CLD-09: Geolocation Requirements for Processing, Storage and Service Locations

There is no evidence of a capability to control the location of cloud processing/storage based on business requirements that includes statutory, regulatory and contractual obligations.

Cloud Security (CLD) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Cloud-based technologies are governed no differently from on-premise network assets (e.g., cloud-based technology is viewed as an extension of the corporate network).
• A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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: o Identify cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements for cloud security management. o Use an informal process to govern cloud-specific cybersecurity and data privacy-specific tools.

• Cloud security management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
• IT/cybersecurity personnel:
• A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.
• IT personnel have a documented architecture for cloud-based technologies to support cybersecurity and data protection requirements.
• Cybersecurity and data privacy requirements are identified and documented for cloud-specific sensitive/regulated data processing, storing and/ or transmitting, including restrictions on data processing and storage locations.

Cloud Security (CLD) 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 Ensure the cloud security architecture supports the organization's technology strategy to securely design, configure and maintain cloud employments. o Ensure multi-tenant CSP assets (physical and virtual) are designed and governed such that provider and customer (tenant) user access is appropriately segmented from other tenant users. o Ensure CSPs use secure protocols for the import, export and management of data in cloud-based services. o Implement a dedicated subnet to host security-specific technologies on all cloud instances, where technically feasible. o Governs changes to cloud-based systems, applications and services to ensure their stability, reliability and predictability. o Reviews processes to identify and prevent use of unapproved CSPs.

• Roles and associated responsibilities for governing cloud instances, including provisioning, maintaining and deprovisioning, are formally assigned.
• A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.
• IT architects, in conjunction with cybersecurity architects:
• A Change Advisory Board (CAB), or similar function:
• A dedicated IT infrastructure team, or similar function, enables the implementation of cloud management controls to ensure cloud instances are both secure and compliant, leveraging industry-recognized secure practices that are CC|P-specific.
• Cybersecurity and data privacy requirements are identified and documented for each CSP instance to address sensitive/regulated data processing, storing and/ or transmitting and provide restrictions on data processing and storage locations.
• A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of sensitive/regulated data processed, stored or transmitted on external systems.

Cloud Security (CLD) 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.

Cloud Security (CLD) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions.
• Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.