+Privileged Account Management (PAM)
---+Privileged Account Inventories
---+Privileged Account Separation
---+Dedicated Privileged Account
---+Privileged Command Execution
---+Manual Override
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Privileged Account Management (PAM)
Description
Mechanisms exist to restrict and control privileged access rights for users and Technology Assets, Applications and/or Services (TAAS).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Strong password policy
∙ MFA for key accounts
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Password manager
∙ MFA on all accounts
∙ Identity policy
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ ManageEngine Enterprise Password Management (https://manageengine.com)
∙ Securden (https://securden.com)
∙ CyberArk (https://cyberark.com)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ ManageEngine Enterprise Password Management (https://manageengine.com)
∙ Securden (https://securden.com)
∙ CyberArk (https://cyberark.com)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ ManageEngine Enterprise Password Management (https://manageengine.com)
∙ Securden (https://securden.com)
∙ CyberArk (https://cyberark.com)
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
Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions.
▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.
Level 2 Planned Tracked
Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
▪ IAM restricts the assignment of privileged accounts to entity-defined personnel and/or roles (privilege assignment requires management approval).
▪ LAC and RBAC enforcements limit the ability of non-administrators from making unauthorized configuration changes to TAAS.
Level 3 Well Defined
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) solution).
▪ 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 IAC 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 restrict and control privileged access rights for users and Technology Assets, Applications and/or Services (TAAS).
Level 4 Quantitatively Controlled
Identification & Authentication (IAC) 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
Identification & Authentication (IAC) 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.
▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.
▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
1. Visão geral
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Norma |
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Privileged Account Inventories
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Description
Mechanisms exist to inventory all privileged accounts and validate that each person with elevated privileges is authorized by the appropriate level of organizational management.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)
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
Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
Level 3 Well Defined
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) solution).
▪ 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 IAC 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 inventory all privileged accounts and validate that each person with elevated privileges is authorized by the appropriate level of organizational management.
Level 4 Quantitatively Controlled
Identification & Authentication (IAC) 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
Identification & Authentication (IAC) 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.
▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.
▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
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Privileged Account Separation
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Description
Mechanisms exist to separate privileged accounts between infrastructure environments to reduce the risk of a compromise in one infrastructure environment from laterally affecting other infrastructure environments.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Use separate accounts for admin vs. regular daily tasks
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Separate privileged and standard accounts for all administrators
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal privileged account separation policy
∙ Dedicated admin accounts
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise privileged account management with dedicated admin accounts (e.g., CyberArk)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise PAM platform (e.g., CyberArk, BeyondTrust)
∙ Dedicated privileged accounts
∙ Separation of duties enforcement
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
Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions.
▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.
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
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) solution).
▪ 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 IAC 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 separate privileged accounts between infrastructure environments to reduce the risk of a compromise in one infrastructure environment from laterally affecting other infrastructure environments.
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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Dedicated Privileged Account
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Description
Mechanisms exist to assign dedicated privileged user accounts to be used solely for duties requiring privileged access.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Use separate dedicated admin account for privileged tasks
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Dedicated privileged account policy
∙ No daily use of admin accounts
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal dedicated privileged account policy
∙ Separate admin credentials from daily-use accounts
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise PAM with dedicated privileged accounts (e.g., CyberArk, BeyondTrust)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise PAM platform with dedicated privileged accounts
∙ Privileged access workstations (PAW)
∙ Just-in-time access
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
Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions.
▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.
Level 2 Planned Tracked
Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
Level 3 Well Defined
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) solution).
▪ 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 IAC 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 assign dedicated privileged user accounts to be used solely for duties requiring privileged access.
Level 4 Quantitatively Controlled
Identification & Authentication (IAC) 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
Identification & Authentication (IAC) 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.
▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.
▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
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Privileged Command Execution
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Description
Mechanisms exist to ensure privilege change requests require additional levels of authentication.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Limit privileged commands to authorized admin accounts only
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Policy restricting privileged command execution to authorized accounts
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal privileged command control policy
∙ Technical enforcement via sudo/RBAC
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise PAM with privileged command controls
∙ Command-level authorization
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise PAM platform with command-level controls and auditing (e.g., CyberArk)
∙ Just enough access (JEA)
∙ Full session recording
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
Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
Level 3 Well Defined
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) solution).
▪ 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 IAC 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 ensure privilege change requests require additional levels of authentication.
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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Manual Override
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Description
Mechanisms exist to enable a manual override of the current account privileges to enable the timely response to unusual conditions without terminating the current session and establishing a new session as a higher-privileged user.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Document manual override procedures for automated systems
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Manual override policy and procedure for automated access controls
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal manual override process with approval and audit trail
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise manual override process with dual authorization and logging
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise PAM with manual override workflows
∙ Dual control for override access
∙ Automated audit trail for all overrides
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
Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) solution).
▪ 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 IAC 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 enable a manual override of the current account privileges to enable the timely response to unusual conditions without terminating the current session and establishing a new session as a higher-privileged user.
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 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 21.o Controlo do acesso
Artigo 21.o
No âmbito do seu controlo da gestão dos direitos de acesso, as entidades financeiras devem desenvolver, documentar e aplicar uma política que contenha todos os elementos seguintes:
a)
A atribuição de direitos de acesso a ativos de TIC com base nos princípios da necessidade de tomar conhecimento, da necessidade de utilizar e do menor privilégio, nomeadamente para o acesso à distância e de emergência;
b)
A segregação de funções destinada a impedir o acesso injustificado a dados críticos ou impedir a atribuição de combinações de direitos de acesso que possam ser utilizadas para contornar os controlos;
c)
Uma disposição sobre a responsabilização dos utilizadores, limitando, na medida do possível, a utilização de contas de utilizador genéricas e partilhadas e assegurando que os utilizadores sejam sempre identificáveis nas ações realizadas nos sistemas de TIC;
d)
Uma disposição em matéria de restrições de acesso a ativos de TIC, estabelecendo controlos e ferramentas para impedir o acesso não autorizado;
e)
Procedimentos de gestão das contas para conceder, alterar ou revogar direitos de acesso a contas de utilizador e a contas genéricas, nomeadamente contas de administrador genéricas, incluindo disposições relativas a todos os aspetos seguintes:
i)
atribuição de funções e responsabilidades para a concessão, revisão e revogação de direitos de acesso,
ii)
atribuição de acesso privilegiado, de emergência e de administrador com base na necessidade de utilização ou numa base ad hoc para todos os sistemas de TIC,
iii)
retirada dos direitos de acesso sem demora injustificada após a cessação do contrato de trabalho ou quando o acesso deixar de ser necessário,
iv)
atualização dos direitos de acesso sempre que sejam necessárias alterações e, pelo menos, uma vez por ano para todos os sistemas de TIC que não sejam sistemas de TIC que apoiem funções críticas ou importantes, e pelo menos a cada seis meses para os sistemas de TIC que apoiem funções críticas ou importantes;
f)
Métodos de autenticação, incluindo todos os elementos seguintes:
i)
a utilização de métodos de autenticação proporcionados à classificação estabelecida em conformidade com o artigo 8.o, n.o 1, do Regulamento (UE) 2022/2554 e ao perfil de risco global dos ativos de TIC e tendo em conta as melhores práticas,
ii)
a utilização de métodos de autenticação forte em conformidade com as melhores práticas e técnicas para o acesso remoto à rede da entidade financeira, para o acesso privilegiado e ainda para o acesso a ativos de TIC que apoiem funções críticas ou importantes ou ativos de TIC acessíveis ao público;
g)
Medidas de controlo do acesso físico, nomeadamente:
i)
a identificação e o registo de pessoas singulares autorizadas a aceder a instalações, centros de dados e áreas consideradas sensíveis identificadas pela entidade financeira onde se encontrem os ativos de TIC e de informação,
ii)
a concessão de direitos de acesso físico a ativos de TIC críticos apenas a pessoas autorizadas, de acordo com os princípios da necessidade de tomar conhecimento e do menor privilégio, e numa base ad hoc,
iii)
a monitorização do acesso físico a instalações, centros de dados e áreas consideradas sensíveis identificadas pela entidade financeira onde se encontrem os ativos de TIC e de informação ou ambos,
iv)
a revisão dos direitos de acesso físico, a fim de assegurar que os direitos de acesso desnecessários são imediatamente revogados.
Para efeitos da alínea e), subalínea i), as entidades financeiras devem estabelecer o período de conservação, tendo em conta os objetivos empresariais e de segurança da informação, o motivo para registar o evento nos registos e os resultados da avaliação do risco associado às TIC.
Para efeitos da alínea e), subalínea ii), as entidades financeiras devem utilizar, sempre que possível, contas específicas para a execução de tarefas administrativas relativas aos sistemas de TIC. Sempre que possível e adequado, as entidades financeiras devem utilizar soluções automatizadas para a gestão do acesso privilegiado.
Para efeitos da alínea g), subalínea i), a identificação e o registo devem ser proporcionados à importância das instalações, dos centros de dados e das áreas consideradas sensíveis e ao caráter crítico das operações ou dos sistemas de TIC aí localizados.
Para efeitos da alínea g), subalínea iii), a monitorização deve ser proporcionada à classificação estabelecida em conformidade com o artigo 8.o, n.o 1, do Regulamento (UE) 2022/2554 e ao caráter crítico da área acedida.
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EULAW
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Artigo 33.o Controlo do acesso
Artigo 33.o
As entidades financeiras a que se refere o artigo 16.o, n.o 1, do Regulamento (UE) 2022/2554 devem elaborar, documentar e aplicar procedimentos de controlo do acesso lógico e físico, bem como fazer cumprir, acompanhar e rever periodicamente esses procedimentos. Esses procedimentos devem incluir os seguintes elementos de controlo do acesso lógico e físico:
a)
Os direitos de acesso a ativos de informação, ativos de TIC e respetivas funções apoiadas, bem como a locais críticos de funcionamento da entidade financeira, são geridos com base nos princípios da necessidade de conhecer, da necessidade de utilizar e do menor privilégio, nomeadamente para o acesso remoto e de emergência;
b)
Responsabilização dos utilizadores, que garanta que os mesmos possam ser identificados no respeitante às ações realizadas nos sistemas de TIC;
c)
Procedimentos de gestão de contas para conceder, alterar ou revogar direitos de acesso a contas de utilizador e a contas genéricas, incluindo contas de administrador genéricas;
d)
Métodos de autenticação que sejam proporcionados à classificação a que se refere o artigo 30.o, n.o 1, e ao perfil de risco global dos ativos de TIC, e que se baseiem nas melhores práticas;
e)
Os direitos de acesso são revistos periodicamente e revogados quando deixarem de ser necessários.
Para efeitos da alínea c), a entidade financeira atribui acesso privilegiado, de emergência e de administrador com base na necessidade de utilizar ou numa base pontual a todos os sistemas de TIC, que deve ser registado em conformidade com o artigo 34.o, primeiro parágrafo, alínea f).
Para efeitos da alínea d), as entidades financeiras devem utilizar métodos de autenticação forte baseados nas melhores práticas para o acesso remoto à rede das entidades financeiras, para o acesso privilegiado e para o acesso a ativos de TIC que apoiam funções críticas ou importantes publicamente disponíveis.
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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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