+Monitoring For Information Disclosure
---+Monitoring for Third-Party Information Disclosure
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Monitoring For Information Disclosure
Description
Mechanisms exist to monitor for evidence of unauthorized exfiltration or disclosure of non-public information.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Content filtering
∙ Keyword alerting (e.g., Google Alerts)
∙ Review of social media outlets
∙ HaveIBeenPwned monitoring (https://haveibeenpwned.com)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Content filtering
∙ Keyword alerting (e.g., Google Alerts)
∙ Review of social media outlets
∙ HaveIBeenPwned monitoring (https://haveibeenpwned.com)
∙ Dark web monitoring (e.g., SpyCloud, HaveIBeenPwned Pro)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Content filtering
∙ Keyword alerting (e.g., Google Alerts)
∙ Dark web monitoring (e.g., SpyCloud, Recorded Future, Digital Shadows)
∙ Data Loss Prevention (DLP) solution
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data Loss Prevention (DLP) solution (e.g., Microsoft Purview DLP, Forcepoint DLP)
∙ Dark web monitoring platform (e.g., Recorded Future, Digital Shadows, SpyCloud)
∙ Brand and digital footprint monitoring
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise DLP solution (e.g., Symantec DLP, Forcepoint DLP, Microsoft Purview DLP)
∙ Dedicated threat intelligence platform with dark web monitoring
∙ Digital risk protection (DRP) service (e.g., ZeroFox, Recorded Future)
∙ Automated exfiltration detection via SIEM/UEBA
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
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 monitor for evidence of unauthorized exfiltration or disclosure of non-public information.
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. Visão geral
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Norma |
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Monitoring for Third-Party Information Disclosure
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Description
Mechanisms exist to monitor for evidence of unauthorized exfiltration or disclosure of organizational information.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Asset management 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 monitor for evidence of unauthorized exfiltration or disclosure of organizational information.
Level 4 Quantitatively Controlled
Third-Party Management (TPM) 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 Referências
1.2 Requisitos identificados
1.3 Regulamentos relacionados
2. Requisitos identificados
Requisitos
| Fonte |
Requisito |
3. Regulamentos relacionados
Regulamentos
| Fonte |
Regulamentação |
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EULAW
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Artigo 23.o Deteção de atividades anómalas e critérios para a deteção e resposta a incidentes relacionados com as TIC
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EULAW
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Artigo 34.o Segurança das operações de TIC
Artigo 34.o
Segurança das operações de TIC
As entidades financeiras a que se refere o artigo 16.o, n.o 1, do Regulamento (UE) 2022/2554 devem, no âmbito dos seus sistemas, protocolos e ferramentas, e em relação a todos os ativos de TIC:
a)
Acompanhar e gerir o ciclo de vida de todos os ativos de TIC;
b)
Verificar se os ativos de TIC são apoiados por terceiros prestadores de serviços de TIC de entidades financeiras, se for caso disso;
c)
Identificar as necessidades de capacidade dos seus ativos de TIC e as medidas para manter e melhorar a disponibilidade e a eficiência dos sistemas de TIC e evitar défices de capacidade das TIC antes da sua ocorrência;
d)
Realizar análises automatizadas das vulnerabilidades e avaliações de ativos de TIC proporcionadas à sua classificação, tal como referido no artigo 30.o, n.o 1, e ao perfil de risco global do ativo de TIC, bem como aplicar correções para resolver as vulnerabilidades identificadas;
e)
Gerir os riscos relacionados com ativos de TIC obsoletos, não apoiados ou legados;
f)
Registar eventos relacionados com o controlo lógico e físico do acesso e com as operações de TIC, incluindo atividades de tráfego nos sistemas e redes e a gestão de alterações das TIC;
g)
Identificar e aplicar medidas para monitorizar e analisar informações sobre atividades e comportamentos anómalos em operações críticas ou importantes no domínio das TIC;
h)
Aplicar medidas para monitorizar informações pertinentes e atualizadas sobre as ciberameaças;
i)
Aplicar medidas para identificar possíveis fugas de informação, códigos maliciosos e outras ameaças à segurança, bem como vulnerabilidades do conhecimento público em software e hardware, e verificar se existem novas atualizações de segurança correspondentes.
Para efeitos da alínea f), as entidades financeiras devem alinhar o nível de pormenor dos registos com a sua finalidade e a utilização do ativo de TIC que dá origem a esses registos.
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Pedidos ligados
- Secure Controls Framework -
"The SCF is the Common Controls Framework™ (CCF), the world's most comprehensive cybersecurity and data privacy metaframework - it is also free to use. The entire concept is building secure, compliant and resilient capabilities in the most efficient and cost-effective manner possible.
The SCF is more than just a unified control catalog, since its included content creates a playbook for Governance, Risk & Compliance (GRC) capabilities. Used globally by organizations of every size, the SCF is a robust and scalable solution for security, compliance and resilience controls. As a comprehensive security framework, the SCF maps 1,400+ controls across 200+ laws, regulations, and industry frameworks so you can implement once and comply everywhere.
Like it or not, cybersecurity is a protracted war on an asymmetric battlefield, where the threats are everywhere and as defenders we have to make the effort to work together to help improve cybersecurity and data privacy practices, since we all suffer when massive data breaches occur or when cyber attacks have physical impacts. Hackers share information on attack methods with other hackers, so why shouldn’t the good guys share information on how to best protect an organization? We decided to take action and make a difference, since we feel it is too important to wait for someone else to fix the problems that exist.
The SCF is made up of volunteers, mainly specialists within the cybersecurity profession, who focus on GRC and the cybersecurity side of data privacy. These are auditors, engineers, architects, incident responders, consultants and other specialists who live and breathe these topics on a daily basis. The end product is "expert-derived content" that makes up the SCF." https://securecontrolsframework.com/
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