CHG-02.1: Prohibition Of Changes

There is no evidence of a capability to prohibit unauthorized changes, unless organization-approved change requests are received.

Change Management (CHG) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: o Govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Notify stakeholders about proposed changes.

• IT personnel use an informal process to:
• Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services.
• Requests for Change (RFC) are submitted to IT personnel.
• prior to changes being made, RFCs are informally reviewed for cybersecurity and data privacy ramifications.
• Whenever possible, IT personnel test changes to business-critical systems/services/applications on a similarly configured IT environment as that of Production, prior to widespread production release of the change.
• Copying, deleting, moving and renaming operations are version controlled.

Change Management (CHG) 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:

• Change 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 change management.
• Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC).
• A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability.
• A CAB, or similar function, reviews RFCs for cybersecurity and data privacy ramifications.
• A CAB, or similar function, notifies stakeholders to ensure awareness of the impact of proposed changes.
• Logical Access Control (LAC) limits the ability of non-administrators from making unauthorized configuration changes to systems, applications and services.
• Cybersecurity controls are tested after a change is implemented to ensure cybersecurity controls are operating properly.
• Asset custodians are assigned responsibilities that cover change management duties, including privileged access to perform change management actions.

Change Management (CHG) 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: o Exists to govern changes to systems, applications and services to ensure their stability, reliability and predictability. o Reviews RFC for cybersecurity and data privacy ramifications. o Notifies stakeholders to ensure awareness of the impact of proposed changes.

• An IT Asset Management (ITAM) function, or similar function, ensures compliance with requirements for asset management.
• ITAM leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets.
• Logical Access Control (LAC) is governed to limit the ability of non-administrators from making configuration changes to systems, applications and services.
• A formal Change Management (CM) program ensures that no unauthorized changes are made, that all changes are documented, that services are not disrupted and that resources are used efficiently.
• The CM function has formally defined roles and associated responsibilities.
• Changes are tracked through a centralized technology solution to submit, review, approve and assign Requests for Change (RFC).
• A Change Advisory Board (CAB), or similar function:
• IT personnel use dedicated development/test/staging environments to deploy and evaluate changes, wherever technically possible.
• Asset custodians are assigned responsibilities that cover change management duties, including privileged access to perform change management actions.
• File Integrity Monitoring (FIM) alerts are investigated for unauthorized changes.
• FIM alerts are investigated for unauthorized changes and are configured to implement remediation actions up on the detection of unauthorized baseline configurations change(s).
• FIM is deployed on systems that store, process or transmit sensitive/regulated/regulated data to monitor the integrity of business-critical files for tampering.
• Endpoint technologies detect and report changes with a centralized Change Management (CM) service to discover unauthorized changes.

Change Management (CHG) 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. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• 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 prohibit unauthorized changes, unless organization-approved change requests are received.