+Prohibition Of Changes

Prohibition Of Changes

Description

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

Possible Solutions & Considerations

Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2

∙ Role Based Access Control (RBAC)
∙ Manual processes/workflows
∙ Application whitelisting

Small Business (10-49 staff) / BLS Firm Size Classes 3-4

∙ Role Based Access Control (RBAC)
∙ Manual processes/workflows
∙ Application whitelisting

Medium Business (50-249 staff) / BLS Firm Size Classes 5-6

∙ Role Based Access Control (RBAC)
∙ Application whitelisting
∙ CimTrak Integrity Suite (https://cimcor.com/cimtrak)

Large Business (250-999 staff) / BLS Firm Size Classes 7-8

∙ Role Based Access Control (RBAC)
∙ Application whitelisting
∙ CimTrak Integrity Suite (https://cimcor.com/cimtrak)

Enterprise (> 1,000 staff) / BLS Firm Size Class 9

∙ Role Based Access Control (RBAC)
∙ Application whitelisting
∙ CimTrak Integrity Suite (https://cimcor.com/cimtrak)

SCR-CMM

Level 0 Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 Performed Informally

Change Management (CHG) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with CHG domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Change management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Requests for Change (RFC) are submitted to IT and/or cybersecurity personnel.
▪ Prior to changes being made, RFCs are informally reviewed for cybersecurity and/or data protection ramifications.
▪ Documented change control processes are either informal or do not exist.

Level 2 Planned Tracked

Change Management (CHG) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with CHG domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CHG domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with CHG domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Change management-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Change management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Business stakeholders and process owners ensure changes to Technology Assets, Applications and/or Services (TAAS) within the System Development Lifecycle (SDLC) are controlled through formal change control procedures.
▪ Configuration management practices prevent unauthorized changes by limiting and reviewing permissions to modify TAAS components within a production/operational environment

Level 3 Well Defined

Change Management (CHG) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with CHG domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with CHG domain capabilities are well-documented and kept current by process owners.
▪ A centralized Change Management Office (CMO), or similar function, is appropriately staffed and supported to implement and maintain CHG domain capabilities.
▪ Technical procedures (e.g., ITIL change enablement) are utilized along with change management governance capabilities (e.g., Change Advisory Board (CAB)) to ensure successful, efficient and secure change management operations.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with CHG domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to prohibit unauthorized changes, unless organization-approved change requests are received.

Level 4 Quantitatively Controlled

Change Management (CHG) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ 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 and data protection 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.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

Level 5 Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

1. Overview

1.1 References

1.2 Identified Requirements

1.3 Related Regulations

2. Identified Requirements

Requirements

3. Related Regulations

Regulations

Linked Issues

Issuelinks
is related to Annual
is related to relative Control Weighting = 10
is related to Process
is related to Protect
is related to SCRM Focus Tier 2 OPERATIONAL
is related to SCRM Focus Tier 3 TACTICAL
blocks Inability to maintain individual accountability
blocks Improper assignment of privileged functions
blocks Privilege escalation
blocks Unauthorized access
blocks Lost, damaged or stolen asset(s)
blocks Loss of integrity through unauthorized changes
blocks Emergent properties and/or unintended consequences
blocks Business interruption
blocks Data loss / corruption
blocks Reduction in productivity
blocks Information loss / corruption or system compromise due to technical attack
blocks Information loss / corruption or system compromise due to non‐technical attack
blocks Loss of revenue
blocks Cancelled contract
blocks Diminished competitive advantage
blocks Diminished reputation
blocks Fines and judgements
blocks Unmitigated vulnerabilities
blocks System compromise
blocks Inability to support business processes
blocks Incorrect controls scoping
blocks Lack of roles & responsibilities
blocks Inadequate internal practices
blocks Inadequate third-party practices
blocks Lack of oversight of internal controls
blocks Lack of oversight of third-party controls
blocks Inability to investigate / prosecute incidents
blocks Improper response to incidents
blocks Ineffective remediation actions
blocks Expense associated with managing a loss event
blocks Inability to maintain situational awareness
blocks Third-party cybersecurity exposure
blocks Third-party physical security exposure
blocks Third-party supply chain relationships, visibility and controls
blocks Third-party compliance / legal exposure
blocks Use of product / service
blocks Reliance on the third-party
  • Secure Controls Framework -

    The Secure Controls Framework® (SCF)

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