+Capabilities Deficiency Tracking
---+Deficiency Tracking Automation

Capabilities Deficiency Tracking

Description

Mechanisms exist to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Possible Solutions & Considerations

Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

Small Business (10-49 staff) / BLS Firm Size Classes 3-4

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

Medium Business (50-249 staff) / BLS Firm Size Classes 5-6

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

Large Business (250-999 staff) / BLS Firm Size Classes 7-8

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

Enterprise (> 1,000 staff) / BLS Firm Size Class 9

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

Level 3 Well Defined

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment 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 IAO 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 govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Level 4 Quantitatively Controlled

Information Assurance (IAO) 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. Ħarsa ġenerali

Titlu Standard
Deficiency Tracking Automation

Description

Automated mechanisms exist to help ensure tracked deficiencies are:
(1) Accurate;
(2) Up-to-date; and
(3) Readily-available.

Possible Solutions & Considerations

Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2

∙ Plan of Action and Milestones (POA&M) spreadsheet kept current

Small Business (10-49 staff) / BLS Firm Size Classes 3-4

∙ POA&M tracked in ticketing/spreadsheet with owners and dates

Medium Business (50-249 staff) / BLS Firm Size Classes 5-6

∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.) for POA&M tracking
∙ Automated reminders and status updates

Large Business (250-999 staff) / BLS Firm Size Classes 7-8

∙ GRC platform with automated deficiency tracking and integration with vulnerability/ticketing systems
∙ Real-time POA&M dashboards

Enterprise (> 1,000 staff) / BLS Firm Size Class 9

∙ Enterprise GRC platform with automated POA&M lifecycle management, integrations and executive dashboards (e.g., Archer, MetricStream, ServiceNow IRM, Cyturus)

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

Information Assurance (IAO) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAO domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Pre-production security testing-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain an informal process to conduct limited control testing of High Value Assets (HVAs) to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

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

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment 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 IAO 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 automate deficiency tracking to ensure records are:
(1) Accurate;
(2) Up-to-date; and
(3) Readily-available.

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.

1.1 Referenzi

1.2 Rekwiżiti identifikati

1.3 Regolamenti relatati

2. Rekwiżiti identifikati

Rekwiżiti
Sors Rekwiżit

3. Regolamenti relatati

Kwistjonijiet marbuta

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Tip ta’ link Kwistjoni
is related to Annual
is related to relative Control Weighting = 09
is related to Process
is related to Detect
is related to SCRM Focus Tier 2 OPERATIONAL
is related to SCRM Focus Tier 3 TACTICAL
blocks Loss of Accountability / Attribution
blocks Regulatory / Legal / Contractual Financial Liability
blocks Exposure from Unaddressed Vulnerabilities
blocks Loss of Authorization / Certification / License
blocks Unaddressed Security / Compliance Exposure
blocks Unperformed / Unowned Control Responsibilities
blocks Uncontrolled Internal Security / Privacy Exposure
blocks Uncontrolled Third-Party Security / Privacy Exposure
blocks Lack of oversight of internal controls
blocks Lack of oversight of third-party controls
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Unreliable Assurance / Decision Information
blocks Incident Persistence / Recurrence
blocks Drought & Water Shortage
blocks Earthquakes
blocks Fire & Wildfires
blocks Floods
blocks Hurricanes & Tropical Storms
blocks Landslides & Debris Flow
blocks Pandemic (Disease) Outbreaks
blocks Severe Weather
blocks Space Weather
blocks Thunderstorms & Lightning
blocks Tornadoes
blocks Tsunamis
blocks Volcanoes
blocks Winter Storms & Extreme Cold
blocks Malicious Cyber Activity
blocks Dysfunctional Management Practices
blocks Human Error
blocks Technical / Mechanical Failure
blocks Statutory / Regulatory / Contractual Change
blocks Data Quality Degradation / Data Poisoning
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
blocks OIS-04.02AC
blocks SP-03.03AC
blocks OPS-13.02AC
blocks IAM-03.03AC
blocks DEV-10.01AC
blocks SIM-03.03AC
blocks COM-03.02AC
blocks INQ-03.02AC
is blocked by IAO-12 Capabilities Deficiency Tracking – Assessment Procedure
blocks CA-05 Plan of Action and Milestones
blocks PM-04 Plan of Action and Milestones Process
blocks SA-15(02) Security and Privacy Tracking Tools
blocks CA-05 [L] Plan of Action and Milestones
blocks CA-05 [M] Plan of Action and Milestones
blocks CA-05 [H] Plan of Action and Milestones
blocks CA-05 [P] Plan of Action and Milestones
blocks PM-04 [P] Plan of Action and Milestones Process
blocks 03.04.11 Information Location
blocks 03.12.02 Plan of Action and Milestones
blocks 03.14.01 Flaw Remediation
blocks ID.RA-01 Vulnerabilities in assets are identified, validated, and recorded
blocks ID.IM-01 Improvements are identified from evaluations
blocks ID.IM-02 Improvements are identified from security tests and exercises, including those done in coordination with suppliers and relevant third parties
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