+Content of Event Logs
---+Audit Trails
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Content of Event Logs
Description
Mechanisms exist to configure Technology Assets, Applications and/or Services (TAAS) to produce event logs that contain sufficient information to, at a minimum:
(1) Establish what type of event occurred;
(2) When (date and time) the event occurred;
(3) Where the event occurred;
(4) The source of the event;
(5) The outcome (success or failure) of the event; and
(6) The identity of any user/subject associated with the event.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Secure Baseline Configurations (SBC)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Secure Baseline Configurations (SBC)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Secure Baseline Configurations (SBC)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Secure Baseline Configurations (SBC)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Secure Baseline Configurations (SBC)
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.
▪ Generating event logs and the review of those event logs is narrowly-focused to business-critical Technology Assets, Applications, Services and/or Data (TAASD).
Level 2 Planned Tracked
Continuous Monitoring (MON) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Continuous monitoring may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ SBC enforce logging to link system access to individual users or service accounts using a non-repudiation capability to protect against an individual falsely denying having performed a particular action.
▪ SBC enforce local security event logging and forward those logs to a centralized log repository to provide an alternate audit capability in the event of a failure in the primary audit capability.
Level 3 Well Defined
Continuous Monitoring (MON) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM)).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MON domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to configure Technology Assets, Applications and/or Services (TAAS) to produce event logs that contain sufficient information to, at a minimum:
(1) Establish what type of event occurred;
(2) When (date and time) the event occurred;
(3) Where the event occurred;
(4) The source of the event;
(5) The outcome (success or failure) of the event; and
(6) The identity of any user/subject associated with the event.
Level 4 Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
1. Panoramica
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Standard |
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Audit Trails
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Description
Mechanisms exist to link system access to individual users or service accounts.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Secure Baseline Configurations (SBC)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Secure Baseline Configurations (SBC)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Secure Baseline Configurations (SBC)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Secure Baseline Configurations (SBC)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Secure Baseline Configurations (SBC)
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
Continuous Monitoring (MON) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with MON domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Event monitoring-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Monitoring is primarily reactive in nature, focused on identifying incidents that occurred.
▪ Event log reviews primarily rely on manual processes to identify anomalous behaviors.
▪ Generating event logs and the review of those event logs is narrowly-focused to business-critical Technology Assets, Applications, Services and/or Data (TAASD).
Level 2 Planned Tracked
Continuous Monitoring (MON) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with MON domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with MON domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Continuous monitoring may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ SBC enforce logging to link system access to individual users or service accounts using a non-repudiation capability to protect against an individual falsely denying having performed a particular action.
▪ SBC enforce local security event logging and forward those logs to a centralized log repository to provide an alternate audit capability in the event of a failure in the primary audit capability.
▪ A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical TAASD.
▪ IT and/or cybersecurity personnel configure alerts for critical or sensitive data that is stored, transmitted and processed on assets.
▪ IT and/or cybersecurity personnel retain security event logs for a time period consistent with records retention requirements to provide support for after-the-fact investigations of security incidents and to meet statutory, regulatory and/or contractual retention requirements.
Level 3 Well Defined
Continuous Monitoring (MON) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs.
▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM)).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MON domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis.
▪ An implemented and operational capability exists to link system access to individual users or service accounts.
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 Riferimenti
1.2 Requisiti identificati
1.3 Regolamentazioni correlate
2. Requisiti identificati
Requisiti
| Fonte |
Requisito |
3. Regolamentazioni correlate
Regolamentazioni
| Fonte |
Regolamentazione |
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EULAW
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Articolo 8 Politiche e procedure per le operazioni riguardanti le TIC
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EULAW
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Articolo 12 Logging
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EULAW
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Articolo 12 Logging
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EULAW
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Articolo 12 Logging
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EULAW
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Articolo 12 Logging
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EULAW
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Articolo 12 Logging
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EULAW
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Articolo 12 Logging
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EULAW
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Articolo 12 Logging
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EULAW
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Articolo 12 Logging
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EULAW
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Articolo 23 Individuazione di attività anomale e criteri per l’individuazione degli incidenti connessi alle TIC e la risposta agli stessi
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EULAW
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Articolo 34 Sicurezza delle operazioni riguardanti le TIC
Articolo 34
Sicurezza delle operazioni riguardanti le TIC
Le entità finanziarie di cui all’articolo 16, paragrafo 1, del regolamento (UE) 2022/2554, nell’ambito dei loro sistemi, protocolli e strumenti e per tutte le risorse TIC:
a)
monitorano e gestiscono il ciclo di vita di tutte le risorse TIC;
b)
monitorano se le risorse TIC sono supportate da fornitori terzi di servizi TIC delle entità finanziarie, ove applicabile;
c)
identificano i requisiti di capacità delle proprie risorse TIC e le misure per mantenere e migliorare la disponibilità e l’efficienza dei sistemi di TIC e prevenire le carenze di capacità TIC prima che si concretizzino;
d)
eseguono scansioni e valutazioni automatizzate delle vulnerabilità delle risorse TIC commisurate alla loro classificazione di cui all’articolo 30, paragrafo 1, e al profilo di rischio complessivo della risorsa TIC, e applicano patch per risolvere le vulnerabilità identificate;
e)
gestiscono i rischi relativi a risorse TIC obsolete, non supportate o legacy;
f)
registrano nei log gli eventi relativi al controllo degli accessi logici e fisici, alle operazioni riguardanti le TIC, comprese le attività di sistema e di traffico di rete, e alla gestione delle modifiche delle TIC;
g)
identificano e attuano misure per monitorare e analizzare le informazioni su attività e comportamenti anomali per le operazioni essenziali o importanti riguardanti le TIC;
h)
attuano misure per monitorare le informazioni pertinenti e aggiornate sulle minacce informatiche;
i)
attuano misure per identificare possibili fughe di informazioni, codici malevoli e altre minacce alla sicurezza, nonché vulnerabilità pubblicamente note in software e hardware e verificano la disponibilità di nuovi aggiornamenti di sicurezza corrispondenti.
Ai fini della lettera f), le entità finanziarie allineano il livello di dettaglio dei log allo scopo e all’utilizzo della risorsa TIC che li produce.
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