+Privileged Account Management (PAM)
---+Privileged Account Inventories
---+Privileged Account Separation
---+Dedicated Privileged Account
---+Privileged Command Execution
---+Manual Override
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Privileged Account Management (PAM)
Description
Mechanisms exist to restrict and control privileged access rights for users and Technology Assets, Applications and/or Services (TAAS).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Strong password policy ∙ MFA for key accounts
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Password manager ∙ MFA on all accounts ∙ Identity policy
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ ManageEngine Enterprise Password Management (https://manageengine.com) ∙ Securden (https://securden.com) ∙ CyberArk (https://cyberark.com)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ ManageEngine Enterprise Password Management (https://manageengine.com) ∙ Securden (https://securden.com) ∙ CyberArk (https://cyberark.com)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ ManageEngine Enterprise Password Management (https://manageengine.com) ∙ Securden (https://securden.com) ∙ CyberArk (https://cyberark.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
Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions. ▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.
Level 2 Planned Tracked
Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC). ▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts. ▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services. ▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS. ▪ IAM restricts the assignment of privileged accounts to entity-defined personnel and/or roles (privilege assignment requires management approval). ▪ LAC and RBAC enforcements limit the ability of non-administrators from making unauthorized configuration changes to TAAS.
Level 3 Well Defined
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners. ▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 restrict and control privileged access rights for users and Technology Assets, Applications and/or Services (TAAS).
Level 4 Quantitatively Controlled
Identification & Authentication (IAC) 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
Identification & Authentication (IAC) 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. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes. ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
1. Forbhreathnú
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Caighdeán |
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Privileged Account Inventories
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Description
Mechanisms exist to inventory all privileged accounts and validate that each person with elevated privileges is authorized by the appropriate level of organizational management.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Microsoft Active Directory (https://microsoft.com) ∙ Microsoft Entra (https://microsoft.com) ∙ AWS IAM (https://aws.amazon.com)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Microsoft Active Directory (https://microsoft.com) ∙ Microsoft Entra (https://microsoft.com) ∙ AWS IAM (https://aws.amazon.com)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Microsoft Active Directory (https://microsoft.com) ∙ Microsoft Entra (https://microsoft.com) ∙ AWS IAM (https://aws.amazon.com)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Microsoft Active Directory (https://microsoft.com) ∙ Microsoft Entra (https://microsoft.com) ∙ AWS IAM (https://aws.amazon.com)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Microsoft Active Directory (https://microsoft.com) ∙ Microsoft Entra (https://microsoft.com) ∙ AWS IAM (https://aws.amazon.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
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
Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC). ▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts. ▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services. ▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
Level 3 Well Defined
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners. ▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 inventory all privileged accounts and validate that each person with elevated privileges is authorized by the appropriate level of organizational management.
Level 4 Quantitatively Controlled
Identification & Authentication (IAC) 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
Identification & Authentication (IAC) 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. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes. ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
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Privileged Account Separation
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Description
Mechanisms exist to separate privileged accounts between infrastructure environments to reduce the risk of a compromise in one infrastructure environment from laterally affecting other infrastructure environments.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Use separate accounts for admin vs. regular daily tasks
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Separate privileged and standard accounts for all administrators
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal privileged account separation policy ∙ Dedicated admin accounts
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise privileged account management with dedicated admin accounts (e.g., CyberArk)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise PAM platform (e.g., CyberArk, BeyondTrust) ∙ Dedicated privileged accounts ∙ Separation of duties enforcement
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
Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions. ▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.
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
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners. ▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 separate privileged accounts between infrastructure environments to reduce the risk of a compromise in one infrastructure environment from laterally affecting other infrastructure environments.
Level 4 Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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Dedicated Privileged Account
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Description
Mechanisms exist to assign dedicated privileged user accounts to be used solely for duties requiring privileged access.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Use separate dedicated admin account for privileged tasks
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Dedicated privileged account policy ∙ No daily use of admin accounts
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal dedicated privileged account policy ∙ Separate admin credentials from daily-use accounts
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise PAM with dedicated privileged accounts (e.g., CyberArk, BeyondTrust)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise PAM platform with dedicated privileged accounts ∙ Privileged access workstations (PAW) ∙ Just-in-time access
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
Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions. ▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.
Level 2 Planned Tracked
Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC). ▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts. ▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services. ▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
Level 3 Well Defined
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners. ▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 assign dedicated privileged user accounts to be used solely for duties requiring privileged access.
Level 4 Quantitatively Controlled
Identification & Authentication (IAC) 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
Identification & Authentication (IAC) 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. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes. ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
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Privileged Command Execution
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Description
Mechanisms exist to ensure privilege change requests require additional levels of authentication.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Limit privileged commands to authorized admin accounts only
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Policy restricting privileged command execution to authorized accounts
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal privileged command control policy ∙ Technical enforcement via sudo/RBAC
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise PAM with privileged command controls ∙ Command-level authorization
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise PAM platform with command-level controls and auditing (e.g., CyberArk) ∙ Just enough access (JEA) ∙ Full session recording
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
Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC). ▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts. ▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services. ▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
Level 3 Well Defined
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners. ▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 ensure privilege change requests require additional levels of authentication.
Level 4 Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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Manual Override
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Description
Mechanisms exist to enable a manual override of the current account privileges to enable the timely response to unusual conditions without terminating the current session and establishing a new session as a higher-privileged user.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Document manual override procedures for automated systems
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Manual override policy and procedure for automated access controls
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal manual override process with approval and audit trail
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise manual override process with dual authorization and logging
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise PAM with manual override workflows ∙ Dual control for override access ∙ Automated audit trail for all overrides
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.
Level 2 Planned Tracked
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners. ▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 enable a manual override of the current account privileges to enable the timely response to unusual conditions without terminating the current session and establishing a new session as a higher-privileged user.
Level 4 Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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1.1 Tagairtí
1.2 Ceanglais aitheanta
1.3 Rialacháin ghaolmhara
2. Ceanglais aitheanta
Ceanglais
| Foinse |
Ceanglas |
3. Rialacháin ghaolmhara
Rialacháin
| Foinse |
Rialáil |
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EULAW
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Airteagal 21 Rialú rochtana
Airteagal 21
Mar chuid dá rialú ar chearta bainistithe rochtana, déanfaidh eintitis airgeadais beartas a fhorbairt, a dhoiciméadú agus a chur chun feidhme ina mbeidh na nithe uile seo a leanas:
(a)
cearta rochtana ar shócmhainní TFC a shannadh bunaithe ar an bprionsabal ‘ar bhonn riachtanais eolais’, an prionsabal ‘ar bhonn riachtanais úsáide’ agus prionsabal an údaráis is lú, lena n-áirítear i gcás cianrochtana agus rochtain éigeandála;
(b)
dualgais a dheighilt sa chaoi go gcoiscfear rochtain neamhúdaraithe ar shonraí criticiúla nó leithdháileadh teaglamaí ceart rochtana a d’fhéadfaí a úsáid chun teacht timpeall ar rialuithe;
(c)
foráil maidir le cuntasacht úsáideora, trí úsáid cuntas cineálach agus comhroinnte a theorannú a mhéid is féidir agus trína áirithiú go mbíonn úsáideoirí in-sainaitheanta i gcónaí i leith na ngníomhaíochtaí a dhéantar sna córais TFC;
(d)
foráil maidir le srianta rochtana ar shócmhainní TFC lena leagtar amach rialuithe agus uirlisí chun rochtain neamhúdaraithe a chosc;
(e)
nósanna imeachta bainistíochta cuntais um chearta rochtana a dheonú, a athrú nó a chúlghairm do chuntais úsáideoirí agus cuntais chineálacha, lena n-áirítear forálacha maidir leis na nithe uile seo a leanas:
(i)
róil agus freagrachtaí a shannadh maidir le cearta rochtana a dheonú, a athbhreithniú agus a chúlghairm;
(ii)
rochtain phribhléidithe, éigeandála agus riarthóra a shannadh ar bhonn riachtanais úsáide nó ar bhonn ad hoc maidir leis na córais TFC uile;
(iii)
cearta rochtana a aistarraingt gan moill mhíchuí ar fhoirceannadh fostaíochta nó i gcás nach mbeidh gá leis an rochtain a thuilleadh;
(iv)
cearta rochtana a thabhairt cothrom le dáta i gcás ina mbeidh gá le hathruithe agus uair amháin sa bhliain ar a laghad maidir leis na córais TFC uile, seachas córais TFC lena dtacaítear le feidhmeanna criticiúla nó tábhachtacha agus gach 6 mhí ar a laghad i gcás córais TFC lena dtacaítear le feidhmeanna criticiúla nó tábhachtacha;
(f)
modhanna fíordheimhniúcháin, lena n-áirítear na nithe uile seo a leanas:
(i)
úsáid a bhaint as modhanna fíordheimhniúcháin atá i gcomhréir leis an aicmiú a bhunaítear i gcomhréir le hAirteagal 8(1) de Rialachán (AE) 2022/2554 agus le próifíl riosca fhoriomlán sócmhainní TFC agus breithniú á dhéanamh ar chleachtais atá chun tosaigh;
(ii)
úsáid a bhaint as modhanna fíordheimhniúcháin láidre i gcomhréir le cleachtais atá chun tosaigh agus teicnící maidir le cianrochtain ar ghréasán an eintitis airgeadais, rochtain phribhléidithe, rochtain ar shócmhainní TFC lena dtacaítear le feidhmeanna criticiúla nó tábhachtacha nó ar shócmhainní TFC atá inrochtana don phobal;
(g)
bearta maidir le rialuithe rochtana fisiciúla, lena n-áirítear:
(i)
sainaithint agus logáil ar dhaoine nádúrtha atá údaraithe chun rochtain a fháil ar áitreabh, lárionaid sonraí agus limistéir ainmnithe íogaire arna sainaithint ag an eintiteas airgeadais ina bhfuil sócmhainní TFC agus sócmhainní faisnéise lonnaithe;
(ii)
cearta rochtana fisiciúla ar shócmhainní TFC criticiúla a dheonú do dhaoine údaraithe amháin, i gcomhréir leis an bprionsabal ‘ar bhonn riachtanais eolais’ agus le prionsabal an údaráis is lú, agus ar bhonn ad hoc;
(iii)
faireachán ar rochtain fhisiciúil ar áitreabh, lárionaid sonraí agus limistéir ainmnithe íogaire arna sainaithint ag an eintiteas airgeadais ina bhfuil sócmhainní TFC nó sócmhainní faisnéise, nó an dá chineál, lonnaithe;
(iv)
athbhreithniú ar chearta rochtana fisiciúla chun a áirithiú go ndéanfar cearta rochtana neamhriachtanacha a chúlghairm go pras.
Chun críocha phointe (e)(i), bunóidh eintitis airgeadais an tréimhse choinneála, á gcur san áireamh na cuspóirí gnó agus slándála faisnéise, na cúiseanna le taifeadadh an teagmhais sna logaí agus torthaí an mheasúnaithe riosca TFC.
Chun críocha phointe (e)(ii), úsáidfidh eintitis airgeadais, i gcás inar féidir, cuntais thiomnaithe chun cúraimí riaracháin a dhéanamh ar chórais TFC. I gcás inarb indéanta agus iomchuí, cuirfidh eintitis airgeadais réitigh uathoibrithe in úsáid le haghaidh an bhainistithe rochtana pribhléidithe.
Chun críocha phointe (g)(i), beidh an tsainaithint agus an logáil i gcomhréir le tábhacht an áitribh, na lárionad sonraí agus na limistéar ainmnithe íogair agus le criticiúlacht na n-oibríochtaí nó na gcóras TFC atá lonnaithe iontu.
Chun críocha phointe (g)(iii), beidh an faireachán i gcomhréir leis an aicmiú a bhunaítear i gcomhréir le hAirteagal 8(1) de Rialachán (AE) 2022/2554 agus le criticiúlacht an limistéir ar a bhfaightear rochtain.
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EULAW
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Airteagal 33 Rialú Rochtana
Airteagal 33
Déanfaidh na heintitis airgeadais dá dtagraítear in Airteagal 16(1) de Rialachán (AE) 2022/2554, nósanna imeachta maidir le rialú ar rochtain loighciúil nó fhisiciúil a fhorbairt, a dhoiciméadú, agus a chur chun feidhme agus déanfaidh siad na nósanna imeachta sin a fhorfheidhmiú, déanfaidh siad faireachán orthu, agus déanfaidh siad iad a athbhreithniú go tréimhsiúil. Beidh na gnéithe seo a leanas maidir le rialú ar rochtain loighciúil agus fhisiciúil sna nósanna imeachta sin:
(a)
déantar cearta rochtana ar shócmhainní faisnéise, sócmhainní TFC, agus na feidhmeanna tacaithe a bhaineann leo, agus rochtain ar shuíomhanna criticiúla an eintitis airgeadais, a bhainistiú ar bhonn riachtanais eolais, ar bhonn riachtanais úsáide agus ar bhonn phrionsabal an údaráis is lú, lena n-áirítear cianrochtain agus rochtain éigeandála;
(b)
freagracht úsáideora, lena n-áirithítear go bhféadfaí úsáideoirí a shainaithint maidir leis na gníomhaíochtaí a rinneadh sna córais TFC;
(c)
nósanna imeachta bainistíochta cuntais maidir le cearta rochtana a dheonú, a athrú nó a chúlghairm do chuntais úsáideoirí agus cuntais chineálacha, lena n-áirítear cuntais chineálacha riarthóra;
(d)
modhanna fíorúcháin atá ag teacht leis an aicmiú dá dtagraítear in Airteagal 30(1) agus le próifíl riosca fhoriomlán na sócmhainní TFC, agus ar a bhfuil cleachtais atá chun tosaigh bunaithe;
(e)
déantar athbhreithniú go tréimhsiúil ar chearta rochtana agus déantar iad a tharraingt siar nuair nach bhfuil gá leo a thuilleadh.
Chun críocha phointe (c), déanfaidh an t-eintiteas airgeadais rochtain pribhléide, éigeandála agus riarthóra a shannadh ar bhonn riachtanais úsáide nó ar bonn ad hoc maidir leis na córais TFC uile, agus logálfar iad i gcomhréir le hAirteagal 34 an chéad mhír, pointe (f).
Chun críocha phointe (d), bainfidh eintitis airgeadais úsáid as modhanna fíorúcháin láidre atá bunaithe ar chleachtais atá chun tosaigh maidir le cianrochtain ar ghréasán na n-eintiteas airgeadais, maidir le rochtain faoi phribhléid, agus maidir le rochtain ar shócmhainní TFC a thacaíonn le feidhmeanna criticiúla nó tábhachtacha atá ar fáil go poiblí.
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Saincheisteanna nasctha
- 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.
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