+Vulnerability & Patch Management Program (VPMP)
---+Attack Surface Scope
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Vulnerability & Patch Management Program (VPMP)
Description
Mechanisms exist to facilitate the implementation and monitoring of vulnerability management controls.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Third-party advisors (e.g., virtual CISO, Managed Security Services Provider (MSSP), etc.)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Third-party advisors (e.g., virtual CISO, Managed Security Services Provider (MSSP), etc.)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Vulnerability & Patch Management Program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Vulnerability & Patch Management Program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Vulnerability & Patch Management 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
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.
▪ IT and/or cybersecurity personnel apply software patches through an informal process.
▪ Occasional vulnerability scanning is conducted on High Value Assets (HVAs).
▪ Vulnerability scanning services may not be internal competencies and have to be outsourced.
▪ Penetration testing services may not be internal competencies and have to be outsourced.
Level 2 Planned Tracked
Vulnerability & 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.
▪ IT and/or cybersecurity personnel define the breadth and depth of coverage for vulnerability scanning that covers system components scanned and types of vulnerabilities that are checked for.
▪ IT and/or cybersecurity personnel maintain a structured process to apply software patches and other vulnerability remediation efforts.
Level 3 Well Defined
Vulnerability & 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 facilitate the implementation and monitoring of vulnerability management controls.
Level 4 Quantitatively Controlled
Vulnerability & 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 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. Übersicht
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Standard |
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Attack Surface Scope
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Description
Mechanisms exist to define and manage the scope for its attack surface management activities.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Identify what systems and software are in scope for security testing
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Attack surface inventory
∙ Define scope for vulnerability management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal attack surface scoping process
∙ Asset-driven attack surface management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise attack surface management (ASM) program
∙ Automated attack surface discovery
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise ASM platform (e.g., CyCognito, Mandiant ASM)
∙ Automated continuous attack surface monitoring
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.
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 Tracked
Vulnerability & 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.
▪ IT and/or cybersecurity personnel define the breadth and depth of coverage for vulnerability scanning that covers system components scanned and types of vulnerabilities that are checked for.
Level 3 Well Defined
Vulnerability & 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 define and manage the scope for its attack surface management activities.
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.
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1.1 Referenzen
1.2 Identifizierte Anforderungen
1.3 Related Regulations
2. Identifizierte Anforderungen
Anforderungen
| Source |
Anforderung |
3. Related Regulations
Regulations
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Regulierung |
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DORA
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DORA Ch. II Sec. II Art. 9 4.
4. As part of the ICT risk management framework referred to in Article 6(1), financial entities shall:
- (a) develop and document an information security policy defining rules to protect the availability, authenticity, integrity and confidentiality of data, information assets and ICT assets, including those of their customers, where applicable;
- (b) following a risk-based approach, establish a sound network and infrastructure management structure using appropriate techniques, methods and protocols that may include implementing automated mechanisms to isolate affected information assets in the event of cyber-attacks;
- For the purposes of the first subparagraph, point (b), financial entities shall design the network connection infrastructure in a way that allows it to be instantaneously severed or segmented in order to minimise and prevent contagion, especially for interconnected financial processes.
- (c) implement policies that limit the physical or logical access to information assets and ICT assets to what is required for legitimate and approved functions and activities only, and establish to that end a set of policies, procedures and controls that address access rights and ensure a sound administration thereof;
- (d) implement policies and protocols for strong authentication mechanisms, based on relevant standards and dedicated control systems, and protection measures of cryptographic keys whereby data is encrypted based on results of approved data classification and ICT risk assessment processes;
- (e) implement documented policies, procedures and controls for ICT change management, including changes to software, hardware, firmware components, systems or security parameters, that are based on a risk assessment approach and are an integral part of the financial entity’s overall change management process, in order to ensure that all changes to ICT systems are recorded, tested, assessed, approved, implemented and verified in a controlled manner;
- For the purposes of the first subparagraph, point (e), the ICT change management process shall be approved by appropriate lines of management and shall have specific protocols in place.
- (f) have appropriate and comprehensive documented policies for patches and updates.
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DORA
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DORA Ch. IV Art. 25 1.
1. The digital operational resilience testing programme referred to in Article 24 shall provide, in accordance with the criteria set out in Article 4(2), for the execution of appropriate tests, such as vulnerability assessments and scans, open source analyses, network security assessments, gap analyses, physical security reviews, questionnaires and scanning software solutions, source code reviews where feasible, scenariobased tests, compatibility testing, performance testing, endto-end testing and penetration testing.
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DORA
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DORA Ch. IV Art. 25 2.
2. Central securities depositories and central counterparties shall perform vulnerability assessments before any deployment or redeployment of new or existing applications and infrastructure components, and ICT services supporting critical or important functions of the financial entity.
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DORA
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DORA Ch. IV Art. 25 3.
3. Microenterprises shall perform the tests referred to in paragraph 1 by combining a risk-based approach with a strategic planning of ICT testing, by duly considering the need to maintain a balanced approach between the scale of resources and the time to be allocated to the ICT testing provided for in this Article, on the one hand, and the urgency, type of risk, criticality of information assets and of services provided, as well as any other relevant factor, including the financial entity’s ability to take calculated risks, on the other hand.
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EULAW
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Article 21 Cybersecurity risk-management measures
Article 21
Cybersecurity risk-management measures
1.
Member States shall ensure that essential and important entities take appropriate and proportionate technical, operational and organisational measures to manage the risks posed to the security of network and information systems which those entities use for their operations or for the provision of their services, and to prevent or minimise the impact of incidents on recipients of their services and on other services.
Taking into account the state-of-the-art and, where applicable, relevant European and international standards, as well as the cost of implementation, the measures referred to in the first subparagraph shall ensure a level of security of network and information systems appropriate to the risks posed. When assessing the proportionality of those measures, due account shall be taken of the degree of the entity’s exposure to risks, the entity’s size and the likelihood of occurrence of incidents and their severity, including their societal and economic impact.
2.
The measures referred to in paragraph 1 shall be based on an all-hazards approach that aims to protect network and information systems and the physical environment of those systems from incidents, and shall include at least the following:
(a)
policies on risk analysis and information system security;
(c)
business continuity, such as backup management and disaster recovery, and crisis management;
(d)
supply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers;
(e)
security in network and information systems acquisition, development and maintenance, including vulnerability handling and disclosure;
(f)
policies and procedures to assess the effectiveness of cybersecurity risk-management measures;
(g)
basic cyber hygiene practices and cybersecurity training;
(h)
policies and procedures regarding the use of cryptography and, where appropriate, encryption;
(i)
human resources security, access control policies and asset management;
(j)
the use of multi-factor authentication or continuous authentication solutions, secured voice, video and text communications and secured emergency communication systems within the entity, where appropriate.
3.
Member States shall ensure that, when considering which measures referred to in paragraph 2, point (d), of this Article are appropriate, entities take into account the vulnerabilities specific to each direct supplier and service provider and the overall quality of products and cybersecurity practices of their suppliers and service providers, including their secure development procedures. Member States shall also ensure that, when considering which measures referred to in that point are appropriate, entities are required to take into account the results of the coordinated security risk assessments of critical supply chains carried out in accordance with Article 22(1).
4.
Member States shall ensure that an entity that finds that it does not comply with the measures provided for in paragraph 2 takes, without undue delay, all necessary, appropriate and proportionate corrective measures.
5.
By 17 October 2024, the Commission shall adopt implementing acts laying down the technical and the methodological requirements of the measures referred to in paragraph 2 with regard to DNS service providers, TLD name registries, cloud computing service providers, data centre service providers, content delivery network providers, managed service providers, managed security service providers, providers of online market places, of online search engines and of social networking services platforms, and trust service providers.
The Commission may adopt implementing acts laying down the technical and the methodological requirements, as well as sectoral requirements, as necessary, of the measures referred to in paragraph 2 with regard to essential and important entities other than those referred to in the first subparagraph of this paragraph.
When preparing the implementing acts referred to in the first and second subparagraphs of this paragraph, the Commission shall, to the extent possible, follow European and international standards, as well as relevant technical specifications. The Commission shall exchange advice and cooperate with the Cooperation Group and ENISA on the draft implementing acts in accordance with Article 14(4), point (e).
Those implementing acts shall be adopted in accordance with the examination procedure referred to in Article 39(2).
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