+Continuous Monitoring
---+Continuous Monitoring
------+Intrusion Detection & Prevention Systems (IDS & IPS)
------+Automated Tools for Real-Time Analysis
------+Inbound & Outbound Communications Traffic
------+System Generated Alerts
------+Wireless Network Monitoring
------+Host-Based Devices
------+File Integrity Monitoring (FIM)
------+Security Event Monitoring
------+Proxy Logging
------+Deactivated Account Activity
------+Automated Response to Suspicious Events
------+Automated Alerts
------+Alert Threshold Tuning
------+Individuals Posing Greater Risk
------+Privileged User Oversight
------+Analyze and Prioritize Monitoring Requirements
------+Real-Time Session Monitoring
---+Centralized Collection of Security Event Logs
------+Correlate Monitoring Information
------+Central Review & Analysis
------+Integration of Scanning & Other Monitoring Information
------+Correlation with Physical Monitoring
------+Permitted Actions
------+Audit Level Adjustments
------+System-Wide / Time-Correlated Audit Trail
------+Changes by Authorized Individuals
------+Inventory of Technology Asset Event Logging
---+Content of Event Logs
------+Sensitive Event Log Information
------+Audit Trails
------+Privileged Functions Logging
------+Verbosity Logging for Boundary Devices
------+Limit Personal Data (PD) In Audit Records
------+Centralized Management of Event Log Content
------+Database Logging
---+Event Log Storage Capacity
---+Response To Event Log Processing Failures
------+Real-Time Alerts of Event Logging Failure
------+Event Log Storage Capacity Alerting
---+Monitoring Reporting
------+Query Parameter Audits of Personal Data (PD)
------+Trend Analysis Reporting
---+Time Stamps
------+Synchronization With Authoritative Time Source
---+Protection of Event Logs
------+Event Log Backup on Separate Physical Systems / Components
------+Access by Subset of Privileged Users
------+Cryptographic Protection of Event Log Information
------+Dual Authorization for Event Log Movement
---+Non-Repudiation
------+Identity Binding
---+Event Log Retention
---+Monitoring For Information Disclosure
------+Analyze Traffic for Covert Exfiltration
------+Unauthorized Network Services
------+Monitoring for Indicators of Compromise (IOC)
---+Session Audit
---+Alternate Event Logging Capability
---+Cross-Organizational Monitoring
------+Sharing of Event Logs
---+Covert Channel Analysis
---+Anomalous Behavior
------+Insider Threats
------+Third-Party Threats
------+Unauthorized Activities
------+Account Creation and Modification Logging
---+Event Log Analysis & Triage
------+Event Log Review Escalation Matrix
---+File Activity Monitoring (FAM)
---+Write Once Read Many (WORM) Event Log Generation

Continuous Monitoring

Security, Compliance & Resilience (SCR) Principles

Maintain situational awareness of security-related events through the centralized collection and analysis of event logs from systems, applications and services.

Principle Intent

Organizations establish and maintain ongoing situational awareness across the enterprise through the centralized collection and review of security-related event logs. Without comprehensive visibility into infrastructure, operating system, database, application and other logs, the organization will have “blind spots” in its situational awareness that could lead to system compromise, data exfiltration, or unavailability of needed computing resources.

1. Overview

Summary Standard
Continuous Monitoring

Description

Mechanisms exist to facilitate the implementation of enterprise-wide monitoring controls.

Possible Solutions & Considerations

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

∙ Centralized event logging
∙ Managed Security Services Provider (MSSP)
∙ Cloud-native SIEM (e.g., Microsoft Sentinel free tier, Elastic SIEM free)

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

∙ Centralized event logging
∙ Managed Security Services Provider (MSSP)
∙ Cloud SIEM (e.g., Microsoft Sentinel, Elastic SIEM, Sumo Logic)

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

∙ Centralized event logging
∙ Security Incident Event Management (SIEM) (e.g., Splunk, Microsoft Sentinel, IBM QRadar)
∙ Managed Security Services Provider (MSSP)
∙ Security Operations Center (SOC)

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

∙ Centralized event logging
∙ Security Incident Event Management (SIEM) (e.g., Splunk, Microsoft Sentinel, IBM QRadar)
∙ Managed Security Services Provider (MSSP)
∙ Security Operations Center (SOC) with 24/7 coverage

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

∙ Enterprise SIEM platform (e.g., Splunk Enterprise Security, IBM QRadar, Microsoft Sentinel)
∙ 24/7 Security Operations Center (SOC)
∙ Security Orchestration, Automation & Response (SOAR)
∙ Threat intelligence integration
∙ Managed Detection & Response (MDR) or in-house SOC

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

Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.
▪ Generating event logs and the review of those event logs is narrowly-focused to business-critical Technology Assets, Applications, Services and/or Data (TAASD).

Level 2 Planned Tracked

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to facilitate the implementation of enterprise-wide monitoring controls.

Level 4 Quantitatively Controlled

Continuous Monitoring (MON) 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.
Centralized Collection of Security Event Logs

Description

Mechanisms exist to utilize a Security Incident Event Manager (SIEM), or similar automated tool, to support the centralized collection of security-related event logs.

Possible Solutions & Considerations

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

∙ Centralized log collector (e.g., Windows Event Forwarding, syslog server)
∙ Managed Security Services Provider (MSSP)
∙ Cloud logging (e.g., Microsoft Sentinel free tier, AWS CloudWatch)

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

∙ Centralized log collector (e.g., Graylog free, Elastic Stack free)
∙ Managed Security Services Provider (MSSP)
∙ Cloud SIEM (e.g., Microsoft Sentinel, Sumo Logic)

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

∙ Centralized log collector
∙ Security Incident Event Manager (SIEM) (e.g., Splunk, Microsoft Sentinel, IBM QRadar)
∙ Managed Security Services Provider (MSSP)

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

∙ Enterprise SIEM with centralized log collection (e.g., Splunk, Microsoft Sentinel)
∙ Log management platform (e.g., Splunk, Elastic Stack, Graylog)
∙ Managed Security Services Provider (MSSP)

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

∙ Enterprise SIEM with scalable log ingestion (e.g., Splunk Enterprise, IBM QRadar)
∙ Log management and analytics platform
∙ Managed Detection and Response (MDR) or in-house SOC
∙ Log data lake for long-term retention and threat hunting

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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical TAASD.
▪ IT and/or cybersecurity personnel configure alerts for critical or sensitive data that is stored, transmitted and processed on assets.

Level 3 Well Defined

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to utilize a Security Incident Event Manager (SIEM), or similar automated tool, to support the centralized collection of security-related event logs.

Level 4 Quantitatively Controlled

Continuous Monitoring (MON) 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.
Content of Event Logs

Description

Mechanisms exist to configure Technology Assets, Applications and/or Services (TAAS) to produce event logs that contain sufficient information to, at a minimum:
(1) Establish what type of event occurred;
(2) When (date and time) the event occurred;
(3) Where the event occurred;
(4) The source of the event;
(5) The outcome (success or failure) of the event; and
(6) The identity of any user/subject associated with the event.

Possible Solutions & Considerations

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.
▪ Generating event logs and the review of those event logs is narrowly-focused to business-critical Technology Assets, Applications, Services and/or Data (TAASD).

Level 2 Planned Tracked

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ SBC enforce logging to link system access to individual users or service accounts using a non-repudiation capability to protect against an individual falsely denying having performed a particular action.
▪ SBC enforce local security event logging and forward those logs to a centralized log repository to provide an alternate audit capability in the event of a failure in the primary audit capability.

Level 3 Well Defined

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to configure Technology Assets, Applications and/or Services (TAAS) to produce event logs that contain sufficient information to, at a minimum:
(1) Establish what type of event occurred;
(2) When (date and time) the event occurred;
(3) Where the event occurred;
(4) The source of the event;
(5) The outcome (success or failure) of the event; and
(6) The identity of any user/subject associated with the event.

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.
Event Log Storage Capacity

Description

Mechanisms exist to allocate and proactively manage sufficient event log storage capacity to reduce the likelihood of such capacity being exceeded.

Possible Solutions & Considerations

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

∙ IT Asset Management (ITAM) program
∙ ITIL 4 (https://axelos.com)

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

∙ IT Asset Management (ITAM) program
∙ ITIL 4 (https://axelos.com)

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

∙ IT Asset Management (ITAM) program
∙ ITIL 4 (https://axelos.com)

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

∙ IT Asset Management (ITAM) program
∙ ITIL 4 (https://axelos.com)

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

∙ IT Asset Management (ITAM) program
∙ ITIL 4 (https://axelos.com)

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

Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.

Level 2 Planned Tracked

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to allocate and proactively manage sufficient event log storage capacity to reduce the likelihood of such capacity being exceeded.

Level 4 Quantitatively Controlled

Continuous Monitoring (MON) 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.
Response To Event Log Processing Failures

Description

Mechanisms exist to alert appropriate personnel in the event of a log processing failure and take actions to remedy the disruption.

Possible Solutions & Considerations

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

∙ Incident Response Plan (IRP)
∙ Managed Security Services Provider (MSSP)

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

∙ Incident Response Plan (IRP)
∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Incident Response Plan (IRP)
∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Incident Response Plan (IRP)
∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Incident Response Plan (IRP)
∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to alert appropriate personnel in the event of a log processing failure and take actions to remedy the disruption.

Level 4 Quantitatively Controlled

Continuous Monitoring (MON) 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.
Monitoring Reporting

Description

Mechanisms exist to provide an event log report generation capability to aid in detecting and assessing anomalous activities.

Possible Solutions & Considerations

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

∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical TAASD.
▪ IT and/or cybersecurity personnel configure alerts for critical or sensitive data that is stored, transmitted and processed on assets.
▪ Logs of privileged functions (e.g., administrator or root actions) are reviewed for evidence of unauthorized activities.

Level 3 Well Defined

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to provide an event log report generation capability to aid in detecting and assessing anomalous 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.
Time Stamps

Description

Mechanisms exist to configure Technology Assets, Applications and/or Services (TAAS) to use an authoritative time source to generate time stamps for event logs.

Possible Solutions & Considerations

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.

Level 2 Planned Tracked

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to configure Technology Assets, Applications and/or Services (TAAS) to use an authoritative time source to generate time stamps for event logs.

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.
Protection of Event Logs

Description

Mechanisms exist to protect event logs and audit tools from unauthorized access, modification and deletion.

Possible Solutions & Considerations

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

∙ Secure Baseline Configurations (SBC)
∙ Role Based Access Control (RBAC)

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

∙ Secure Baseline Configurations (SBC)
∙ Role Based Access Control (RBAC)

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

∙ Secure Baseline Configurations (SBC)
∙ Role Based Access Control (RBAC)

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

∙ Secure Baseline Configurations (SBC)
∙ Role Based Access Control (RBAC)

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

∙ Secure Baseline Configurations (SBC)
∙ Role Based Access Control (RBAC)

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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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 retain security event logs for a time period consistent with records retention requirements to provide support for after-the-fact investigations of security incidents and to meet statutory, regulatory and/or contractual retention requirements.
▪ IT and/or cybersecurity personnel restrict access to the management of event logs for privileged users to protect event logs and audit tools from unauthorized access, modification and deletion.

Level 3 Well Defined

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to protect event logs and audit tools from unauthorized access, modification and deletion.

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.
Non-Repudiation

Description

Mechanisms exist to utilize a non-repudiation capability to protect against an individual falsely denying having performed a particular action.

Possible Solutions & Considerations

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

∙ Secure Baseline Configurations (SBC)

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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to utilize a non-repudiation capability to protect against an individual falsely denying having performed a particular action.

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.
Event Log Retention

Description

Mechanisms exist to retain event logs for a time period consistent with records retention requirements to provide support for after-the-fact investigations of security incidents and to meet statutory, regulatory and contractual retention requirements.

Possible Solutions & Considerations

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

∙ Managed Security Services Provider (MSSP)
∙ Log retention policy (minimum 90 days online, 1 year archived)
∙ Cloud log storage (e.g., AWS S3, Azure Storage)

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

∙ Managed Security Services Provider (MSSP)
∙ Log retention policy (minimum 90 days online, 1 year archived)
∙ Cloud SIEM with configurable retention

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

∙ Security Incident Event Manager (SIEM) with defined retention schedules
∙ Managed Security Services Provider (MSSP)
∙ Log archiving to cold storage (e.g., AWS S3 Glacier, Azure Archive)

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

∙ SIEM with tiered log retention (hot/warm/cold storage)
∙ Log retention policy aligned to regulatory requirements (e.g., HIPAA 6 yrs, PCI DSS 1 yr)
∙ Managed Security Services Provider (MSSP)

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

∙ Enterprise log retention program aligned to all applicable regulations
∙ SIEM with tiered retention (hot/warm/cold storage)
∙ Immutable log archives (e.g., AWS S3 Object Lock, Azure Blob WORM)
∙ Legal hold capability for investigation support

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

Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.

Level 2 Planned Tracked

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to retain event logs for a time period consistent with records retention requirements to provide support for after-the-fact investigations of security incidents and to meet statutory, regulatory and contractual retention requirements.

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.
Monitoring For Information Disclosure

Description

Mechanisms exist to monitor for evidence of unauthorized exfiltration or disclosure of non-public information.

Possible Solutions & Considerations

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

∙ Content filtering
∙ Keyword alerting (e.g., Google Alerts)
∙ Review of social media outlets
∙ HaveIBeenPwned monitoring (https://haveibeenpwned.com)

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

∙ Content filtering
∙ Keyword alerting (e.g., Google Alerts)
∙ Review of social media outlets
∙ HaveIBeenPwned monitoring (https://haveibeenpwned.com)
∙ Dark web monitoring (e.g., SpyCloud, HaveIBeenPwned Pro)

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

∙ Content filtering
∙ Keyword alerting (e.g., Google Alerts)
∙ Dark web monitoring (e.g., SpyCloud, Recorded Future, Digital Shadows)
∙ Data Loss Prevention (DLP) solution

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

∙ Data Loss Prevention (DLP) solution (e.g., Microsoft Purview DLP, Forcepoint DLP)
∙ Dark web monitoring platform (e.g., Recorded Future, Digital Shadows, SpyCloud)
∙ Brand and digital footprint monitoring

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

∙ Enterprise DLP solution (e.g., Symantec DLP, Forcepoint DLP, Microsoft Purview DLP)
∙ Dedicated threat intelligence platform with dark web monitoring
∙ Digital risk protection (DRP) service (e.g., ZeroFox, Recorded Future)
∙ Automated exfiltration detection via SIEM/UEBA

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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to monitor for evidence of unauthorized exfiltration or disclosure of non-public information.

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.
Session Audit

Description

Mechanisms exist to provide session audit capabilities that can:
(1) Capture and log all content related to a user session; and
(2) Remotely view all content related to an established user session in real time.

Possible Solutions & Considerations

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

∙ ManageEngine PAM360 (https://manageengine.com)
∙ Basic privileged session recording (e.g., built-in OS logging)

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

∙ ManageEngine PAM360 (https://manageengine.com)
∙ Privileged Access Workstation (PAW) or jump server logging

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

∙ ManageEngine PAM360 (https://manageengine.com)
∙ Ekran User Activity Monitoring (UAM) (https://ekransystem.com)
∙ Privileged Access Management (PAM) solution with session recording

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

∙ ManageEngine PAM360 (https://manageengine.com)
∙ Ekran User Activity Monitoring (UAM) (https://ekransystem.com)
∙ CyberArk Privileged Session Manager or BeyondTrust Session Management

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

∙ Enterprise PAM with session audit (e.g., CyberArk, BeyondTrust, Delinea)
∙ ManageEngine PAM360 (https://manageengine.com)
∙ Ekran User Activity Monitoring (UAM) (https://ekransystem.com)
∙ AI-powered anomalous behavior detection in privileged sessions

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

Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.

Level 2 Planned Tracked

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to provide session audit capabilities that can:
(1) Capture and log all content related to a user session; and
(2) Remotely view all content related to an established user session in real time.

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.
Alternate Event Logging Capability

Description

Mechanisms exist to provide an alternate event logging capability in the event of a failure in primary audit capability.

Possible Solutions & Considerations

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

∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.

Level 2 Planned Tracked

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to provide an alternate event logging capability in the event of a failure in primary audit capability.

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.
Cross-Organizational Monitoring

Description

Mechanisms exist to coordinate sanitized event logs among external organizations to identify anomalous events when event logs are shared across organizational boundaries, without giving away sensitive or critical business data.

Possible Solutions & Considerations

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

∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)

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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to coordinate sanitized event logs among external organizations to identify anomalous events when event logs are shared across organizational boundaries, without giving away sensitive or critical business data.

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.
Covert Channel Analysis

Description

Mechanisms exist to conduct covert channel analysis to identify aspects of communications that are potential avenues for covert channels.

Possible Solutions & Considerations

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

∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)

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

∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)

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

Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.

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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to conduct covert channel analysis to identify aspects of communications that are potential avenues for covert channels.

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.
Anomalous Behavior

Description

Mechanisms exist to utilize User & Entity Behavior Analytics (UEBA) and/or User Activity Monitoring (UAM) solutions to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities.

Possible Solutions & Considerations

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

∙ Indicators of Compromise (IoC)
∙ Indicators of Exposure (IoE)
∙ Managed Security Services Provider (MSSP)

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

∙ Indicators of Compromise (IoC)
∙ Indicators of Exposure (IoE)
∙ Security Incident Event Manager (SIEM)
∙ Managed Security Services Provider (MSSP)

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

∙ Indicators of Compromise (IoC)
∙ Indicators of Exposure (IoE)
∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)

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

∙ Indicators of Compromise (IoC)
∙ Indicators of Exposure (IoE)
∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)

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

∙ Indicators of Compromise (IoC)
∙ Indicators of Exposure (IoE)
∙ Security Incident Event Manager (SIEM)
∙ Extended Detection and Response (XDR)
∙ Managed Security Services Provider (MSSP)

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

Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.

Level 2 Planned Tracked

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to utilize User & Entity Behavior Analytics (UEBA) and/or User Activity Monitoring (UAM) solutions to detect and respond to anomalous behavior that could indicate account compromise or other malicious 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.
Event Log Analysis & Triage

Description

Mechanisms exist to ensure event log reviews include analysis and triage practices that integrate with the organization's established incident response processes.

Possible Solutions & Considerations

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

∙ Review system logs periodically

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

∙ Log monitoring policy
∙ Regular review of key system logs

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

∙ SIEM (e.g., Wazuh)
∙ Automated log collection and alerting

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

∙ Enterprise SIEM (e.g., Splunk, IBM QRadar)
∙ Continuous monitoring program
∙ SOC monitoring

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

∙ Enterprise SIEM/SOAR platform
∙ 24/7 SOC monitoring
∙ Threat hunting
∙ Automated incident response

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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to ensure event log reviews include analysis and triage practices that integrate with the organization's established incident response processes.

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.
File Activity Monitoring (FAM)

Description

Automated mechanisms exist to monitor sensitive/regulated data in Technology Assets, Applications and/or Services (TAAS) and data repositories.

Possible Solutions & Considerations

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

∙ Review system logs periodically

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

∙ Log monitoring policy
∙ Regular review of key system logs

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

∙ SIEM (e.g., Wazuh)
∙ Automated log collection and alerting

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

∙ Enterprise SIEM (e.g., Splunk, IBM QRadar)
∙ Continuous monitoring program
∙ SOC monitoring

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

∙ Enterprise SIEM/SOAR platform
∙ 24/7 SOC monitoring
∙ Threat hunting
∙ Automated incident response

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

Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.

Level 2 Planned Tracked

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to automatically monitor sensitive/regulated data in Technology Assets, Applications and/or Services (TAAS) and data repositories.

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.
Write Once Read Many (WORM) Event Log Generation

Description

Mechanisms exist to produce event logs on hardware-enforced, write-once media (e.g., Write Once Read Many (WORM) technologies).

Possible Solutions & Considerations

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

∙ Review system logs periodically

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

∙ Log monitoring policy
∙ Regular review of key system logs

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

∙ SIEM (e.g., Wazuh)
∙ Automated log collection and alerting

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

∙ Enterprise SIEM (e.g., Splunk, IBM QRadar)
∙ Continuous monitoring program
∙ SOC monitoring

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

∙ Enterprise SIEM/SOAR platform
∙ 24/7 SOC monitoring
∙ Threat hunting
∙ Automated incident response

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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON 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 MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Continuous monitoring 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

Continuous Monitoring (MON) 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 MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM), 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 MON 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).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to produce event logs on hardware-enforced, write-once media (e.g., Write Once Read Many (WORM) technologies).

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 References

1.2 Identified Requirements

1.3 Related Regulations

2. Identified Requirements

Requirements
Source Requirement

3. Related Regulations

Regulations
Source Regulation
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