+Artikel 19 Automatisch gegenereerde logs
---+Artikel 19 1.
---+Artikel 19 2.
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Artikel 19 Automatisch gegenereerde logs
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1. Overzicht
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Regelgeving |
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Artikel 19 1.
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Aanbieders van AI-systemen met een hoog risico bewaren de in artikel 12, lid 1, bedoelde logs die automatisch worden gegenereerd door hun AI-systemen met een hoog risico voor zover dergelijke logs onder hun controle vallen. Onverminderd het toepasselijke Unie- of nationale recht worden deze logs bewaard gedurende een periode, die passend is voor het beoogde doel van het AI-systeem met een hoog risico, van ten minste zes maanden, tenzij anders is bepaald in het toepasselijke Unie- of nationaal recht, met name het Unierecht inzake de bescherming van persoonsgegevens.
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Artikel 19 2.
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Aanbieders die in de hoedanigheid van financiële instellingen onderworpen zijn aan eisen met betrekking tot hun interne governance, regelingen of processen uit hoofde van het Unierecht inzake financiële diensten, bewaren de automatisch door hun AI-systemen met een hoog risico gegenereerde logs, als onderdeel van de documentatie die bewaard wordt krachtens het desbetreffende recht inzake financiële diensten.
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1.1 Referenties
1.2 Geïdentificeerde eisen
1.3 Gerelateerde standaarden
2. Geïdentificeerde eisen
3. Gerelateerde standaarden
Standaarden
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Eis |
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SCF
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Event Log & Security-Relevant Telemetry Retention
Description
Mechanisms exist to retain event logs and security-relevant telemetry 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 contractual retention requirements.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Managed Security Services Provider (MSSP)
∙ Log retention policy (minimum 90 days online, 1 year archived)
∙ Cloud log storage (e.g., AWS S3, Azure Storage)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Managed Security Services Provider (MSSP)
∙ Log retention policy (minimum 90 days online, 1 year archived)
∙ Cloud SIEM with configurable retention
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Security Incident Event Manager (SIEM) with defined retention schedules
∙ Managed Security Services Provider (MSSP)
∙ Log archiving to cold storage (e.g., AWS S3 Glacier, Azure Archive)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ SIEM with tiered log retention (hot/warm/cold storage)
∙ Log retention policy aligned to regulatory requirements (e.g., HIPAA 6 yrs, PCI DSS 1 yr)
∙ Managed Security Services Provider (MSSP)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise log retention program aligned to all applicable regulations
∙ SIEM with tiered retention (hot/warm/cold storage)
∙ Immutable log archives (e.g., AWS S3 Object Lock, Azure Blob WORM)
∙ Legal hold capability for investigation support
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.
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.
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 retain 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 contractual retention requirements.
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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SCF
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Event Log & Security-Relevant Telemetry Retention
Description
Mechanisms exist to retain event logs and security-relevant telemetry 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 contractual retention requirements.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Managed Security Services Provider (MSSP)
∙ Log retention policy (minimum 90 days online, 1 year archived)
∙ Cloud log storage (e.g., AWS S3, Azure Storage)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Managed Security Services Provider (MSSP)
∙ Log retention policy (minimum 90 days online, 1 year archived)
∙ Cloud SIEM with configurable retention
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Security Incident Event Manager (SIEM) with defined retention schedules
∙ Managed Security Services Provider (MSSP)
∙ Log archiving to cold storage (e.g., AWS S3 Glacier, Azure Archive)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ SIEM with tiered log retention (hot/warm/cold storage)
∙ Log retention policy aligned to regulatory requirements (e.g., HIPAA 6 yrs, PCI DSS 1 yr)
∙ Managed Security Services Provider (MSSP)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise log retention program aligned to all applicable regulations
∙ SIEM with tiered retention (hot/warm/cold storage)
∙ Immutable log archives (e.g., AWS S3 Object Lock, Azure Blob WORM)
∙ Legal hold capability for investigation support
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.
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.
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 retain 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 contractual retention requirements.
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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