CFG-23: Control Assurance Automation (CAA) Change Control
Mechanisms exist to place Control Assurance Automation (CAA) collection code, queries and transformation logic under version control, peer review, testing and change management commensurate with the sensitivity of the Technology Assets, Applications, Services and/or Data (TAASD) accessed.
Control Question: Does the organization place Control Assurance Automation (CAA) collection code, queries and transformation logic under version control, peer review, testing and change management commensurate with the sensitivity of the Technology Assets, Applications, Services and/or Data (TAASD) accessed?
Capability Maturity Model
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
Configuration Management (CFG) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with CFG domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Configuration management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
Level 2 — Planned & Tracked
Configuration Management (CFG) 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 CFG domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with CFG 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 CFG domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Configuration management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Configuration 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
Configuration Management (CFG) 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 CFG 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 CFG domain capabilities are well-documented and kept current by process owners. ▪ A configuration management team, or similar function, is appropriately staffed and supported to implement and maintain CFG domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of configuration management operations (e.g., Configuration Management Database (CMBD) Asset Management 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 CFG 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).
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.
Assessment Objectives
- CFG-23_A01 Control Assurance Automation (CAA) collection code, queries and transformation logic are maintained under version control.
- CFG-23_A02 changes to Control Assurance Automation (CAA) collection code, queries and transformation logic are peer reviewed by an individual other than the author prior to deployment.
- CFG-23_A03 changes to Control Assurance Automation (CAA) collection code, queries and transformation logic are tested prior to deployment to confirm they produce the intended results.
- CFG-23_A04 changes to Control Assurance Automation (CAA) collection code, queries and transformation logic are authorized through change management, with approval recorded prior to deployment.
- CFG-23_A05 the level of review, testing and change management rigor applied to Control Assurance Automation (CAA) logic is defined commensurate with the sensitivity of the Technology Assets, Applications, Services and/or Data (TAASD) accessed.
Evidence Requirements
- E-CFG-02 Control Assurance Automation (CAA) Change Control Records
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Documented evidence that Control Assurance Automation (CAA) collection code, queries and scoring logic are under version control, peer review and change management, with separation of duties and unauthorized change detection.
Asset Management
Technology Recommendations
Micro/Small
- Compliance scripts stored in a shared repository with change history
- Second-person review of script changes
Small
- Version control (e.g., GitHub, GitLab, Azure DevOps) for compliance automation
- Peer review before deployment
Medium
- Version control with pull request review
- Test environment for CAA logic
- CAA changes recorded in the change management system
Large
- Source control with protected branches and mandatory review
- Automated testing of CAA logic in CI/CD
- Change Advisory Board (CAB) visibility for CAA changes
Enterprise
- Enterprise SCM with protected branches, signed commits and mandatory review
- Automated regression testing of collection and scoring logic
- CAA changes integrated with enterprise change management (e.g., ServiceNow)