END-13.2: Notice of Collection

There is no evidence of a capability to notify individuals that Personal Data (PD) is collected by sensors.

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

• Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel.
• IT/cybersecurity personnel use an informal process to design, build and maintain secure configurations for test, development, staging and production environments, including the implementation of appropriate cybersecurity and data protection controls.
• Anti-malware technologies are decentralized but are deployed on all technology assets that can run Anti-malware software.
• Data management is decentralized.

Endpoint Security (END) 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:

• Endpoint 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 identify cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements for endpoint security management.
• Anti-malware technologies are decentralized but are deployed on all technology assets that can run anti-malware software.
• Physical controls, administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
• Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.
• A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of Personal Data (PD) processed, stored or transmitted on endpoint devices, so that cybersecurity and data protection controls are implemented in accordance with applicable statutory, regulatory and contractual obligations.
• Administrative processes exist and technologies are configured to notify individuals that Personal Data (PD) is collected by sensors.

Endpoint Security (END) 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:

• Configuration management is centralized for all operating systems, applications, servers and other configurable technologies.
• Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including test, development, staging and production environments.
• Configurations conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides) for test, development, staging and production environments.
• An Identity & Access Management (IAM) function, or similar function, centrally manages permissions and implements “least privileges” practices for the management of user, group and system accounts, including privileged accounts.
• An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data that conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).
• A Security Operations Center (SOC), or similar function, centrally manages anti-malware and anti-phishing technologies, in accordance with industry-recognized practices for Prevention, Detection & Response (PDR) activities.
• A Security Incident Event Manager (SIEM), or similar automated tool, is tuned to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities.
• The Human Resources (HR) department ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices.
• Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the any unauthorized configuration is malicious in nature.
• A Data Protection Impact Assessment (DPIA) is used to help ensure the protection of Personal Data (PD) processed, stored or transmitted on endpoint devices, so that cybersecurity and data protection controls are implemented in accordance with applicable statutory, regulatory and contractual obligations.
• Administrative processes exist and technologies are configured to notify individuals that Personal Data (PD) is collected by sensors.

Endpoint Security (END) 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 notify individuals that Personal Data (PD) is collected by sensors.