+Cryptographic Agility Risk Assessment (CARA)
---+Cryptographic Exception Register
---+Compensating Controls for Quantum-Vulnerable Systems
---+Crypto Agility Maturity Assessment

Cryptographic Agility Risk Assessment (CARA)

Description

Mechanisms exist to perform a Cryptographic Agility Risk Assessment (CARA) that analyzes Technology Assets, Applications, Services and Data (TAASD) to:
(1) Identify TAASD most vulnerable to quantum-enabled cryptanalytic threats; and
(2) Prioritize TAASD based on potential business impact.

Possible Solutions & Considerations

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

∙ List where encryption is used (website TLS, VPN, email, backups) and note quantum-vulnerable algorithms (RSA, ECC)

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

∙ Inventory of cryptographic algorithms in use
∙ Identification of quantum-vulnerable algorithms (RSA, ECDSA, DH)

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

∙ Structured CARA aligned to NIST guidance
∙ Asset-level mapping of cryptographic algorithm use
∙ Prioritization by business impact

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

∙ Formal CARA process aligned to NIST IR 8547 or equivalent methodology
∙ Integration with risk register and PQC migration planning

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

∙ Enterprise CARA program with automated cryptographic discovery
∙ NIST IR 8547 methodology implementation
∙ Integration with GRC platform and PQC migration roadmap

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.
▪ IT and/or cybersecurity personnel use an informal process to identify, assess, remediate and report on quantum security-related risk.

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 perform a Cryptographic Agility Risk Assessment (CARA) that maps Technology Assets, Applications, Services and Data (TAASD) to:
(1) Identify TAASD most vulnerable to quantum-enabled cryptanalytic threats; and
(2) Prioritize TAASD based on potential business impact.

Level 4 Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

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. Oversigt

Titel Standard
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.
Compensating Controls for Quantum-Vulnerable Systems

Description

Mechanisms exist to implement short-term compensating measures for Technology Assets, Applications and Services (TAAS) that cannot be migrated to Post-Quantum Cryptography (PQC) on the planned schedule, (e.g., network segmentation, additional pre-shared-key layers, reduced key lifetimes, out-of-band key transport and data minimization).

Possible Solutions & Considerations

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

∙ Network isolation of legacy systems using quantum-vulnerable algorithms
∙ Shorten certificate validity periods

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

∙ Network segmentation of quantum-vulnerable systems
∙ Reduce key lifetimes for quantum-vulnerable certificates

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

∙ Network segmentation and additional authentication for quantum-vulnerable systems
∙ Shortened key validity periods
∙ Out-of-band key transport where applicable

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

∙ Network micro-segmentation of quantum-vulnerable systems
∙ Shortened key lifetimes and certificate validity periods
∙ Pre-shared key (PSK) layers on quantum-vulnerable links
∙ Data minimization on quantum-vulnerable paths

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

∙ Automated micro-segmentation of quantum-vulnerable systems
∙ Enterprise PSK and data minimization controls
∙ Continuous monitoring of quantum-vulnerable system exposure
∙ Integration with PQC migration prioritization

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.
▪ 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

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

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 implement short-term compensating measures for Technology Assets, Applications and Services (TAAS) that cannot be migrated to Post-Quantum Cryptography (PQC) on the planned schedule, (e.g., network segmentation, additional pre-shared-key layers, reduced key lifetimes, out-of-band key transport and data minimization).

Level 4 Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

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.
Crypto Agility Maturity Assessment

Description

Mechanisms exist to measure progress in adopting cryptographic agility using defined maturity criteria to support resilience against evolving Post-Quantum Cryptography (PQC) requirements and threats.

Possible Solutions & Considerations

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

∙ Note: Typically not required at this size; review CISA/NIST PQC readiness guidance annually

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

∙ Self-assessment against basic cryptographic agility criteria
∙ NIST PQC readiness checklist

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

∙ Crypto agility maturity assessment against defined criteria
∙ NIST or CISA PQC maturity model
∙ Integration with annual security assessments

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

∙ Formal crypto agility maturity assessment using NIST or CISA PQC maturity framework
∙ Annual assessment with improvement roadmap

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

∙ Enterprise crypto agility maturity program
∙ Third-party validated maturity assessments
∙ Continuous maturity monitoring via GRC platform
∙ Board-level reporting on crypto agility progress

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

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 measure progress in adopting cryptographic agility using defined maturity criteria to support resilience against evolving Post-Quantum Cryptography (PQC) requirements and threats.

Level 4 Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

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 Referencer

1.2 Identificerede krav

1.3 Relaterede reguleringer

2. Identificerede krav

Krav
Kilde Krav

3. Relaterede reguleringer

Reguleringer
Kilde Regulering
EULAW Artikel 6 Kryptering og kryptografiske kontroller
-

Linkede sager

  • Secure Controls Framework -

    The Secure Controls Framework® (SCF)

    "The SCF is the Common Controls Framework™ (CCF), the world's most comprehensive cybersecurity and data privacy metaframework - it is also free to use. The entire concept is building secure, compliant and resilient capabilities in the most efficient and cost-effective manner possible.

    The SCF is more than just a unified control catalog, since its included content creates a playbook for Governance, Risk & Compliance (GRC) capabilities. Used globally by organizations of every size, the SCF is a robust and scalable solution for security, compliance and resilience controls. As a comprehensive security framework, the SCF maps 1,400+ controls across 200+ laws, regulations, and industry frameworks so you can implement once and comply everywhere.

    Like it or not, cybersecurity is a protracted war on an asymmetric battlefield, where the threats are everywhere and as defenders we have to make the effort to work together to help improve cybersecurity and data privacy practices, since we all suffer when massive data breaches occur or when cyber attacks have physical impacts. Hackers share information on attack methods with other hackers, so why shouldn’t the good guys share information on how to best protect an organization? We decided to take action and make a difference, since we feel it is too important to wait for someone else to fix the problems that exist.

    The SCF is made up of volunteers, mainly specialists within the cybersecurity profession, who focus on GRC and the cybersecurity side of data privacy. These are auditors, engineers, architects, incident responders, consultants and other specialists who live and breathe these topics on a daily basis. The end product is "expert-derived content" that makes up the SCF." https://securecontrolsframework.com/ 

    Terms & Conditions

    The SCF End User License Agreement (EULA) governs the use of the Secure Controls Framework® (SCF) under the Creative Commons Attribution-No Derivatives 4.0 International Public License.