+Cryptographic Exception Register

Cryptographic Exception Register

Description

Mechanisms exist to govern each Post-Quantum Cryptography (PQC) deviation in a formal cryptographic exception register that contains, at a minimum:
(1) Asset and/or process owner(s);
(2) Compensating control(s);
(3) Planned remediation date; and
(4) Re-evaluation date.

Possible Solutions & Considerations

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

∙ Note known uses of quantum-vulnerable cryptography that cannot yet be changed (simple list)

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

∙ Simple exception register for known quantum-vulnerable algorithm uses

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

∙ Cryptographic exception register with owner, compensating controls, and remediation dates
∙ Integration with risk register

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

∙ Formal cryptographic exception register
∙ GRC platform integration
∙ Regular review and escalation process for aged exceptions

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

∙ Enterprise cryptographic exception register within GRC platform
∙ Automated exception tracking and escalation
∙ Integration with PQC migration roadmap and compliance reporting

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

Quantum Security (QTS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with QTS domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Risk management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Inventories are manual (e.g., spreadsheets).
▪ IT and/or cybersecurity personnel use an informal process to identify, assess, remediate and report on quantum security-related risk.
▪ Data/process owners are expected to self-manage risks associated with their Technology Assets, Applications, Services and/or Data (TAASD), based on the organization's published policies and standards, including the identification, remediation and reporting of risks.

Level 2 Planned Tracked

Quantum Security (QTS) 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 QTS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with QTS domain capabilities are documented and maintained by process owners.
▪ Quantum security risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk 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 Defined

Quantum Security (QTS) 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 QTS 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 QTS domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain QTS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 QTS 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 govern each Post-Quantum Cryptography (PQC) deviation in a formal cryptographic exception register that contains, at a minimum:
(1) Asset and/or process owner(s);
(2) Compensating control(s);
(3) Planned remediation date; and
(4) Re-evaluation date.

Level 4 Quantitatively Controlled

Quantum Security (QTS) 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. Přehled

Název Standard

1.1 Odkazy

1.2 Identifikované požadavky

1.3 Související regulace

2. Identifikované požadavky

Požadavky
Zdroj Požadavek

3. Související regulace

Regulace
Zdroj Regulace

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