+Encrypting Data In Transit
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Encrypting Data In Transit
Description
Cryptographic mechanisms exist to prevent the unauthorized disclosure of data in transit.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)
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
Cryptographic Protections (CRY) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with CRY domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Cryptography management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel provide an encryption solution (software or hardware) for the storage of sensitive/regulated data.
▪ Sensitive/regulated data is encrypted in transit according to standardized processes.
Level 2 Planned Tracked
Cryptographic Protections (CRY) 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 CRY domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CRY 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 CRY domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Cryptographic management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Cryptographic management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Technology Assets, Applications and/or Services (TAAS) that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.
▪ External compliance requirements for cryptography are identified and documented, based on applicable laws, regulations and contractual obligations.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to implement cryptographic mechanisms that are applicability for statutory, regulatory and/or contractual compliance obligations.
▪ Sensitive/regulated data is encrypted at rest using cryptographic protections that are commensurate with the sensitivity of the data.
▪ Sensitive/regulated data is encrypted during transmission using cryptographic protections that are commensurate with the sensitivity of the data.
Level 3 Well Defined
Cryptographic Protections (CRY) 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 CRY domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with CRY domain capabilities are well-documented and kept current by process owners.
▪ A security engineering team, or similar function, is appropriately staffed and supported to implement and maintain CRY domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of cryptographic protections operations (e.g., PKI management tool).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with CRY domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational cryptographic capability exists to protect the confidentiality of data being transmitted.
Level 4 Quantitatively Controlled
Cryptographic Protections (CRY) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
1. Overview
1.1 References
1.2 Identified Requirements
1.3 Related Regulations
2. Identified Requirements
Requirements
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Requirement |
3. Related Regulations
Regulations
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Regulation |
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EULAW
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Article 6 Encryption and cryptographic controls
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EULAW
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Article 6 Encryption and cryptographic controls
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EULAW
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Article 13 Network security management
Article 13
Network security management
Financial entities shall, as part of the safeguards ensuring the security of networks against intrusions and data misuse, develop, document, and implement policies, procedures, protocols, and tools on network security management, including all of the following:
(a)
the segregation and segmentation of ICT systems and networks taking into account:
(i)
the criticality or importance of the function those ICT systems and networks support;
(ii)
the classification established in accordance with Article 8(1) of Regulation (EU) 2022/2554;
(iii)
the overall risk profile of ICT assets using those ICT systems and networks;
(b)
the documentation of all of the financial entity’s network connections and data flows;
(c)
the use of a separate and dedicated network for the administration of ICT assets;
(d)
the identification and implementation of network access controls to prevent and detect connections to the financial entity’s network by any unauthorised device or system, or any endpoint not meeting the financial entity’s security requirements;
(e)
the encryption of network connections passing over corporate networks, public networks, domestic networks, third-party networks, and wireless networks, for communication protocols used, taking into account the results of the approved data classification, the results of the ICT risk assessment and the encryption of network connections referred to in Article 6(2);
(f)
the design of networks in line with the ICT security requirements established by the financial entity, taking into account leading practices to ensure the confidentiality, integrity, and availability of the network;
(g)
the securing of network traffic between the internal networks and the internet and other external connections;
(h)
the identification of the roles and responsibilities and steps for the specification, implementation, approval, change, and review of firewall rules and connections filters;
(i)
the performance of reviews of the network architecture and of the network security design once a year, and periodically for microenterprises, to identify potential vulnerabilities;
(j)
the measures to temporarily isolate, where necessary, subnetworks, and network components and devices;
(k)
the implementation of a secure configuration baseline of all network components, and the hardening of the network and of network devices in line with any vendor instructions, where applicable standards, as defined in Article 2, point (1), of Regulation (EU) No 1025/2012, and leading practices;
(l)
the procedures to limit, lock, and terminate system and remote sessions after a specified period of inactivity;
(m)
for network services agreements:
(i)
the identification and specification of ICT and information security measures, service levels, and management requirements of all network services;
(ii)
whether those services are provided by an ICT intra-group service provider or by ICT third-party service providers.
For the purposes of point (h), financial entities shall perform the review of firewall rules and connections filters on a regular basis in accordance with the classification established in accordance with Article 8(1) of Regulation (EU) 2022/2554 and the overall risk profile of ICT systems involved. For ICT systems that support critical or important functions, financial entities shall verify the adequacy of the existing firewall rules and connection filters at least every 6 months.
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EULAW
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Article 14 Securing information in transit
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EULAW
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Article 14 Securing information in transit
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EULAW
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Article 35 Data, system and network security
Article 35
Data, system and network security
The financial entities referred to in Article 16(1) of Regulation (EU) 2022/2554 shall, as part of their systems, protocols, and tools, develop and implement safeguards that ensure the security of networks against intrusions and data misuse and that preserve the availability, authenticity, integrity, and confidentiality of data. In particular, financial entities shall, taking into account the classification referred to in Article 30(1) of this Regulation, establish all of the following:
(a)
the identification and implementation of measures to protect data in use, in transit, and at rest;
(b)
the identification and implementation of security measures regarding the use of software, data storage media, systems and endpoint devices that transfer and store data of the financial entity;
(c)
the identification and implementation of measures to prevent and detect unauthorised connections to the financial entity’s network, and to secure the network traffic between the financial entity’s internal networks and the internet and other external connections;
(d)
the identification and implementation of measures that ensure the availability, authenticity, integrity, and confidentiality of data during network transmissions;
(e)
a process to securely delete data on premises, or that are stored externally, that the financial entity no longer needs to collect or store;
(f)
a process to securely dispose of, or decommission, data storage devices on premises, or data storage devices that are stored externally, that contain confidential information;
(g)
the identification and implementation of measures to ensure that teleworking and the use of private endpoint devices does not adversely impact the financial entity’s ability to carry out its critical activities in an adequate, timely, and secure manner.
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EULAW
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Article 35 Data, system and network security
Article 35
Data, system and network security
The financial entities referred to in Article 16(1) of Regulation (EU) 2022/2554 shall, as part of their systems, protocols, and tools, develop and implement safeguards that ensure the security of networks against intrusions and data misuse and that preserve the availability, authenticity, integrity, and confidentiality of data. In particular, financial entities shall, taking into account the classification referred to in Article 30(1) of this Regulation, establish all of the following:
(a)
the identification and implementation of measures to protect data in use, in transit, and at rest;
(b)
the identification and implementation of security measures regarding the use of software, data storage media, systems and endpoint devices that transfer and store data of the financial entity;
(c)
the identification and implementation of measures to prevent and detect unauthorised connections to the financial entity’s network, and to secure the network traffic between the financial entity’s internal networks and the internet and other external connections;
(d)
the identification and implementation of measures that ensure the availability, authenticity, integrity, and confidentiality of data during network transmissions;
(e)
a process to securely delete data on premises, or that are stored externally, that the financial entity no longer needs to collect or store;
(f)
a process to securely dispose of, or decommission, data storage devices on premises, or data storage devices that are stored externally, that contain confidential information;
(g)
the identification and implementation of measures to ensure that teleworking and the use of private endpoint devices does not adversely impact the financial entity’s ability to carry out its critical activities in an adequate, timely, and secure manner.
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Linked Issues
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