+Threat Intelligence Program
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Threat Intelligence Program
Description
Mechanisms exist to implement a threat intelligence program that includes a cross-organization information-sharing capability that can influence the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, response and recovery activities.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Subscribe to free threat intelligence feeds (e.g., CISA alerts)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ CISA alerts subscription
∙ Basic threat awareness program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Threat intelligence program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Threat intelligence program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Threat intelligence program
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
Threat Management (THR) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with THR domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Threat 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 subscribe to threat feeds to maintain situational awareness of emerging threats.
Level 2 Planned Tracked
Threat Management (THR) 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 THR domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with THR 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 THR domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Threat management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Threat management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
Level 3 Well Defined
Threat Management (THR) 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 THR 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 THR domain capabilities are well-documented and kept current by process owners.
▪ A threat management team, or similar function, is appropriately staffed and supported to implement and maintain THR domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of threat management operations (e.g., threat intelligence solution and bug bounty solution).
▪ 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 THR domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to implement a threat intelligence program that includes a cross-organization information-sharing capability that can influence the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, response and recovery activities.
Level 4 Quantitatively Controlled
Threat Management (THR) 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 2 General elements of ICT security policies, procedures, protocols, and tools
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EULAW
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Article 3 ICT risk management
Article 3
Financial entities shall develop, document, and implement ICT risk management policies and procedures that shall contain all of the following:
(a)
an indication of the approval of the risk tolerance level for ICT risk established in accordance with Article 6(8), point (b), of Regulation (EU) 2022/2554;
(b)
a procedure and a methodology to conduct the ICT risk assessment, identifying:
(i)
vulnerabilities and threats that affect or may affect the supported business functions, the ICT systems and ICT assets supporting those functions;
(ii)
the quantitative or qualitative indicators to measure the impact and likelihood of the vulnerabilities and threats referred to in point (i);
(c)
the procedure to identify, implement, and document ICT risk treatment measures for the ICT risks identified and assessed, including the determination of ICT risk treatment measures necessary to bring ICT risk within the risk tolerance level referred to in point (a);
(d)
for the residual ICT risks that are still present following the implementation of the ICT risk treatment measures referred to in point (c):
(i)
provisions on the identification of those residual ICT risks;
(ii)
the assignment of roles and responsibilities regarding:
(1)
the acceptance of the residual ICT risks that exceed the financial entity’s risk tolerance level referred to in point (a);
(2)
for the review process referred to in point (iv) of this point (d);
(iii)
the development of an inventory of the accepted residual ICT risks, including a justification for their acceptance;
(iv)
provisions on the review of the accepted residual ICT risks at least once a year, including:
(1)
the identification of any changes to the residual ICT risks;
(2)
the assessment of available mitigation measures;
(3)
the assessment of whether the reasons justifying the acceptance of residual ICT risks are still valid and applicable at the date of the review;
(e)
provisions on the monitoring of:
(i)
any changes to the ICT risk and cyber threat landscape;
(ii)
internal and external vulnerabilities and threats:
(iii)
ICT risk of the financial entity that enables promp detection of changes that could affect its ICT risk profile;
(f)
provisions on a process to ensure that any changes to the business strategy and the digital operational resilience strategy of the financial entity are taken into account.
For the purposes of the first paragraph, point (c), the procedure referred to in that point shall ensure:
(a)
the monitoring of the effectiveness of the ICT risk treatment measures implemented;
(b)
the assessment of whether the established risk tolerance levels of the financial entity have been attained;
(c)
the assessment of whether the financial entity has taken actions to correct or improve those measures where necessary.
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EULAW
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Article 23 Anomalous activities detection and criteria for ICT-related incidents detection and response
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EULAW
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Article 31 ICT risk management
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EULAW
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Article 34 ICT operations security
Article 34
The financial entities referred to in Article 16(1) of Regulation (EU) 2022/2554 shall, as part of their systems, protocols, and tools, and for all ICT assets:
(a)
monitor and manage the lifecycle of all ICT assets;
(b)
monitor whether the ICT assets are supported by ICT third-party service providers of financial entities, where applicable;
(c)
identify capacity requirements of their ICT assets and measures to maintain and improve the availability and efficiency of ICT systems and prevent ICT capacity shortages before they materialise;
(d)
perform automated vulnerability scanning and assessments of ICT assets commensurate to their classification as referred to in Article 30(1) and to the overall risk profile of the ICT asset, and deploy patches to address identified vulnerabilities;
(e)
manage the risks related to outdated, unsupported, or legacy ICT assets;
(f)
log events related to logical and physical access control, ICT operations, including system and network traffic activities, and ICT change management;
(g)
identify and implement measures to monitor and analyse information on anomalous activities and behaviour for critical or important ICT operations;
(h)
implement measures to monitor relevant and up-to-date information about cyber threats;
(i)
implement measures to identify possible information leakages, malicious code and other security threats, and publicly known vulnerabilities in software and hardware, and check for corresponding new security updates.
For the purposes of point (f), financial entities shall align the level of detail of the logs with their purpose and usage of the ICT asset producing those logs.
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EULAW
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Article 13 Learning and evolving
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EULAW
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Article 45 Information-sharing arrangements on cyber threat information and intelligence
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EULAW
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Article 13 1
1. Financial entities shall have in place capabilities and staff to gather information on vulnerabilities and cyber threats, ICT-related incidents, in particular cyber-attacks, and analyse the impact they are likely to have on their digital operational resilience.
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EULAW
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Article 45 1
1. Financial entities may exchange amongst themselves cyber threat information and intelligence, including indicators of compromise, tactics, techniques, and procedures, cyber security alerts and configuration tools, to the extent that such information and intelligence sharing:
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(a)
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aims to enhance the digital operational resilience of financial entities, in particular through raising awareness in relation to cyber threats, limiting or impeding the cyber threats’ ability to spread, supporting defence capabilities, threat detection techniques, mitigation strategies or response and recovery stages;
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(b)
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takes places within trusted communities of financial entities;
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(c)
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is implemented through information-sharing arrangements that protect the potentially sensitive nature of the information shared, and that are governed by rules of conduct in full respect of business confidentiality, protection of personal data in accordance with Regulation (EU) 2016/679 and guidelines on competition policy.
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EULAW
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Article 45 2
2. For the purpose of paragraph 1, point (c), the information-sharing arrangements shall define the conditions for participation and, where appropriate, shall set out the details on the involvement of public authorities and the capacity in which they may be associated to the information-sharing arrangements, on the involvement of ICT third-party service providers, and on operational elements, including the use of dedicated IT platforms.
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EULAW
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Article 45 3
3. Financial entities shall notify competent authorities of their participation in the information-sharing arrangements referred to in paragraph 1, upon validation of their membership, or, as applicable, of the cessation of their membership, once it takes effect.
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Linked Issues
- Secure Controls Framework -
"The SCF is the Common Controls Framework™ (CCF), the world's most comprehensive cybersecurity and data privacy metaframework - it is also free to use. The entire concept is building secure, compliant and resilient capabilities in the most efficient and cost-effective manner possible.
The SCF is more than just a unified control catalog, since its included content creates a playbook for Governance, Risk & Compliance (GRC) capabilities. Used globally by organizations of every size, the SCF is a robust and scalable solution for security, compliance and resilience controls. As a comprehensive security framework, the SCF maps 1,400+ controls across 200+ laws, regulations, and industry frameworks so you can implement once and comply everywhere.
Like it or not, cybersecurity is a protracted war on an asymmetric battlefield, where the threats are everywhere and as defenders we have to make the effort to work together to help improve cybersecurity and data privacy practices, since we all suffer when massive data breaches occur or when cyber attacks have physical impacts. Hackers share information on attack methods with other hackers, so why shouldn’t the good guys share information on how to best protect an organization? We decided to take action and make a difference, since we feel it is too important to wait for someone else to fix the problems that exist.
The SCF is made up of volunteers, mainly specialists within the cybersecurity profession, who focus on GRC and the cybersecurity side of data privacy. These are auditors, engineers, architects, incident responders, consultants and other specialists who live and breathe these topics on a daily basis. The end product is "expert-derived content" that makes up the SCF." https://securecontrolsframework.com/
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