+Articolo 15 Segnalazione volontaria
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Articolo 15 Segnalazione volontaria
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1. Panoramica
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Regolamentazione |
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Articolo 15 1.
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I fabbricanti e altre persone fisiche o giuridiche possono notificare a un CSIRT designato come coordinatore o all’ENISA, su base volontaria, qualsiasi vulnerabilità contenuta in un prodotto con elementi digitali nonché le minacce informatiche che potrebbero incidere sul profilo di rischio di un prodotto con elementi digitali.
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Articolo 15 2.
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I fabbricanti e altre persone fisiche o giuridiche possono notificare a un CSIRT designato come coordinatore o all’ENISA, su base volontaria, qualsiasi incidente che abbia un impatto sulla sicurezza del prodotto con elementi digitali e qualsiasi quasi incidente che avrebbe potuto tradursi in un simile incidente.
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Articolo 15 3.
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Il CSIRT designato come coordinatore o l’ENISA trattano le notifiche di cui ai paragrafi 1 e 2 del presente articolo secondo la procedura di cui all’articolo 16. Il CSIRT designato come coordinatore può trattare le notifiche obbligatorie in via prioritaria rispetto alle notifiche volontarie.
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Articolo 15 4.
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Qualora una persona fisica o giuridica diversa dal fabbricante notifichi una vulnerabilità attivamente sfruttata o un incidente grave che ha un impatto sulla sicurezza di un prodotto con elementi digitali conformemente al paragrafo 1 o 2, il CSIRT designato come coordinatore ne informa senza indebito ritardo il fabbricante.
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Articolo 15 5.
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I CSIRT designati come coordinatori e l’ENISA garantiscono la riservatezza e la protezione adeguata delle informazioni fornite da una persona fisica o giuridica notificante. Fatti salvi la prevenzione, l’indagine, l’accertamento e il perseguimento di reati, la segnalazione volontaria non ha l’effetto di imporre alla persona fisica o giuridica notificante alcun obbligo aggiuntivo a cui non sarebbe stata sottoposta se non avesse trasmesso la notifica.
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1.1 Riferimenti
1.2 Requisiti identificati
1.3 Standard correlati
2. Requisiti identificati
Requisiti
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Requisito |
3. Standard correlati
Standard
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Requisito |
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SCF
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Incident Stakeholder Reporting
Description
Mechanisms exist to timely-report incidents to applicable:
(1) Internal stakeholders;
(2) Affected clients & third-parties; and
(3) Regulatory authorities.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Basic incident response plan
∙ Designate incident response contact
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Documented incident response plan
∙ Incident log
∙ Designated IR team
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal incident response program
∙ IR playbooks
∙ Tabletop exercises
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise incident response program
∙ 24/7 SOC monitoring
∙ SOAR platform
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise SOC with SIEM/SOAR (e.g., Splunk SOAR, Palo Alto XSOAR)
∙ IR retainer
∙ 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
Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH 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 IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ IT and/or cybersecurity personnel facilitate prompt response to suspected or confirmed security incidents, including timely notification to affected stakeholders.
Level 3 Well Defined
Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 timely-report incidents to applicable:
(1) Internal stakeholders;
(2) Affected clients & third-parties; and
(3) Regulatory authorities.
Level 4 Quantitatively Controlled
Incident Response (IRO) 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.
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SCF
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Incident Stakeholder Reporting
Description
Mechanisms exist to timely-report incidents to applicable:
(1) Internal stakeholders;
(2) Affected clients & third-parties; and
(3) Regulatory authorities.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Basic incident response plan
∙ Designate incident response contact
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Documented incident response plan
∙ Incident log
∙ Designated IR team
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal incident response program
∙ IR playbooks
∙ Tabletop exercises
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise incident response program
∙ 24/7 SOC monitoring
∙ SOAR platform
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise SOC with SIEM/SOAR (e.g., Splunk SOAR, Palo Alto XSOAR)
∙ IR retainer
∙ 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
Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH 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 IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ IT and/or cybersecurity personnel facilitate prompt response to suspected or confirmed security incidents, including timely notification to affected stakeholders.
Level 3 Well Defined
Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 timely-report incidents to applicable:
(1) Internal stakeholders;
(2) Affected clients & third-parties; and
(3) Regulatory authorities.
Level 4 Quantitatively Controlled
Incident Response (IRO) 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.
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