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CFG-25: Control Assurance Automation (CAA) Separation of Duties

CFG 8 — High Protect

Mechanisms exist to prevent an individual responsible for operating a control from unilaterally modifying the Control Assurance Automation (CAA) automated collection, transformation, or scoring logic used to evidence that control.

Control Question: Does the organization prevent an individual responsible for operating a control from unilaterally modifying the Control Assurance Automation (CAA) automated collection, transformation, or scoring logic used to evidence that control?

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

  1. CFG-25_A01 the individuals or roles responsible for operating each control evidenced by Control Assurance Automation (CAA) are identified and documented.
  2. CFG-25_A02 the individuals or roles authorized to modify Control Assurance Automation (CAA) collection, transformation or scoring logic are identified and documented.
  3. CFG-25_A03 access controls prevent an individual responsible for operating a control from modifying the Control Assurance Automation (CAA) collection, transformation or scoring logic used to evidence that control without independent approval (e.g., enforced peer review, protected branches or a separate deployment role).
  4. CFG-25_A04 separation of duties between control operation and Control Assurance Automation (CAA) logic modification is reviewed at a defined frequency and when personnel or role assignments change.
  5. CFG-25_A05 where separation of duties cannot be achieved, compensating controls (e.g., independent review of all Control Assurance Automation (CAA) logic changes) are documented and approved.

Evidence Requirements

E-CFG-02 Control Assurance Automation (CAA) Change Control Records

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

  • Second-person review of any change to compliance scripts
  • Documented compensating control where SoD is not feasible

Small

  • Repository permissions separating control operators from automation maintainers
  • Mandatory review of changes by a second individual

Medium

  • Role Based Access Control (RBAC) on CAA repositories and platforms
  • Mandatory independent approval for CAA changes
  • Annual access review

Large

  • RBAC with protected branches and required reviewers
  • Separation of Duties (SoD) matrix covering CAA
  • Independent assurance function review

Enterprise

  • Enterprise SoD enforcement across CAA platforms and repositories
  • Independent assurance / internal audit ownership of scoring logic
  • Automated SoD conflict detection (e.g., IGA platform)

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