AST-07: Kiosks & Point of Interaction (PoI) Devices

There is no evidence of a capability to appropriately protect devices that capture sensitive/regulated data via direct physical interaction from tampering and substitution.

Asset Management (AST) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel.
• Asset inventories are performed in an ad hoc manner.
• Software licensing is tracked as part of IT asset inventories.
• Data process owners maintain limited network diagrams to document the flow of sensitive/regulated data that is specific to their initiative.
• IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Asset Management (AST) efforts are requirements-driven and governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Asset management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
• IT/cybersecurity personnel identify cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements for asset management.
• Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
• Asset management is formally assigned as an additional duty to existing IT/cybersecurity personnel.
• Technology assets are categorized according to data classification and business criticality.
• Inventories cover technology assets in scope for statutory, regulatory and/ or contractual compliance, which includes both physical and virtual assets.
• Software licensing is tracked as part of IT asset inventories.
• Users are educated on their responsibilities to protect technology assets assigned to them or under their supervision.
• IT/cybersecurity personnel maintain network diagrams to document the flow of sensitive/regulated data across the network.
• Hardened system configurations are used for unattended systems to enforce the principle of least functionality by removing unnecessary accounts, applications and services.
• Periodic physical inspections are performed to validate the integrity of unattended systems (e.g., kiosks, ATMs, etc.) and Point of Sale (POS) devices.
• Organizational policies and standards cover Enhanced security requirements for unattended systems (e.g., kiosks, ATMs, etc.) and POS devices.

Asset Management (AST) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• An IT Asset Management (ITAM) function, or similar function, governs asset management to help ensure compliance with requirements for asset management.
• An ITAM function, or similar function, maintains an inventory of IT assets, covering both physical and virtual assets, as well as centrally managed asset ownership assignments.
• Technology assets and data are categorized according to data classification and business criticality criteria.
• A Cybersecurity Supply Chain Risk Management (C-SCRM) function oversees supply chain risks including the removal and prevention of certain technology services and/ or equipment designated as supply chain threats by a statutory or regulatory body.
• Data/process owners document where sensitive/regulated data is stored, transmitted and processed, generating Data Flow Diagrams (DFDs) and network diagrams to document the flow of data.
• Hardened system configurations are used for unattended systems to enforce the principle of least functionality by removing unnecessary accounts, applications and services.
• Periodic physical inspections are performed to validate the integrity of unattended systems (e.g., kiosks, ATMs, etc.) and Point of Sale (POS) devices.
• Organizational policies and standards cover Enhanced security requirements for unattended systems (e.g., kiosks, ATMs, etc.) and POS devices.
• Periodic physical and local inspections are performed to validate the integrity of unattended systems (e.g., kiosks, ATMs, etc.), sensitive/regulated systems and Point of Sale (POS) devices.
• File Integrity Monitoring (FIM) is deployed on systems and unattended systems that store, process or transmit sensitive/regulated data to monitor the integrity of business-critical files to detect tampering.
• Host-based Intrusion Prevention System (HIPS) is deployed on both systems and unattended systems to identify and block hostile activities.

See C|P-CMM3. There are no defined C|P-CMM4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to appropriately protect devices that capture sensitive/regulated data via direct physical interaction from tampering and substitution.

See C|P-CMM4. There are no defined C|P-CMM5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to appropriately protect devices that capture sensitive/regulated data via direct physical interaction from tampering and substitution.