CHG-04.1: Automated Access Enforcement / Auditing

There is no evidence of a capability to perform after-the-fact reviews of configuration change logs to discover any unauthorized changes.

C|P-CMM1 is N/A, since a structured process is required to perform after-the-fact reviews of configuration change logs to discover any unauthorized changes.

C|P-CMM2 is N/A, since a well-defined process is required to perform after-the-fact reviews of configuration change logs to discover any unauthorized changes.

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.

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 perform after-the-fact reviews of configuration change logs to discover any unauthorized changes.