+Digital & Non-Digital Media Disposal
---+Dual Authorization for Sensitive / Regulated Data Destruction
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Digital & Non-Digital Media Disposal
Description
Mechanisms exist to securely dispose of, destroy and/or erase digital and non-digital media when it is no longer required, using organization-defined procedures.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Shred-it (https://shredit.com)
∙ IronMountain (https://ironmountain.com)
∙ BitRaser (https://bitraser.com)
∙ DBAN (https://dban.org)
∙ DoD-strength data erasers
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Shred-it (https://shredit.com)
∙ IronMountain (https://ironmountain.com)
∙ BitRaser (https://bitraser.com)
∙ DBAN (https://dban.org)
∙ DoD-strength data erasers
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Shred-it (https://shredit.com)
∙ IronMountain (https://ironmountain.com)
∙ BitRaser (https://bitraser.com)
∙ DBAN (https://dban.org)
∙ DoD-strength data erasers
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Shred-it (https://shredit.com)
∙ IronMountain (https://ironmountain.com)
∙ BitRaser (https://bitraser.com)
∙ DBAN (https://dban.org)
∙ DoD-strength data erasers
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Shred-it (https://shredit.com)
∙ IronMountain (https://ironmountain.com)
∙ BitRaser (https://bitraser.com)
∙ DBAN (https://dban.org)
∙ DoD-strength data erasers
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
Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations.
▪ The data retention process is manual and IT and/or cybersecurity personnel work with business stakeholders and process owners to manage the process.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to dispose of, destroy, erase, and/or anonymize sensitive/regulated data.
Level 3 Well Defined
Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners.
▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform).
▪ 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 DCH 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 securely dispose of, destroy or erase information.
Level 4 Quantitatively Controlled
Data Classification & Handling (DCH) 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. Panoramica
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Standard |
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Dual Authorization for Sensitive / Regulated Data Destruction
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Description
Mechanisms exist to enforce dual authorization for the destruction, disposal or sanitization of digital media that contains sensitive and/or regulated data.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Logical Access Control (LAC)
∙ Physical Access Control (PAC)
∙ Role Based Access Control (RBAC)
∙ Separation of Duties (SoD)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Logical Access Control (LAC)
∙ Physical Access Control (PAC)
∙ Role Based Access Control (RBAC)
∙ Separation of Duties (SoD)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Logical Access Control (LAC)
∙ Physical Access Control (PAC)
∙ Role Based Access Control (RBAC)
∙ Separation of Duties (SoD)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Logical Access Control (LAC)
∙ Physical Access Control (PAC)
∙ Role Based Access Control (RBAC)
∙ Separation of Duties (SoD)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Logical Access Control (LAC)
∙ Physical Access Control (PAC)
∙ Role Based Access Control (RBAC)
∙ Separation of Duties (SoD)
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
Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners.
▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform).
▪ 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 DCH 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 enforce dual authorization for the destruction, disposal or sanitization of digital media that contains sensitive/regulated data.
Level 4 Quantitatively Controlled
Data Classification & Handling (DCH) 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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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 11 Sicurezza dei dati e dei sistemi
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EULAW
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Articolo 11 Sicurezza dei dati e dei sistemi
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EULAW
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Articolo 35 Sicurezza dei dati, dei sistemi e delle reti
Articolo 35
Sicurezza dei dati, dei sistemi e delle reti
Le entità finanziarie di cui all’articolo 16, paragrafo 1, del regolamento (UE) 2022/2554, nell’ambito dei loro sistemi, protocolli e strumenti, elaborano e attuano salvaguardie che garantiscono la sicurezza delle reti contro le intrusioni e l’uso improprio dei dati e che preservano la disponibilità, l’autenticità, l’integrità e la riservatezza dei dati. In particolare, le entità finanziarie, tenendo conto della classificazione di cui all’articolo 30, paragrafo 1, del presente regolamento, stabiliscono tutti gli elementi seguenti:
a)
l’identificazione e l’attuazione di misure di protezione dei dati in uso, in transito e a riposo;
b)
l’identificazione e l’attuazione di misure di sicurezza relative all’uso di software, supporti di memorizzazione dei dati, sistemi e dispositivi endpoint utilizzati per trasferire e memorizzare dati dell’entità finanziaria;
c)
l’identificazione e l’attuazione di misure per prevenire e individuare connessioni non autorizzate alla rete dell’entità finanziaria e per proteggere il traffico di rete tra le reti interne dell’entità finanziaria e Internet e altre connessioni esterne;
d)
l’identificazione e l’attuazione di misure che garantiscano la disponibilità, l’autenticità, l’integrità e la riservatezza dei dati durante le trasmissioni di rete;
e)
un processo per cancellare in modo sicuro i dati nei locali o memorizzati esternamente che l’entità finanziaria non ha più bisogno di raccogliere o conservare;
f)
un processo per smaltire o dismettere in modo sicuro i dispositivi di archiviazione dati presenti nei locali o quelli conservati all’esterno contenenti informazioni riservate;
g)
l’identificazione e l’attuazione di misure per garantire che il telelavoro e l’uso di dispositivi endpoint privati non abbiano un impatto negativo sulla capacità dell’entità finanziaria di svolgere le proprie attività critiche in modo adeguato, tempestivo e sicuro.
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Ticket collegati
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