+Sensitive Data Inventories
---+Periodic Scans for Sensitive / Regulated Data

Sensitive Data Inventories

Description

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

Possible Solutions & Considerations

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

∙ Data classification program
∙ Sensitive data inventories

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

∙ Data classification program
∙ Sensitive data inventories

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

∙ Data classification program
∙ Sensitive data inventories

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

∙ Data classification program
∙ Sensitive data inventories
∙ Data governance program

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

∙ Data classification program
∙ Sensitive data inventories
∙ Data governance program

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

SCR-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.

Level 2 Planned Tracked

Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to document where sensitive/regulated data is stored, transmitted and/or processed.

Level 3 Well Defined

Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners.
▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform).
▪ 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 DCH 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 maintain inventory logs of all sensitive media and conduct sensitive media inventories at least annually.

Level 4 Quantitatively Controlled

Data Classification & Handling (DCH) 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
Periodic Scans for Sensitive / Regulated Data

Description

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

Possible Solutions & Considerations

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

∙ Data classification policy (public/internal/confidential)

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

∙ Data classification policy
∙ Data handling procedures

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

∙ Data classification program
∙ DLP tools
∙ Data handling standards

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

∙ Enterprise DLP solution (e.g., Microsoft Purview, Symantec DLP)
∙ Data classification tool

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

∙ Enterprise data governance platform (e.g., Collibra)
∙ DLP with automated classification
∙ Data lifecycle management

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

SCR-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.

Level 2 Planned Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners.
▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform).
▪ 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 DCH 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 periodically scan unstructured data sources for sensitive/regulated data or data requiring special protection measures by statutory, regulatory or contractual obligations.

Level 4 Quantitatively Controlled

Data Classification & Handling (DCH) 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.

1.1 Odkazy

1.2 Identifikované požadavky

1.3 Související regulace

2. Identifikované požadavky

Požadavky
Zdroj Požadavek

3. Související regulace

Regulace
Zdroj Regulace

Propojené úkoly

Vazby
Typ vazby Úkol
is related to Annual
is related to relative Control Weighting = 02
is related to Technology
is related to Protect
is related to SCRM Focus Tier 3 TACTICAL
blocks Unauthorized Access
blocks Unauthorized Retention / Inability to Dispose of Data
blocks Data Loss / Integrity Compromise
blocks System / Data Compromise (Technical Vector)
blocks System / Data Compromise (Non-Technical Vector)
blocks Revenue Loss
blocks Contractual Default / Termination
blocks Loss of Competitive Advantage
blocks Reputational Harm / Loss of Stakeholder Trust
blocks Regulatory / Legal / Contractual Financial Liability
blocks Exposure from Unaddressed Vulnerabilities
blocks System / Service Compromise
blocks Failure to Support Business / Mission Objectives
blocks Unaddressed Security / Compliance Exposure
blocks Uncontrolled Internal Security / Privacy Exposure
blocks Uncontrolled Third-Party Security / Privacy Exposure
blocks OS Credential Dumping
blocks NTDS
blocks Data from Local System
blocks Traffic Duplication
blocks Data from Removable Media
blocks Network Sniffing
blocks Exfiltration Over C2 Channel
blocks Exfiltration Over Alternative Protocol
blocks Exfiltration Over Asymmetric Encrypted Non-C2 Protocol
blocks Exfiltration Over Unencrypted Non-C2 Protocol
blocks Exfiltration Over Physical Medium
blocks Exfiltration over USB
blocks Indicator Removal
blocks Clear Mailbox Data
blocks Email Collection
blocks Local Email Collection
blocks Remote Email Collection
blocks Email Forwarding Rule
blocks Automated Collection
blocks Data from Information Repositories
blocks Confluence
blocks Sharepoint
blocks Customer Relationship Management Software
blocks Messaging Applications
blocks File and Directory Permissions Modification
blocks Windows Permissions
blocks Linux and Mac Permissions
blocks Server Software Component
blocks Transport Agent
blocks Data from Cloud Storage
blocks Transfer Data to Cloud Account
blocks Re-opened Applications
blocks Abuse Elevation Control Mechanism
blocks Sudo and Sudo Caching
blocks TCC Manipulation
blocks Application Access Token
blocks Unsecured Credentials
blocks Private Keys
blocks Cloud Instance Metadata API
blocks Conditional Access Policies
blocks Adversary-in-the-Middle
blocks ARP Cache Poisoning
blocks Steal or Forge Kerberos Tickets
blocks Silver Ticket
blocks Kerberoasting
blocks AS-REP Roasting
blocks NTFS File Attributes
blocks Data Manipulation
blocks Stored Data Manipulation
blocks Transmitted Data Manipulation
blocks Exfiltration Over Web Service
blocks Data from Configuration Repository
blocks SNMP (MIB Dump)
blocks Network Device Configuration Dump
blocks Plist File Modification
is related to relative Control Weighting = 09
is related to Data
is related to Detect
is related to SCRM Focus Tier 2 OPERATIONAL
blocks Loss of Accountability / Attribution
blocks Loss, Theft or Damage of Assets
blocks Intellectual Property / Trade Secret Loss
blocks Loss of Authorization / Certification / License
blocks Lack of oversight of internal controls
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Unreliable Assurance / Decision Information
blocks Loss of Investigative / Evidentiary Capability
blocks Undetected / Delayed Detection of Adverse Activity
blocks Loss of Confidentiality
blocks Privacy Harm / Unauthorized Processing
blocks Drought & Water Shortage
blocks Earthquakes
blocks Fire & Wildfires
blocks Floods
blocks Hurricanes & Tropical Storms
blocks Landslides & Debris Flow
blocks Pandemic (Disease) Outbreaks
blocks Severe Weather
blocks Space Weather
blocks Thunderstorms & Lightning
blocks Tornadoes
blocks Tsunamis
blocks Volcanoes
blocks Winter Storms & Extreme Cold
blocks Civil or Political Unrest
blocks Malicious Cyber Activity
blocks Hazardous Materials Emergencies
blocks Nuclear, Biological and Chemical (NBC) Weapons
blocks Physical Crime
blocks Terrorism & Armed Attacks
blocks Dysfunctional Management Practices
blocks Human Error
blocks Technical / Mechanical Failure
blocks Statutory / Regulatory / Contractual Change
blocks Data Quality Degradation / Data Poisoning
blocks Fraud, Corruption and/or Intentional Criminal Conduct
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
is blocked by DCH-05 Sensitive Data Inventories – Assessment Procedure
blocks 03.04.11 Information Location
blocks ID.AM-07 Inventories of data and corresponding metadata for designated data types are maintained
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