AST-12: Use of Personal Devices

There is no evidence of a capability to restrict the possession and/or use of personally-owned Technology Assets, Applications and/or Services (TAAS) within organization-controlled facilities.

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.
• Organizational policies and standards cover the use of personal devices (e.g., Bring Your Own Device (BYOD), as part of acceptable and unacceptable behaviors.

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.
• Organizational policies and standards cover the use of personal devices (e.g., Bring Your Own Device (BYOD), as part of acceptable and unacceptable behaviors.
• Mobile Device Management (MDM) software is used to restrict sensitive data from residing on personal devices.

Asset Management (AST) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement.

• 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.
• Both business and technical stakeholders are involved in reviewing and approving proposed changes.

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 restrict the possession and/or use of personally-owned Technology Assets, Applications and/or Services (TAAS) within organization-controlled facilities.