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

Data Classification & Handling

Identity Association Techniques & Technologies

DCH-05.8

Mechanisms exist to associate cybersecurity & data privacy attributes to information.

null

Does the organization associate cybersecurity & data privacy attributes to information?

2

Protect

null

X

There is no evidence of a capability to associate cybersecurity & data privacy attributes to information.

SP-CMM1 is N/A, since a structured process is required to associate cybersecurity & data privacy attributes to information.

SP-CMM2 is N/A, since a well-defined process is required to associate cybersecurity & data privacy attributes to information.

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 associate cybersecurity & data privacy attributes to information.

null

CT.DP-P1 CT.DP-P2 CT.DP-P3 CT.DP-P4 CT.DP-P5

null

AC-16(8)

null

AC-16(8)

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

Attribute Reassignment

DCH-05.9

Mechanisms exist to reclassify data as required, due to changing business/technical requirements.

null

Does the organization reclassify data as required, due to changing business/technical requirements?

7

Protect

null

X

There is no evidence of a capability to reclassify data as required, due to changing business/technical requirements.

SP-CMM1 is N/A, since a structured process is required to reclassify data as required, due to changing business/technical 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 reclassify data as required, due to changing business/technical requirements.

null

CT.DM-P7

null

AC-16(9)

null

AC-16(9)

null

D.7.1

null

4.M.E

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

Attribute Configuration By Authorized Individuals

DCH-05.10

Mechanisms exist to provide authorized individuals the capability to define or change the type and value of cybersecurity & data privacy attributes available for association with subjects and objects.

null

Does the organization provide authorized individuals the capability to define or change the type and value of cybersecurity & data privacy attributes available for association with subjects and objects?

8

Protect

null

X

There is no evidence of a capability to provide authorized individuals the capability to define or change the type and value of cybersecurity & data privacy attributes available for association with subjects and objects.

SP-CMM1 is N/A, since a structured process is required to provide authorized individuals the capability to define or change the type and value of cybersecurity & data privacy attributes available for association with subjects and objects.

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 provide authorized individuals the capability to define or change the type and value of cybersecurity & data privacy attributes available for association with subjects and objects.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide authorized individuals the capability to define or change the type and value of cybersecurity & data privacy attributes available for association with subjects and objects.

null

AC-16(10)

null

AC-16(10)

null

D.8.2

null

4.M.E

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

Audit Changes

DCH-05.11

Mechanisms exist to audit changes to cybersecurity & data privacy attributes and responds to events in accordance with incident response procedures.

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

null

Does the organization audit changes to cybersecurity & data privacy attributes and responds to events in accordance with incident response procedures?

7

Detect

null

X

There is no evidence of a capability to audit changes to cybersecurity & data privacy attributes and responds to events in accordance with incident response procedures.

SP-CMM1 is N/A, since a structured process is required to audit changes to cybersecurity & data privacy attributes and responds to events in accordance with incident response procedures.

SP-CMM2 is N/A, since a well-defined process is required to audit changes to cybersecurity & data privacy attributes and responds to events in accordance with incident response procedures.

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.

Data Classification & Handling (DCH) 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

C.5.3

null

4.M.E

null

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

null

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-1

null

R-IR-3

null

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Classification & Handling

Media Storage

DCH-06

Mechanisms exist to: ▪ Physically control and securely store digital and non-digital media within controlled areas using organization-defined security measures; and ▪ Protect system media until the media are destroyed or sanitized using approved equipment, techniques and procedures.

null

Does the organization: ▪ Physically control and securely store digital and non-digital media within controlled areas using organization-defined security measures; and ▪ Protect system media until the media are destroyed or sanitized using approved equipment, techniques and procedures?

8

Protect

X

There is no evidence of a capability: ▪ Physically control and securely store digital and non-digital media within controlled areas using organization-defined security measures; and ▪ Protect system media until the media are destroyed or sanitized using approved equipment, techniques and procedures.

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. • Media is securely stored until it is destroyed or sanitized using approved equipment, techniques and procedures. • A data retention process exists and is a manual process to govern.

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.

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

null

7.10

null

OP-1.3 OP-3.0 OP-3.2

null

MP-4

null

MP-4

null

MP-4

null

MP-4

null

MP-4

null

MP-4

null

3.8.1

null

A.03.08.01[01] A.03.08.01[02]

null

9.5 9.5.1 9.6 9.6.1 9.6.2 9.7

9.4 9.4.1 9.4.1.2

9.4.1

9.4.1 9.4.1.2

9.4.1

D.3.7

null

KIM:SG4.SP2 KIM:SG4.SP3

3.4

4.2.4 5.8.1

null

MP.L2-3.8.1

null

MP.L2-3.8.1

MP-4

null

MP-4

null

MP-4

null

MP-4

null

MP-4

null

MP-4

null

8-308

10.5 10.8

null

MP-4

null

17.03(2)(c)

null

622(2)(d)(C)(i) 620

null

MP-4

null

15.3

null

2-3-3-2

null

8.4.10.C.01 8.4.11.C.01 8.4.12.C.01 8.4.13.C.01 13.3.5.C.01

null

MA 201 CMR 17 OR 6464A

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-IR-1 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

null

R-IR-1

null

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

Physically Secure All Media

DCH-06.1

Mechanisms exist to physically secure all media that contains sensitive information.

- Lockbox

null

Does the organization physically secure all media that contains sensitive information?

9

Protect

null

X

null

There is no evidence of a capability to physically secure all media that contains sensitive information.

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. • Media is securely stored until it is destroyed or sanitized using approved equipment, techniques and procedures. • A data retention process exists and is a manual process to govern.

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 physically secure all media that contains sensitive information.

null

OP-1.3 OP-3.0 OP-3.2

null

3.8.1

null

9.5 9.5.1

9.4 9.4.1 9.4.1.2

9.4.1

9.4.1 9.4.1.2

9.4.1

F.10

null

5.8.1

null

2.B.1

null

10.8

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-IR-1 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

null

R-IR-1

null

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

Sensitive Data Inventories

DCH-06.2

Mechanisms exist to maintain inventory logs of all sensitive media and conduct sensitive media inventories at least annually.

null

E-AST-08

Does the organization maintain inventory logs of all sensitive media and conduct sensitive media inventories at least annually?

9

Detect

null

X

null

There is no evidence of a capability to maintain inventory logs of all sensitive media and conduct sensitive media inventories at least annually.

SP-CMM1 is N/A, since a structured process is required to maintain inventory logs of all sensitive media and conduct sensitive media inventories at least annually.

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 maintain inventory logs of all sensitive media and conduct sensitive media inventories at least annually.

null

C1.1-POF1

null

3.2

null

DSP-03 DSP-17 STA-07

null

OP-3.2

null

ID.IM-P3

null

3.4.11.a 3.4.11.b 3.4.11.c

null

ID.AM-07

null

9.7.1

9.4.1.2 9.4.5 9.4.5.1

null

9.4.1.2 9.4.5 9.4.5.1

null

D.1.1

null

2.A.2

null

B3.e

null

0336

null

3.1.4

null

x

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-IR-1 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

null

R-IR-1

null

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

Periodic Scans for Sensitive Data

DCH-06.3

Mechanisms exist to periodically scan unstructured data sources for sensitive/regulated data or data requiring special protection measures by statutory, regulatory or contractual obligations.

null

Does the organization periodically scan unstructured data sources for sensitive/regulated data or data requiring special protection measures by statutory, regulatory or contractual obligations?

7

Detect

null

X

There is no evidence of a capability to periodically scan unstructured data sources for sensitive/regulated data or data requiring special protection measures by statutory, regulatory or contractual obligations.

SP-CMM1 is N/A, since a structured process is required to periodically scan unstructured data sources for sensitive/regulated data or data requiring special protection measures by statutory, regulatory or contractual obligations.

SP-CMM2 is N/A, since a well-defined process is required to periodically scan unstructured data sources for sensitive/regulated data or data requiring special protection measures by statutory, regulatory or contractual obligations.

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 periodically scan unstructured data sources for sensitive/regulated data or data requiring special protection measures by statutory, regulatory or contractual obligations.

null

3.2

null

A3.2.5 A3.2.5.1

null

D.5.5

null

x

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-IR-1 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

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

Data Classification & Handling

Making Sensitive Data Unreadable In Storage

DCH-06.4

Mechanisms exist to ensure sensitive/regulated data is rendered human unreadable anywhere sensitive/regulated data is stored.

null

Does the organization ensure sensitive/regulated data is rendered human unreadable anywhere sensitive/regulated data is stored?

9

Protect

null

X

There is no evidence of a capability to ensure sensitive/regulated data is rendered human unreadable anywhere sensitive/regulated data is stored.

SP-CMM1 is N/A, since a structured process is required to ensure sensitive/regulated data is rendered human unreadable anywhere sensitive/regulated data is stored.

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 sensitive/regulated data is rendered human unreadable anywhere sensitive/regulated data is stored.

null

DSP-17

null

3.4 3.4.1

9.4

null

D.6

null

4.2.4

null

8.4.13.C.01

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-IR-1 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

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

Data Classification & Handling

Storing Authentication Data

DCH-06.5

Mechanisms exist to prohibit the storage of sensitive transaction authentication data after authorization.

null

Does the organization prohibit the storage of sensitive transaction authentication data after authorization?

5

Protect

null

X

There is no evidence of a capability to prohibit the storage of sensitive transaction authentication data after authorization.

SP-CMM1 is N/A, since a structured process is required to prohibit the storage of sensitive transaction authentication data after authorization.

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 prohibit the storage of sensitive transaction authentication data after authorization.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to prohibit the storage of sensitive transaction authentication data after authorization.

null

3.2 3.2.1 3.2.2 3.2.3

3.3.1 3.3.1.1 3.3.1.2 3.3.1.3 3.3.3

null

3.3.1 3.3.1.2 3.3.1.3

3.3.1 3.3.1.1 3.3.1.2 3.3.1.3

3.3.1 3.3.1.2 3.3.1.3

3.3.1 3.3.1.2

3.3.1 3.3.1.1 3.3.1.2 3.3.1.3

3.3.1 3.3.1.1 3.3.1.2 3.3.1.3 3.3.3

3.1.1 3.3.1.2

H.3.20

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-IR-1 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

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

Data Classification & Handling

Media Transportation

DCH-07

Mechanisms exist to protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures.

- Assigned couriers

null

Does the organization protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures?

9

Protect

X

null

There is no evidence of a capability to protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures.

SP-CMM1 is N/A, since a structured process is required to protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures.

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 protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures.

null

8.2.6

null

8.3.3

5.14 7.10

8.3.3

null

OP-1.1 OP-1.2 OP-1.3

null

MP-5

null

MP-5

null

MP-5

null

MP-5

null

MP-5

null

MP-5

null

3.8.5

3.8.5.a 3.8.5.b

3.8.5[a] 3.8.5[b]

A.03.08.05.a[01] A.03.08.05.a[02] A.03.08.05.b A.03.08.05.c

null

9.6 9.6.2 9.6.3 9.7

9.4.3

null

D.9.3

null

8.3.1

null

KIM:SG4.SP2 KIM:SG4.SP3

null

5.8.2 5.8.2.1

null

MP.L2-3.8.5

null

MP.L2-3.8.5

MP-5

null

MP-5

null

MP-5

null

MP-5

null

MP-5

null

2.B.4 2.B.4.1 MP-5

null

8-605

10.7 10.8

null

MP-5

null

17.03(2)(c)

null

620

null

MP-5

null

15.7

null

2-6-1-4

null

8.5.4 [MP.SI.4]

null

B3.b

null

8.3.3

null

x

MA 201 CMR 17 OR 6464A

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

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

null

R-IR-1

null

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

Custodians

DCH-07.1

Mechanisms exist to identify custodians throughout the transport of digital or non-digital media.

- Chain of custody

null

Does the organization identify custodians throughout the transport of digital or non-digital media?

9

Protect

null

X

null

There is no evidence of a capability to identify custodians throughout the transport of digital or non-digital media.

SP-CMM1 is N/A, since a structured process is required to identify custodians throughout the transport of digital or non-digital 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.

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 identify custodians throughout the transport of digital or non-digital media.

null

8.2.3

5.10 5.14

8.2.3

null

6.5.2.3

null

OP-1.1 OP-1.2 OP-1.3

null

MP-5(3)

null

MP-5(3)

null

MP-5(3)

null

3.4.11.b 3.8.5.b

null

9.4.3

null

D.9.3

null

8.3.1

null

5.8.2.2

null

2.B.4 2.B.4.1 MP-5(3)

null

10.8

null

15.7

null

2-6-1-4

null

8.5.3 [MP.SI.3]

null

B3.b

null

8.2.3

null

x

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

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

null

R-IR-1

null

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

Encrypting Data In Storage Media

DCH-07.2

Cryptographic mechanisms exist to protect the confidentiality and integrity of information stored on digital media during transport outside of controlled areas.

null

Are cryptographic mechanisms utilized to protect the confidentiality and integrity of information stored on digital media during transport outside of controlled areas?

5

Protect

null

X

There is no evidence of a capability to Cryptographic protect the confidentiality and integrity of information stored on digital media during transport outside of controlled areas.

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 Cryptographic protect the confidentiality and integrity of information stored on digital media during transport outside of controlled areas.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to Cryptographic protect the confidentiality and integrity of information stored on digital media during transport outside of controlled areas.

null

CR 4.1 (8.3.1(a))

null

7.10

null

MP-5(4)

null

MP-5(4)

SC-28(1)

null

SC-28(1)

null

SC-28(1)

null

3.8.5.a

null

D.5.2

null

4.2.4 5.8.2.1

null

MP-5(4)

null

MP-5(4)

null

MP-5(4)

null

SC-28(1)

null

10.8 18.3

null

MP-5(4)

null

MP-5(4)

null

B3.b

null

8.4.13.C.01

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-IR-1 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

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

Data Classification & Handling

Physical Media Disposal

DCH-08

Mechanisms exist to securely dispose of media when it is no longer required, using formal procedures.

- Shred-it - IronMountain - DoD-strength data erasers

E-AST-03

Does the organization securely dispose of media when it is no longer required, using formal procedures?

10

Protect

null

X

There is no evidence of a capability to securely dispose of media when it is no longer required, using formal procedures.

SP-CMM1 is N/A, since a structured process is required to securely dispose of media when it is no longer required, using formal procedures.

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. • Devices are escrowed in storage for a period of time before being wiped and reissued, in case data on the devices are needed for investigations or business purposes.

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 securely dispose of media when it is no longer required, using formal procedures.

CC6.5

CC6.5-POF2 C1.2-POF2 P4.3-POF2 P4.3-POF3

null

3.1 3.5

null

DSP-02

POL-04

null

8.3.2

7.10 8.10

8.3.2

null

6.5.3.2 7.4.8

null

OP-3.3

Sec 4(D)(2)(k)

null

CT.DM-P5

null

MP-6

null

MP-6

3.4.14

MP-6

null

MP-6

null

3.8.3

null

PR.IP-6

null

9.4.6

9.4.1

D.4.3

null

ASSET-2.H.MIL3

KIM:SG4.SP3

null

5.8.4

null

MP.L1-b.1.vii

null

MP-6

null

52.204-21(b)(1)(vii)

null

MP-6

null

D1.G.IT.B.19

null

314.4(c)(6)(i)

null

5.S.C

4.M.C 5.M.D

4.M.C 5.M.D 9.L.C

2.D.7 2.F.1 2.F.3 MP-6

null

8-301 8-608

10.3 10.4 18.5 19.5

null

MP-6

null

45.48.500 45.48.510

null

Sec 40(b)(1)

null

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

Sec. 521.052(b)

null

MP-6

null

Art 24

null

PI-03

null

15.4

null

3.3.11

null

2-6-1-3

null

8.5.5 [MP.SI.5]

null

Chapter29-Schedule1-Part1-Principle 5

null

1550 0311 1217 0315 1218 0312 0363 1361 1160 1517 0368 0840 0839 0374 0375 0378

null

8.3.2

null

11.7.35.C.01 12.6.6.C.01 12.6.6.C.02 12.6.7.C.01 12.6.7.C.02 13.5.23.C.01 13.5.24.C.01 13.5.24.C.02 13.5.24.C.03 13.5.24.C.04 13.5.25.C.01 13.5.26.C.01 13.5.26.C.02 13.5.26.C.03 13.5.29.C.01 13.5.29.C.02 13.5.30.C.01

null

11.1.7

null

x

FAR 52.204-21 NAIC

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-IR-1 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

null

R-IR-1

null

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

System Media Sanitization

DCH-09

Mechanisms exist to sanitize system media with the strength and integrity commensurate with the classification or sensitivity of the information prior to disposal, release out of organizational control or release for reuse.

null

E-AST-03 E-DCH-07

Does the organization sanitize system media with the strength and integrity commensurate with the classification or sensitivity of the information prior to disposal, release out of organizational control or release for reuse?

10

Protect

null

X

There is no evidence of a capability to sanitize system media with the strength and integrity commensurate with the classification or sensitivity of the information prior to disposal, release out of organizational control or release for reuse.

SP-CMM1 is N/A, since a structured process is required to sanitize system media with the strength and integrity commensurate with the classification or sensitivity of the information prior to disposal, release out of organizational control or release for reuse.

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-system 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. • An ITAM function, or similar function, ensures sanitization equipment and procedures are tested to verify that the intended result is achieved.

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 sanitize system media with the strength and integrity commensurate with the classification or sensitivity of the information prior to disposal, release out of organizational control or release for reuse.

CC6.5

CC6.5-POF2 C1.2-POF2

null

3.1 3.5

APO14.07

null

CR 4.2 (8.4.3(1)) CR 4.2 (8.4.3(2))

null

8.10

null

7.4.8

null

Sec 4(D)(2)(k)

null

MP-6 MP-6(3)

MP-6

MP-6 MP-6(3)

MP-6

MP-6 MP-6(3)

null

MP-6

MP-6 MP-6(3)

null

MP-6

null

MP-6

3.7.3 3.8.3

3.7.4.d 3.7.4.d.2 3.8.3

3.7.3 3.8.3[a] 3.8.3[b]

A.03.08.03

null

PR.IP-6

null

9.8 9.8.1 9.8.2

9.4.7

null

9.4.7

null

D.4.3.2

null

ASSET-2.H.MIL3

KIM:SG4.SP3

null

5.8.3

MP.L1-3.8.3

MA.L2-3.7.3 MP.L1-3.8.3

MP.L1-b.1.vii

MA.L2-3.7.3 MA.L2-3.8.3

MP-6

null

52.204-21(b)(1)(vii)

null

MP-6

null

4.M.C 5.M.D

2.D.7 2.F.1 2.F.3 2.F.3.1 MP-6

null

CIP-011-2 R2

8-301 8-608

null

5.8

MP-6

null

45.48.500 45.48.510

null

Sec 40(b)(2)

null

622(2)(d)(C)(i) 622(2)(d)(C)(iv)

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

null

MP-6

null

15.4

null

TPC-19 TPC-66

null

2-6-1-3

null

8.7.6 [MP.INFO.6]

null

B3.e

null

0313 1600 0947 0348 0351 0352 0835 1065 0354 1067 0356 0357 0836 0358 0359 0360 0361 0362 1735

null

13.4.9.C.01 13.4.11.C.01 13.4.12.C.01 13.4.13.C.01 13.4.13.C.02 13.4.13.C.03 13.4.13.C.04 13.4.13.C.05 13.4.14.C.01 13.4.15.C.01 12.6.5.C.05 13.4.19.C.02 13.4.16.C.01 13.4.17.C.01 13.4.18.C.01 13.4.19.C.01 13.4.20.C.01 13.4.20.C.02 13.4.20.C.03 13.4.21.C.01 13.4.22.C.01

null

11.1.7

null

6.17

null

FAR 52.204-21 NAIC OR 6464A

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-IR-1 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

null

R-IR-1

null

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

- renamed control - wordsmithed control

Data Classification & Handling

System Media Sanitization Documentation

DCH-09.1

Mechanisms exist to supervise, track, document and verify system media sanitization and disposal actions.

- Certificate of destruction

E-AST-03 E-DCH-07

Does the organization supervise, track, document and verify system media sanitization and disposal actions?

7

Protect

null

X

null

There is no evidence of a capability to supervise, track, document and verify system media sanitization and disposal actions.

SP-CMM1 is N/A, since a structured process is required to supervise, track, document and verify system media sanitization and disposal actions.

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 supervise, track, document and verify system media sanitization and disposal actions.

null

APO14.07

null

8.10

null

7.4.8

null

MP-6(1)

null

MP-6(1)

null

MP-6(1)

null

MP-6(1)

null

9.7.1

9.4.7

null

9.4.7

null

D.4.3.4

null

5.8.3

null

MP-6(1)

null

MP-6(1)

null

MP-6(1)

null

MP-6(1)

null

MP-6(1)

null

MP-6(1)

null

5.8

null

MP-6(1)

null

15.8

null

0316 0363 0370 0371 0372 0373

null

13.5.22.C.01 13.5.27.C.01 13.5.27.C.02 13.5.27.C.03 13.5.28.C.01 13.5.28.C.02

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-IR-1 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

null

R-IR-1

null

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

- renamed control - wordsmithed control

Data Classification & Handling

Equipment Testing

DCH-09.2

Mechanisms exist to test sanitization equipment and procedures to verify that the intended result is achieved.

null

Does the organization test sanitization equipment and procedures to verify that the intended result is achieved?

5

Detect

null

X

There is no evidence of a capability to test sanitization equipment and procedures to verify that the intended result is achieved.

SP-CMM1 is N/A, since a structured process is required to test sanitization equipment and procedures to verify that the intended result is achieved.

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 test sanitization equipment and procedures to verify that the intended result is achieved.

null

7.4.8

null

MP-6(2)

null

MP-6(2)

null

MP-6(2)

null

MP-6(2)

null

P.7.2

null

MP-6(2)

null

MP-6(2)

null

MP-6(2)

null

MP-6(2)

null

MP-6(2)

null

MP-6(2)

null

15.8

null

13.4.23.C.01

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-IR-1 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

null

R-IR-1

null

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

Sanitization of Personal Data (PD)

DCH-09.3

Mechanisms exist to facilitate the sanitization of Personal Data (PD).

- De-identifying PI

null

Does the organization facilitate the sanitization of Personal Data (PD)?

9

Protect

null

X

There is no evidence of a capability to facilitate the sanitization of Personal Data (PD).

SP-CMM1 is N/A, since a structured process is required to facilitate the sanitization of Personal Data (PD).

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 facilitate the sanitization of Personal Data (PD).

P4.3

null

APO14.07

null

8.10

null

7.4.8

null

CT.DM-P5

null

MP-6 MP-6(3)

MP-6

MP-6 MP-6(3)

null

MP-6

MP-6 MP-6(3)

null

MP-6

null

MP-6

null

P.7.7

null

ASSET-2.H.MIL3

null

2.D.7 2.F.1 2.F.3 2.F.3.1 MP-6

null

5.5 5.9

null

45.48.500

null

MP-6

null

Art 5.1

null

Art 24

null

15.4

null

Sec 16.1

null

Art 4.7 Art 16.7 Art 25.2

null

Art 16

null

x

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-IR-1 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

null

R-IR-1

null

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

First Time Use Sanitization

DCH-09.4

Mechanisms exist to apply nondestructive sanitization techniques to portable storage devices prior to first use.

null

Does the organization apply nondestructive sanitization techniques to portable storage devices prior to first use?

5

Protect

null

X

There is no evidence of a capability to apply nondestructive sanitization techniques to portable storage devices prior to first use.

SP-CMM1 is N/A, since a structured process is required to apply nondestructive sanitization techniques to portable storage devices prior to first use.

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 apply nondestructive sanitization techniques to portable storage devices prior to first use.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to apply nondestructive sanitization techniques to portable storage devices prior to first use.

null

APO14.07

null

7.4.8

null

MP-6(3)

null

MP-6(3)

null

MP-6(3)

null

MP-6(3)

null

L.23.4

null

MP-6(3)

null

MP-6(3)

null

MP-6(3)

null

MP-6(3)

null

1600 1642

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-IR-1 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

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

Data Classification & Handling

Dual Authorization for Sensitive Data Destruction

DCH-09.5

Mechanisms exist to enforce dual authorization for the destruction, disposal or sanitization of digital media that contains sensitive / regulated data.

null

Does the organization enforce dual authorization for the destruction, disposal or sanitization of digital media that contains sensitive / regulated data?

5

Protect

null

X

There is no evidence of a capability to enforce dual authorization for the destruction, disposal or sanitization of digital media that contains sensitive / regulated data.

SP-CMM1 is N/A, since a structured process is required to enforce dual authorization for the destruction, disposal or sanitization of digital media that contains sensitive / regulated data.

SP-CMM2 is N/A, since a well-defined process is required to enforce dual authorization for the destruction, disposal or sanitization of digital media that contains 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.

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 enforce dual authorization for the destruction, disposal or sanitization of digital media that contains sensitive / regulated data.

null

MP-6(7)

null

MP-6(7)

null

MP-6(7)

null

3.1.1e

null

D.4.3.2

null

TBD - 3.1.1e

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-IR-1 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

null

R-IR-1

null

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

Media Use

DCH-10

Mechanisms exist to restrict the use of types of digital media on systems or system components.

null

Does the organization restrict the use of types of digital media on systems or system components?

8

Protect

null

X

null

There is no evidence of a capability to restrict the use of types of digital media on systems or system components.

SP-CMM1 is N/A, since a structured process is required to restrict the use of types of digital media on systems or system components.

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 use of types of digital media on systems or system components.

CC6.7

null

8.3.1

7.10

8.3.1

null

6.5.3.1

null

T1025, T1052, T1052.001, T1091, T1092, T1200

null

MP-7 SC-8(2)

MP-7

MP-7 SC-8(2)

null

MP-7

SC-8(2)

null

MP-7

null

3.8.7

3.8.7.a 3.8.7.b

3.8.7

A.03.08.07.a A.03.08.07.ODP[01]

null

D.3

null

KIM:SG2.SP2 TM:SG2.SP2

null

MP.L2-3.8.7

null

MP.L2-3.8.7

MP-7 SC-8(2)

null

MP-7 MP-7(1)

MP-7

MP-7 MP-7(1)

MP-7

null

MP-7

null

8-306 8-310

null

MP-7

null

2-3-3-2

null

0341 0343

null

8.3.1

null

13.3.4.C.01

null

x

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-IR-1 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

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

Data Classification & Handling

Limitations on Use

DCH-10.1

Mechanisms exist to restrict the use and distribution of sensitive / regulated data.

null

Does the organization restrict the use and distribution of sensitive / regulated data?

10

Protect

null

X

null

There is no evidence of a capability to restrict the use and distribution of sensitive / regulated data.

SP-CMM1 is N/A, since a structured process is required to restrict the use and distribution 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: • 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. • Administrative processes and technologies: o Collect Personal data (PD) directly from the individual. o Correct Personal data (PD) that is inaccurate or outdated, incorrectly determined regarding impact, or incorrectly de-identified. o De-identify the dataset up on collection by not collecting Personal data (PD). o Govern how data is reclassified due to changing business/technical requirements to ensure the integrity of data classification is upheld through the data lifecycle. o Limit Personal data (PD) being processed in the information lifecycle to elements identified in the Data Protection Impact Assessment (DPIA). o Refrain from archiving Personal data (PD) elements if those elements in a dataset will not be needed after the dataset is archived. o Remove Personal data (PD) elements from a dataset prior to its release if those elements in the dataset do not need to be part of the data release. o Remove Personal data (PD) from datasets. o Limit Personal data (PD) being processed in the information lifecycle to elements identified in the DPIA. o Identify custodians throughout the transport of system media. o Minimize the use of Personal data (PD) for research, testing or training, in accordance with the DPIA. o Minimize the use of Personal data (PD) for research, testing, or training, in accordance with the Data Protection Impact Assessment (DPIA). o Perform a motivated intruder test on the de-identified dataset to determine if the identified data remains or if the de-identified data can be re-identified.

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.

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

null

7.10

null

7.4.2

null

3.1.5.a 3.1.5.b 3.8.4

null

A.03.01.02

null

D.3.1

null

252.204-7009

null

0341 0343

null

13.3.4.C.01

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-IR-1 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

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

Data Classification & Handling

Prohibit Use Without Owner

DCH-10.2

Mechanisms exist to prohibit the use of portable storage devices in organizational information systems when such devices have no identifiable owner.

null

Does the organization prohibit the use of portable storage devices in organizational information systems when such devices have no identifiable owner?

5

Protect

null

X

There is no evidence of a capability to prohibit the use of portable storage devices in organizational information systems when such devices have no identifiable owner.

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: • 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 prohibit the use of portable storage devices in organizational information systems when such devices have no identifiable owner.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to prohibit the use of portable storage devices in organizational information systems when such devices have no identifiable owner.

null

MP-7(1)

null

MP-7

null

MP-7

null

MP-7

null

3.8.8

3.8.7.b

3.8.8

A.03.08.07.b

null

D.3.5

null

MP.L2-3.8.8

null

MP.L2-3.8.8

MP-7(1)

null

MP-7

null

MP-7

null

MP-7(1)

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-IR-1 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

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

Data Classification & Handling

Data Reclassification

DCH-11

Mechanisms exist to reclassify data, including associated systems, applications and services, commensurate with the security category and/or classification level of the information.

null

Does the organization reclassify data, including associated systems, applications and services, commensurate with the security category and/or classification level of the information?

8

Protect

null

X

There is no evidence of a capability to reclassify data, including associated systems, applications and services, commensurate with the security category and/ or classification level of the information.

SP-CMM1 is N/A, since a structured process is required to reclassify data, including associated systems, applications and services, commensurate with the security category and/ or classification level of the information.

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.

Data Classification & Handling (DCH) 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

MP-8

null

MP-8 MP-8(3)

null

MP-8 MP-8(3)

null

D.7.1

null

KIM:SG4.SP3

null

8-310

null

0330

null

13.2.10.C.01 13.2.11.C.01

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-IR-1 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

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

Data Classification & Handling

Removable Media Security

DCH-12

Mechanisms exist to restrict removable media in accordance with data handling and acceptable usage parameters.

null

Does the organization restrict removable media in accordance with data handling and acceptable usage parameters?

10

Protect

X

There is no evidence of a capability to restrict removable media in accordance with data handling and acceptable usage parameters.

SP-CMM1 is N/A, since a structured process is required to restrict removable media in accordance with data handling and acceptable usage parameters.

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 removable media in accordance with data handling and acceptable usage parameters.

CC6.7

CC6.7-POF3

null

8.3.1

7.10

8.3.1

null

6.5.3.1

null

PR.PT-P1

null

3.8.7.b

null

PR.PT-2

null

D.3.5

null

ARCHITECTURE-5.G.MIL3

null

2.4

null

D1.G.SP.B.4 D3.PC.De.B.1 D3.PC.Im.E.3

null

CIP-010-2 R4

null

12.24

null

2-3-3-2

null

1359 1713

null

8.3.1

null

13.3.6.C.01 13.3.6.C.02 13.3.6.C.03 13.3.10.C.01

null

x

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-IR-1 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

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

Data Classification & Handling

Use of External Information Systems

DCH-13

Mechanisms exist to govern how external parties, systems and services are used to securely store, process and transmit data.

null

Does the organization govern how external parties, systems and services are used to securely store, process and transmit data?

9

Protect

X

There is no evidence of a capability to govern how external parties, systems and services are used to securely store, process and transmit data.

SP-CMM1 is N/A, since a structured process is required to govern how external parties, systems and services are used to securely store, process and transmit 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: • 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.

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

CC6.7

null

T1020.001, T1021, T1021.001, T1021.004, T1041, T1048, T1048.002, T1048.003, T1052, T1052.001, T1072, T1078.002, T1078.004, T1098.001, T1098.002, T1098.003, T1110, T1110.001, T1110.002, T1110.003, T1110.004, T1114, T1114.001, T1114.002, T1114.003, T1119, T1133, T1134.005, T1136, T1136.001, T1136.002, T1136.003, T1200, T1530, T1537, T1539, T1550.001, T1552, T1552.004, T1552.005, T1556, T1556.001, T1556.003, T1556.004, T1557, T1557.002, T1565, T1565.001, T1565.002, T1567, T1567.001, T1567.002, T1602, T1602.001, T1602.002

null

AC-20

null

AC-20

null

AC-20

null

AC-20

3.1.20

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

3.1.20[a] 3.1.20[b] 3.1.20[c] 3.1.20[d] 3.1.20[e] 3.1.20[f]

A.03.01.20.a A.03.01.20.b[01] A.03.01.20.b[02] A.03.01.20.c.01 A.03.01.20.c.02 A.03.01.20.ODP[01] A.03.01.20.ODP[02]

null

ID.AM-4

null

P.9.2

null

5.3.4

null

EXD:SG3.SP1

null

AC.L1-3.1.20

AC.L1-b.1.iii

AC.L2-3.1.20

AC-20

null

52.204-21(b)(1)(iii)

null

AC-20

null

AC-20

null

8-700

null

6.4

null

AC-20

null

AC-20

null

11.6

null

4-2-3-1

null

x

FAR 52.204-21

null

x

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-IR-1 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

null

R-IR-1

null

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

Limits of Authorized Use

DCH-13.1

Mechanisms exist to prohibit external parties, systems and services from storing, processing and transmitting data unless authorized individuals first: ▪ Verifying the implementation of required security controls; or ▪ Retaining a processing agreement with the entity hosting the external systems or service.

null

Does the organization prohibit external parties, systems and services from storing, processing and transmitting data unless authorized individuals first: ▪ Verifying the implementation of required security controls; or ▪ Retaining a processing agreement with the entity hosting the external systems or service?

8

Protect

null

X

There is no evidence of a capability to prohibit external parties, systems and services from storing, processing and transmitting data unless authorized individuals first: ▪ Verifying the implementation of required security controls; or ▪ Retaining a processing agreement with the entity hosting the external systems or service.

SP-CMM1 is N/A, since a structured process is required to prohibit external parties, systems and services from storing, processing and transmitting data unless authorized individuals first: ▪ Verifying the implementation of required security controls; or ▪ Retaining a processing agreement with the entity hosting the external systems or service.

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 prohibit external parties, systems and services from storing, processing and transmitting data unless authorized individuals first: ▪ Verifying the implementation of required security controls; or ▪ Retaining a processing agreement with the entity hosting the external systems or service.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to prohibit external parties, systems and services from storing, processing and transmitting data unless authorized individuals first: ▪ Verifying the implementation of required security controls; or ▪ Retaining a processing agreement with the entity hosting the external systems or service.

null

3.3

null

AC-20(1)

null

AC-20(1)

null

AC-20(1)

null

AC-20(1)

null

AC-20(1)

null

AC-20(1)

3.1.20

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

null

P.9.2

null

AC.L1-3.1.20

null

AC.L1-b.1.iii

AC.L2-3.1.20

AC-20(1)

null

52.204-21(b)(1)(iii)

null

AC-20(1)

null

AC-20(1)

null

AC-20(1)

null

AC-20(1)

null

AC-20(1)

null

AC-20(1)

null

Article 5.1

null

FAR 52.204-21

null

x

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-IR-1 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

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

Data Classification & Handling

Portable Storage Devices

DCH-13.2

Mechanisms exist to restrict or prohibit the use of portable storage devices by users on external systems.

null

Does the organization restrict or prohibit the use of portable storage devices by users on external systems?

9

Protect

null

X

There is no evidence of a capability to restrict or prohibit the use of portable storage devices by users on external systems.

SP-CMM1 is N/A, since a structured process is required to restrict or prohibit the use of portable storage devices by users on external systems.

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 restrict or prohibit the use of portable storage devices by users on external systems.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to restrict or prohibit the use of portable storage devices by users on external systems.

CC6.7

null

AC-20(2) AC-20(5)

null

AC-20(2)

AC-20(2) AC-20(5)

null

AC-20(2)

null

AC-20(2)

null

3.1.21

3.1.20.a 3.1.20.c 3.1.20.c.1 3.1.20.c.2 3.1.20.d 3.8.7.b

3.1.21[a] 3.1.21[b] 3.1.21[c]

A.03.01.20.d

null

M.1.28

null

2.4

4.2.4

null

AC.L2-3.1.21

AC.L1-b.1.iii

AC.L2-3.1.21

AC-20(2)

null

52.204-21(b)(1)(iii)

null

AC-20(2)

null

AC-20(2)

null

AC-20(2)

null

AC-20(2)

null

AC-20(2) AC-20(5)

null

10.7

null

AC-20(2)

null

AC-20(2)

null

5-1-3-5

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

null

13.3.7.C.01 13.3.7.C.02 13.3.8.C.01 13.3.8.C.02 13.3.9.C.01 13.3.9.C.02 13.3.10.C.01

null

FAR 52.204-21

null

x

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-IR-1 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

null

R-IR-1

null

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

Protecting Sensitive Data on External Systems

DCH-13.3

Mechanisms exist to ensure that the requirements for the protection of sensitive information processed, stored or transmitted on external systems, are implemented in accordance with applicable statutory, regulatory and contractual obligations.

- NIST 800-171 Compliance Criteria (NCC) (ComplianceForge)

null

Does the organization ensure that the requirements for the protection of sensitive information processed, stored or transmitted on external systems, are implemented in accordance with applicable statutory, regulatory and contractual obligations?

10

Protect

X

There is no evidence of a capability to ensure that the requirements for the protection of sensitive information processed, stored or transmitted on external systems, are implemented in accordance with applicable statutory, regulatory and contractual obligations.

SP-CMM1 is N/A, since a structured process is required to ensure that the requirements for the protection of sensitive information processed, stored or transmitted on external systems, are implemented in accordance with applicable statutory, regulatory and contractual obligations.

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 the requirements for the protection of sensitive information processed, stored or transmitted on external systems, are implemented in accordance with applicable statutory, regulatory and contractual obligations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure that the requirements for the protection of sensitive information processed, stored or transmitted on external systems, are implemented in accordance with applicable statutory, regulatory and contractual obligations.

null

DSP-17

null

PM-17

null

PM-17

null

PM-17

null

P.7.5

null

AC.L1-b.1.iii

null

52.204-21(b)(1)(iii)

null

6.4

null

6-1-1308(7)

null

11.6

null

FAR 52.204-21

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-IR-1 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

null

R-IR-1

null

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

Non-Organizationally Owned Systems / Components / Devices

DCH-13.4

Mechanisms exist to restrict the use of non-organizationally owned information systems, system components or devices to process, store or transmit organizational information.

null

Does the organization restrict the use of non-organizationally owned information systems, system components or devices to process, store or transmit organizational information?

5

Protect

null

X

There is no evidence of a capability to restrict the use of non-organizationally owned information systems, system components or devices to process, store or transmit organizational information.

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: • 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 use of non-organizationally owned information systems, system components or devices to process, store or transmit organizational information.

null

AC-20(3)

null

AC-20(3)

null

AC-20(3)

null

AC-20(3)

null

AC-20(3)

null

3.1.20.a 3.1.20.c 3.1.20.c.1 3.1.20.c.2 3.1.20.d

null

3.1.2e

null

M.1.16

null

TBD - 3.1.2e

null

AC.L3-3.1.2e

null

AC-20(3)

null

x

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-IR-1 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

null

R-IR-1

null

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

Information Sharing

DCH-14

Mechanisms exist to utilize a process to assist users in making information sharing decisions to ensure data is appropriately protected.

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

null

Does the organization utilize a process to assist users in making information sharing decisions to ensure data is appropriately protected?

9

Protect

X

null

There is no evidence of a capability to utilize a process to assist users in making information sharing decisions to ensure data is appropriately protected.

SP-CMM1 is N/A, since a structured process is required to utilize a process to assist users in making information sharing decisions to ensure data is appropriately protected.

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.

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

CC6.7

null

3.3

null

DSP-10

null

RQ-05-09

null

13.2 13.2.1 13.2.2

5.14

13.2 13.2.1 13.2.2

null

6.10.2 6.10.2.1 6.10.2.2 7.4.9 8.4.3

null

T1213, T1213.001, T1213.002

null

AC-21

null

AC-21

null

AC-21

null

AC-21

null

AC-21

null

AC-21

null

P.9.1

2.1 2.11A

null

KIM:SG2.SP1 KIM:SG2.SP2

null

5.1 5.1.1 5.1.1.2 5.1.1.3 5.1.1.4 5.1.1.5 5.1.1.6 5.1.1.7 5.1.1.8 5.1.4

null

AC-21

null

AC-21

null

AC-21

null

AC-21

null

AC-21

null

AC-21

120.54(a)(5)

null

AC-21

null

45.48.420 45.48.430

null

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

null

AC-21

null

Art 46

null

5.4 10.5

null

Sec 72

null

B3.b

null

0663 0661 0665 0664 0675 0657 1187 0669 1535

null

13.2 13.2.1 13.2.2

null

20.1.6.C.01 20.1.6.C.02 20.1.7.C.01 20.1.7.C.02 20.1.8.C.01 20.1.9.C.01 20.1.10.C.01 20.1.10.C.02 20.1.11.C.01 20.1.12.C.01 20.1.13.C.01 20.2.3.C.01 20.2.4.C.01 20.2.5.C.01 20.2.6.C.01 20.2.6.C.02 20.2.6.C.03 20.2.7.C.01 20.2.8.C.01 20.2.9.C.01 20.2.9.C.02 20.2.9.C.03 20.2.9.C.04 20.2.10.C.01 20.2.10.C.02 20.2.11.C.01 20.2.11.C.02 20.2.11.C.03

null

Art 23

null

x

null

x

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-IR-1 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

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

Data Classification & Handling

Information Search & Retrieval

DCH-14.1

Mechanisms exist to ensure information systems implement data search and retrieval functions that properly enforce data protection / sharing restrictions.

null

Does the organization ensure information systems implement data search and retrieval functions that properly enforce data protection / sharing restrictions?

5

Protect

null

X

There is no evidence of a capability to ensure information systems implement data search and retrieval functions that properly enforce data protection / sharing restrictions.

SP-CMM1 is N/A, since a structured process is required to ensure information systems implement data search and retrieval functions that properly enforce data protection / sharing restrictions.

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 information systems implement data search and retrieval functions that properly enforce data protection / sharing restrictions.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure information systems implement data search and retrieval functions that properly enforce data protection / sharing restrictions.

null

AC-21(2)

null

AC-21(2)

null

AC-21(2)

null

P.7.5

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-IR-1 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

null

R-IR-1

null

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

Transfer Authorizations

DCH-14.2

Mechanisms exist to verify that individuals or systems transferring data between interconnecting systems have the requisite authorizations (e.g., write permissions or privileges) prior to transferring said data.

null

Does the organization verify that individuals or systems transferring data between interconnecting systems have the requisite authorizations (e.g., write permissions or privileges) prior to transferring said data?

8

Protect

null

X

null

There is no evidence of a capability to verify that individuals or systems transferring data between interconnecting systems have the requisite authorizations (e.g., write permissions or privileges) prior to transferring said data.

SP-CMM1 is N/A, since a structured process is required to verify that individuals or systems transferring data between interconnecting systems have the requisite authorizations (e.g., write permissions or privileges) prior to transferring said 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: • 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 verify that individuals or systems transferring data between interconnecting systems have the requisite authorizations (e.g., write permissions or privileges) prior to transferring said data.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to verify that individuals or systems transferring data between interconnecting systems have the requisite authorizations (e.g., write permissions or privileges) prior to transferring said data.

null

3.3

null

DSP-10

null

TS-1.15

null

CA-3(6)

null

CA-3(6)

null

CA-3(6)

null

N.11.1

2.4A 2.5A 2.9

null

CA-3(6)

null

CA-3(6)

null

25(h)

null

2-6-1-5

null

Article 64 Article 64.1 Article 64.2 Article 64.3 Article 64.4

null

B3.b

null

20.1.8.C.01 20.2.4.C.01

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-IR-1 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

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

Data Classification & Handling

Data Access Mapping

DCH-14.3

Mechanisms exist to develop a data-specific Access Control List (ACL) or Data Information Sharing Agreement (DISA) to determine the parties with whom sensitive/regulated data is shared.

null

Does the organization develop a data-specific Access Control List (ACL) or Data Information Sharing Agreement (DISA) to determine the parties with whom sensitive/regulated data is shared?

9

Identify

X

null

There is no evidence of a capability to develop a data-specific Access Control List (ACL) or Data Information Sharing Agreement (DISA) to determine the parties with whom sensitive/regulated data is shared.

SP-CMM1 is N/A, since a structured process is required to develop a data-specific Access Control List (ACL) or Data Information Sharing Agreement (DISA) to determine the parties with whom sensitive/regulated data is shared.

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 develop a data-specific Access Control List (ACL) or Data Information Sharing Agreement (DISA) to determine the parties with whom sensitive/regulated data is shared.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to develop a data-specific Access Control List (ACL) or Data Information Sharing Agreement (DISA) to determine the parties with whom sensitive/regulated data is shared.

null

3.3

null

N.2.2

null

B3.a

null

16.2.5.C.01 16.2.6.C.01

null

R-AC-1 R-AC-2 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-4 R-EX-5 R-EX-6 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

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

null

R-EX-4

R-EX-5

R-EX-6

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

- wordsmithed control

Data Classification & Handling

Publicly Accessible Content

DCH-15

Mechanisms exist to control publicly-accessible content.

- Designate individuals authorized to post information onto systems that are publicly accessible. - Train authorized individuals to ensure that publicly accessible information does not contain nonpublic information. - Review the proposed content of publicly accessible information for nonpublic information prior to posting. - Remove nonpublic information from the publicly accessible system.

null

Does the organization control publicly-accessible content?

10

Protect

null

X

There is no evidence of a capability to control publicly-accessible content.

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: • 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 publicly-accessible content.

null

AC-22

null

AC-22

null

AC-22

null

AC-22

null

AC-22

3.1.22

3.1.22.a 3.1.22.b

3.1.22[a] 3.1.22[b] 3.1.22[c] 3.1.22[d] 3.1.22[e]

A.03.01.22.a A.03.01.22.b[01] A.03.01.22.b[02]

null

1.4.4

null

1.4.4

null

1.4.4

null

D.12.1

null

ID:SG1.SP2 KIM:SG1.SP2

null

AC.L1-3.1.22

AC.L1-b.1.iv

AC.L2-3.1.22

AC-22

null

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

null

AC-22

null

3.3.8 AC-22

120.11

null

6.5

null

AC-22

null

AC-22

null

FAR 52.204-21

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-IR-1 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

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

Data Classification & Handling

Data Mining Protection

DCH-16

Mechanisms exist to protect data storage objects against unauthorized data mining and data harvesting techniques.

null

Does the organization protect data storage objects against unauthorized data mining and data harvesting techniques?

7

Protect

null

X

There is no evidence of a capability to protect data storage objects against unauthorized data mining and data harvesting techniques.

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: • 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 protect data storage objects against unauthorized data mining and data harvesting techniques.

null

T1005, T1025, T1041, T1048, T1048.002, T1048.003, T1052, T1052.001, T1133, T1213, T1213.001, T1213.002, T1552.007, T1567

null

AC-23

null

AC-23

null

AC-23

null

AC-23

null

AC-23

null

AC-23

null

D.3

null

KIM:SG2.SP2 KIM:SG4.SP2

null

AC.L1-b.1.iv

null

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

null

AC-23

null

20.4.3.C.01 20.4.3.C.02 20.4.3.C.03 20.4.3.C.04 20.4.4.C.01 20.4.4.C.02 20.4.5.C.01 20.4.5.C.02 20.4.6.C.01 20.4.6.C.02

null

FAR 52.204-21

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-IR-1 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

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

Data Classification & Handling

Ad-Hoc Transfers

DCH-17

Mechanisms exist to secure ad-hoc exchanges of large digital files with internal or external parties.

- ShareFile - Box

null

Does the organization secure ad-hoc exchanges of large digital files with internal or external parties?

8

Protect

null

X

There is no evidence of a capability to secure ad-hoc exchanges of large digital files with internal or external parties.

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: • 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.

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

CC6.7

CC6.7-POF1

null

DSP-10

null

13.2.1

5.14

13.2.1

null

TS-1.15

null

3.1.3E

null

D.24.1

2.1 2.4A 2.5A

null

AC.L1-b.1.iii

null

AC.L3-3.1.3e

null

52.204-21(b)(1)(iii)

null

1.3

null

5.1 5.4 10.5

null

2-6-1-5

null

B3.b

null

0347 0947 1778 1779

null

13.2.1

null

20.1.11.C.01 20.2.6.C.01 20.2.6.C.02 20.2.6.C.03 20.2.7.C.01 20.2.8.C.01 20.2.9.C.01 20.2.9.C.02 20.2.9.C.03 20.2.9.C.04

null

Art 23

null

FAR 52.204-21

null

x

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-IR-1 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

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

Data Classification & Handling

Media & Data Retention

DCH-18

Mechanisms exist to retain media and data in accordance with applicable statutory, regulatory and contractual obligations.

- Data Protection Impact Assessment (DPIA)

E-AST-11

Does the organization retain media and data in accordance with applicable statutory, regulatory and contractual obligations?

8

Protect

null

X

There is no evidence of a capability to retain media and data in accordance with applicable statutory, regulatory and contractual obligations.

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: • 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 retain media and data in accordance with applicable statutory, regulatory and contractual obligations.

PI1.5

null

3.1 3.4

APO14.09

null

DSP-16

null

8.3 18.1.3

5.33 8.10

8.3 18.1.3

null

6.5.3 6.15.1.3 7.4.7

null

T1003, T1003.003, T1020.001, T1040, T1070, T1070.001, T1070.002, T1114, T1114.001, T1114.002, T1114.003, T1119, T1530, T1548, T1548.004, T1550.001, T1552, T1552.004, T1557, T1557.002, T1558, T1558.002, T1558.003, T1558.004, T1565, T1565.001, T1565.002, T1602, T1602.001, T1602.002

PS-1.1 TS-1.0

null

MP-7 SI-12

SI-12

MP-7 SI-12

null

MP-7 SI-12

null

SI-12

null

SI-12

null

3.14.8

null

A.03.14.08[01] A.03.14.08[02] A.03.14.08[03] A.03.14.08[04]

3.14.5e

null

3.1 3.2 3.2.1 3.2.2 3.2.3 10.7

3.2.1 9.4.6 9.4.7 10.5.1 11.4.1

3.2.1 9.4.6

3.2.1 9.4.6 10.5.1 11.4.1

9.4.6

9.4.6 10.5.1

9.4.6

3.2.1 9.4.6 9.4.7 10.5.1 11.4.1

3.2.1 9.4.6

D.4

null

KIM:SG2.SP2 KIM:SG6.SP1 TM:SG2.SP2

null

TBD - 3.14.5e

null

MP-7 SI-12

null

§ 11.2 § 11.2(a) § 11.2(a)(1) § 11.2(a)(2) § 11.10

MP-7 SI-12

null

Securities Exchange Act of 1934 (17 CFR §240.17a-4(f))

null

314.4(c)(6)(ii)

164.316(b)(2) 164.316(b)(2)(i) 164.530(j)(1)

null

MP-7 SI-12

null

8-306 8-310

null

SI-12

IV.A IV.B IV.B.1 IV.B.2

null

500.12

null

622(2)(C)(i) (iv)

null

MP-7 SI-12

null

Art 5.1

null

2-6-1-4 2-11-2

null

Article 5.5

null

Sec 9

null

9

null

B3.a

null

Chapter29-Schedule1-Part1-Principle 3 & 5

null

1510 0859 0991

null

Article 19

null

8.3 18.1.3 18.1.3.13.PB

null

x

OR 6464A

null

x

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-IR-1 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

null

R-IR-1

null

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

Minimize Personal Data (PD)

DCH-18.1

Mechanisms exist to limit Personal Data (PD) being processed in the information lifecycle to elements identified in the Data Protection Impact Assessment (DPIA).

- Data Protection Impact Assessment (DPIA)

null

Does the organization limit Personal Data (PD) being processed in the information lifecycle to elements identified in the Data Protection Impact Assessment (DPIA)?

8

Protect

null

X

null

There is no evidence of a capability to limit Personal Data (PD) being processed in the information lifecycle to elements identified in the Data Protection Impact Assessment (DPIA).

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: • 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/process owners document where personal data is stored, transmitted and processed in order to document sensitive/regulated data flows. • Administrative processes and technologies: o Collect Personal data (PD) directly from the individual. o Correct Personal data (PD) that is inaccurate or outdated, incorrectly determined regarding impact, or incorrectly de-identified. o De-identify the dataset up on collection by not collecting Personal data (PD). o Govern how data is reclassified due to changing business/technical requirements to ensure the integrity of data classification is upheld through the data lifecycle. o Limit Personal data (PD) being processed in the information lifecycle to elements identified in the Data Protection Impact Assessment (DPIA). o Refrain from archiving Personal data (PD) elements if those elements in a dataset will not be needed after the dataset is archived. o Remove Personal data (PD) elements from a dataset prior to its release if those elements in the dataset do not need to be part of the data release. o Remove Personal data (PD) from datasets. o Limit Personal data (PD) being processed in the information lifecycle to elements identified in the DPIA. o Identify custodians throughout the transport of system media. o Minimize the use of Personal data (PD) for research, testing or training, in accordance with the DPIA. o Minimize the use of Personal data (PD) for research, testing, or training, in accordance with the Data Protection Impact Assessment (DPIA). o Perform a motivated intruder test on the de-identified dataset to determine if the identified data remains or if the de-identified data can be re-identified.

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.

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

null

7.4.2 7.4.4

null

SI-12(1)

null

P.5

null

Sec 2.3

null

Art 35.1 Art 35.2 Art 35.3 Art 35.6 Art 35.8 Art 35.9 Art 35.11

null

Sec 19

null

x

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-IR-1 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

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

Data Classification & Handling

Limit Personal Data (PD) Elements In Testing, Training & Research

DCH-18.2

Mechanisms exist to minimize the use of Personal Data (PD) for research, testing, or training, in accordance with the Data Protection Impact Assessment (DPIA).

- Data Protection Impact Assessment (DPIA)

null

Does the organization minimize the use of Personal Data (PD) for research, testing, or training, in accordance with the Data Protection Impact Assessment (DPIA)?

8

Protect

null

X

There is no evidence of a capability to minimize the use of Personal Data (PD) for research, testing, or training, in accordance with the Data Protection Impact Assessment (DPIA).

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: • 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/process owners document where personal data is stored, transmitted and processed in order to document sensitive/regulated data flows. • Administrative processes and technologies: o Collect Personal data (PD) directly from the individual. o Correct Personal data (PD) that is inaccurate or outdated, incorrectly determined regarding impact, or incorrectly de-identified. o De-identify the dataset up on collection by not collecting Personal data (PD). o Govern how data is reclassified due to changing business/technical requirements to ensure the integrity of data classification is upheld through the data lifecycle. o Limit Personal data (PD) being processed in the information lifecycle to elements identified in the Data Protection Impact Assessment (DPIA). o Refrain from archiving Personal data (PD) elements if those elements in a dataset will not be needed after the dataset is archived. o Remove Personal data (PD) elements from a dataset prior to its release if those elements in the dataset do not need to be part of the data release. o Remove Personal data (PD) from datasets. o Limit Personal data (PD) being processed in the information lifecycle to elements identified in the DPIA. o Identify custodians throughout the transport of system media. o Minimize the use of Personal data (PD) for research, testing or training, in accordance with the DPIA. o Minimize the use of Personal data (PD) for research, testing, or training, in accordance with the Data Protection Impact Assessment (DPIA). o Perform a motivated intruder test on the de-identified dataset to determine if the identified data remains or if the de-identified data can be re-identified.

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 minimize the use of Personal Data (PD) for research, testing, or training, in accordance with the Data Protection Impact Assessment (DPIA).

null

7.4.4

5.5

null

PM-25 SI-12(2) SA-8(33) SA-15(12)

PM-25 SI-12(2) SA-8(33)

null

SA-15(12)

null

PM-25

null

PM-25

null

P.7.4

null

SI-12(2)

null

6-1-1308(3)

null

Art 5.1 Art 35.1 Art 35.2 Art 35.3 Art 35.6 Art 35.8 Art 35.9 Art 35.11

null

Article 5.1

null

Sec 19

null

Article 6

null

x

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-IR-1 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

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

Data Classification & Handling

Temporary Files Containing Personal Data (PD)

DCH-18.3

Mechanisms exist to perform periodic checks of temporary files for the existence of Personal Data (PD).

null

Does the organization perform periodic checks of temporary files for the existence of Personal Data (PD)?

5

Protect

null

X

There is no evidence of a capability to perform periodic checks of temporary files for the existence of Personal Data (PD).

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: • 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/process owners document where personal data is stored, transmitted and processed in order to document sensitive/regulated data flows. • Administrative processes and technologies: o Collect Personal data (PD) directly from the individual. o Correct Personal data (PD) that is inaccurate or outdated, incorrectly determined regarding impact, or incorrectly de-identified. o De-identify the dataset up on collection by not collecting Personal data (PD). o Govern how data is reclassified due to changing business/technical requirements to ensure the integrity of data classification is upheld through the data lifecycle. o Limit Personal data (PD) being processed in the information lifecycle to elements identified in the Data Protection Impact Assessment (DPIA). o Refrain from archiving Personal data (PD) elements if those elements in a dataset will not be needed after the dataset is archived. o Remove Personal data (PD) elements from a dataset prior to its release if those elements in the dataset do not need to be part of the data release. o Remove Personal data (PD) from datasets. o Limit Personal data (PD) being processed in the information lifecycle to elements identified in the DPIA. o Identify custodians throughout the transport of system media. o Minimize the use of Personal data (PD) for research, testing or training, in accordance with the DPIA. o Minimize the use of Personal data (PD) for research, testing, or training, in accordance with the Data Protection Impact Assessment (DPIA). o Perform a motivated intruder test on the de-identified dataset to determine if the identified data remains or if the de-identified data can be re-identified.

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.

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

null

7.4.6 8.4.1

null

D.4.4

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-IR-1 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

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

Data Classification & Handling

Geographic Location of Data

DCH-19

Mechanisms exist to inventory, document and maintain data flows for data that is resident (permanently or temporarily) within a service's geographically distributed applications (physical and virtual), infrastructure, systems components and/or shared with other third-parties.

null

E-AST-23

Does the organization inventory, document and maintain data flows for data that is resident (permanently or temporarily) within a service's geographically distributed applications (physical and virtual), infrastructure, systems components and/or shared with other third-parties?

9

Identify

null

X

There is no evidence of a capability to inventory, document and maintain data flows for data that is resident (permanently or temporarily) within a service's geographically distributed applications (physical and virtual), infrastructure, systems components and/ or shared with other third-parties.

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: • 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. • DPO maintains a centralized repository of sensitive Personal Data (sPD) data flows.

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.

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

null

DSP-19

null

7.5 7.5.1 7.5.2 8.5.1 8.5.2

null

SA-9(5)

null

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

null

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

null

3.4.11.a 3.4.11.c

null

P.2.3

null

SA-9(5)

null

SA-9(5)

null

SA-9(5)

null

SA-9(5)

null

SA-9(5)

null

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

null

SA-9(5)

null

11.6

null

25(h)

null

Article 15

null

TPC-30

null

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

null

APP 8

null

Article 38 Article 39 Article 40

null

Article 24(1)

null

Art 23

null

x

null

x

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-IR-1 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

null

R-IR-1

null

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

Archived Data Sets

DCH-20

Mechanisms exist to protect archived data in accordance with applicable statutory, regulatory and contractual obligations.

null

Does the organization protect archived data in accordance with applicable statutory, regulatory and contractual obligations?

8

Protect

null

X

null

There is no evidence of a capability to protect archived data in accordance with applicable statutory, regulatory and contractual obligations.

SP-CMM1 is N/A, since a structured process is required to protect archived data in accordance with applicable statutory, regulatory and contractual obligations.

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 protect archived data in accordance with applicable statutory, regulatory and contractual obligations.

null

D.4.1

null

x

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-IR-1 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

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

Data Classification & Handling

Information Disposal

DCH-21

Mechanisms exist to securely dispose of, destroy or erase information.

- Shred-it - IronMountain

null

Does the organization securely dispose of, destroy or erase information?

10

Protect

X

There is no evidence of a capability to securely dispose of, destroy or erase information.

SP-CMM1 is N/A, since a structured process is required to securely dispose of, destroy or erase information.

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. • Physical controls, administrative processes and technologies: o Physically secure all media that contains sensitive/regulated data. o Restrict access to digital and non-digital media to authorized individuals. o Restrict the types, usage and distribution of digital media. o Securely dispose of, destroy or erase information.

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 securely dispose of, destroy or erase information.

CC6.5 C1.2 P4.3

CC6.5-POF2 C1.2-POF2 P4.3-POF2 P4.3-POF3

null

3.5

null

POL-04

null

8.10

null

7.4.8 8.4.2

null

OP-3.3

null

CT.DM-P5

null

DM-2

null

SI-12(3)

null

3.4.14

null

3.8.3

null

PR.DS-09

null

D.4.3

null

ASSET-2.H.MIL3

KIM:SG4.SP3

null

MP.L1-b.1.vii

null

DM-2

null

52.204-21(b)(1)(vii)

null

314.4(c)(6)(i)

null

9.L.C

2.F.1 2.F.3

null

5.8

null

45.48.500 45.48.510

null

Sec 40(a) Sec 40(b) Sec 40(b)(1) Sec 40(b)(2) Sec 40(c) Sec 40(d) Sec 40(e) Sec 40(f)

null

Sec. 521.052(b)

null

Art 24

null

PI-03

null

11.12 15.4

null

3.3.11

null

11.1.7

null

x

FAR 52.204-21

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-IR-1 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

null

R-IR-1

null

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

Data Quality Operations

DCH-22

Mechanisms exist to check for the accuracy, relevance, timeliness, impact, completeness and de-identification of information across the information lifecycle.

- Data Protection Impact Assessment (DPIA)

null

Does the organization check for the accuracy, relevance, timeliness, impact, completeness and de-identification of information across the information lifecycle?

5

Protect

X

null

There is no evidence of a capability to check for the accuracy, relevance, timeliness, impact, completeness and de-identification of information across the information lifecycle.

SP-CMM1 is N/A, since a structured process is required to check for the accuracy, relevance, timeliness, impact, completeness and de-identification of information across the information lifecycle.

SP-CMM2 is N/A, since a well-defined process is required to check for the accuracy, relevance, timeliness, impact, completeness and de-identification of information across the information lifecycle.

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.

Data Classification & Handling (DCH) 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.

CC2.1

null

APO11.01 APO11.02 APO11.03 APO11.04 APO11.05

Principle 13

null

9.2.1

null

RQ-05-11

null

A.6

null

DI-1

null

PM-22 SI-18 SI-18(1)

PM-22 SI-18

null

SI-18(1)

null

PM-22

null

PM-22

null

P.5.3

null

KIM:SG5.SP2 KIM:SG5.SP3

null

DI-1

null

Chapter29-Schedule1-Part1-Principle 1

null

Article 8

null

5.8.1 5.8.2

null

x

null

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

null

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

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

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

Data Classification & Handling

Updating & Correcting Personal Data (PD)

DCH-22.1

Mechanisms exist to utilize technical controls to correct Personal Data (PD) that is inaccurate or outdated, incorrectly determined regarding impact, or incorrectly de-identified.

- Data Protection Impact Assessment (DPIA)

null

Does the organization utilize technical controls to correct Personal Data (PD) that is inaccurate or outdated, incorrectly determined regarding impact, or incorrectly de-identified?

6

Protect

null

X

null

There is no evidence of a capability to utilize technical controls to correct Personal Data (PD) that is inaccurate or outdated, incorrectly determined regarding impact, or incorrectly de-identified.

SP-CMM1 is N/A, since a structured process is required to utilize technical controls to correct Personal Data (PD) that is inaccurate or outdated, incorrectly determined regarding impact, or incorrectly de-identified.

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 utilize technical controls to correct Personal Data (PD) that is inaccurate or outdated, incorrectly determined regarding impact, or incorrectly de-identified.

P5.1 P5.2

null

6.2.5 6.2.6 10.2.1 10.2.2

null

7.3.6

5.9

null

CT.DM-P3

null

IP-3

null

SI-18(4) SI-18(5)

SI-18(4)

null

SI-18(5)

null

P.5.2

null

COMM:SG1.SP3 KIM:SG5.SP1

null

IP-3

null

164.526 164.526(a) 164.526(b) 164.526(c) 164.526(d) 164.526(e) 164.526(f)

null

Principle 7

null

6-1-1306(1)(c)

null

59.1-577.A.2

null

Art 12.3 Art 14.2 Art 16 Art 18.1 Art 26.3

null

Sec 27

Art 10 Art 12

Art 21

Art 24 Art 37

Sec 29

Art 38 Art 39

Sec 20

null

Art 13

Sec 14 Sec 15 Sec 17

Sec 2

null

Sec 14

Sec 7

null

Sec 36

null

Sec 27

Art 32

Art 12

null

Art 17

null

Sec 24

Art 23 Art 24 Art 31 Art 32

null

Sec 28

Art 5

null

Sec 17

null

Article 5(1)(d) Article 16 Article 19

null

APP Part 13

APP 13

null

Sec 8

Article 46 Article 49

Sec 22

null

Article 26(1) Article 26(1)(i) Article 26(1)(ii) Article 29(1) Article 29(2) Article 29(3)

null

Sec 34

null

P6-(2) Principle 7 P7-(1) P7-(2) P7-(3)(a) P7-(3)(b) P7-(4) P7-(5) P7-(6)

Sec 34

Sec 22

null

Art 4 Art 36

Art 3

Art 16

Art 16.1 Art 16.3

Sec 10

null

Art 18.3

null

Principle 10

Art 13

Art 8 Art 11

Art 7

Art 24 Art 28 Art 29

Art 20

Art 15 Art 16

null

x

null

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

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

R-BC-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

NT-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

Data Tags

DCH-22.2

Mechanisms exist to utilize data tags to automate tracking of sensitive/regulated data across the information lifecycle.

- Data Protection Impact Assessment (DPIA)

null

Does the organization utilize data tags to automate tracking of sensitive/regulated data across the information lifecycle?

3

Protect

null

X

There is no evidence of a capability to utilize data tags to automate tracking of sensitive/regulated data across the information lifecycle.

SP-CMM1 is N/A, since a structured process is required to utilize data tags to automate tracking of sensitive/regulated data across the information lifecycle.

SP-CMM2 is N/A, since a well-defined process is required to utilize data tags to automate tracking of sensitive/regulated data across the information lifecycle.

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.

Data Classification & Handling (DCH) 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

PT-2(1) PT-3(1) SI-18(2)

null

PT-2(1) PT-3(1) SI-18(2)

null

P.2.3.7

null

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

null

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

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

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

Data Classification & Handling

Primary Source Personal Data (PD) Collection

DCH-22.3

Mechanisms exist to collect Personal Data (PD) directly from the individual.

- Data Protection Impact Assessment (DPIA)

null

Does the organization collect Personal Data (PD) directly from the individual?

8

Identify

null

X

null

There is no evidence of a capability to collect Personal Data (PD) directly from the individual.

SP-CMM1 is N/A, since a structured process is required to collect Personal Data (PD) directly from the individual.

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 collect Personal Data (PD) directly from the individual.

null

7.4.1

null

SI-18(3) SI-19(1)

null

SI-18(3) SI-19(1)

null

P.5.4

null

Article 17(1)

null

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

null

R-AM-3

null

R-BC-3

null

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

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

De-Identification (Anonymization)

DCH-23

Mechanisms exist to anonymize data by removing Personal Data (PD) from datasets.

- Data Protection Impact Assessment (DPIA)

null

Does the organization anonymize data by removing Personal Data (PD) from datasets?

8

Protect

null

X

There is no evidence of a capability to anonymize data by removing Personal Data (PD) from datasets.

SP-CMM1 is N/A, since a structured process is required to anonymize data by removing Personal Data (PD) from datasets.

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 anonymize data by removing Personal Data (PD) from datasets.

null

GVN-05

null

8.33

null

7.4.5

null

DM-1(1) DM-3(1)

null

SI-19

null

P.7.7

null

DM-1(1) DM-3(1)

null

6-1-1307(1)(a) 6-1-1307(1)(b) 6-1-1307(1)(b)(I)(A) 6-1-1307(1)(b)(I)(B) 6-1-1307(1)(b)(II) 6-1-1307(1)(b)(III)

null

59.1-581.A 59.1-581.A.1 59.1-581.A.2 59.1-581.A.3 59.1-581.B 59.1-581.B(i) 59.1-581.B(ii) 59.1-581.C 59.1-581.C.1 59.1-581.C.2 59.1-581.C.3 59.1-581.D 59.1-581.E

null

39(2)

null

Article 50.1

null

Article 35-2(1) Article 35-2(2) Article 35-2(3) Article 35-2(4) Article 35-2(5) Article 35-2(6) Article 35-2(7) Article 35-2(8) Article 35-2(9) Article 36(1) Article 36(2) Article 36(3) Article 36(4) Article 37 Article 38 Article 39

null

Art 12

null

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

null

R-AM-3

null

R-BC-2

R-BC-3

null

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

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

De-Identify Dataset Upon Collection

DCH-23.1

Mechanisms exist to de-identify the dataset upon collection by not collecting Personal Data (PD).

- Data Protection Impact Assessment (DPIA)

null

Does the organization de-identify the dataset upon collection by not collecting Personal Data (PD)?

8

Protect

null

X

null

There is no evidence of a capability to de-identify the dataset up on collection by not collecting Personal Data (PD).

SP-CMM1 is N/A, since a structured process is required to de-identify the dataset up on collection by not collecting Personal Data (PD).

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 de-identify the dataset up on collection by not collecting Personal Data (PD).

null

7.4.5

null

SI-19(1)

null

SI-19(1)

null

P.5.5.2

null

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

null

R-AM-3

null

R-BC-2

R-BC-3

null

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

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

Archiving

DCH-23.2

Mechanisms exist to refrain from archiving Personal Data (PD) elements if those elements in a dataset will not be needed after the dataset is archived.

- Data Protection Impact Assessment (DPIA)

null

Does the organization refrain from archiving Personal Data (PD) elements if those elements in a dataset will not be needed after the dataset is archived?

8

Protect

null

X

null

There is no evidence of a capability to refrain from archiving Personal Data (PD) elements if those elements in a dataset will not be needed after the dataset is archived.

SP-CMM1 is N/A, since a structured process is required to refrain from archiving Personal Data (PD) elements if those elements in a dataset will not be needed after the dataset is archived.

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 refrain from archiving Personal Data (PD) elements if those elements in a dataset will not be needed after the dataset is archived.

null

7.4.6

null

SI-19(2)

null

SI-19(2)

null

P.7.1

null

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

null

R-AM-3

null

R-BC-2

R-BC-3

null

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

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

Release

DCH-23.3

Mechanisms exist to remove Personal Data (PD) elements from a dataset prior to its release if those elements in the dataset do not need to be part of the data release.

- Data Protection Impact Assessment (DPIA)

null

Does the organization remove Personal Data (PD) elements from a dataset prior to its release if those elements in the dataset do not need to be part of the data release?

8

Protect

null

X

null

There is no evidence of a capability to remove Personal Data (PD) elements from a dataset prior to its release if those elements in the dataset do not need to be part of the data release.

SP-CMM1 is N/A, since a structured process is required to remove Personal Data (PD) elements from a dataset prior to its release if those elements in the dataset do not need to be part of the data release.

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 remove Personal Data (PD) elements from a dataset prior to its release if those elements in the dataset do not need to be part of the data release.

null

7.3.7 7.3.10

null

SI-19(3)

null

SI-19(3)

null

P.5.1

null

R-AM-3 R-BC-2 R-BC-3 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-GV-6 R-GV-7

null

R-AM-3

null

R-BC-2

R-BC-3

null

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

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

Data Classification & Handling

Removal, Masking, Encryption, Hashing or Replacement of Direct Identifiers

DCH-23.4

Mechanisms exist to remove, mask, encrypt, hash or replace direct identifiers in a dataset.

- Data Protection Impact Assessment (DPIA)

null

Does the organization remove, mask, encrypt, hash or replace direct identifiers in a dataset?

8

Protect

null

X

There is no evidence of a capability to remove, mask, encrypt, hash or replace direct identifiers in a dataset.

SP-CMM1 is N/A, since a structured process is required to remove, mask, encrypt, hash or replace direct identifiers in a dataset.

SP-CMM2 is N/A, since a well-defined process is required to remove, mask, encrypt, hash or replace direct identifiers in a dataset.

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 remove, mask, encrypt, hash or replace direct identifiers in a dataset.

null

8.11

null

7.4.5

null

SI-19(4)

null

SI-19(4)

null

P.7.7

null

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

null

R-AC-4

null

R-AM-3

null

R-BC-2

R-BC-3

null

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

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

Statistical Disclosure Control

DCH-23.5

Mechanisms exist to manipulate numerical data, contingency tables and statistical findings so that no person or organization is identifiable in the results of the analysis.

null

Does the organization manipulate numerical data, contingency tables and statistical findings so that no person or organization is identifiable in the results of the analysis?

1

Protect

null

X

null

There is no evidence of a capability to manipulate numerical data, contingency tables and statistical findings so that no pers on or organization is identifiable in the results of the analysis.

SP-CMM1 is N/A, since a structured process is required to manipulate numerical data, contingency tables and statistical findings so that no pers on or organization is identifiable in the results of the analysis.

SP-CMM2 is N/A, since a well-defined process is required to manipulate numerical data, contingency tables and statistical findings so that no person or organization is identifiable in the results of the analysis.

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 manipulate numerical data, contingency tables and statistical findings so that no pers on or organization is identifiable in the results of the analysis.

null

SI-19(5)

null

SI-19(5)

null

P.7.7

null

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

null

R-AM-3

null

R-EX-3

R-EX-4

R-EX-5

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-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

Differential Data Privacy

DCH-23.6

Mechanisms exist to prevent disclosure of Personal Data (PD) by adding non-deterministic noise to the results of mathematical operations before the results are reported.

- Data Protection Impact Assessment (DPIA)

null

Does the organization prevent disclosure of Personal Data (PD) by adding non-deterministic noise to the results of mathematical operations before the results are reported?

1

Protect

null

X

null

There is no evidence of a capability to prevent disclosure of Personal Data (PD) by adding non-deterministic noise to the results of mathematical operations before the results are reported.

SP-CMM1 is N/A, since a structured process is required to prevent disclosure of Personal Data (PD) by adding non-deterministic noise to the results of mathematical operations before the results are reported.

SP-CMM2 is N/A, since a well-defined process is required to prevent disclosure of Personal Data (PD) by adding non-deterministic noise to the results of mathematical operations before the results are reported.

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 prevent disclosure of Personal Data (PD) by adding non-deterministic noise to the results of mathematical operations before the results are reported.

null

SI-19(6)

null

SI-19(6)

null

P.7.7

null

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

null

R-AM-3

null

R-EX-3

R-EX-4

R-EX-5

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-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 De-Identification of Sensitive Data

DCH-23.7

Mechanisms exist to perform de-identification of sensitive/regulated data, using validated algorithms and software to implement the algorithms.

- Data Protection Impact Assessment (DPIA)

null

Does the organization perform de-identification of sensitive/regulated data, using validated algorithms and software to implement the algorithms?

1

Protect

null

X

There is no evidence of a capability to perform de-identification of sensitive/regulated data, using validated algorithms and software to implement the algorithms.

SP-CMM1 is N/A, since a structured process is required to perform de-identification of sensitive/regulated data, using validated algorithms and software to implement the algorithms.

SP-CMM2 is N/A, since a well-defined process is required to perform de-identification of sensitive/regulated data, using validated algorithms and software to implement the algorithms.

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 perform de-identification of sensitive/regulated data, using validated algorithms and software to implement the algorithms.

null

SI-19(7)

null

SI-19(7)

null

P.7.6

null

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

null

R-AM-3

null

R-EX-3

R-EX-4

R-EX-5

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-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

Data Classification & Handling

Motivated Intruder

DCH-23.8

Mechanisms exist to perform a motivated intruder test on the de-identified dataset to determine if the identified data remains or if the de-identified data can be re-identified.

null

Does the organization perform a motivated intruder test on the de-identified dataset to determine if the identified data remains or if the de-identified data can be re-identified?

3

Protect

null

X

null

There is no evidence of a capability to perform a motivated intruder test on the de-identified dataset to determine if the identified data remains or if the de-identified data can be re-identified.

SP-CMM1 is N/A, since a structured process is required to perform a motivated intruder test on the de-identified dataset to determine if the identified data remains or if the de-identified data can be re-identified.

SP-CMM2 is N/A, since a well-defined process is required to perform a motivated intruder test on the de-identified dataset to determine if the identified data remains or if the de-identified data can be re-identified.

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 perform a motivated intruder test on the de-identified dataset to determine if the identified data remains or if the de-identified data can be re-identified.

null

SI-19(8)

null

SI-19(8)

null

P.7.7.1

null

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

null

R-AM-3

null

R-EX-3

R-EX-4

R-EX-5

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-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

Code Names

DCH-23.9

Mechanisms exist to use aliases to name assets, which are mission-critical and/or contain highly-sensitive/regulated data, are unique and not readily associated with a product, project or type of data.

null

Does the organization use aliases to name assets, which are mission-critical and/or contain highly-sensitive/regulated data, are unique and not readily associated with a product, project or type of data?

1

Protect

null

X

null

There is no evidence of a capability to use aliases to name assets, which are mission-critical and/ or contain highly-sensitive/regulated data, are unique and not readily associated with a product, project or type of data.

SP-CMM1 is N/A, since a structured process is required to use aliases to name assets, which are mission-critical and/ or contain highly-sensitive/regulated data, are unique and not readily associated with a product, project or type of 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: • 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 use aliases to name assets, which are mission-critical and/ or contain highly-sensitive/regulated data, are unique and not readily associated with a product, project or type of data.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to use aliases to name assets, which are mission-critical and/ or contain highly-sensitive/regulated data, are unique and not readily associated with a product, project or type of data.

null

OP-3.1

null

D.1.1.2

null

8.2.4 8.4.1

null

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

null

R-AM-3

null

R-EX-3

R-EX-4

R-EX-5

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-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

Information Location

DCH-24

Mechanisms exist to identify and document the location of information and the specific system components on which the information resides.

- Data Flow Diagram (DFD)

E-AST-23

Does the organization identify and document the location of information and the specific system components on which the information resides?

10

Identify

null

X

There is no evidence of a capability to identify and document the location of information and the specific system components on which the information resides.

SP-CMM1 is N/A, since a structured process is required to identify and document the location of information and the specific system components on which the information resides.

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.

Data Classification & Handling (DCH) 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

T1005, T1025

null

CM-12

null

CM-12

null

CM-12

null

CM-12

null

CM-12

null

A.03.04.11.a[01] A.03.04.11.a[02] A.03.04.11.a[03] A.03.04.11.b[01] A.03.04.11.b[02] A.03.04.11.c[01] A.03.04.11.c[02]

null

D.1.1.3

null

CM-12

null

CM-12

null

2.C.7 CM-12

null

Art 6.1 Art 26.1 Art 26.2 Art 27.3 Art 28.1 Art 28.2 Art 28.3 Art 28.4 Art 28.5 Art 28.6 Art 28.9 Art 28.10 Art 29 Art 44 Art 45.1 Art 45.2 Art 46.1 Art 46.2 Art 46.3 Art 47.1 Art 47.2 Art 48 Art 49.1 Art 49.2 Art 49.6

null

Sec 10

Chapter 4 - Art 16

Art 14 Art 16 Art 27

Art 41

null

Art 34

null

Sec 7

Sec 2

null

Sec 16 Sec 17

Sec 31

null

Art 3 Art 4

Sec 12 Sec 13 Sec 14

null

Sec 13 Sec 14

Art 1 Art 36

Art 14 Art 15

null

Art 7

null

4-2-3-1

null

Sec 19 Sec 21

null

Sec 31

null

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

null

Art 1

Article 20

null

Sec 9

null

Sec 25

Sec 24 Sec 26

null

Art 17 Art 27

null

Art 9 Art 26

null

Sec 20

Art 7

Art 26

null

Art 23

null

x

null

R-AC-1 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-4 R-SA-1

R-AC-1

null

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Classification & Handling

Automated Tools to Support Information Location

DCH-24.1

Automated mechanisms exist to identify by data classification type to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy.

null

Does the organization use automated mechanisms to identify by data classification type to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy?

6

Identify

null

X

There is no evidence of a capability to identify by data classification type to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy.

SP-CMM1 is N/A, since a structured process is required to identify by data classification type to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy.

SP-CMM2 is N/A, since a well-defined process is required to identify by data classification type to ensure adequate cybersecurity & data privacy controls are in place to protect organizational information and individual data privacy.

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.

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

null

CM-12(1)

null

CM-12(1)

null

CM-12(1)

null

CM-12(1)

null

CM-12(1)

null

D.1.1.11

null

CM-12(1)

null

CM-12(1)

null

CM-12(1)

null

Sec 10

Chapter 4 - Art 16

Art 14 Art 16 Art 27

Art 41

null

Art 34

null

Sec 7

Sec 2

null

Sec 16 Sec 17

Sec 31

null

Art 3 Art 4

Sec 12 Sec 13 Sec 14

null

Sec 13 Sec 14

Art 1 Art 36

Art 14 Art 15

null

Art 7

null

Sec 19 Sec 21

null

Sec 31

null

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

null

Sec 9

null

Sec 25

Sec 24 Sec 26

null

Art 17 Art 27

null

Art 9 Art 26

null

Sec 20

Art 7

Art 26

null

x

null

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

null

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

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

null

R-IR-4

R-SA-1

null

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

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

null

Data Classification & Handling

Transfer of Sensitive and/or Regulated Data

DCH-25

Mechanisms exist to restrict and govern the transfer of sensitive and/or regulated data to third-countries or international organizations.

- Model contracts - Privacy Shield - Binding Corporate Rules (BCR)

null

Does the organization restrict and govern the transfer of sensitive and/or regulated data to third-countries or international organizations?

10

Protect

null

X

null

There is no evidence of a capability to restrict and govern the transfer of sensitive and/ or regulated data to third-countries or international organizations.

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: • 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.

Data Classification & Handling (DCH) 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

P.1.6.2.3

2.4A 2.5A 2.9

null

Art 44 Art 45.1 Art 45.2 Art 46.1 Art 46.2 Art 46.3 Art 47.1 Art 47.2 Art 48 Art 49.1 Art 49.2 Art 49.6

null

Sec 10

null

Art 14 Art 27

null

10.5

null

25(h) 48(a) 48(b) 48(c)(i) 48(c)(ii) 48(c)(iii) 48(c)(iv) 48(c)(v) 48(c)(vi) 49(1) 49(2) 49(3) 50

null

2.11 2.11(a) 2.11(b) 2.11(c) 2.11(d) 2.11(e) 2.12 2.12(a) 2.12(b) 2.12(c) 2.12(d) 2.12(e) 2.12(f)

null

Article 15

null

2-6-1-5

TPC-30

null

Article 23 Article 63 Article 63.1 Article 63.2 Article 63.3 Article 63.4 Article 65 Article 68 Article 69 Article 69.x Article 70 Article 70.1 Article 70.2 Article 70.3 Article 70.4 Article 70.5 Article 71 Article 71.1 Article 71.2 Article 71.3 Article 71.4 Article 71.5

null

Sec 72

null

Article 44 Article 45(1) Article 45(2)(a) Article 45(2)(b) Article 45(2)(c) Article 46(1) Article 46(2)(a) Article 46(2)(b) Article 46(2)(c) Article 46(2)(d) Article 46(2)(e) Article 46(2)(f) Article 46(3)(a) Article 46(3)(b) Article 48 Article 49(1)(a) Article 49(1)(b) Article 49(1)(c) Article 49(1)(d) Article 49(1)(e) Article 49(1)(f) Article 49(1)(g) Article 49(2) Article 49(3) Article 49(4) Article 49(5) Article 49(6)

null

Article 24(1)

null

Sec 9

null

Principle 12 P12-(1) P12-(1)(a) P12-(1)(b) P12-(1)(c) P12-(1)(d) P12-(1)(e) P12-(1)(f) P12-(2) P12-(3)

null

Sec 24 Sec 26

null

Art 17 Art 26 Art 27

null

Sec 20

null

Art 26

null

x

null

R-AC-1 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-4 R-SA-1

R-AC-1

null

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Classification & Handling

Transfer Activity Limits

DCH-25.1

Mechanisms exist to establish organization-defined "normal business activities" to identify anomalous transaction activities that can reduce the opportunity for sending (outbound) and/or receiving (inbound) fraudulent actions.

null

Does the organization establish organization-defined "normal business activities" to identify anomalous transaction activities that can reduce the opportunity for sending (outbound) and/or receiving (inbound) fraudulent actions?

7

Protect

null

X

null

There is no evidence of a capability to establish organization-defined "normal business activities" to identify anomalous transaction activities that can reduce the opportunity for sending (outbound) and/ or receiving (inbound) fraudulent actions.

SP-CMM1 is N/A, since a structured process is required to establish organization-defined "normal business activities" to identify anomalous transaction activities that can reduce the opportunity for sending (outbound) and/ or receiving (inbound) fraudulent actions.

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 establish organization-defined "normal business activities" to identify anomalous transaction activities that can reduce the opportunity for sending (outbound) and/ or receiving (inbound) fraudulent actions.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to establish organization-defined "normal business activities" to identify anomalous transaction activities that can reduce the opportunity for sending (outbound) and/ or receiving (inbound) fraudulent actions.

null

L.7

2.9

null

R-AM-3 R-EX-1 R-GV-1 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-AM-3

null

R-EX-1

null

R-GV-1

null

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

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

Data Classification & Handling

Data Localization

DCH-26

Mechanisms exist to constrain the impact of "digital sovereignty laws," that require localized data within the host country, where data and processes may be subjected to arbitrary enforcement actions that potentially violate other applicable statutory, regulatory and/or contractual obligations.

- Board of Directors (Bod) Ethics Committee

null

Does the organization constrain the impact of "digital sovereignty laws," that require localized data within the host country, where data and processes may be subjected to arbitrary enforcement actions that potentially violate other applicable statutory, regulatory and/or contractual obligations?

10

Protect

X

There is no evidence of a capability to constrain the impact of "digital sovereignty laws," that require localized data within the host country, where data and processes may be subjected to arbitrary enforcement actions that potentially violate other applicable statutory, regulatory and/ or contractual obligations.

SP-CMM1 is N/A, since a structured process is required to constrain the impact of "digital sovereignty laws," that require localized data within the host country, where data and processes may be subjected to arbitrary enforcement actions that potentially violate other applicable statutory, regulatory and/ or contractual obligations.

SP-CMM2 is N/A, since a well-defined process is required to constrain the impact of "digital sovereignty laws," that require localized data within the host country, where data and processes may be subjected to arbitrary enforcement actions that potentially violate other applicable statutory, regulatory and/ or contractual obligations.

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 constrain the impact of "digital sovereignty laws," that require localized data within the host country, where data and processes may be subjected to arbitrary enforcement actions that potentially violate other applicable statutory, regulatory and/ or contractual obligations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to constrain the impact of "digital sovereignty laws," that require localized data within the host country, where data and processes may be subjected to arbitrary enforcement actions that potentially violate other applicable statutory, regulatory and/ or contractual obligations.

null

L.11.5

null

50

null

Article 36

null

Article 36 Article 38 Article 40

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

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

null

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Embedded Technology

Embedded Technology Security Program

EMB-01

Mechanisms exist to facilitate the implementation of embedded technology controls.

null

E-AST-07

Does the organization facilitate the implementation of embedded technology controls?

10

Protect

X

There is no evidence of a capability to facilitate the implementation of embedded technology controls.

Embedded Technology (EMB) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Embedded technologies (e.g., Operational Technology (OT) and Internet of Things (IoT) are managed in the same manner as any other technology asset. • Embedded technologies management is decentralized.

Embedded Technology (EMB) 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: • Embedded technology 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 embedded technology management. • Embedded technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data. • Deviations to baseline for embedded technologies configurations are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Special baselines for embedded technologies configurations are created for higher-risk environments. • IT/cybersecurity personnel perform an annual review of existing for embedded technologies configurations to ensure security objectives are still being met. • Data management for embedded technologies is decentralized where 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 protection controls are primarily administrative in nature (e.g., policies & standards) to manage embedded technologies. • Historical versions of configurations are maintained for troubleshooting and forensics purposes. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, 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 embedded technologies governance practices. • The CISO, or similar function, develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures to apply defense-in-depth techniques across the enterprise, including governance of embedded technologies. • A Governance, Risk & Compliance (GRC) function, or similar function, provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to embedded technologies. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including embedded technologies governance. • An IT Asset Management (ITAM) function, or similar function: o Categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. o Ensures known vulnerabilities to embedded technologies are remediated or appropriate compensating controls are implemented to counter the threat. o Ensures that media sanitization and disposal actions are documented and verified. o Subscribes to threat feeds and performs vulnerability scanning to maintain situational awareness on existing threats within the operating environment. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Administrative processes and technologies limit Personal Data (PD) being processed by embedded technologies to elements identified in the DPIA.

Embedded Technology (EMB) 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 embedded technology controls.

null

GVN-01 GVN-02 POL-03 VLN-04

null

EDR 2.4 (13.2.1) EDR 2.4 (13.2.1(a)) EDR 2.4 (13.2.1(b)) EDR 2.4 (13.2.1(c))

null

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

null

M.1.1

null

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

ARCHITECTURE-3.A.MIL1 ARCHITECTURE-3.B.MIL1

null

9.S.A

6.M.B 9.M.A

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

12.1 12.2 12.3

null

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

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

null

Sec 19

null

11.5.1 11.5.2 11.5.3 11.5.4 11.5.5

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-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

Embedded Technology

Internet of Things (IOT)

EMB-02

Mechanisms exist to proactively manage the cybersecurity & data privacy risks associated with Internet of Things (IoT).

null

Does the organization proactively manage the cybersecurity & data privacy risks associated with Internet of Things (IoT)?

9

Protect

null

X

null

There is no evidence of a capability to proactively manage the cybersecurity & data privacy risks associated with Internet of Things (IoT).

SP-CMM1 is N/A, since a structured process is required to proactively manage the cybersecurity & data privacy risks associated with Internet of Things (IoT).

Embedded Technology (EMB) 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: • Embedded technology 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 embedded technology management. • Embedded technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data. • Deviations to baseline for embedded technologies configurations are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Special baselines for embedded technologies configurations are created for higher-risk environments. • IT/cybersecurity personnel perform an annual review of existing for embedded technologies configurations to ensure security objectives are still being met. • Data management for embedded technologies is decentralized where 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 protection controls are primarily administrative in nature (e.g., policies & standards) to manage embedded technologies. • Historical versions of configurations are maintained for troubleshooting and forensics purposes. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations.

Embedded Technology (EMB) 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 proactively manage the cybersecurity & data privacy risks associated with Internet of Things (IoT).

null

GVN-02

null

U.2.5

null

ARCHITECTURE-3.A.MIL1 ARCHITECTURE-3.B.MIL1

null

9.S.A

6.M.B 9.M.A

null

Sec 19

null

Principle 11 Principle 13

null

Article 26

null

11.5.1 11.5.2 11.5.3 11.5.4 11.5.5

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-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

Embedded Technology

Operational Technology (OT)

EMB-03

Mechanisms exist to proactively manage the cybersecurity & data privacy risks associated with Operational Technology (OT).

null

Does the organization proactively manage the cybersecurity & data privacy risks associated with Operational Technology (OT)?

9

Protect

null

X

null

There is no evidence of a capability to proactively manage the cybersecurity & data privacy risks associated with Operational Technology (OT).

SP-CMM1 is N/A, since a structured process is required to proactively manage the cybersecurity & data privacy risks associated with Operational Technology (OT).

Embedded Technology (EMB) 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: • Embedded technology 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 embedded technology management. • Embedded technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data. • Deviations to baseline for embedded technologies configurations are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Special baselines for embedded technologies configurations are created for higher-risk environments. • IT/cybersecurity personnel perform an annual review of existing for embedded technologies configurations to ensure security objectives are still being met. • Data management for embedded technologies is decentralized where 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 protection controls are primarily administrative in nature (e.g., policies & standards) to manage embedded technologies. • Historical versions of configurations are maintained for troubleshooting and forensics purposes. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations.

Embedded Technology (EMB) 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 proactively manage the cybersecurity & data privacy risks associated with Operational Technology (OT).

null

GVN-02

null

N.30.2

null

ARCHITECTURE-3.A.MIL1 ARCHITECTURE-3.B.MIL1

null

9.S.A

6.M.B 9.M.A

null

Sec 19

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-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

Embedded Technology

Interface Security

EMB-04

Mechanisms exist to protect embedded devices against unauthorized use of the physical factory diagnostic and test interface(s).

null

Does the organization protect embedded devices against unauthorized use of the physical factory diagnostic and test interface(s)?

4

Protect

null

X

There is no evidence of a capability to protect embedded devices against unauthorized use of the physical factory diagnostic and test interface(s).

SP-CMM1 is N/A, since a structured process is required to protect embedded devices against unauthorized use of the physical factory diagnostic and test interface(s).

Embedded Technology (EMB) 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: • Embedded technology 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 embedded technology management. • Embedded technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data. • Deviations to baseline for embedded technologies configurations are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Special baselines for embedded technologies configurations are created for higher-risk environments.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to protect embedded devices against unauthorized use of the physical factory diagnostic and test interface(s).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to protect embedded devices against unauthorized use of the physical factory diagnostic and test interface(s).

null

IOT-05

null

EDR 2.13 (13.3.1)

null

N.21

null

Principle 6 Principle 13

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-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

Embedded Technology

Embedded Technology Configuration Monitoring

EMB-05

Mechanisms exist to generate log entries on embedded devices when configuration changes or attempts to access interfaces are detected.

null

Does the organization generate log entries on embedded devices when configuration changes or attempts to access interfaces are detected?

6

Detect

null

X

There is no evidence of a capability to generate log entries on embedded devices when configuration changes or attempts to access interfaces are detected.

SP-CMM1 is N/A, since a structured process is required to generate log entries on embedded devices when configuration changes or attempts to access interfaces are detected.

Embedded Technology (EMB) 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: • Embedded technology 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 embedded technology management. • Embedded technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data. • Deviations to baseline for embedded technologies configurations are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Special baselines for embedded technologies configurations are created for higher-risk environments.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Previous versions of configurations are maintained for troubleshooting and forensics reasons.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to generate log entries on embedded devices when configuration changes or attempts to access interfaces are detected.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to generate log entries on embedded devices when configuration changes or attempts to access interfaces are detected.

null

SNT-03

null

EDR 2.13 (13.3.3(1)) EDR 3.11 (13.6.3(1))

null

A05:2021

null

I.3.15

null

7.3.7(a) 7.3.7(b)

null

1-5-4

null

Principle 8 Principle 10

null

11.5.5

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-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

Embedded Technology

Prevent Alterations

EMB-06

Mechanisms exist to protect embedded devices by preventing the unauthorized installation and execution of software.

null

Does the organization protect embedded devices by preventing the unauthorized installation and execution of software?

6

Protect

null

X

There is no evidence of a capability to protect embedded devices by preventing the unauthorized installation and execution of software.

SP-CMM1 is N/A, since a structured process is required to protect embedded devices by preventing the unauthorized installation and execution of software.

Embedded Technology (EMB) 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: • Embedded technology 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 embedded technology management. • Embedded technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data. • Deviations to baseline for embedded technologies configurations are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Special baselines for embedded technologies configurations are created for higher-risk environments.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to protect embedded devices by preventing the unauthorized installation and execution of software.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to protect embedded devices by preventing the unauthorized installation and execution of software.

null

IOT-05

null

EDR 3.2 (13.4.1) EDR 3.11 (13.6.3(1))

null

A05:2021

null

M.1.45

null

ARCHITECTURE-3.E.MIL2 ARCHITECTURE-3.F.MIL2 ARCHITECTURE-3.H.MIL2 ARCHITECTURE-3.I.MIL2 ARCHITECTURE-3.L.MIL3 ARCHITECTURE-3.M.MIL3

null

1-5-2 1-5-3 1-5-4 2-3-1-5 2-3-1-6

null

Principle 6

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-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

Embedded Technology

Embedded Technology Maintenance

EMB-07

Mechanisms exist to securely update software and upgrade functionality on embedded devices.

null

Does the organization securely update software and upgrade functionality on embedded devices?

6

Protect

null

X

There is no evidence of a capability to securely update software and upgrade functionality on embedded devices.

SP-CMM1 is N/A, since a structured process is required to securely update software and upgrade functionality on embedded devices.

Embedded Technology (EMB) 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: • Embedded technology 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 embedded technology management. • Embedded technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data. • Deviations to baseline for embedded technologies configurations are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Special baselines for embedded technologies configurations are created for higher-risk environments.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to securely update software and upgrade functionality on embedded devices.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to securely update software and upgrade functionality on embedded devices.

null

EDR 3.10 (13.5.1)

null

N.3

null

ARCHITECTURE-3.E.MIL2 ARCHITECTURE-3.F.MIL2 ARCHITECTURE-3.H.MIL2 ARCHITECTURE-3.I.MIL2 ARCHITECTURE-3.L.MIL3 ARCHITECTURE-3.M.MIL3

null

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

null

Principle 3 Principle 12

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-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

Embedded Technology

Resilience To Outages

EMB-08

Mechanisms exist to configure embedded technology to be resilient to data network and power outages.

null

Does the organization configure embedded technology to be resilient to data network and power outages?

2

Protect

null

X

There is no evidence of a capability to configure embedded technology to be resilient to data network and power outages.

SP-CMM1 is N/A, since a structured process is required to configure embedded technology to be resilient to data network and power outages.

Embedded Technology (EMB) 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: • Embedded technology 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 embedded technology management. • Embedded technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data. • Deviations to baseline for embedded technologies configurations are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • Special baselines for embedded technologies configurations are created for higher-risk environments.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to configure embedded technology to be resilient to data network and power outages.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to configure embedded technology to be resilient to data network and power outages.

null

SAP-03

null

M.1.7

null

Principle 9

null

x

null

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

R-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

Embedded Technology

Power Level Monitoring

EMB-09

Automated mechanisms exist to monitor the power levels of embedded technologies for decreased or excessive power usage, including battery drainage, to investigate for device tampering.

null

Does the organization use automated mechanisms to monitor the power levels of embedded technologies for decreased or excessive power usage, including battery drainage, to investigate for device tampering?

4

Detect

null

X

There is no evidence of a capability to monitor the power levels of embedded technologies for decreased or excessive power usage, including battery drainage, to investigate for device tampering.

SP-CMM1 is N/A, since a structured process is required to monitor the power levels of embedded technologies for decreased or excessive power usage, including battery drainage, to investigate for device tampering.

SP-CMM2 is N/A, since a well-defined process is required to monitor the power levels of embedded technologies for decreased or excessive power usage, including battery drainage, to investigate for device tampering.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Power levels of embedded technologies are monitored for excessive power usage or battery drainage due to device tampering.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to monitor the power levels of embedded technologies for decreased or excessive power usage, including battery drainage, to investigate for device tampering.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to monitor the power levels of embedded technologies for decreased or excessive power usage, including battery drainage, to investigate for device tampering.

null

ASM-03

null

G.2.14

null

x

null

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

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-6

null

R-GV-1

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

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

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

null

NT-11

NT-12

NT-13

null

MT-1

MT-2

null

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

null

Embedded Technology

Embedded Technology Reviews

EMB-10

Mechanisms exist to perform evaluations of deployed embedded technologies as needed, or at least on an annual basis, to ensure that necessary updates to mitigate the risks associated with legacy embedded technologies are identified and implemented.

null

Does the organization perform evaluations of deployed embedded technologies as needed, or at least on an annual basis, to ensure that necessary updates to mitigate the risks associated with legacy embedded technologies are identified and implemented?

8

Identify

null

X

There is no evidence of a capability to perform evaluations of deployed embedded technologies as needed, or at least on an annual basis, to ensure that necessary updates to mitigate the risks associated with legacy embedded technologies are identified and implemented.

SP-CMM1 is N/A, since a structured process is required to perform evaluations of deployed embedded technologies as needed, or at least on an annual basis, to ensure that necessary updates to mitigate the risks associated with legacy embedded technologies are identified and implemented.

SP-CMM2 is N/A, since a well-defined process is required to perform evaluations of deployed embedded technologies as needed, or at least on an annual basis, to ensure that necessary updates to mitigate the risks associated with legacy embedded technologies are identified and implemented.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to perform evaluations of deployed embedded technologies as needed, or at least on an annual basis, to ensure that necessary updates to mitigate the risks associated with legacy embedded technologies are identified and implemented.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to perform evaluations of deployed embedded technologies as needed, or at least on an annual basis, to ensure that necessary updates to mitigate the risks associated with legacy embedded technologies are identified and implemented.

null

CCM-01 IOT-08

null

A06:2021

null

N.1.1

null

III.C.5

null

1-6 1-6-1 1-6-2 2-1-2 2-3-2 2-7-2 2-9-2

null

x

null

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

null

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

null

R-EX-6

null

R-GV-1

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 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-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Embedded Technology

Message Queuing Telemetry Transport (MQTT) Security

EMB-11

Mechanisms exist to enforce the security of Message Queuing Telemetry Transport (MQTT) traffic.

null

Does the organization enforce the security of Message Queuing Telemetry Transport (MQTT) traffic?

7

Protect

null

X

There is no evidence of a capability to enforce the security of Message Queuing Telemetry Transport (MQTT) traffic.

SP-CMM1 is N/A, since a structured process is required to enforce the security of Message Queuing Telemetry Transport (MQTT) traffic.

SP-CMM2 is N/A, since a well-defined process is required to enforce the security of Message Queuing Telemetry Transport (MQTT) traffic.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Message Queuing Telemetry Transport (MQTT) traffic is securely enforced.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to enforce the security of Message Queuing Telemetry Transport (MQTT) traffic.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to enforce the security of Message Queuing Telemetry Transport (MQTT) traffic.

null

COM-01

null

N.1

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-6 R-EX-7 R-GV-1 R-GV-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

null

R-EX-6

R-EX-7

R-GV-1

null

R-GV-4

null

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

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Embedded Technology

Restrict Communications

EMB-12

Mechanisms exist to require embedded technologies to initiate all communications and drop new, incoming communications.

null

Does the organization require embedded technologies to initiate all communications and drop new, incoming communications?

8

Protect

null

X

There is no evidence of a capability to require embedded technologies to initiate all communications and drop new, incoming communications.

SP-CMM1 is N/A, since a structured process is required to require embedded technologies to initiate all communications and drop new, incoming communications.

SP-CMM2 is N/A, since a well-defined process is required to require embedded technologies to initiate all communications and drop new, incoming communications.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Embedded technologies are restricted to communicate only with authorized peers and service endpoints.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to require embedded technologies to initiate all communications and drop new, incoming communications.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to require embedded technologies to initiate all communications and drop new, incoming communications.

null

COM-10

null

N.9

null

x

null

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

null

R-EX-6

R-EX-7

R-GV-1

null

R-GV-4

null

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

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Embedded Technology

Authorized Communications

EMB-13

Mechanisms exist to restrict embedded technologies to communicate only with authorized peers and service endpoints.

null

Does the organization restrict embedded technologies to communicate only with authorized peers and service endpoints?

8

Protect

null

X

There is no evidence of a capability to restrict embedded technologies to communicate only with authorized peers and service endpoints.

SP-CMM1 is N/A, since a structured process is required to restrict embedded technologies to communicate only with authorized peers and service endpoints.

SP-CMM2 is N/A, since a well-defined process is required to restrict embedded technologies to communicate only with authorized peers and service endpoints.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Embedded technologies are configured to initiate all communications and drop any new incoming communications.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to restrict embedded technologies to communicate only with authorized peers and service endpoints.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to restrict embedded technologies to communicate only with authorized peers and service endpoints.

null

COM-11 SNT-04

null

A07:2021

null

M.1.1

null

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

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-6 R-EX-7 R-GV-1 R-GV-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

null

R-EX-6

R-EX-7

R-GV-1

null

R-GV-4

null

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

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Embedded Technology

Operating Environment Certification

EMB-14

Mechanisms exist to determine if embedded technologies are certified for secure use in the proposed operating environment.

null

Does the organization determine if embedded technologies are certified for secure use in the proposed operating environment?

9

Identify

null

X

There is no evidence of a capability to determine if embedded technologies are certified for secure use in the proposed operating environment.

SP-CMM1 is N/A, since a structured process is required to determine if embedded technologies are certified for secure use in the proposed operating environment.

SP-CMM2 is N/A, since a well-defined process is required to determine if embedded technologies are certified for secure use in the proposed operating environment.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Embedded technologies are certified for use in the proposed operating environment and the safety aspects of the technology formally evaluated using a fault tree analysis, or similar method, to determine possible consequences of misuse, misconfiguration or failure.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to determine if embedded technologies are certified for secure use in the proposed operating environment.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to determine if embedded technologies are certified for secure use in the proposed operating environment.

null

GVN-09 GVN-10 IOT-08 LGL-01 RSM-03

null

I.1.18

null

1-5-3-3 2-4-1-15

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-6 R-EX-7 R-GV-1 R-GV-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

null

R-EX-6

R-EX-7

R-GV-1

null

R-GV-4

null

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

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

null

NT-11

NT-12

NT-13

null

MT-1

MT-2

null

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Embedded Technology

Safety Assessment

EMB-15

Mechanisms exist to evaluate the safety aspects of embedded technologies via a fault tree analysis, or similar method, to determine possible consequences of misuse, misconfiguration and/or failure.

null

Does the organization evaluate the safety aspects of embedded technologies via a fault tree analysis, or similar method, to determine possible consequences of misuse, misconfiguration and/or failure?

9

Identify

null

X

There is no evidence of a capability to evaluate the safety aspects of embedded technologies via a fault tree analysis, or similar method, to determine possible consequences of misuse, misconfiguration and/ or failure.

SP-CMM1 is N/A, since a structured process is required to evaluate the safety aspects of embedded technologies via a fault tree analysis, or similar method, to determine possible consequences of misuse, misconfiguration and/ or failure.

SP-CMM2 is N/A, since a well-defined process is required to evaluate the safety aspects of embedded technologies via a fault tree analysis, or similar method, to determine possible consequences of misuse, misconfiguration and/ or failure.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to evaluate the safety aspects of embedded technologies via a fault tree analysis, or similar method, to determine possible consequences of misuse, misconfiguration and/ or failure.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to evaluate the safety aspects of embedded technologies via a fault tree analysis, or similar method, to determine possible consequences of misuse, misconfiguration and/ or failure.

null

M.1.37

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

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

null

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Embedded Technology

Certificate-Based Authentication

EMB-16

Mechanisms exist to enforce certificate-based authentication for embedded technologies (e.g., IoT, OT, etc.) and their supporting services.

null

Does the organization enforce certificate-based authentication for embedded technologies (e.g., IoT, OT, etc.?) and their supporting services?

5

Protect

null

X

There is no evidence of a capability to enforce certificate-based authentication for embedded technologies (e.g., IoT, OT, etc.) and their supporting services.

SP-CMM1 is N/A, since a structured process is required to enforce certificate-based authentication for embedded technologies (e.g., IoT, OT, etc.) and their supporting services.

SP-CMM2 is N/A, since a well-defined process is required to enforce certificate-based authentication for embedded technologies (e.g., IoT, OT, etc.) and their supporting services.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Certificate-based authentication is enforced for embedded technologies (e.g., IoT, OT, etc.) and their supporting services.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to enforce certificate-based authentication for embedded technologies (e.g., IoT, OT, etc.) and their supporting services.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to enforce certificate-based authentication for embedded technologies (e.g., IoT, OT, etc.) and their supporting services.

null

IAM-03

null

EDR 3.10 (13.5.3(1))

null

A08:2021

null

U.2.5

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-6 R-EX-7 R-GV-1 R-GV-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

null

R-EX-6

R-EX-7

R-GV-1

null

R-GV-4

null

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

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Embedded Technology

Chip-To-Cloud Security

EMB-17

Mechanisms exist to implement embedded technologies that utilize pre-provisioned cloud trust anchors to support secure bootstrap and Zero Touch Provisioning (ZTP).

null

Does the organization implement embedded technologies that utilize pre-provisioned cloud trust anchors to support secure bootstrap and Zero Touch Provisioning (ZTP)?

6

Protect

null

X

There is no evidence of a capability to implement embedded technologies that utilize pre-provisioned cloud trust anchors to support secure bootstrap and Zero Touch Provisioning (ZTP).

SP-CMM1 is N/A, since a structured process is required to implement embedded technologies that utilize pre-provisioned cloud trust anchors to support secure bootstrap and Zero Touch Provisioning (ZTP).

SP-CMM2 is N/A, since a well-defined process is required to implement embedded technologies that utilize pre-provisioned cloud trust anchors to support secure bootstrap and Zero Touch Provisioning (ZTP).

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Embedded technologies use pre-provisioned cloud trust anchors to support secure bootstrap and Zero Touch Provisioning (ZTP).

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to implement embedded technologies that utilize pre-provisioned cloud trust anchors to support secure bootstrap and Zero Touch Provisioning (ZTP).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to implement embedded technologies that utilize pre-provisioned cloud trust anchors to support secure bootstrap and Zero Touch Provisioning (ZTP).

null

IOT-04

null

C.5

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-6 R-EX-7 R-GV-1 R-GV-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

null

R-EX-6

R-EX-7

R-GV-1

null

R-GV-4

null

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

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Embedded Technology

Real-Time Operating System (RTOS) Security

EMB-18

Mechanisms exist to ensure embedded technologies utilize a securely configured Real-Time Operating System (RTOS).

null

Does the organization ensure embedded technologies utilize a securely configured Real-Time Operating System (RTOS)?

5

Protect

null

X

There is no evidence of a capability to ensure embedded technologies utilize a securely configured Real-Time Operating System (RTOS).

SP-CMM1 is N/A, since a structured process is required to ensure embedded technologies utilize a securely configured Real-Time Operating System (RTOS).

SP-CMM2 is N/A, since a well-defined process is required to ensure embedded technologies utilize a securely configured Real-Time Operating System (RTOS).

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Embedded technologies use a securely configured Real-Time Operating System (RTOS).

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure embedded technologies utilize a securely configured Real-Time Operating System (RTOS).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure embedded technologies utilize a securely configured Real-Time Operating System (RTOS).

null

IOT-06 IOT-07 IOT-09

null

I.1.10

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-6 R-EX-7 R-GV-1 R-GV-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

null

R-EX-6

R-EX-7

R-GV-1

null

R-GV-4

null

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

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Embedded Technology

Safe Operations

EMB-19

Mechanisms exist to continuously validate autonomous systems that trigger an automatic state change when safe operation is no longer assured.

null

Does the organization continuously validate autonomous systems that trigger an automatic state change when safe operation is no longer assured?

9

Protect

null

X

There is no evidence of a capability to continuously validate autonomous systems that trigger an automatic state change when safe operation is no longer assured.

SP-CMM1 is N/A, since a structured process is required to continuously validate autonomous systems that trigger an automatic state change when safe operation is no longer assured.

SP-CMM2 is N/A, since a well-defined process is required to continuously validate autonomous systems that trigger an automatic state change when safe operation is no longer assured.

Embedded Technology (EMB) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • An IT Asset Management (ITAM) function, or similar function, categorizes embedded technologies according to the data the asset stores, transmits and/ or processes to ensure that the appropriate technology controls are applied to protect the asset and the data it stores, transmits or processes. • An IT infrastructure team, or similar function, ensures that statutory, regulatory and contractual cybersecurity & data privacy obligations are addressed to ensure secure configurations for embedded technologies are designed, built and maintained for embedded technologies. • Cybersecurity personnel perform annual evaluations of deployed embedded technologies to identify necessary updates to mitigate any newly discovered risks associated with legacy embedded technologies. • Configurations for embedded technologies conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • Configuration management of embedded technologies is centralized for all operating systems, applications, servers and other technologies that are capable of being configured. • Special baseline configurations for embedded technologies are created for higher-risk environments. • Deviations to baseline configurations for embedded technologies are required to have a risk assessment and the business process owner accepts the risk(s) associated with the deviation. • Unauthorized configuration changes to embedded technologies are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on embedded technologies, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Autonomous systems are configured to continuously validate safe operation parameters that trigger an automatic state change when safe operation is no longer assured.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to continuously validate autonomous systems that trigger an automatic state change when safe operation is no longer assured.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to continuously validate autonomous systems that trigger an automatic state change when safe operation is no longer assured.

null

SAP-02 SAP-09

null

T.1.1.2

null

3-1-1-5

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-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

null

R-GV-4

null

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

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

null

NT-11

NT-12

NT-13

null

MT-1

MT-2

null

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Endpoint Security

END-01

Mechanisms exist to facilitate the implementation of endpoint security controls.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Group Policy Objects (GPOs) - Antimalware technologies - Software firewalls - Host-based IDS/IPS technologies - NNT Change Tracker (https://www.newnettechnologies.com)

null

Does the organization facilitate the implementation of endpoint security controls?

10

Protect

X

There is no evidence of a capability to facilitate the implementation of endpoint security controls.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data. • 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 protection controls are primarily administrative in nature (e.g., policies & standards) to manage endpoint devices. IT personnel implement and maintain an asset management capability, including endpoint devices.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, 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 endpoint security practices. • The CISO, or similar function, develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures to apply defense-in-depth techniques across the enterprise with regards to endpoint security. • A Governance, Risk & Compliance (GRC) function, or similar function, provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to endpoint security. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including endpoint security. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • An ITAM function, or similar function, uses a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets that is configured to perform integrity checking and alert on unauthorized configuration changes. • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of Personal Data (PD) processed, stored or transmitted on endpoint devices, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Administrative processes exist and technologies are configured to notify individuals that Personal Data (PD) is collected by sensors. • File Integrity monitor (FIM) technology is deployed to all HVAs to detect and report unauthorized changes to business-critical system files and configurations. • Host-based Intrusion Detection/Prevention Systems (HIDS/HIPS) technology is deployed to all HVAs to detect and report unauthorized changes to business-critical system files and configurations.

Endpoint Security (END) 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 endpoint security controls.

null

CC6.7-POF4

null

10.1

DSS05.01 DSS05.02 DSS05.03 DSS05.04 DSS05.05 DSS05.06 DSS05.07

null

TVM-02 UEM-01 UEM-05 UEM-07

null

11.2.9

7.7 8.1 8.5

11.2.9

null

6.8.2.9

null

MP-2

null

MP-2

null

MP-2

null

MP-2

null

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

A.03.01.01.ODP[01]

null

DE.CM-4

PR.DS-10 PR.PS

null

1.5 1.5.1

null

1.5.1

null

1.5.1

null

M.1.1

6.1

null

ARCHITECTURE-3.A.MIL1 ARCHITECTURE-3.B.MIL1

AM:SG1.SP1 KIM:SG2.SP1 KIM:SG2.SP2

null

5.13.3 5.13.4

null

MP-2

null

MP-2

null

164.310(c)

2.S.A 8.S.A

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

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

2.D.8 3.3.7 MP-2

null

8-310

5.1 5.2 17.2

6.10

null

5.8

null

MP-2

null

§ 2447(c)(6) § 2447(c)(7)

3.4.4(36)(d)

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

7.1 7.3 15.5

null

2-3-1-2 2-5

TPC-12 TPC-22

null

2-3-4 2-4-4

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

null

Sec 19

null

8.3.1 [MP.EQ.1]

null

4

null

Principle 1.1

Principle 1.1 Principle 1.2

null

11.2.9

null

4.5

11.3.1 11.3.2 11.3.3 11.3.4 11.3.5 11.4.1 11.4.2 11.4.3

null

5.12

null

4.3 4.4

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-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

null

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

Endpoint Security

Endpoint Protection Measures

END-02

Mechanisms exist to protect the confidentiality, integrity, availability and safety of endpoint devices.

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

null

Does the organization protect the confidentiality, integrity, availability and safety of endpoint devices?

9

Protect

null

X

There is no evidence of a capability to protect the confidentiality, integrity, availability and safety of endpoint devices.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized. • All endpoint devices containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information at rest (e.g., full drive encryption). • Security awareness training covers unauthorized alterations and evidence of tampering of technology assets. • IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all projects.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • An ITAM function, or similar function, uses a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets that is configured to perform integrity checking and alert on unauthorized configuration changes. • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature. • A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of Personal Data (PD) processed, stored or transmitted on endpoint devices, so that cybersecurity & data privacy controls are implemented in accordance with applicable statutory, regulatory and contractual obligations. • Administrative processes exist and technologies are configured to notify individuals that Personal Data (PD) is collected by sensors. • File Integrity monitor (FIM) technology is deployed to all HVAs to detect and report unauthorized changes to business-critical system files and configurations. • Host-based Intrusion Detection/Prevention Systems (HIDS/HIPS) technology is deployed to all HVAs to detect and report unauthorized changes to business-critical system files and configurations.

Endpoint Security (END) 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.

Endpoint Security (END) 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

10.0 10.3 10.4 10.5 11.0

10.3

10.3 10.4 10.5

DSS05.01 DSS05.03

null

TVM-02 TVM-04 UEM-02 UEM-05

null

FR 3 (7.1)

null

8.1 8.5

null

T1003, T1003.001, T1003.002, T1003.003, T1003.004, T1003.005, T1003.006, T1003.007, T1003.008, T1005, T1025, T1041, T1048, T1048.002, T1048.003, T1052, T1052.001, T1078, T1078.001, T1078.003, T1078.004, T1213, T1213.001, T1213.002, T1530, T1550.001, T1552, T1552.001, T1552.002, T1552.003, T1552.004, T1565, T1565.001, T1565.003, T1567, T1599, T1599.001, T1602, T1602.001, T1602.002

null

SC-28

null

SC-28

null

SC-28

null

SC-28

null

SC-28

null

SC-28

null

SC-28

3.13.16

null

3.13.16

null

PR.DS-10

null

3.4 3.4.1

1.5 1.5.1

null

1.5.1

null

1.5.1

null

M.1.7

null

5.2.3

null

5.13.3 5.13.4

null

SC.L2-3.13.16

null

SC.L2-3.13.16

SC-28

null

SC-28

null

SC-28

null

SC-28

null

164.310(c)

2.S.A 8.S.A

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

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

SC-28

null

8-604

5.1 5.2

6.10

null

5.8

null

SC-28

null

17.04(5)

null

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

null

SC-28

null

§ 2447(c)(6) § 2447(c)(7)

null

7.1 7.3 15.5

null

2-3-1-2

TPC-22

null

4

null

4.5

null

4.3 4.4

null

MA 201 CMR 17 OR 6464A

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-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

null

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

Endpoint Security

Prohibit Installation Without Privileged Status

END-03

Automated mechanisms exist to prohibit software installations without explicitly assigned privileged status.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/) - Removal of local admin rights - Privileged Account Management (PAM) - NNT Change Tracker (https://www.newnettechnologies.com)

null

Does the organization use automated mechanisms to prohibit software installations without explicitly assigned privileged status?

9

Protect

X

There is no evidence of a capability to prohibit software installations without explicitly assigned privileged status.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, 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 Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

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

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to prohibit software installations without explicitly assigned privileged status.

null

CC6.8-POF1

null

UEM-07

IAM-04

null

12.5.1 12.6.2

8.19

12.5.1 12.6.2

null

6.9.6.2

null

CM-11 CM-11(2)

CM-11

CM-11 CM-11(2)

null

CM-11

CM-11(2)

null

CM-11

null

CM-11

null

CM-11

3.4.9

null

PR.PS-05

null

M.1.31

null

AM:SG1.SP1 COMP:SG3.SP2 MON:SG2.SP3

1.5

null

CM.L2-3.4.9

null

CM.L2-3.4.9

CM-11

null

CM-11

null

2.S.A

2.M.A

CM-11

null

6.10

null

III.D.1.d

null

CM-11

null

6.3

null

3

null

Principle 1.1

Principle 1.1 Principle 1.2

null

12.5.1 12.5.1.1.PB 12.6.2

null

x

null

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-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

Endpoint Security

Software Installation Alerts

END-03.1

Mechanisms exist to generate an alert when new software is detected.

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

null

Does the organization generate an alert when new software is detected?

8

Protect

null

X

There is no evidence of a capability to generate an alert when new software is detected.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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 generate an alert when new software is detected.

null

CC6.8-POF2

null

2.3

null

CM-11(1)

null

CM-8(3) CM-11(3)

null

CM-8(3)

CM-11(3)

null

CM-8(3)

null

G.2.5.7

null

CM-11(1)

null

CM-11(1)

null

6.3

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-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

null

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

Endpoint Security

Governing Access Restriction for Change

END-03.2

Mechanisms exist to define, document, approve and enforce access restrictions associated with changes to systems.

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

null

Does the organization define, document, approve and enforce access restrictions associated with changes to systems?

8

Protect

null

X

There is no evidence of a capability to define, document, approve and enforce access restrictions associated with changes to systems.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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 define, document, approve and enforce access restrictions associated with changes to systems.

null

UEM-02 UEM-03

null

12.5.1

8.19

12.5.1

null

6.9.5 6.9.5.1

null

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

null

CM-5

null

CM-5

null

CM-5

null

CM-5

null

CM-5

null

CM-5

null

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

null

G.2.5.7

null

TM:SG4.SP1

null

CM-5

null

CM-5

null

CM-5

null

CM-5

null

CM-5

null

CM-5

null

CM-5

null

12.5.1 12.5.1.1.PB

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-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

null

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

Endpoint Security

Malicious Code Protection (Anti-Malware)

END-04

Mechanisms exist to utilize antimalware technologies to detect and eradicate malicious code.

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

null

Does the organization utilize antimalware technologies to detect and eradicate malicious code?

10

Detect

null

X

There is no evidence of a capability to utilize antimalware technologies to detect and eradicate malicious code.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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 antimalware technologies to detect and eradicate malicious code.

CC6.8

CC6.8-POF4

null

9.7 10.1

10.1

9.7 10.1

DSS05.01

null

TVM-02 UEM-09

CLS-14

SO12

null

CR 3.2 (7.4) SAR 3.2 (12.3.1) HDR 3.2 (14.4.1) NDR 3.2 (15.6.1)

null

12.2.1

8.7

12.2.1

null

6.9.2 6.9.2.1

null

T1001, T1001.001, T1001.002, T1001.003, T1003, T1003.001, T1003.002, T1003.003, T1003.004, T1003.005, T1003.006, T1003.007, T1003.008, T1005, T1008, T1011.001, T1021.003, T1021.005, T1025, T1027, T1027.002, T1029, T1030, T1036, T1036.003, T1036.005, T1037, T1037.002, T1037.003, T1037.004, T1037.005, T1041, T1046, T1047, T1048, T1048.001, T1048.002, T1048.003, T1052, T1052.001, T1055, T1055.001, T1055.002, T1055.003, T1055.004, T1055.005, T1055.008, T1055.009, T1055.011, T1055.012, T1055.013, T1055.014, T1056.002, T1059, T1059.001, T1059.002, T1059.003, T1059.004, T1059.005, T1059.006, T1059.007, T1059.008, T1068, T1070, T1070.001, T1070.002, T1070.003, T1071, T1071.001, T1071.002, T1071.003, T1071.004, T1072, T1080, T1090, T1090.001, T1090.002, T1091, T1092, T1095, T1098.004, T1102, T1102.001, T1102.002, T1102.003, T1104, T1105, T1106, T1111, T1132, T1132.001, T1132.002, T1137, T1137.001, T1176, T1185, T1189, T1190, T1201, T1203, T1204, T1204.001, T1204.002, T1204.003, T1210, T1211, T1212, T1218, T1218.001, T1218.002, T1218.003, T1218.004, T1218.005, T1218.008, T1218.009, T1218.012, T1218.013, T1218.014, T1219, T1221, T1485, T1486, T1490, T1491, T1491.001, T1491.002, T1505.004, T1525, T1539, T1543, T1543.002, T1546.002, T1546.003, T1546.004, T1546.006, T1546.013, T1546.014, T1547.002, T1547.005, T1547.006, T1547.007, T1547.008, T1547.013, T1548, T1548.004, T1553.003, T1557, T1557.001, T1557.002, T1558, T1558.002, T1558.003, T1558.004, T1559, T1559.001, T1559.002, T1560, T1560.001, T1561, T1561.001, T1561.002, T1562, T1562.001, T1562.002, T1562.004, T1562.006, T1564.004, T1564.008, T1564.009, T1566, T1566.001, T1566.002, T1566.003, T1567, T1568, T1568.002, T1569, T1569.002, T1570, T1571, T1572, T1573, T1573.001, T1573.002, T1574, T1574.001, T1574.004, T1574.007, T1574.008, T1574.009, T1598, T1598.001, T1598.002, T1598.003, T1602, T1602.001, T1602.002, T1611

TS-1.0 TS-1.3

null

SI-3

null

SI-3

null

SI-3

null

SI-3

null

SI-3

3.14.2

3.14.2.a 3.14.2.c 3.14.2.c.1 3.14.2.c.2

3.14.2[a] 3.14.2[b] 3.14.5[a] 3.14.5[b] 3.14.5[c]

A.03.14.02.a[01] A.03.14.02.a[02] A.03.14.02.c.01[01] A.03.14.02.c.01[02] A.03.14.02.c.02 A.03.14.02.ODP[01]

3.13.1e

null

DE.CM-4

null

5.1 5.1.1 5.1.2 5.2 5.3

5.2.1 5.2.2 5.3.1 5.3.2 5.3.2.1 5.3.3 5.3.4 5.3.5

null

5.2.1 5.2.2 5.3.1 5.3.2 5.3.2.1 5.3.3 5.3.4 5.3.5

null

5.2.1 5.2.2 5.3.1 5.3.2 5.3.2.1 5.3.3 5.3.4 5.3.5

5.2.1 5.2.2 5.3.1 5.3.2 5.3.3 5.3.4 5.3.5

5.2.1 5.2.2 5.3.1 5.3.2 5.3.2.1 5.3.3 5.3.4 5.3.5

null

U.1.5.1

6.1

5.2.3

14.1 14.2

null

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

null

5.10.4.2

SI.L1-3.14.2

SI.L1-3.14.2 TBD - 3.13.1e

SI.L1-b.1.xii SI.L1-b.1.xiii SI.L1-b.1.xiv SI.L1-b.1.xv

SI.L2-3.14.2

SI-3

null

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

null

SI-3

null

D3.DC.Th.B.2

null

2.S.A 8.S.A

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

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

SI-3

null

CIP-007-6 R3

8-305

17.2

6.10 6.12 6.14

null

5.8

SI-3

null

17.04(7)

null

SI-3

null

§ 2447(c)(6)

null

OPS-04 OPS-05

null

7.1 7.3 12.20 15.5

null

TPC-12

null

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

2-3-1-8

null

7.3.6 [OP.EXP.6]

null

B4.c

null

4

null

1417 1286 1284 1288 1289 1290

null

12.2.1

null

14.1.9.C.02

null

4.5

11.3.3

null

6.12

null

4.3 4.4

null

x

FAR 52.204-21 MA 201 CMR 17

null

x

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

null

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

- updated DFARS mapping - updated CIS 8.0

Endpoint Security

Automatic Antimalware Signature Updates

END-04.1

Mechanisms exist to automatically update antimalware technologies, including signature definitions.

- Antimalware software

null

Does the organization automatically update antimalware technologies, including signature definitions?

9

Protect

null

X

There is no evidence of a capability to automatically update antimalware technologies, including signature definitions.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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 automatically update antimalware technologies, including signature definitions.

null

10.2

null

TVM-04 TVM-05

null

HDR 3.2 (14.4.3(1))

null

12.2.1

8.7

12.2.1

null

TS-1.3

null

SI-3(2)

null

SI-3(2)

SI-2 SI-3

null

SI-2 SI-3

null

SI-2 SI-3

null

SI-2 SI-3

null

SI-2 SI-3

3.14.4

3.14.2.b

3.14.4

A.03.14.02.b

null

5.2

5.3.1

null

5.3.1

null

5.3.1

null

U.1.5.2.1

6.1

null

SI.L1-3.14.4

SI.L1-b.1.xiv

SI.L2-3.14.4

SI-3(2)

null

52.204-21(b)(1)(xiv)

null

SI-3(2)

null

SI-3(2)

null

2.S.A

1.M.A 2.M.A

SI-2 SI-3

null

6.13

null

SI-3(2)

null

SI-2 SI-3

null

SI-3(2)

null

§ 2447(c)(7)

null

7.9

null

C1.d

null

4

null

12.2.1

null

11.3.4

null

x

FAR 52.204-21

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-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

null

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

Endpoint Security

Documented Protection Measures

END-04.2

Mechanisms exist to document antimalware technologies.

null

Does the organization document antimalware technologies?

3

Identify

null

X

null

There is no evidence of a capability to document antimalware technologies.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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 document antimalware technologies.

null

TVM-02

null

5.4

5.1.2

null

5.1.2

null

U.1.5.1

null

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

null

R-AM-3

null

R-BC-2

null

R-BC-4

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

null

R-GV-4

null

R-GV-6

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

Endpoint Security

Centralized Management of Antimalware Technologies

END-04.3

Mechanisms exist to centrally-manage antimalware technologies.

- Antimalware software

E-MON-02

Does the organization centrally-manage antimalware technologies?

8

Detect

X

There is no evidence of a capability to centrally-manage antimalware technologies.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

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

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

null

9.7 10.6

null

10.6

9.7 10.6

null

TVM-03 TVM-04 TVM-05

null

HDR 3.2 (14.4.3(1))

null

TS-1.3

null

SI-3(1)

null

SI-3(1)

PL-9

null

PL-9

null

PL-9

null

5.3.4

null

5.3.4

null

5.3.4

null

U.1.5.2

null

SI-3(1)

null

SI-3(1)

null

SI-3(1)

null

SI-3(1)

null

SI-3(1)

null

7.7 12.20

null

11.3.5

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

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

- updated CIS 8.0

Endpoint Security

Heuristic / Nonsignature-Based Detection

END-04.4

Mechanisms exist to utilize heuristic / nonsignature-based antimalware detection capabilities.

- Antimalware software

null

Does the organization utilize heuristic / nonsignature-based antimalware detection capabilities?

8

Detect

null

X

There is no evidence of a capability to utilize heuristic / nonsignature-based antimalware detection capabilities.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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 heuristic / nonsignature-based antimalware detection capabilities.

null

10.7

null

10.7

null

TS-1.3

null

SI-3(7)

null

SI-3

null

SI-3

null

SI-3

null

SI-3

null

SI-3

null

U.1.5.1

null

SI-3(7)

null

SI-3(7)

null

1.L.A

SI-3

null

SI-3(7)

null

SI-3

null

SI-3(7)

null

7.8

null

2-4-3-4

null

1286

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

Endpoint Security

Malware Protection Mechanism Testing

END-04.5

Mechanisms exist to test antimalware technologies by introducing a known benign, non-spreading test case into the system and subsequently verifying that both detection of the test case and associated incident reporting occurs.

- EICAR test file

null

Does the organization test antimalware technologies by introducing a known benign, non-spreading test case into the system and subsequently verifying that both detection of the test case and associated incident reporting occurs?

5

Detect

null

X

There is no evidence of a capability to test antimalware technologies by introducing a known benign, non-spreading test case into the system and subsequently verifying that both detection of the test case and associated incident reporting occurs.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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 test antimalware technologies by introducing a known benign, non-spreading test case into the system and subsequently verifying that both detection of the test case and associated incident reporting occurs.

null

CR 3.3 (7.5.1)

null

SI-3(6)

null

SI-3(6)

null

SI-3(6)

null

K.16.1

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

Endpoint Security

Evolving Malware Threats

END-04.6

Mechanisms exist to perform periodic evaluations evolving malware threats to assess systems that are generally not considered to be commonly affected by malicious software.

null

Does the organization perform periodic evaluations evolving malware threats to assess systems that are generally not considered to be commonly affected by malicious software?

3

Detect

null

X

null

There is no evidence of a capability to perform periodic evaluations evolving malware threats to assess systems that are generally not considered to be commonly affected by malicious software.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

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

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to perform periodic evaluations evolving malware threats to assess systems that are generally not considered to be commonly affected by malicious software.

null

3.13.1e

null

5.1.2

5.2.3 5.2.3.1

null

5.2.3 5.2.3.1

null

5.2.3 5.2.3.1

null

5.2.3 5.2.3.1

null

J.3.1

null

TBD - 3.13.1e

null

12.20

null

x

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

R-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

Endpoint Security

Always On Protection

END-04.7

Mechanisms exist to ensure that anti-malware technologies are continuously running in real-time and cannot be disabled or altered by non-privileged users, unless specifically authorized by management on a case-by-case basis for a limited time period.

- Antimalware software

null

Does the organization ensure that anti-malware technologies are continuously running in real-time and cannot be disabled or altered by non-privileged users, unless specifically authorized by management on a case-by-case basis for a limited time period?

9

Detect

null

X

There is no evidence of a capability to ensure that anti-malware technologies are continuously running in real-time and cannot be disabled or altered by non-privileged users, unless specifically authorized by management on a case-by-case basis for a limited time period.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

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

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure that anti-malware technologies are continuously running in real-time and cannot be disabled or altered by non-privileged users, unless specifically authorized by management on a case-by-case basis for a limited time period.

null

CC6.8-POF5

null

TVM-02 UEM-09

null

TS-1.0 TS-1.3

null

3.14.5

3.14.2.a 3.14.2.c 3.14.2.c.1 3.14.2.c.2

3.14.5[c]

null

5.3

5.3.2 5.3.2.1 5.3.3 5.3.5

null

5.3.2 5.3.2.1 5.3.3 5.3.5

null

5.3.2 5.3.2.1 5.3.3 5.3.5

5.3.2 5.3.3 5.3.5

5.3.2 5.3.2.1 5.3.3 5.3.5

null

U.1.5.2.4

null

SI.L1-3.14.5

SI.L1-b.1.xv

SI.L2-3.14.5

null

52.204-21(b)(1)(xv)

null

2.S.A 8.S.A

null

6.12 6.14

null

7.5 12.25

null

2-3-1-8

null

x

FAR 52.204-21

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

Endpoint Security

Software Firewall

END-05

Mechanisms exist to utilize host-based firewall software, or a similar technology, on all information systems, where technically feasible.

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

null

Does the organization utilize host-based firewall software, or a similar technology, on all information systems, where technically feasible?

9

Protect

null

X

There is no evidence of a capability to utilize host-based firewall software, or a similar technology, on all information systems, where technically feasible.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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 host-based firewall software, or a similar technology, on all information systems, where technically feasible.

null

4.5

null

UEM-10

null

6.11.1.2

null

1.4

1.5.1

null

1.5.1

null

1.5.1

null

I.3.23

null

2.S.A

null

§ 2447(c)(6)

null

1

null

1416

null

4.3 4.4

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

Endpoint Security

Endpoint File Integrity Monitoring (FIM)

END-06

Mechanisms exist to utilize File Integrity Monitor (FIM) technology to detect and report unauthorized changes to system files and configurations.

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

null

Does the organization utilize File Integrity Monitor (FIM) technology to detect and report unauthorized changes to system files and configurations?

8

Protect

null

X

There is no evidence of a capability to utilize File Integrity monitor (FIM) technology to detect and report unauthorized changes to system files and configurations.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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.

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

CC6.8

CC7.1-POF2 CC7.1-POF3 CC7.1-POF4

null

SAP-06

SO12

null

FR 3 (7.1)

null

T1003, T1003.003, T1020.001, T1027, T1027.002, T1036, T1036.001, T1036.005, T1037, T1037.002, T1037.003, T1037.004, T1037.005, T1040, T1047, T1053.006, T1056.002, T1059, T1059.001, T1059.002, T1059.003, T1059.004, T1059.005, T1059.006, T1059.007, T1059.008, T1068, T1070, T1070.001, T1070.002, T1070.003, T1072, T1080, T1098.001, T1098.002, T1098.003, T1114, T1114.001, T1114.002, T1114.003, T1119, T1127, T1129, T1133, T1136, T1136.001, T1136.002, T1136.003, T1176, T1185, T1189, T1190, T1195.003, T1203, T1204, T1204.002, T1204.003, T1210, T1211, T1212, T1213, T1213.001, T1213.002, T1216, T1216.001, T1218, T1218.001, T1218.002, T1218.003, T1218.004, T1218.005, T1218.008, T1218.009, T1218.010, T1218.011, T1218.012, T1218.013, T1218.014, T1219, T1220, T1221, T1222, T1222.001, T1222.002, T1485, T1486, T1490, T1491, T1491.001, T1491.002, T1495, T1505, T1505.001, T1505.002, T1505.004, T1525, T1530, T1542, T1542.001, T1542.003, T1542.004, T1542.005, T1543, T1543.002, T1546, T1546.002, T1546.004, T1546.006, T1546.008, T1546.009, T1546.010, T1546.013, T1547.002, T1547.003, T1547.004, T1547.005, T1547.006, T1547.008, T1547.011, T1547.013, T1548, T1548.004, T1550.001, T1550.004, T1552, T1552.004, T1553, T1553.001, T1553.003, T1553.005, T1553.006, T1554, T1556, T1556.001, T1556.003, T1556.004, T1557, T1557.002, T1558, T1558.002, T1558.003, T1558.004, T1561, T1561.001, T1561.002, T1562, T1562.001, T1562.002, T1562.004, T1562.006, T1562.009, T1564.003, T1564.004, T1564.006, T1564.008, T1564.009, T1565, T1565.001, T1565.002, T1569, T1569.002, T1574, T1574.001, T1574.004, T1574.006, T1574.007, T1574.008, T1574.009, T1574.012, T1599, T1599.001, T1601, T1601.001, T1601.002, T1602, T1602.001, T1602.002, T1609, T1611

TS-2.6

null

PR.DS-P6 PR.DS-P8

null

SI-7

null

SI-7

null

SI-7

null

SI-7

null

SI-7

null

SI-7

null

PR.DS-6

DE.CM-09

null

11.5 11.5.1

10.3.4 11.5 11.5.2

null

11.5.2

null

11.5.2

null

11.5.2

null

M.1.43

6.2

null

KIM:SG5.SP1 KIM:SG5.SP2 KIM:SG5.SP3 TM:SG4.SP1 TM:SG4.SP2 TM:SG4.SP3 TM:SG4.SP4

null

SI-7

null

SI-7

null

SI-7

null

SI-7

null

SI-7

null

D3.PC.Se.Int.3 D3.PC.De.Int.2

null

2.L.D

SI-7

null

8-302

null

SI-7

null

SI-7

null

3.4.4(36)(e)

null

6.4 12.19

null

1-5-4

null

14.1.12.C.01 14.1.12.C.02 14.1.12.C.03

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

Endpoint Security

Integrity Checks

END-06.1

Mechanisms exist to validate configurations through integrity checking of software and firmware.

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

null

Does the organization validate configurations through integrity checking of software and firmware?

6

Detect

null

X

There is no evidence of a capability to validate configurations through integrity checking of software and firmware.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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.

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

CC7.1

null

PR.DS-P6 PR.DS-P8

null

SI-7(1)

null

SI-7(1)

null

SI-7(1)

null

SI-7(1)

null

PR.DS-6

null

L.24.3.1

6.2

null

SI-7(1)

null

SI-7(1)

null

SI-7(1)

null

SI-7(1)

null

SI-7(1)

null

SI-7(1)

null

SI-7(1)

null

SI-7(1)

null

x

null

x

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

Endpoint Security

Integration of Detection & Response

END-06.2

Mechanisms exist to detect and respond to unauthorized configuration changes as cybersecurity incidents.

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

null

Does the organization detect and respond to unauthorized configuration changes as cybersecurity incidents?

9

Respond

null

X

null

There is no evidence of a capability to detect and respond to unauthorized configuration changes as cybersecurity incidents.

Endpoint Security (END) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel. • IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity & data privacy controls. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software. • Data management is decentralized.

Endpoint Security (END) 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: • Endpoint security 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 endpoint security management. • Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software. • Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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 detect and respond to unauthorized configuration changes as cybersecurity incidents.

CC7.3

null

PR.DS-P6 PR.DS-P8

null

SI-7(7)

null

SI-7(7)

null

SI-7(7)

null

SI-7(7)

null

10.7 10.7.1 10.7.2 10.7.3

null

10.7.2 10.7.3

10.7.1 10.7.2 10.7.3

null

J.2

null

SITUATION-3.G.MIL3

null

SI-7(7)

null

SI-7(7)

null

SI-7(7)

null

SI-7(7)

null

SI-7(7)

null

2.L.D

SI-7(7)

null

SI-7(7)

null

SI-7(7)

null

7.2

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

Endpoint Security

Automated Notifications of Integrity Violations

END-06.3

Automated mechanisms exist to alert incident response personnel upon discovering discrepancies during integrity verification.

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

null

Does the organization use automated mechanisms to alert incident response personnel upon discovering discrepancies during integrity verification?

5

Respond

null

X

There is no evidence of a capability to alert incident response personnel up on discovering discrepancies during integrity verification.

SP-CMM1 is N/A, since a structured process is required to alert incident response personnel up on discovering discrepancies during integrity verification.

SP-CMM2 is N/A, since a well-defined process is required to alert incident response personnel up on discovering discrepancies during integrity verification.

Endpoint Security (END) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Configuration management is centralized for all operating systems, applications, servers and other configurable technologies. • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments. • Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments. • An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities. • A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities. • The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. • Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.

Endpoint Security (END) 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.

Endpoint Security (END) 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

PR.DS-P6 PR.DS-P8

null

SI-7(2)

null

SI-7(2)

null

SI-7(2)

null

SI-7(2)

null

J.2.10

null

SI-7(2)

null

SI-7(2)

null

SI-7(2)

null

SI-7(2)

null

x

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

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

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

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

null