+Root Cause Analysis (RCA) & Lessons Learned

Root Cause Analysis (RCA) & Lessons Learned

Description

Mechanisms exist to incorporate lessons learned from analyzing and resolving cybersecurity and data protection incidents to reduce the likelihood or impact of future incidents.

Possible Solutions & Considerations

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

∙ Root Cause Analysis (RCA)

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

∙ Root Cause Analysis (RCA)

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

∙ Root Cause Analysis (RCA)

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

∙ Root Cause Analysis (RCA)

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

∙ Root Cause Analysis (RCA)

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

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ Incident responders provide After Action Review (AAR) feedback on what worked, what did not work and ways to improve future responses to similar incidents.
▪ A formal Root Cause Analysis (RCA) is performed that documents the findings in a report for both technical and business leadership management.

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management 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 IRO 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 incorporate lessons learned from analyzing and resolving cybersecurity and data protection incidents to reduce the likelihood or impact of future incidents.

Level 4 Quantitatively Controlled

Incident Response (IRO) 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. Pregled

Naslov Standard

1.1 Sklici

1.2 Ugotovljene zahteve

1.3 Povezani predpisi

2. Ugotovljene zahteve

Zahteve
Vir Zahteva

3. Povezani predpisi

Predpisi
Vir Regulativa
EULAW Člen 22 Politika obvladovanja incidentov, povezanih z IKT

Člen 22

Politika obvladovanja incidentov, povezanih z IKT

Finančni subjekti v okviru mehanizmov za odkrivanje neobičajnega ravnanja, vključno s težavami v zvezi z zmogljivostjo omrežja IKT in incidenti, povezanimi z IKT, razvijejo, dokumentirajo in izvajajo politiko glede incidentov, povezanih z IKT, s katero:

(a) 

dokumentirajo postopek obvladovanja incidentov, povezanih z IKT, iz člena 17 Uredbe (EU) 2022/2554;

(b) 

pripravijo seznam ustreznih stikov z notranjimi funkcijami in zunanjimi deležniki, ki so neposredno vključeni v varnost delovanja IKT, vključno z:

(i) 

odkrivanjem in spremljanjem kibernetskih groženj;

(ii) 

odkrivanjem neobičajnega ravnanja;

(iii) 

upravljanjem ranljivosti;

(c) 

vzpostavijo, izvajajo in upravljajo tehnične, organizacijske in operativne mehanizme za podporo postopku obvladovanja incidentov, povezanih z IKT, vključno z mehanizmi, ki omogočajo takojšnje odkrivanje neobičajnega ravnanja in vedenja v skladu s členom 23 te uredbe;

▼C1

(d) 

hranijo vse dokaze v zvezi z incidenti, povezanimi z IKT, za obdobje, ki ni daljše, kot je potrebno za namene, za katere se zbirajo podatki, sorazmerno s kritičnostjo prizadetih poslovnih funkcij, podpornih postopkov ter sredstev IKT in informacijskih sredstev, v skladu s členom 8(2) Delegirane uredbe Komisije (EU) 2024/1772 ( 2 ), in vsemi veljavnimi zahtevami glede hrambe v skladu s pravom Unije;

▼B

(e) 

vzpostavijo in izvajajo mehanizme za analizo pomembnih ali ponavljajočih se incidentov, povezanih z IKT, ter vzorcev v številu in pojavljanju incidentov, povezanih z IKT.

Za namene točke (d) finančni subjekti varno hranijo dokaze iz navedene točke.

EULAW Člen 41 Oblika in vsebina poročila o pregledu poenostavljenega okvira za obvladovanje tveganj na področju IKT
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EULAW Člen 13 Učenje in razvoj
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EULAW Člen 23 Obveznosti poročanja
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EULAW Člen 13 Učenje in razvoj
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EULAW Člen 23 Obveznosti poročanja
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EULAW Article 13 2

2.   Financial entities shall put in place post ICT-related incident reviews after a major ICT-related incident disrupts their core activities, analysing the causes of disruption and identifying required improvements to the ICT operations or within the ICT business continuity policy referred to in Article 11.

Financial entities, other than microenterprises, shall, upon request, communicate to the competent authorities, the changes that were implemented following post ICT-related incident reviews as referred to in the first subparagraph.

The post ICT-related incident reviews referred to in the first subparagraph shall determine whether the established procedures were followed and the actions taken were effective, including in relation to the following:

(a)

the promptness in responding to security alerts and determining the impact of ICT-related incidents and their severity;

(b)

the quality and speed of performing a forensic analysis, where deemed appropriate;

(c)

the effectiveness of incident escalation within the financial entity;

(d)

the effectiveness of internal and external communication.

EULAW Article 13 3

3.   Lessons derived from the digital operational resilience testing carried out in accordance with Articles 26 and 27 and from real life ICT-related incidents, in particular cyber-attacks, along with challenges faced upon the activation of ICT business continuity plans and ICT response and recovery plans, together with relevant information exchanged with counterparts and assessed during supervisory reviews, shall be duly incorporated on a continuous basis into the ICT risk assessment process. Those findings shall form the basis for appropriate reviews of relevant components of the ICT risk management framework referred to in Article 6(1).

Povezane zadeve

Povezave
Vrsta povezave Zadeva
is related to Annual
is related to relative Control Weighting = 09
is related to Process
is related to Identify
is related to SCRM Focus Tier 2 OPERATIONAL
blocks Loss of Accountability / Attribution
blocks Excessive or Unauthorized Privilege
blocks Unauthorized Privilege Elevation
blocks Unauthorized Access
blocks Loss, Theft or Damage of Assets
blocks Unauthorized Modification / Loss of System Integrity
blocks Business / Service Interruption
blocks Data Loss / Integrity Compromise
blocks Reduced Operational Productivity
blocks System / Data Compromise (Technical Vector)
blocks System / Data Compromise (Non-Technical Vector)
blocks Revenue Loss
blocks Contractual Default / Termination
blocks Loss of Competitive Advantage
blocks Reputational Harm / Loss of Stakeholder Trust
blocks Regulatory / Legal / Contractual Financial Liability
blocks Exposure from Unaddressed Vulnerabilities
blocks System / Service Compromise
blocks Failure to Support Business / Mission Objectives
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 Harm from Illegal, Abusive or Unsafe Content / Conduct
blocks Loss of Investigative / Evidentiary Capability
blocks Delayed Containment / Increased Incident Impact
blocks Incident Persistence / Recurrence
blocks Incident Response / Recovery Cost
blocks Undetected / Delayed Detection of Adverse Activity
blocks Third-Party Cybersecurity Compromise / Exposure
blocks Third-Party Physical Security Disruption / Exposure
blocks Sub-Tier / Fourth-Party Supply Chain Exposure
blocks Third-Party Legal / Compliance Exposure
blocks Harm from Unauthorized / Unintended Product or Service Use
blocks Third-Party Dependency Failure
is related to relative Control Weighting = 08
is related to Respond
is related to SCRM Focus Tier 1 STRATEGIC
is related to SCRM Focus Tier 3 TACTICAL
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Lack of a security-minded workforce
blocks Loss of Critical Knowledge / Capability
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 Data Quality Degradation / Data Poisoning
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
blocks OPS-19.01B
blocks OPS-22.08B
blocks OPS-22.05AC
blocks OPS-23.01B
blocks SIM-03.01B
blocks SIM-03.02B
blocks SIM-03.07B
blocks SIM-06.02B
blocks SIM-06.03B
blocks SIM-06.04B
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Lack of a security-minded workforce
blocks Loss of Critical Knowledge / Capability
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 Data Quality Degradation / Data Poisoning
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
blocks OPS-19.01B
blocks OPS-22.08B
blocks OPS-22.05AC
blocks OPS-23.01B
blocks SIM-03.01B
blocks SIM-03.02B
blocks SIM-03.07B
blocks SIM-06.02B
blocks SIM-06.03B
blocks SIM-06.04B
is blocked by IRO-14 Root Cause Analysis (RCA) & Lessons Learned – Assessment Procedure
blocks IR-01 Policy and Procedures
blocks IR-04(12) Malicious Code and Forensic Analysis
blocks IR-06(02) Vulnerabilities Related to Incidents
blocks IR-01 [L] Policy and Procedures
blocks IR-01 [M] Policy and Procedures
blocks IR-01 [H] Policy and Procedures
blocks IR-01 [P] Policy and Procedures
blocks 03.06.04 Incident Response Training
blocks ID.IM-02 Improvements are identified from security tests and exercises, including those done in coordination with suppliers and relevant third parties
blocks ID.IM-03 Improvements are identified from execution of operational processes, procedures, and activities
blocks RS.AN-03 Analysis is performed to establish what has taken place during an incident and the root cause of the incident
blocks RV.3 Analyze Vulnerabilities to Identify Their Root Causes
  • Secure Controls Framework -

    The Secure Controls Framework® (SCF)

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    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.

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