CLD-13.2: Sensitive / Regulated Data On Hosted Assets, Applications & Services

There is no evidence of a capability to define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external Technology Assets, Applications and/or Services (TAAS), in accordance with all applicable statutory, regulatory and/or contractual obligations.

C|P-CMM1 is N/A, since a structured process is required to define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external Technology Assets, Applications and/or Services (TAAS), in accordance with all applicable statutory, regulatory and/or contractual obligations.

C|P-CMM2 is N/A, since a well-defined process is required to define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external Technology Assets, Applications and/or Services (TAAS), in accordance with all applicable statutory, regulatory and/or contractual obligations.

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. IT infrastructure team assigns roles and responsibilities for governing Content Delivery Network (CDN) instances, including provisioning, maintaining and deprovisioning of instances.

• 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.

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 define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external Technology Assets, Applications and/or Services (TAAS), in accordance with all applicable statutory, regulatory and/or contractual obligations.

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 define formal processes to store, process and/or transmit sensitive/regulated data using External Service Providers (ESP) owned, operated and/or maintained external Technology Assets, Applications and/or Services (TAAS), in accordance with all applicable statutory, regulatory and/or contractual obligations.