IRO-10: Incident Stakeholder Reporting

There is no evidence of a capability to timely-report incidents to applicable: (1) Internal stakeholders; (2) Affected clients & third-parties; and (3) Regulatory authorities.

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

• IT personnel use an informal process to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
• Incident response operations are decentralized.

Incident Response (IRO) 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 incident response operations. o Implement and maintain an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.

• Incident response operations are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
• IT/cybersecurity personnel:
• Administrative processes and technologies exist to document, manage and report on actual and potential cybersecurity and data privacy incidents.
• Administrative processes and technologies exist to maintain incident response contacts with applicable regulatory and law enforcement agencies.

Incident Response (IR) processes 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:

• An Integrated Security Incident Response Team (ISIRT), or similar function, exists to form an on-demand, scalable and integrated team of formally-assigned cybersecurity, IT, data privacy and business function representatives that can perform coordinated incident response.
• The ISIRT, or similar function, develops and maintains a documented, program-level Integrated Incident Response Program (IIRP) that provides operational and tactical-level guidance for cybersecurity and data privacy response operations.
• A Security Operations Center (SOC), or similar function, facilitates incident management operations that includes preparation, detection and analysis, containment, eradication and recovery.
• Business Process Owners (BPOs), in conjunction with the SOC and ISIRT functions, develop and maintain a documented Incident Response Plan (IRP) specific to the business process / business unit but inclusive of the organization's larger approach to incident response operations.
• An IT Asset Management (ITAM) function, or similar function, categorizes endpoint devices according to the data the asset stores, transmits and/ or processes and provides that information to the SOC for Incident Response Operations (IRO).
• Administrative processes and technologies exist to report incidents both internally to organizational incident response personnel (within defined time-periods) and externally to governmental authorities and affected parties, as necessary.
• Administrative processes and technologies exist to maintain incident response contacts with applicable regulatory and law enforcement agencies.

Incident Response (IR) is metrics driven and provides sufficient management insight (based on a quantitative understanding of process 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 timely-report incidents to applicable: (1) Internal stakeholders; (2) Affected clients & third-parties; and (3) Regulatory authorities.