CHG-02.2: Test, Validate & Document Changes

There is no evidence of a capability to appropriately test and document proposed changes in a non-production environment before changes are implemented in a production environment.

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.
• IT personnel use an informal process to verify the functionality of security controls when anomalies or misconfigurations are discovered.

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.
• Up on implementing the RFC, the technician implementing a change tests to ensure anti-malware, logging and other cybersecurity and data protection controls are still implemented and operating properly.
• Results from testing changes are documented.
• Up on completing the RFC, the CAB reports the results of cybersecurity and data privacy function verification to senior management.

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.
• Up on implementing the RFC, the technician implementing a change tests to ensure anti-malware, logging and other cybersecurity and data protection controls are still implemented and operating properly.
• Results from testing changes are documented.
• A structured set of controls are tested after a change is implemented to ensure cybersecurity controls are operating properly.
• Results from testing changes are documented.
• CM leverages Information Technology Infrastructure Library (ITIL) Service Management practices to govern CM operations (includes SecDevOps considerations).
• Up on completing the RFC, the CAB reports the results of cybersecurity and data privacy function verification to senior management.
• Up on implementing the RFC, the technician implementing a change tests to ensure anti-malware, logging and other cybersecurity and data protection controls are still implemented and operating properly.
• A vulnerability assessment is conducted on systems/applications/services to detect any new vulnerabilities that a change may have introduced.

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 test and document proposed changes in a non-production environment before changes are implemented in a production environment.

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 test and document proposed changes in a non-production environment before changes are implemented in a production environment.