IRO-12: Sensitive / Regulated Data Spill Response

There is no evidence of a capability to respond to sensitive/regulated data spills.

C|P-CMM1 is N/A, since a structured process is required to respond to sensitive/regulated data spills.

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:

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 respond to sensitive/regulated data spills.

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 respond to sensitive/regulated data spills.