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+Flaw Remediation with Personal Data (PD) |
Flaw Remediation with Personal Data (PD)DescriptionMechanisms exist to identify and correct flaws related to the collection, usage, processing or dissemination of Personal Data (PD).Possible Solutions & ConsiderationsMicro-Small Business (<10 staff) / BLS Firm Size Classes 1-2∙ Patch systems containing personal data promptlySmall Business (10-49 staff) / BLS Firm Size Classes 3-4∙ Priority patching policy for systems containing personal dataMedium Business (50-249 staff) / BLS Firm Size Classes 5-6∙ Formal vulnerability remediation policy for PD systems∙ Accelerated SLAs for PD systems Large Business (250-999 staff) / BLS Firm Size Classes 7-8∙ Enterprise vulnerability management with PD system prioritizationEnterprise (> 1,000 staff) / BLS Firm Size Class 9∙ Enterprise vulnerability management platform with data sensitivity tagging∙ Automated PD system prioritization SCR-CMMLevel 0 Not PerformedPractices 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 InformallySCR-CMM Level 1 criteria definitions are not available for this control:▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Vulnerability & Patch Management (VPM) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with VPM domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Attack Surface Management (ASM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. Level 2 Planned TrackedVulnerability & Patch Management (VPM) 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 VPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with VPM 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 VPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Vulnerability management-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Vulnerability management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. Level 3 Well DefinedVulnerability & Patch Management (VPM) 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 VPM 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 VPM domain capabilities are well-documented and kept current by process owners. ▪ A vulnerability management team, or similar function, is appropriately staffed and supported to implement and maintain VPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of vulnerability management operations (e.g., patch management solution, vulnerability scanning solution, etc.). ▪ 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 VPM 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 identify and correct flaws related to the collection, usage, processing or dissemination of Personal Data (PD). Level 4 Quantitatively ControlledVulnerability & Patch Management (VPM) 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 ImprovingVulnerability & Patch Management (VPM) 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. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes. ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. 1. Overview
1.1 References1.2 Identified Requirements1.3 Related Regulations2. Identified Requirements
3. Related Regulations
Linked Issues
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