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END-13.3: Collection Minimization

END 8 — High Protect

Mechanisms exist to utilize sensors that are configured to minimize the collection of information about individuals.

Control Question: Does the organization utilize sensors that are configured to minimize the collection of information about individuals?

General (7)
Framework Mapping Values
IEC TR 60601-4-5 2021 4.5
NIST 800-53 R5 (source) PM-25 SA-8(33) SC-42(5)
NIST 800-53B R5 (privacy) (source) PM-25 SA-8(33)
NIST 800-53 R5 (NOC) (source) SC-42(5)
NIST 800-161 R1 PM-25
NIST 800-161 R1 Level 2 PM-25
SCF CORE Mergers, Acquisitions & Divestitures (MA&D) END-13.3
US (1)
Framework Mapping Values
US - CO Colorado Privacy Act 6-1-1308(3)
EMEA (2)
Framework Mapping Values
EMEA Saudi Arabia IoT CGIoT-1 2024 2-6-3
EMEA South Africa 10

Capability Maturity Model

Level 0 — Not Performed

There is no evidence of a capability to utilize sensors that are configured to minimize the collection of information about individuals.

Level 1 — Performed Informally

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.
Level 2 — Planned & Tracked

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.
Level 3 — Well Defined

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.
Level 4 — Quantitatively Controlled

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 utilize sensors that are configured to minimize the collection of information about individuals.

Level 5 — Continuously Improving

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 utilize sensors that are configured to minimize the collection of information about individuals.

Assessment Objectives

  1. END-13.3_A01 processes that implement the privacy principle of minimization are defined.
  2. END-13.3_A02 the privacy principle of minimization is implemented using organization-defined processes.
  3. END-13.3_A03 the sensors that are configured to minimize the collection of unneeded information about individuals are defined.
  4. END-13.3_A04 sensors configured to minimize the collection of information about individuals that is not needed are employed.
  5. END-13.3_A05 the frequency for reviewing / updating policies that address the use of Personal Data (PD) for internal testing, training and research is defined.
  6. END-13.3_A06 policies that address the use of Personal Data (PD) for internal testing, training and research are developed and documented.
  7. END-13.3_A07 procedures that address the use of Personal Data (PD) for internal testing, training and research are developed and documented.
  8. END-13.3_A08 policies that address the use of Personal Data (PD) for internal testing, training and research are implemented.
  9. END-13.3_A09 procedures that address the use of Personal Data (PD) for internal testing, training and research are implemented.
  10. END-13.3_A10 the amount of Personal Data (PD) used for internal testing, training and research purposes is limited or minimized.
  11. END-13.3_A11 the required use of Personal Data (PD) for internal testing, training and research is authorized.
  12. END-13.3_A12 policies are reviewed / updated frequently.
  13. END-13.3_A13 procedures are reviewed / updated frequently.

Technology Recommendations

Micro/Small

  • Secure Baseline Configurations (SBC)
  • Data Protection Impact Assessment (DPIA)
  • Product / project management

Small

  • Secure Baseline Configurations (SBC)
  • Data Protection Impact Assessment (DPIA)
  • Product / project management

Medium

  • Secure Baseline Configurations (SBC)
  • Data Protection Impact Assessment (DPIA)
  • Product / project management

Large

  • Secure Baseline Configurations (SBC)
  • Data Protection Impact Assessment (DPIA)
  • Product / project management

Enterprise

  • Secure Baseline Configurations (SBC)
  • Data Protection Impact Assessment (DPIA)
  • Product / project management

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