of data being transmitted.

Cryptographic Protections (CRY) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption. • IT personnel use an informal process to design, build and maintain secure configurations for the test, development, staging and production environments, implementing cryptographic protections controls using known public standards and trusted cryptographic technologies to protect the confidentiality and integrity of the data.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • Network communications containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption. • Instances of non-console administrative access use cryptographic mechanisms to protect the confidentiality and integrity of the data being transmitted.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • Instances of non-console administrative access use cryptographic mechanisms to protect the confidentiality and integrity of the data being transmitted. • Mobile devices containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information at rest (e.g., whole drive encryption). • Network communications containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption.

Cryptographic Protections (CRY) 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 Cryptographic protect the confidentiality of data being transmitted.

CC6.1 CC6.7

CC6.1-POF9 CC6.7-POF2

null

3.10

null

3.10

null

CEK-03 DSP-10

COM-07 COM-08 COM-09 IOT-10 SAP-07

null

8.2.5

CR 4.1 (8.3.1(a))

null

10.1.1 13.2.3 14.1.2 14.1.3

5.14 8.24 8.26

10.1.1 13.2.3 14.1.2 14.1.3

null

6.10.2.3

null

T1020.001, T1040, T1090, T1090.004, T1550.001, T1550.004, T1552.007, T1557, T1557.001, T1557.002, T1562.006, T1562.009, T1602, T1602.001, T1602.002

TS-1.9 TS-1.15 TS-3.0

Sec 4(D)(2)(d)

null

PR.DS-P2

null

SC-8 SC-8(1)

null

SC-8

SC-8 SC-8(1)

null

SC-8

SC-8(1)

null

SC-8

null

SC-8

null

SC-8

null

SC-8

3.13.8

3.13.8 3.13.11

3.13.8[a] 3.13.11

A.03.13.08[01]

null

PR.DS-2

PR.AA-04 PR.DS-02

null

4.2.1.2 8.3.2 A2.1 A2.1.1 A2.1.2

null

8.3.2

null

A2.1.1

4.2.1.2 8.3.2 A2.1.1

4.2.1.2

4.2.1.2 8.3.2 A2.1.1

4.2.1.2 8.3.2 A2.1.1 A2.1.2

null

D.5.3

2.1 2.4A 2.6

5.1.1 5.1.2

null

ARCHITECTURE-5.C.MIL2

KIM:SG4.SP1 KIM:SG5.SP3 SC:SG2.SP2 SC:SG2.SP3

3.3 3.4 8.3

5.10.1.2 5.10.1.2.1

null

SC.L2-3.13.8

null

SC.L2-3.13.8

SC-8

null

§ 11.10 § 11.10(c)

SC-8

null

SC-8

null

SC-8

null

D3.PC.Am.B.13 D3.PC.Am.E.5 D3.PC.Am.Int.7

null

164.312(a)(2)(iv) 164.312(e) 164.312(e)(1) 164.312(e)(2)(ii)

1.S.A 2.S.A

1.M.A 1.M.C 4.M.C

1.M.A 1.M.C 4.M.C 1.L.A

2.E.3 SC-8 SC-8(1)

120.54(a)(5)

null

8-605

18.1 19.1

null

5.8

null

SC-8

null

17.04(3)

null

500.15

null

622(2)(d)(C)(iii)

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

null

SC-8

null

SC-8

null

§ 2447(c)(3)

3.4.4(36)(f)

null

Art 5

Art 5.1

null

Art 20 Art 30

null

CRY-02

null

4.22 8.4 8.5 8.6 9.8 9.20 12.10 13.6

null

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

TPC-52 TPC-53

null

2-8-3-3

2-2-1-4

null

Sec 14.1

null

B3.b

null

0231 0232 0547 0465 0467 0469 1139 1369 1370 1372 1448 1373 1374 1375 1553 1453 1506 0484 1781

null

10.1.1 10.1.1.9.PB 13.2.3 14.1.2 14.1.3

null

x

NAIC MA 201 CMR 17 OR 6464A Lockton 9

x

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Transmission Integrity

CRY-04

Cryptographic mechanisms exist to protect the integrity of data being transmitted.

null

E-CRY-01

Are cryptographic mechanisms utilized to protect the integrity of data being transmitted?

10

Protect

null

X

There is no evidence of a capability to Cryptographic protect the integrity of data being transmitted.

Cryptographic Protections (CRY) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption. • IT personnel use an informal process to design, build and maintain secure configurations for the test, development, staging and production environments, implementing cryptographic protections controls using known public standards and trusted cryptographic technologies to protect the confidentiality and integrity of the data.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

Cryptographic Protections (CRY) 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 Cryptographic protect the integrity of data being transmitted.

null

SAP-07

null

CR 3.1 (7.3.1) CR 3.1 (7.3.3(1))

null

10.1.1 14.1.3

8.24 8.26

10.1.1 14.1.3

null

6.11.1.3

null

T1020.001, T1040, T1090, T1090.004, T1550.001, T1550.004, T1552.007, T1557, T1557.001, T1557.002, T1562.006, T1562.009, T1602, T1602.001, T1602.002

null

PR.AC-P5 PR.DS-P6

null

SC-8 SC-16(1) SC-28(1)

null

SC-8

SC-8 SC-16(1) SC-28(1)

null

SC-8 SC-28(1)

SC-16(1)

null

SC-8 SC-28(1)

null

SC-8

null

SC-8

null

SC-8

NFO - SI-1

null

PR.DS-8

null

3.4 3.4.1 4.1 9.8.2

3.7.5

null

3.7.5

null

D.5.2

2.1 2.4A 2.6

5.1.1 5.1.2

null

KIM:SG4.SP1 KIM:SG5.SP3 SC:SG2.SP2 SC:SG2.SP3

3.3

null

SC-8

null

§ 11.10 § 11.10(c)

MP-5(4) SC-8 SC-28(1)

null

SC-8 SC-28(1)

null

SC-8 SC-28(1)

null

SC-8 SC-28(1)

null

164.312(c) 164.312(c)(1) 164.312(c)(2) 164.312(e)(2)(i)

null

SC-8 SC-28(1)

null

8-605

null

5.9

null

SC-8

SC-8 SC-28(1)

null

17.04(3)

null

622(2)(d)(C)(iii)

null

SC-8

null

SC-8 SC-28(1)

null

Art 5.1

null

Art 20 Art 30

null

OPS-09

null

4.22 9.8 9.20 12.10 13.6

null

2-2-1-4

null

Sec 14.1

null

0677

null

10.1.1 10.1.1.9.PB 14.1.3

null

x

MA 201 CMR 17 OR 6464A

x

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Encrypting Data At Rest

CRY-05

Cryptographic mechanisms exist to prevent unauthorized disclosure of data at rest.

- Symantec Endpoint Encryption (https://www.symantec.com/products/endpoint-protection)

null

Are cryptographic mechanisms utilized to prevent unauthorized disclosure of data at rest?

10

Protect

null

X

There is no evidence of a capability to Cryptographic prevent unauthorized disclosure of data at rest.

Cryptographic Protections (CRY) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption. • Mobile devices containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information at rest (e.g., whole drive encryption). • IT personnel use an informal process to design, build and maintain secure configurations for the test, development, staging and production environments, implementing cryptographic protections controls using known public standards and trusted cryptographic technologies to protect the confidentiality and integrity of the data.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • Mobile devices containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information at rest (e.g., whole drive encryption).

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • Mobile devices containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information at rest (e.g., whole drive encryption).

Cryptographic Protections (CRY) 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 Cryptographic prevent unauthorized disclosure of data at rest.

CC6.1 CC6.7

CC6.1-POF9 CC6.7-POF2

null

3.6 3.11

3.6

3.6 3.11

null

CEK-03 UEM-08

DAT-04

null

CR 4.1 (8.3.1(a))

null

10.1.1

8.24

10.1.1

null

6.7 6.7.1 6.7.1.1

null

TS-1.15 TS-3.0

Sec 4(D)(2)(d)

null

PR.DS-P1

null

SC-13 SC-28 SC-28(1)

SC-13

SC-13 SC-28

SC-13 SC-28 SC-28(1)

null

SC-13

SC-13 SC-28

null

SC-13

SC-13 SC-28

null

3.8.6

3.13.8 3.13.11

3.8.6

A.03.13.08[02]

3.14.5e

null

PR.DS-1

PR.DS-01

null

3.4 3.4.1

3.3.2 3.5.1.2 3.5.1.3 8.3.2

null

8.3.2

null

8.3.2

null

3.3.2 3.5.1.2 3.5.1.3 8.3.2

null

D.24

null

ARCHITECTURE-5.B.MIL2 ARCHITECTURE-5.G.MIL3

KIM:SG4.SP1

3.3 3.4 8.3

5.10.1.2 5.10.1.2.2

null

MP.L2-3.8.6

MP.L2-3.8.6 TBD - 3.14.5e

null

MP.L2-3.8.6

SC-13

null

§ 11.10 § 11.10(c)

SC-13

SC-13 SC-28(1)

null

D1.G.IT.B.13 D3.PC.Am.B.14 D4.RM.Co.B.1 D3.PC.Am.A.1

null

164.312(a)(2)(iv)

2.S.A

2.M.A 4.M.C 9.M.B

2.E.3 SC-13

120.54(a)(5)

null

9-400

18.2 19.2

null

5.9

SC-13

null

17.04(5)

null

500.15

null

622(2)(d)(C)(iii)

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

null

SC-13

null

SC-13

null

§ 2447(c)(5)

3.4.4(36)(f)

null

Art 5.1

null

CRY-03

null

8.7 15.7

null

2-7-1-2

null

2-8-3-3

null

Sec 14.1

null

B3.c

null

0459 1080

null

10.1.1 10.1.1.9.PB

null

8.4.13.C.01

null

x

NAIC MA 201 CMR 17 OR 6464A Lockton 9

x

null

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

null

MT-13

MT-14

MT-15

null

- Updated CIS 8.0

Cryptographic Protections

Storage Media

CRY-05.1

Cryptographic mechanisms exist to protect the confidentiality and integrity of sensitive/regulated data residing on storage media.

- Native Storage Area Network (SAN) encryption functionality - BitLocker and EFS

null

Are cryptographic mechanisms utilized to protect the confidentiality and integrity of sensitive/regulated data residing on storage media?

8

Protect

null

X

There is no evidence of a capability to Cryptographic protect the confidentiality and integrity of sensitive/regulated data residing on storage media.

Cryptographic Protections (CRY) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption. • Mobile devices containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information at rest (e.g., whole drive encryption).

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

Cryptographic Protections (CRY) 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 Cryptographic protect the confidentiality and integrity of sensitive/regulated data residing on storage media.

null

3.6

null

UEM-08

null

PR.DS-P1

null

3.13.8

null

D.6.1

null

ARCHITECTURE-5.G.MIL3

null

4.2.4 5.8.1

null

2.M.A

null

18.3 19.3

null

CRY-03

null

15.7

null

2-3-1-8 2-3-1-9

null

B3.c

null

8.4.13.C.01

null

x

null

x

null

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Offline Storage

CRY-05.2

Mechanisms exist to remove unused data from online storage and archive it off-line in a secure location until it can be disposed of according to data retention requirements.

null

Does the organization remove unused data from online storage and archive it off-line in a secure location until it can be disposed of according to data retention requirements?

5

Protect

null

X

There is no evidence of a capability to remove unused data from online storage and archive it off-line in a secure location until it can be disposed of according to data retention requirements.

SP-CMM1 is N/A, since a structured process is required to remove unused data from online storage and archive it off-line in a secure location until it can be disposed of according to data retention requirements.

SP-CMM2 is N/A, since a well-defined process is required to remove unused data from online storage and archive it off-line in a secure location until it can be disposed of according to data retention requirements.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

Cryptographic Protections (CRY) 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 remove unused data from online storage and archive it off-line in a secure location until it can be disposed of according to data retention requirements.

null

PR.DS-P1

null

SC-28(2)

null

SC-28(2)

null

SC-28(2)

null

3.14.5e

null

D.4.1

null

4.2.4

null

TBD - 3.14.5e

null

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-1

null

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-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

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Database Encryption

CRY-05.3

Mechanisms exist to ensure that database servers utilize encryption to protect the confidentiality of the data within the databases.

null

Does the organization ensure that database servers utilize encryption to protect the confidentiality of the data within the databases?

8

Protect

null

X

There is no evidence of a capability to ensure that database servers utilize encryption to protect the confidentiality of the data within the databases.

Cryptographic Protections (CRY) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption. • Databases containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information in the database (e.g., column-level, Transparent Data Encryption (TDE), etc.).

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • Databases containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information in the database (e.g., column-level, Transparent Data Encryption (TDE), etc.).

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • Databases containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information in the database (e.g., column-level, Transparent Data Encryption (TDE), etc.).

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure that database servers utilize encryption to protect the confidentiality of the data within the databases.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure that database servers utilize encryption to protect the confidentiality of the data within the databases.

null

D.6.1

null

1080

null

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-1

null

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-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

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Non-Console Administrative Access

CRY-06

Cryptographic mechanisms exist to protect the confidentiality and integrity of non-console administrative access.

null

Are cryptographic mechanisms utilized to protect the confidentiality and integrity of non-console administrative access?

9

Protect

null

X

There is no evidence of a capability to Cryptographic protect the confidentiality and integrity of non-console administrative access.

Cryptographic Protections (CRY) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • Instances of non-console administrative access use cryptographic mechanisms to protect the confidentiality and integrity of the data being transmitted.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • Instances of non-console administrative access use cryptographic mechanisms to protect the confidentiality and integrity of the data being transmitted.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to Cryptographic protect the confidentiality and integrity of non-console administrative access.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to Cryptographic protect the confidentiality and integrity of non-console administrative access.

null

4.6 12.3

4.6

4.6 12.3

null

PR.DS-P2

null

2.3

2.2.7

null

2.2.7

null

2.2.7

null

I.3.8

null

x

null

x

null

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Wireless Access Authentication & Encryption

CRY-07

Mechanisms exist to protect wireless access via secure authentication and encryption.

null

Does the organization protect wireless access via secure authentication and encryption?

9

Protect

X

There is no evidence of a capability to protect wireless access via secure authentication and encryption.

Cryptographic Protections (CRY) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

Cryptographic Protections (CRY) 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 protect wireless access via secure authentication and encryption.

null

SWS-07 SWS-08 SWS-11

null

CR 1.6 (5.8)

null

T1011, T1011.001, T1020.001, T1040, T1070, T1070.001, T1070.002, T1119, T1530, T1552, T1552.004, T1557, T1557.002, T1558, T1558.002, T1558.003, T1558.004, T1565, T1565.001, T1565.002, T1602, T1602.001, T1602.002

TS-2.11

null

AC-18 SC-40

AC-18

AC-18 SC-40

null

AC-18

SC-40

null

AC-18

null

AC-18

null

AC-18

null

3.1.16.a

null

4.1.1

2.3.1 2.3.2 4.2.1.2

null

2.3.1 2.3.2

2.3.1 2.3.2 4.2.1.2

null

N.8.1

null

EC:SG2.SP2 TM:SG4.SP1 TM:SG2.SP2

null

AC-18

null

AC-18

null

AC-18

null

8-311

null

AC-18

null

4.22

null

TPC-42

null

2-5-3-4

null

1314 1332

null

18.2.9.C.01 18.2.10.C.01 18.2.10.C.02 18.2.11.C.01 18.2.11.C.02 18.2.11.C.03 18.2.11.C.04 18.2.11.C.05 18.2.12.C.01 18.2.12.C.02 18.2.13.C.01 18.2.14.C.01 18.2.15.C.01 18.2.16.C.01 18.2.17.C.01 18.2.18.C.01 18.2.19.C.01 18.2.20.C.01 18.2.20.C.02 18.2.20.C.03 18.2.21.C.01 18.2.22.C.01 18.2.23.C.01 18.2.23.C.02 18.2.24.C.01 18.2.25.C.01

null

x

null

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

null

R-AC-4

null

R-AM-2

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

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

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-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

null

MT-13

MT-14

MT-15

null

Cryptographic Protections

Public Key Infrastructure (PKI)

CRY-08

Mechanisms exist to securely implement an internal Public Key Infrastructure (PKI) infrastructure or obtain PKI services from a reputable PKI service provider.

- Microsoft Active Directory (AD) Certificate Services - Digitcert (https://www.digicert.com) - Entrust (https://www.entrust.com) - Comodo (https://www.comodo.com) - Vault (https://www.vaultproject.io/)

null

Does the organization securely implement an internal Public Key Infrastructure (PKI) infrastructure or obtain PKI services from a reputable PKI service provider?

9

Protect

X

There is no evidence of a capability to securely implement an internal Public Key Infrastructure (PKI) infrastructure or obtain PKI services from a reputable PKI service provider.

Cryptographic Protections (CRY) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS, VPN, etc.). • Wireless access is protected via secure authentication and encryption.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The IT department implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. • The IT department implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The Public Key Infrastructure (PKI) management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • An IT infrastructure team, or similar function, enables: o The production and management of asymmetric cryptographic keys using approved key management technology and processes that protect the user’s private key. o The production and management of symmetric cryptographic keys using approved key management technology and processes that protect the user’s private key.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to securely implement an internal Public Key Infrastructure (PKI) infrastructure or obtain PKI services from a reputable PKI service provider.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to securely implement an internal Public Key Infrastructure (PKI) infrastructure or obtain PKI services from a reputable PKI service provider.

CC6.1

CC6.1-POF10

null

CEK-02 CEK-08 LOG-10 LOG-11

CLS-01 IAM-10 IAM-11 IAM-12 IAM-13 IAM-14 IAM-15 IAM-22 IOT-09 SDV-01

null

CR 1.8 (5.10.1) CR 1.9 (5.11.1)

null

T1072, T1606

null

SC-12 SC-12(4) SC-12(5) SC-17

SC-12

SC-12 SC-17

null

SC-12

SC-12 SC-17

null

SC-12

SC-12 SC-17

null

3.13.10

3.13.10[a] 3.13.10[b]

null

D.13.5

null

KIM:SG4.SP1

null

5.10.1.2.3

null

SC.L2-3.13.10

null

SC.L2-3.13.10

SC-12 SC-17

null

§ 11.2 § 11.2(a) § 11.100

SC-12 SC-17

SC-12

SC-12 SC-17

SC-12

SC-12 SC-17

SC-12

SC-12 SC-17

SC-12

null

1.L.B

SC-12 SC-17

null

8-303

null

SC-12

SC-12 SC-17

null

SC-12

null

SC-12 SC-17

null

8.2 8.9

null

0485 1449

null

17.1.51.C.01 17.1.51.C.02 17.1.51.C.03 23.3.21.C.01 23.3.22.C.01

null

x

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-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

Cryptographic Protections

Availability

CRY-08.1

Resiliency mechanisms exist to ensure the availability of data in the event of the loss of cryptographic keys.

null

Does the organization ensure the availability of data in the event of the loss of cryptographic keys?

9

Recover

X

There is no evidence of a capability to Resiliency ensure the availability of data in the event of the loss of cryptographic keys.

SP-CMM1 is N/A, since a structured process is required to Resiliency ensure the availability of data in the event of the loss of cryptographic keys.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The IT department implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. • The IT department implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to Resiliency ensure the availability of data in the event of the loss of cryptographic keys.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to Resiliency ensure the availability of data in the event of the loss of cryptographic keys.

null

3.6.4 3.6.5

3.6.1

null

3.6.1

null

D.13.1

null

17.1.51.C.01 17.1.51.C.02 17.1.51.C.03

null

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

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-1

null

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

Cryptographic Protections

Cryptographic Key Management

CRY-09

Mechanisms exist to facilitate cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

- Microsoft Active Directory (AD) Certificate Services - Digitcert (https://www.digicert.com) - Entrust (https://www.entrust.com) - Comodo (https://www.comodo.com) - Vault (https://www.vaultproject.io/)

E-CRY-01

Does the organization facilitate cryptographic key management controls to protect the confidentiality, integrity and availability of keys?

10

Protect

X

There is no evidence of a capability to facilitate cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

SP-CMM1 is N/A, since a structured process is required to facilitate cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The IT infrastructure team provides customers with appropriate key management guidance whenever cryptographic keys are shared.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The Public Key Infrastructure (PKI) management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • An IT infrastructure team, or similar function, enables: o The production and management of asymmetric cryptographic keys using approved key management technology and processes that protect the user’s private key. o The production and management of symmetric cryptographic keys using approved key management technology and processes that protect the user’s private key. • The IT infrastructure team provides customers with appropriate key management guidance whenever cryptographic keys are shared.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to facilitate cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

CC6.1

CC6.1-POF10

null

CEK-02 CEK-08 CEK-10 CEK-11 CEK-12 CEK-13 CEK-14 CEK-15 CEK-16 CEK-17 CEK-18 CEK-19 CEK-20 CEK-21 LOG-10 LOG-11

IAM-08 IAM-10 IAM-11 IAM-12 IAM-13 IAM-14 IAM-15 IOT-09 SDV-01 SWS-08 SWS-09 SWS-10

null

CR 1.8 (5.10.1) CR 1.9 (5.11.1)

null

10.1.2

8.24

10.1.2

null

6.7.1.2

null

T1072, T1098.004, T1552, T1552.001, T1552.002, T1552.004, T1563.001, T1573, T1573.001, T1573.002

TS-3.0 TS-3.1

null

SC-28(3)

null

SC-28(3)

null

3.13.10

3.13.10[a] 3.13.10[b]

A.03.13.10.ODP[01] A.03.13.10[01] A.03.13.10[02]

null

3.5 3.5.1 3.5.2 3.5.3 3.5.4 3.6 3.6.1 3.6.2 3.6.3 3.6.4 3.6.5 3.6.6 3.6.7 3.6.8

3.5.1.1 3.6.1 3.6.1.1 3.6.1.2 3.6.1.3 3.6.1.4 3.7.1 3.7.2 3.7.3 3.7.4 3.7.5 3.7.6 3.7.7 4.2.1.1

null

3.5.1.1 3.6.1 3.6.1.2 3.6.1.3 3.6.1.4 3.7.1 3.7.2 3.7.3 3.7.4 3.7.5 3.7.6 3.7.7 4.2.1.1

3.5.1.1 3.6.1 3.6.1.1 3.6.1.2 3.6.1.3 3.6.1.4 3.7.1 3.7.2 3.7.3 3.7.4 3.7.5 3.7.6 3.7.7 4.2.1.1

null

D.13.5

null

ARCHITECTURE-5.E.MIL2

null

SC.L2-3.13.10

null

SC.L2-3.13.10

null

§ 11.50 § 11.50(a) § 11.50(a)(1) § 11.50(a)(2) § 11.50(a)(3) § 11.50(b) § 11.70 § 11.100 § 11.100(a) § 11.100(b)

null

1.L.B

null

5.8

null

CRY-04

null

8.2 8.9 8.10

null

TPC-55

null

2-8-3-2

null

7.3.11 [OP.EXP.11]

null

0455 0507

null

10.1.2 10.1.2.20.PB

null

17.1.51.C.01 17.1.58.C.01 17.1.58.C.02 17.1.58.C.03 23.3.21.C.01 23.3.22.C.01 23.4.9.C.02 23.4.9.C.03

null

10.2.1 10.2.2 10.2.3 10.2.4 10.2.5 10.2.6 10.2.7 10.2.8 10.2.9 10.2.10

null

x

null

x

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

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

Cryptographic Protections

Symmetric Keys

CRY-09.1

Mechanisms exist to facilitate the production and management of symmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes.

null

E-CRY-01

Does the organization facilitate the production and management of symmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes?

9

Protect

null

X

There is no evidence of a capability to facilitate the production and management of symmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes.

SP-CMM1 is N/A, since a structured process is required to facilitate the production and management of symmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The IT department implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. • The IT department implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The Public Key Infrastructure (PKI) management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • An IT infrastructure team, or similar function, enables: o The production and management of asymmetric cryptographic keys using approved key management technology and processes that protect the user’s private key. o The production and management of symmetric cryptographic keys using approved key management technology and processes that protect the user’s private key.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to facilitate the production and management of symmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the production and management of symmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes.

CC6.1

CC6.1-POF10

null

CR 1.14 (5.16.1)

null

SC-12(2)

null

SC-12(2)

null

SC-12(2)

null

D.13.7.1

null

10.4

null

SC-12(2)

null

SC-12(2)

null

SC-12(2)

null

SC-12(2)

null

SC-12(2)

null

x

null

x

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

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

Cryptographic Protections

Asymmetric Keys

CRY-09.2

Mechanisms exist to facilitate the production and management of asymmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes that protect the user’s private key.

null

E-CRY-01

Does the organization facilitate the production and management of asymmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes that protect the user’s private key?

9

Protect

null

X

There is no evidence of a capability to facilitate the production and management of asymmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes that protect the user’s private key.

SP-CMM1 is N/A, since a structured process is required to facilitate the production and management of asymmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes that protect the user’s private key.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The IT department implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. • The IT department implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The Public Key Infrastructure (PKI) management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • An IT infrastructure team, or similar function, enables: o The production and management of asymmetric cryptographic keys using approved key management technology and processes that protect the user’s private key. o The production and management of symmetric cryptographic keys using approved key management technology and processes that protect the user’s private key.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to facilitate the production and management of asymmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes that protect the user’s private key.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the production and management of asymmetric cryptographic keys using Federal Information Processing Standards (FIPS)-compliant key management technology and processes that protect the user’s private key.

CC6.1

CC6.1-POF10

null

SC-12(3)

null

SC-12(3)

null

SC-12(3)

null

D.13.7

null

SC-12(3)

null

SC-12(3)

null

SC-12(3)

null

SC-12(3)

null

x

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

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

Cryptographic Protections

Cryptographic Key Loss or Change

CRY-09.3

Mechanisms exist to ensure the availability of information in the event of the loss of cryptographic keys by individual users.

- Escrowing of encryption keys is a common practice for ensuring availability in the event of loss of keys.

null

Does the organization ensure the availability of information in the event of the loss of cryptographic keys by individual users?

8

Protect

X

There is no evidence of a capability to ensure the availability of information in the event of the loss of cryptographic keys by individual users.

SP-CMM1 is N/A, since a structured process is required to ensure the availability of information in the event of the loss of cryptographic keys by individual users.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The Public Key Infrastructure (PKI) management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • An IT infrastructure team, or similar function, enables: o The production and management of asymmetric cryptographic keys using approved key management technology and processes that protect the user’s private key. o The production and management of symmetric cryptographic keys using approved key management technology and processes that protect the user’s private key.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure the availability of information in the event of the loss of cryptographic keys by individual users.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure the availability of information in the event of the loss of cryptographic keys by individual users.

null

CEK-12 CEK-13 CEK-14 CEK-15 CEK-16 CEK-17 CEK-18 CEK-19 CEK-20

IAM-10 IAM-11 IAM-12 IAM-13 IAM-14 IAM-15

null

10.1.2

8.24

10.1.2

null

SC-12(1)

null

SC-12(1)

null

SC-12(1)

null

SC-12(1)

null

3.13.10

null

3.6.4 3.6.5

2.3.2 3.6.1 3.7.5

null

2.3.2

2.3.2 3.6.1 3.7.5

null

D.13.3

null

SC-12(1)

null

SC-12(1)

null

SC-12(1)

null

SC-12(1)

null

8.3 8.11

null

0455 0462

null

10.1.2 10.1.2.20.PB

null

7.2.24.C.01 7.2.25.C.01

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

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

Cryptographic Protections

Control & Distribution of Cryptographic Keys

CRY-09.4

Mechanisms exist to facilitate the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes.

null

Does the organization facilitate the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes?

9

Protect

X

There is no evidence of a capability to facilitate the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes.

SP-CMM1 is N/A, since a structured process is required to facilitate the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The IT department implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. • The IT department implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The Public Key Infrastructure (PKI) management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • An IT infrastructure team, or similar function, enables: o The production and management of asymmetric cryptographic keys using approved key management technology and processes that protect the user’s private key. o The production and management of symmetric cryptographic keys using approved key management technology and processes that protect the user’s private key.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to facilitate the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes.

null

CEK-10 CEK-11 CEK-12 CEK-15

null

10.1.2

8.24

10.1.2

null

TS-3.0 TS-3.1

null

3.13.10

null

3.6.6 3.6.7 3.6.8

3.6.1

null

3.6.1

null

D.13.1

null

8.9 8.11

null

10.1.2 10.1.2.20.PB

null

10.2.5

null

x

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

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

Cryptographic Protections

Assigned Owners

CRY-09.5

Mechanisms exist to ensure cryptographic keys are bound to individual identities.

null

Does the organization ensure cryptographic keys are bound to individual identities?

8

Protect

null

X

There is no evidence of a capability to ensure cryptographic keys are bound to individual identities.

SP-CMM1 is N/A, since a structured process is required to ensure cryptographic keys are bound to individual identities.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • Cryptographic keys are bound to individual identities.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • The Public Key Infrastructure (PKI) management function enables the implementation of cryptographic key management controls to protect the confidentiality, integrity and availability of keys. • The PKI infrastructure enables the secure distribution of symmetric and asymmetric cryptographic keys using industry recognized key management technology and processes. • The PKI infrastructure ensures the availability of information in the event of the loss of cryptographic keys by individual users. • An IT infrastructure team, or similar function, enables: o The production and management of asymmetric cryptographic keys using approved key management technology and processes that protect the user’s private key. o The production and management of symmetric cryptographic keys using approved key management technology and processes that protect the user’s private key. • Cryptographic keys are bound to individual identities.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure cryptographic keys are bound to individual identities.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure cryptographic keys are bound to individual identities.

null

6.1

null

D.13.4

null

x

null

x

null

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

R-AC-1

null

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

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

Cryptographic Protections

Third-Party Cryptographic Keys

CRY-09.6

Mechanisms exist to ensure customers are provided with appropriate key management guidance whenever cryptographic keys are shared.

null

Does the organization ensure customers are provided with appropriate key management guidance whenever cryptographic keys are shared?

7

Protect

null

X

There is no evidence of a capability to ensure customers are provided with appropriate key management guidance whenever cryptographic keys are shared.

SP-CMM1 is N/A, since a structured process is required to ensure customers are provided with appropriate key management guidance whenever cryptographic keys are shared.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure customers are provided with appropriate key management guidance whenever cryptographic keys are shared.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure customers are provided with appropriate key management guidance whenever cryptographic keys are shared.

null

TS-3.0

null

3.7.9

null

3.7.9

null

D.13.6

null

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

R-AC-1

null

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-GV-1

null

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

null

MT-8

MT-9

MT-10

null

MT-12

MT-13

MT-14

MT-15

null

Cryptographic Protections

External System Cryptographic Key Control

CRY-09.7

Mechanisms exist to maintain control of cryptographic keys for encrypted material stored or transmitted through an external system.

null

Does the organization maintain control of cryptographic keys for encrypted material stored or transmitted through an external system?

5

Protect

null

X

There is no evidence of a capability to maintain control of cryptographic keys for encrypted material stored or transmitted through an external system.

SP-CMM1 is N/A, since a structured process is required to maintain control of cryptographic keys for encrypted material stored or transmitted through an external system.

SP-CMM2 is N/A, since a well-defined process is required to maintain control of cryptographic keys for encrypted material stored or transmitted through an external system.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to maintain control of cryptographic keys for encrypted material stored or transmitted through an external system.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to maintain control of cryptographic keys for encrypted material stored or transmitted through an external system.

null

TS-3.0

null

SA-9(6)

null

SA-9(6)

null

SA-9(6)

null

23.4.9.C.02 23.4.9.C.03

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-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

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

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

Cryptographic Protections

Transmission of Cybersecurity & Data Privacy Attributes

CRY-10

Mechanisms exist to ensure systems associate security attributes with information exchanged between systems.

- Integrity checking

null

Does the organization ensure systems associate security attributes with information exchanged between systems?

5

Protect

null

X

There is no evidence of a capability to ensure systems associate security attributes with information exchanged between systems.

SP-CMM1 is N/A, since a structured process is required to ensure systems associate security attributes with information exchanged between systems.

Cryptographic Protections (CRY) 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: • Cryptographic 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 cryptographic management. • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure systems associate security attributes with information exchanged between systems.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure systems associate security attributes with information exchanged between systems.

null

T1505, T1505.002, T1573, T1573.001, T1573.002

null

SC-16 SC-16(1)

null

SC-16 SC-16(1)

null

SC-16 SC-16(1)

null

PR.AA-04

null

D.24.1

null

8-700

null

x

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

R-AC-1

null

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-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

Cryptographic Protections

Certificate Authorities

CRY-11

Automated mechanisms exist to enable the use of organization-defined Certificate Authorities (CAs) to facilitate the establishment of protected sessions.

null

Does the organization use automated mechanisms to enable the use of organization-defined Certificate Authorities (CAs) to facilitate the establishment of protected sessions?

8

Protect

X

null

There is no evidence of a capability to enable the use of organization-defined Certificate Authorities (CAs) to facilitate the establishment of protected sessions.

SP-CMM1 is N/A, since a structured process is required to enable the use of organization-defined Certificate Authorities (CAs) to facilitate the establishment of protected sessions.

SP-CMM2 is N/A, since a well-defined process is required to enable the use of organization-defined Certificate Authorities (CAs) to facilitate the establishment of protected sessions.

Cryptographic Protections (CRY) 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: • Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage. • Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage. • Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards. • An IT infrastructure team, or similar function: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to enable the use of organization-defined Certificate Authorities (CAs) to facilitate the establishment of protected sessions.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to enable the use of organization-defined Certificate Authorities (CAs) to facilitate the establishment of protected sessions.

null

SC-23(5)

null

SC-23(5)

null

SC-23(5)

null

SC-23(5)

null

23.3.21.C.01 23.3.22.C.01

null

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

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

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

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

Data Classification & Handling

Data Protection

DCH-01

Mechanisms exist to facilitate the implementation of data protection controls.

null

Does the organization facilitate the implementation of data protection controls?

10

Protect

X

null

There is no evidence of a capability to facilitate the implementation of data protection controls.

Data Classification & Handling (DCH) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data protection controls are primarily administrative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A manual data retention process exists. • Data/process owners are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data.

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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 data classification and handling 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 data classification and handling. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including data classification and handling. • 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 regarding data classification and handling. • A GRC function, or similar function, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the data according to the organization’s data classification and handling requirements. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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 data protection controls.

CC2.1 CC6.7 C1.1 PI1.5

CC6.7-POF2 C1.1-POF2 PI1.4-POF1 PI1.4-POF2 PI1.4-POF3 PI1.4-POF4 PI1.5-POF1 PI1.5-POF2 PI1.5-POF3 PI1.5-POF4

null

3.0 3.1 3.3 11.0 11.3

3.1 3.3 11.3

APO14.01 APO14.02 APO14.03 APO14.04 APO14.05 APO14.06 APO14.07 APO14.08 APO14.09 APO14.10

Principle 13

CEK-04 DCS-01 DCS-02 DCS-03 DCS-04 DSP-01 DSP-10 DSP-17 HRS-03

DAT-02 LGL-08

null

FR 4 (8.1)

RQ-05-09

null

8.2 8.2.3 8.3

5.9 5.10 5.12 5.33 7.10 8.12

8.2 8.2.3 8.3

null

6.5.2 6.5.3.3

null

OP-1.1 OP-2.0 OP-3.1 OP-3.3 TS-1.15

null

GV.PO-P1

null

MP-1

null

MP-1

3.3.6

MP-1

null

MP-1

null

3.8.1 NFO - MP-1

3.8.1 3.17.1.c

3.8.1[a] 3.8.1[b] 3.8.1[c] 3.8.1[d]

null

3.1.3E

null

PR.DS-5

PR.DS PR.DS-01 PR.DS-02 PR.DS-09 PR.DS-10

null

9.7 9.7.1

9.4 9.4.1

9.4.1

P.2

2.1 2.4A 2.9 2.11A

3.1.4 8.2.4 8.3.1 8.4.1 9.1

10.1

null

ARCHITECTURE-5.A.MIL1 ARCHITECTURE-5.B.MIL2 ARCHITECTURE-5.C.MIL2

KIM:SG2.SP2

3.4 8.3

4.2.3.1 5.1.1.1 5.7.2 5.8

null

MP.L2-3.8.1

null

MP.L2-3.8.1

AC.L3-3.1.3e MP.L2-3.8.1

MP-1

null

§ 11.2 § 11.2(a) § 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)

MP-1

§ 1232g § 1232h

null

314.4(c)(1)(i) 314.4(c)(6)(ii)

null

4.M.B 4.M.E 7.M.C

1.3 1.9.1 1.9.2 2.A.2 2.A.3 2.B.2 2.B.3 2.C.5 2.D.1 3.3.8 MP-1

120.2 120.10 120.11 120.17 120.18 120.19 120.20 120.21 120.22 120.23 120.50 120.51

CIP-002-5.1a R1 & R2

8-306 8-309

10.1

6.10

null

5.5 5.8

MP-1

null

45.48.100

null

6-1-1305(4) 6-1-1307(2) 6-1-1307(3) 6-1-1308(5)

null

17.03(2)(c)

null

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)

null

Sec 13

MP-1

null

§ 2447(a) § 2447(a)(1) § 2447(a)(1)(A) § 2447(a)(1)(B) § 2447(a)(1)(C) § 2447(a)(1)(D) § 2447(a)(2)

null

Art 5.1 Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

Art 13 Art 27

Art 27 Art 41

Sec 5 Sec 32 Sec 33 Sec 34 Sec 35

Art 34

Sec 4b Sec 9 Sec 9a Sec 16 Annex

null

COS-08

Art 9

Sec 7 Sec 8

Sec 2

5.1 5.2 5.3 5.5 11.6 15.1 15.6 15.7

Sec 16 Sec 17

Sec 31 Sec 33 Sec 34 Sec 35 Sec 42

null

Art 3 Art 4

Sec 12 Sec 13 Sec 14

null

Sec 13 Sec 14 Sec 29

Art 1 Art 36 Art 47

Art 14 Art 15 Art 16 Art 17 Art 18 Art 19

null

Art 7 Art 12 Art 19

2-6 2-6-1-3

TPC-24 TPC-39 TPC-58

null

2-1-6 2-3-3 2-3-3-2 2-3-4 2-7-1 2-7-2 2-7-3 2-7-4 2-7-3-3

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

Article 65

null

Sec 14.1 Sec 19 Sec 21

null

8.5.3 [MP.SI.3]

Sec 31 Sec 33

Art 6 Art 7

Art 8 Art 12

Sec 11 Sec 15 Sec 16

A3.a B3.a B3.b B3.c

B3

null

APP Part 8 APP Part 11

APP 11

1599 1549 0337 0831 1059

null

20 21(a)

null

Sec 4

null

Principle 4 Sec 33

Sec 7 Sec 8

null

Article 20

8.2.3

Sec 9

null

4.4.10.C.01 9.2.12.C.01 9.2.13.C.01 9.2.13.C.02 9.2.14.C.01 9.2.15.C.01 9.2.15.C.02 9.2.17.C.01 9.2.17.C.02 9.2.18.C.01 9.2.19.C.01 9.2.19.C.02 9.2.19.C.03 9.2.19.C.04 9.2.20.C.01 13.2.6.C.01 13.2.7.C.01

null

Sec 25

Sec 24 Sec 26

null

11.1.1 11.1.1(a) 11.1.1(b) 11.1.1(c) 11.1.2 11.1.3 11.1.4 11.1.5 11.1.6 11.1.7

null

Art 21

Art 9 Art 12

null

6.8 6.10 6.13

Art 46 Art 47

null

Principle 7

Art 7

null

Art 11 Art 12

null

x

MA 201 CMR 17

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-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

Data Classification & Handling

Data Stewardship

DCH-01.1

Mechanisms exist to ensure data stewardship is assigned, documented and communicated.

null

Does the organization ensure data stewardship is assigned, documented and communicated?

10

Protect

X

There is no evidence of a capability to ensure data stewardship is assigned, documented and communicated.

Data Classification & Handling (DCH) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data protection controls are primarily administrative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A manual data retention process exists. • Data/process owners are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • Security awareness training covers the restrictions on: o Disposing protected data. o Posting content to websites, social media or other publicly-accessible sources. o Use of sensitive/regulated data. o Sharing sensitive/regulated data and approved transfer technologies. o Encrypting sensitive/regulated data whenever it is being transmitted or stored. • Administrative means (e.g., policies and standards): o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Restrict types of ad-hoc transfers. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • HR requires personnel with access to sensitive/regulated data to sign a Non-Disclosure Agreement (NDA).

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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 data stewardship is assigned, documented and communicated.

CC2.1

null

3.1

null

Principle 13

DSP-03 DSP-06 HRS-03

null

OP-1.1 OP-3.2

null

SA-4(12)

null

SA-4(12)

null

3.8.1

null

9.4.1

P.7

2.9 2.11A

null

4.2.3.3 5.1.1.1

null

4.M.B

SA-4(12)

null

CIP-011-2 R1

null

10.2

null

AM-06

null

11.6

null

TPC-39 TPC-58

null

2-7-3-1

null

8.5.3 [MP.SI.3]

null

B3.a B3.b

null

Article 21

null

3.3.1(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-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-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

Data Classification & Handling

Sensitive / Regulated Data Protection

DCH-01.2

Mechanisms exist to protect sensitive/regulated data wherever it is stored.

null

Does the organization protect sensitive/regulated data wherever it is stored?

9

Protect

X

There is no evidence of a capability to protect sensitive/regulated data wherever it is stored.

Data Classification & Handling (DCH) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Data protection controls are primarily administrative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A manual data retention process exists. • Data/process owners are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT personnel provide an encryption solution (software or hardware) for storage media.

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to protect sensitive/regulated data wherever it is stored.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to protect sensitive/regulated data wherever it is stored.

null

C1.1-POF2

null

OP-3.2

null

3.1.2 3.1.20.a 3.1.20.b 3.1.20.c.1 3.1.20.c.2 3.1.20.d 3.8.1 3.17.1.c

null

PR.DS-01 PR.DS-02

null

3.5.1

null

3.5.1

null

D.8.2

2.9 2.11A

null

3.4

null

252.204-7012(h) 252.204-7012(i)(1) 252.204-7012(i)(2) 252.204-7012(i)(3) 252.204-7012(i)(4) 252.204-7012(i)(5) 252.204-7012(j)

null

2.A.2 2.B.2 2.D.5

null

10.1 10.2 10.5 10.8

null

TPC-24 TPC-39 TPC-58

null

2-6-1-1

null

B3.a B3.b B3.c

B3

null

1802

null

18.6.8.C.01

null

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

R-AC-1

null

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-GV-1

null

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

- updated DFARS mapping

Data Classification & Handling

Sensitive / Regulated Media Records

DCH-01.3

Mechanisms exist to ensure media records for sensitive/regulated data contain sufficient information to determine the potential impact in the event of a data loss incident.

null

Does the organization ensure media records for sensitive/regulated data contain sufficient information to determine the potential impact in the event of a data loss incident?

6

Protect

null

X

null

There is no evidence of a capability to ensure media records for sensitive/regulated data contain sufficient information to determine the potential impact in the event of a data loss incident.

SP-CMM1 is N/A, since a structured process is required to ensure media records for sensitive/regulated data contain sufficient information to determine the potential impact in the event of a data loss incident.

SP-CMM2 is N/A, since a well-defined process is required to ensure media records for sensitive/regulated data contain sufficient information to determine the potential impact in the event of a data loss incident.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure media records for sensitive/regulated data contain sufficient information to determine the potential impact in the event of a data loss incident.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure media records for sensitive/regulated data contain sufficient information to determine the potential impact in the event of a data loss incident.

null

2.9

null

MP-CMS-1

null

7101(a) 7101(b) 7101(c) 7101(d) 7101(e)

null

B3.a B3.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 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

Data Classification & Handling

Defining Access Authorizations for Sensitive/Regulated Data

DCH-01.4

Mechanisms exist to explicitly define authorizations for specific individuals and/or roles for logical and /or physical access to sensitive/regulated data.

null

Does the organization explicitly define authorizations for specific individuals and/or roles for logical and /or physical access to sensitive/regulated data?

9

Protect

null

x

There is no evidence of a capability to explicitly define authorizations for specific individuals and/or roles for logical and /or physical access to sensitive/regulated data.

SP-CMM1 is N/A, since a structured process is required to explicitly define authorizations for specific individuals and/or roles for logical and /or physical access to sensitive/regulated data.

SP-CMM2 is N/A, since a well-defined process is required to explicitly define authorizations for specific individuals and/or roles for logical and /or physical access to sensitive/regulated data.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to explicitly define authorizations for specific individuals and/or roles for logical and /or physical access to sensitive/regulated data.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to explicitly define authorizations for specific individuals and/or roles for logical and /or physical access to sensitive/regulated data.

null

3.1.1.a 3.1.2 3.1.3 3.1.4.b 3.17.1.c

null

A.03.01.01.g.01 A.03.01.01.g.02 A.03.01.01.g.03

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

Data Classification & Handling

Data & Asset Classification

DCH-02

Mechanisms exist to ensure data and assets are categorized in accordance with applicable statutory, regulatory and contractual requirements.

null

E-DCH-01 E-DCH-02

Does the organization ensure data and assets are categorized in accordance with applicable statutory, regulatory and contractual requirements?

10

Identify

X

There is no evidence of a capability to ensure data and assets are categorized in accordance with applicable statutory, regulatory and contractual requirements.

SP-CMM1 is N/A, since a structured process is required to ensure data and assets are categorized in accordance with applicable statutory, regulatory and contractual requirements.

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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 data and assets are categorized in accordance with applicable statutory, regulatory and contractual requirements.

CC2.1 C1.1

CC6.1-POF1

null

3.1 3.7

3.1

3.1 3.7

null

Principle 13

DCS-05 DSP-04

DAT-01

null

8.2.1

5.9 5.12

8.2.1

null

6.5.2.1

null

OP-3.2

null

GOVERN 1.6

null

P-12

null

3.8.4

null

ID.AM-5

null

9.6.1

9.4.2

null

D.7

2.9 2.10

1.3.2 8.2.4

10.2

null

4.1.1 4.2.1 4.2.2 4.3

null

D1.G.IT.B.2

null

4.S.A 10.S.A

4.M.A 4.M.E

null

120.6 120.7 120.8 120.9 120.10 120.46

null

3.3.3(17) 3.3.3(18) 3.3.3(19) 3.5(54)

null

7.13 7.14 12.4

AM-02 AM-06 COS-08 PI-01

null

5.3 15.2

null

2-6-1-2

TPC-24

null

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

2-6-1-1

null

8.7.2 [MP.INFO.2]

null

A3.a B3.a

B3

null

Article 4

null

0294 0296 0323

null

20 21(a)

null

8.2.1

null

12.3.4.C.01 12.3.5.C.01 12.3.5.C.02 12.3.6.C.01 12.3.7.C.01 18.6.8.C.01

null

3.3.1(b)

null

6.8

null

x

Lockton

null

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-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

Data Classification & Handling

Highest Classification Level

DCH-02.1

Mechanisms exist to ensure that systems, applications and services are classified according to the highest level of data sensitivity that is stored, transmitted and/or processed.

null

Does the organization ensure that systems, applications and services are classified according to the highest level of data sensitivity that is stored, transmitted and/or processed?

8

Protect

X

There is no evidence of a capability to ensure that systems, applications and services are classified according to the highest level of data sensitivity that is stored, transmitted and/ or processed.

SP-CMM1 is N/A, since a structured process is required to ensure that systems, applications and services are classified according to the highest level of data sensitivity that is stored, transmitted and/ or processed.

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure that systems, applications and services are classified according to the highest level of data sensitivity that is stored, transmitted and/ or processed.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure that systems, applications and services are classified according to the highest level of data sensitivity that is stored, transmitted and/ or processed.

null

3.7 3.12

null

3.7 3.12

null

DSP-17

null

D.7

2.10

null

2.B.2

null

2-6-1-1

TPC-24

null

2-6-1-4

null

0323 0325

null

4.4.9.C.01 13.2.8.C.01 13.2.9.C.01 18.6.9.C.01

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-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

Data Classification & Handling

Media Access

DCH-03

Mechanisms exist to control and restrict access to digital and non-digital media to authorized individuals.

- Data Loss Prevention (DLP)

null

Does the organization control and restrict access to digital and non-digital media to authorized individuals?

8

Protect

null

X

There is no evidence of a capability to control and restrict access to digital and non-digital media to authorized individuals.

SP-CMM1 is N/A, since a structured process is required to control and restrict access to digital and non-digital media to authorized individuals.

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

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

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to control and restrict access to digital and non-digital media to authorized individuals.

C1.1

null

3.1 3.3

null

DSP-10 HRS-03

null

7.10

null

OP-3.2

null

MP-2

null

MP-2

null

MP-2

null

3.1.3 3.8.2

3.1.3[c] 3.8.2

A.03.08.02

null

D.3.1

2.11A

null

AM:SG1.SP1 KIM:SG2.SP1 KIM:SG2.SP2

null

AC.L2-3.1.3 MP.L2-3.8.2

MP.L2-3.8.2

null

AC.L2-3.1.3 MP.L2-3.8.2

MP-2

null

MP-2

§ 1232h

null

MP-2

null

8-310

10.2 10.5 10.6 10.7 10.8

null

MP-2

null

MP-2

null

TPC-39

null

B3.a B3.b B3.c

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-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-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

Data Classification & Handling

Disclosure of Information

DCH-03.1

Mechanisms exist to restrict the disclosure of sensitive / regulated data to authorized parties with a need to know.

null

Does the organization restrict the disclosure of sensitive / regulated data to authorized parties with a need to know?

10

Protect

null

X

There is no evidence of a capability to restrict the disclosure of sensitive / regulated data to authorized parties with a need to know.

SP-CMM1 is N/A, since a structured process is required to restrict the disclosure of sensitive / regulated data to authorized parties with a need to know.

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

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

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to restrict the disclosure of sensitive / regulated data to authorized parties with a need to know.

P6.0

P6.1-POF2 P6.1-POF3 P6.1-POF4 P6.4-POF1

null

3.1 3.3

null

DSP-18

null

RQ-05-09

null

3.1.22.a 3.17.1.c

null

D.3.1

2.4A 2.9 2.11A

null

4.2.3.3 5.1.3 5.1.4

null

252.204-7000

null

§ 1232h

null

2.A.4 2.C.11 2.C.11.1 2.C.11.2 2.C.11.3 2.C.11.4 2.C.11.5 2.C.11.6 2.C.11.7 2.C.11.8

120.10

null

10.5

null

2-6-1-3

TPC-39

null

2-6-1-4

null

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

R-AC-1

null

R-AC-4

R-AM-1

null

R-AM-3

null

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

null

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

Data Classification & Handling

Masking Displayed Data

DCH-03.2

Mechanisms exist to apply data masking to sensitive/regulated information that is displayed or printed.

null

Does the organization apply data masking to sensitive/regulated information that is displayed or printed?

7

Protect

null

X

There is no evidence of a capability to apply data masking to sensitive information that is displayed or printed.

SP-CMM1 is N/A, since a structured process is required to apply data masking to sensitive information that is displayed or printed.

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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 apply data masking to sensitive information that is displayed or printed.

null

8.11

null

3.3

3.4.1

null

3.4.1

null

P.7.7

null

4.M.B

null

Sec 10(a)(2) Sec 10(a)(4) Sec 30

null

Sec 4

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 R-EX-6 R-EX-7 R-GV-1 R-GV-4 R-GV-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

R-EX-6

R-EX-7

R-GV-1

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

Data Classification & Handling

Controlled Release

DCH-03.3

Automated mechanisms exist to validate cybersecurity & data privacy attributes prior to releasing information to external systems.

null

Does the organization use automated mechanisms to validate cybersecurity & data privacy attributes prior to releasing information to external systems?

4

Protect

null

There is no evidence of a capability to validate cybersecurity & data privacy attributes prior to releasing information to external systems.

SP-CMM1 is N/A, since a structured process is required to validate cybersecurity & data privacy attributes prior to releasing information to external systems.

SP-CMM2 is N/A, since a well-defined process is required to validate cybersecurity & data privacy attributes prior to releasing information to external systems.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to validate cybersecurity & data privacy attributes prior to releasing information to external systems.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to validate cybersecurity & data privacy attributes prior to releasing information to external systems.

null

AC-3(9)

null

AC-3(9)

null

AC-3(9)

null

AC-3(9)

null

C.8

null

AC-3(9)

null

AC-3(9)

null

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

R-AC-1

null

R-AM-3

null

R-BC-5

null

R-GV-1

null

R-GV-4

null

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

null

MT-8

MT-9

MT-10

null

MT-12

MT-13

MT-14

null

Data Classification & Handling

Media Marking

DCH-04

Mechanisms exist to mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements.

null

Does the organization mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements?

7

Protect

null

X

There is no evidence of a capability to mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements.

SP-CMM1 is N/A, since a structured process is required to mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements.

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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 mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements.

null

1.2.3

null

8.2.2

5.10 5.13

8.2.2

null

6.5.2.2

null

OP-3.2

null

MP-3

null

MP-3

null

MP-3

null

MP-3

null

3.8.4

3.8.4[a] 3.8.4[b]

A.03.08.04[01] A.03.08.04[02] A.03.08.04[03]

null

D.3.6

null

KIM:SG4.SP2 KIM:SG4.SP3

null

MP.L2-3.8.4

null

MP.L2-3.8.4

MP-3

null

MP-3

null

MP-3

null

MP-3

null

MP-3

null

4.M.B

MP-3

120.10

null

8-306 8-310

18.4 19.4

null

MP-3

null

MP-3

null

AM-06

null

15.2

null

8.5.1 [MP.SI.1]

null

0294 0296 0332

null

8.2.2 8.2.2.7.PB

null

4.4.10.C.01 12.3.4.C.01 12.3.5.C.01 12.3.5.C.02 12.3.6.C.01 12.3.7.C.01 13.2.12.C.01 13.2.12.C.02 13.2.12.C.03 13.2.12.C.04 13.2.13.C.01 13.2.14.C.01 13.2.14.C.02 21.1.21.C.01

null

x

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 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-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

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

Data Classification & Handling

Automated Marking

DCH-04.1

Automated mechanisms exist to mark physical media and digital files to indicate the distribution limitations, handling requirements and applicable security markings (if any) of the information to aid Data Loss Prevention (DLP) technologies.

null

Does the organization use automated mechanisms to mark physical media and digital files to indicate the distribution limitations, handling requirements and applicable security markings (if any) of the information to aid Data Loss Prevention (DLP) technologies?

2

Protect

null

X

There is no evidence of a capability to mark physical media and digital files to indicate the distribution limitations, handling requirements and applicable security markings (if any) of the information to aid Data Loss Prevention (DLP) technologies.

SP-CMM1 is N/A, since a structured process is required to mark physical media and digital files to indicate the distribution limitations, handling requirements and applicable security markings (if any) of the information to aid Data Loss Prevention (DLP) technologies.

SP-CMM2 is N/A, since a well-defined process is required to mark physical media and digital files to indicate the distribution limitations, handling requirements and applicable security markings (if any) of the information to aid Data Loss Prevention (DLP) technologies.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to mark physical media and digital files to indicate the distribution limitations, handling requirements and applicable security markings (if any) of the information to aid Data Loss Prevention (DLP) technologies.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to mark physical media and digital files to indicate the distribution limitations, handling requirements and applicable security markings (if any) of the information to aid Data Loss Prevention (DLP) technologies.

null

UEM-11

null

CT.DM-P7

null

MP-3

null

MP-3

null

MP-3

null

D.10.13

null

4.M.E

MP-3

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 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-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

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

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

Data Classification & Handling

Cybersecurity & Data Privacy Attributes

DCH-05

Mechanisms exist to bind cybersecurity & data privacy attributes to information as it is stored, transmitted and processed.

null

Does the organization bind cybersecurity & data privacy attributes to information as it is stored, transmitted and processed?

2

Protect

null

X

There is no evidence of a capability to bind security attributes to information as it is stored, transmitted and processed.

SP-CMM1 is N/A, since a structured process is required to bind security attributes to information as it is stored, transmitted and processed.

SP-CMM2 is N/A, since a well-defined process is required to bind security attributes to information as it is stored, transmitted and processed.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to bind security attributes to information as it is stored, transmitted and processed.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to bind security attributes to information as it is stored, transmitted and processed.

null

DAT-01

null

T1003, T1003.003, T1005, T1020.001, T1025, T1040, T1041, T1048, T1048.002, T1048.003, T1052, T1052.001, T1070, T1070.001, T1070.002, T1114, T1114.001, T1114.002, T1114.003, T1119, T1213, T1213.001, T1213.002, T1222, T1222.001, T1222.002, T1505, T1505.002, T1530, T1537, T1547.007, T1547.011, T1548, T1548.003, T1550.001, T1552, T1552.004, T1552.005, T1557, T1557.002, T1558, T1558.002, T1558.003, T1558.004, T1564.004, T1565, T1565.001, T1565.002, T1567, T1602, T1602.001, T1602.002

null

CT.DM-P7

null

AC-16

null

AC-16

null

AC-16

null

D.3.6

null

KIM:SG2.SP1 KIM:SG2.SP2

null

4.M.E

null

8-306

null

x

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 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-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

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

Data Classification & Handling

Dynamic Attribute Association

DCH-05.1

Mechanisms exist to dynamically associate cybersecurity & data privacy attributes with individuals and objects as information is created, combined, or transformed, in accordance with organization-defined cybersecurity and data privacy policies.

null

Does the organization dynamically associate cybersecurity & data privacy attributes with individuals and objects as information is created, combined, or transformed, in accordance with organization-defined cybersecurity and data privacy policies?

2

Protect

null

X

There is no evidence of a capability to dynamically associate cybersecurity & data privacy attributes with individuals and objects as information is created, combined, or transformed, in accordance with organization-defined cybersecurity & data privacy policies.

SP-CMM1 is N/A, since a structured process is required to dynamically associate cybersecurity & data privacy attributes with individuals and objects as information is created, combined, or transformed, in accordance with organization-defined cybersecurity & data privacy policies.

SP-CMM2 is N/A, since a well-defined process is required to dynamically associate cybersecurity & data privacy attributes with individuals and objects as information is created, combined, or transformed, in accordance with organization-defined cybersecurity & data privacy policies.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to dynamically associate cybersecurity & data privacy attributes with individuals and objects as information is created, combined, or transformed, in accordance with organization-defined cybersecurity & data privacy policies.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to dynamically associate cybersecurity & data privacy attributes with individuals and objects as information is created, combined, or transformed, in accordance with organization-defined cybersecurity & data privacy policies.

null

CT.DM-P7

null

AC-16(1)

null

AC-16(1)

null

D.7.1

null

4.M.E

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 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-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

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

Data Classification & Handling

Attribute Value Changes By Authorized Individuals

DCH-05.2

Mechanisms exist to provide authorized individuals (or processes acting on behalf of individuals) the capability to define or change the value of associated cybersecurity & data privacy attributes.

null

Does the organization provide authorized individuals (or processes acting on behalf of individuals) the capability to define or change the value of associated cybersecurity & data privacy attributes?

8

Protect

null

X

There is no evidence of a capability to provide authorized individuals ( or processes acting on behalf of individuals) the capability to define or change the value of associated cybersecurity & data privacy attributes.

SP-CMM1 is N/A, since a structured process is required to provide authorized individuals ( or processes acting on behalf of individuals) the capability to define or change the value of associated cybersecurity & data privacy attributes.

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

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

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide authorized individuals ( or processes acting on behalf of individuals) the capability to define or change the value of associated cybersecurity & data privacy attributes.

null

AC-16(2)

null

AC-16(2)

null

D.8.2

null

4.M.E

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 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-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

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

Data Classification & Handling

Maintenance of Attribute Associations By System

DCH-05.3

Mechanisms exist to maintain the association and integrity of cybersecurity & data privacy attributes to individuals and objects.

null

Does the organization maintain the association and integrity of cybersecurity & data privacy attributes to individuals and objects?

2

Protect

null

X

There is no evidence of a capability to maintain the association and integrity of cybersecurity & data privacy attributes to individuals and objects.

SP-CMM1 is N/A, since a structured process is required to maintain the association and integrity of cybersecurity & data privacy attributes to individuals and objects.

SP-CMM2 is N/A, since a well-defined process is required to maintain the association and integrity of cybersecurity & data privacy attributes to individuals and objects.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

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

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to maintain the association and integrity of cybersecurity & data privacy attributes to individuals and objects.

null

AC-16(3)

null

AC-16(3)

null

D.3

null

4.M.E

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 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-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

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

Data Classification & Handling

Association of Attributes By Authorized Individuals

DCH-05.4

Mechanisms exist to provide the capability to associate cybersecurity & data privacy attributes with individuals and objects by authorized individuals (or processes acting on behalf of individuals).

null

Does the organization provide the capability to associate cybersecurity & data privacy attributes with individuals and objects by authorized individuals (or processes acting on behalf of individuals)?

2

Protect

null

X

There is no evidence of a capability to provide the capability to associate cybersecurity & data privacy attributes with individuals and objects by authorized individuals ( or processes acting on behalf of individuals).

SP-CMM1 is N/A, since a structured process is required to provide the capability to associate cybersecurity & data privacy attributes with individuals and objects by authorized individuals ( or processes acting on behalf of individuals).

Data Classification & Handling (DCH) 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: • Data 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 data management. • Data protection controls are primarily administrative and preventative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists and is a manual process to govern. • Data/process owners: o Document where sensitive/regulated data is stored, transmitted and processed to identify data repositories and data flows. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data • A manual data retention process exists. • Content filtering blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Administrative means (e.g., policies and standards) dictate: o Geolocation requirements for sensitive/regulated data types, including the transfer of data to third-countries or international organizations. o Requirements for minimizing data collection to what is necessary for business purposes. o Requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

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

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide the capability to associate cybersecurity & data privacy attributes with individuals and objects by authorized individuals ( or processes acting on behalf of individuals).

null

AC-16(4)

null

AC-16(4)

null

D.8.2

null

4.M.E

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 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-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

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

Data Classification & Handling

Attribute Displays for Output Devices

DCH-05.5

Mechanisms exist to display cybersecurity & data privacy attributes in human-readable form on each object that the system transmits to output devices to identify special dissemination, handling or distribution instructions using human-readable, standard naming conventions.

null

Does the organization display cybersecurity & data privacy attributes in human-readable form on each object that the system transmits to output devices to identify special dissemination, handling or distribution instructions using human-readable, standard naming conventions?

8

Protect

null

X

There is no evidence of a capability to display cybersecurity & data privacy attributes in human-readable form on each object that the system transmits to output devices to identify special dissemination, handling or distribution instructions using human-readable, standard naming conventions.

SP-CMM1 is N/A, since a structured process is required to display cybersecurity & data privacy attributes in human-readable form on each object that the system transmits to output devices to identify special dissemination, handling or distribution instructions using human-readable, standard naming conventions.

SP-CMM2 is N/A, since a well-defined process is required to display cybersecurity & data privacy attributes in human-readable form on each object that the system transmits to output devices to identify special dissemination, handling or distribution instructions using human-readable, standard naming conventions.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

Data Classification & Handling (DCH) 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 display cybersecurity & data privacy attributes in human-readable form on each object that the system transmits to output devices to identify special dissemination, handling or distribution instructions using human-readable, standard naming conventions.

null

DSS05.06

null

AC-16(5)

null

AC-16(5)

null

D.3.6

null

4.M.E

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 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-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

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

Data Classification & Handling

Data Subject Attribute Associations

DCH-05.6

Mechanisms exist to require personnel to associate and maintain the association of cybersecurity & data privacy attributes with individuals and objects in accordance with cybersecurity and data privacy policies.

null

Does the organization require personnel to associate and maintain the association of cybersecurity & data privacy attributes with individuals and objects in accordance with cybersecurity and data privacy policies?

2

Protect

null

X

There is no evidence of a capability to require personnel to associate and maintain the association of cybersecurity & data privacy attributes with individuals and objects in accordance with cybersecurity & data privacy policies.

SP-CMM1 is N/A, since a structured process is required to require personnel to associate and maintain the association of cybersecurity & data privacy attributes with individuals and objects in accordance with cybersecurity & data privacy policies.

SP-CMM2 is N/A, since a well-defined process is required to require personnel to associate and maintain the association of cybersecurity & data privacy attributes with individuals and objects in accordance with cybersecurity & data privacy policies.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

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

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to require personnel to associate and maintain the association of cybersecurity & data privacy attributes with individuals and objects in accordance with cybersecurity & data privacy policies.

null

CT.DP-P1 CT.DP-P2 CT.DP-P3 CT.DP-P4 CT.DP-P5

null

AC-16(6)

null

AC-16(6)

null

D.3

null

4.M.E

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 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-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

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

Data Classification & Handling

Consistent Attribute Interpretation

DCH-05.7

Mechanisms exist to provide a consistent, organizationally agreed upon interpretation of cybersecurity & data privacy attributes employed in access enforcement and flow enforcement decisions between distributed system components.

null

Does the organization provide a consistent, organizationally agreed upon interpretation of cybersecurity & data privacy attributes employed in access enforcement and flow enforcement decisions between distributed system components?

2

Protect

null

X

There is no evidence of a capability to provide a consistent, organizationally agreed up on interpretation of cybersecurity & data privacy attributes employed in access enforcement and flow enforcement decisions between distributed system components.

SP-CMM1 is N/A, since a structured process is required to provide a consistent, organizationally agreed up on interpretation of cybersecurity & data privacy attributes employed in access enforcement and flow enforcement decisions between distributed system components.

SP-CMM2 is N/A, since a well-defined process is required to provide a consistent, organizationally agreed up on interpretation of cybersecurity & data privacy attributes employed in access enforcement and flow enforcement decisions between distributed system components.

Data Classification & Handling (DCH) 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, assists users in making information sharing decisions to ensure data is appropriately protected, regardless of where or how it is stored, processed and/ or transmitted. • A data classification process exists to identify categories of data and specific protection requirements. • A data retention process exists to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. • Data/process owners: o Are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. o Maintain decentralized inventory logs of all sensitive/regulated media and update sensitive/regulated media inventories at least annually. o Create and maintain Data Flow Diagrams (DFDs) and network diagrams. o Document where sensitive/regulated data is stored, transmitted and processed in order to document data repositories and data flows. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on internal or external systems, in order to implement cybersecurity & data privacy controls in accordance with applicable statutory, regulatory and contractual obligations. • Human Resources (HR), documents formal “rules of behavior” as an employment requirement that stipulates acceptable and unacceptable practices pertaining to sensitive/regulated data handling. • Data Loss Prevention (DLP), or similar content filtering capabilities, blocks users from performing ad hoc file transfers through unapproved file transfer services (e.g., Box, Dropbox, Google Drive, etc.). • Mobile Device Management (MDM) software is used to restrict and protect the data that resides on mobile devices. • Administrative processes and technologies: o Identify data classification types to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy. o Identify and document the location of information on which the information resides. o Restrict and govern the transfer of data to third-countries or international organizations. o Limit the disclosure of data to authorized parties. o Mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. o Prohibit “rogue instances” where unapproved third parties are engaged to store, process or transmit data, including budget reviews and firewall connection authorizations. o Protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. o Govern the use of personal devices (e.g., Bring Your Own Device (BYOD)) as part of acceptable and unacceptable behaviors. o Dictate requirements for minimizing data collection to what is necessary for business purposes. o Dictate requirements for limiting the use of sensitive/regulated data in testing, training and research.

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

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide a consistent, organizationally agreed up on interpretation of cybersecurity & data privacy attributes employed in access enforcement and flow enforcement decisions between distributed system components.

null

AC-16(7)

null

AC-16(7)

null

D.7.2

null

4.M.E

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 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-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

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