MON-01.14: Individuals Posing Greater Risk

There is no evidence of a capability to implement enhanced activity monitoring for individuals who have been identified as posing an increased level of risk.

C|P-CMM1 is N/A, since a structured process is required to implement enhanced activity monitoring for individuals who have been identified as posing an increased level of risk.

C|P-CMM2 is N/A, since a well-defined process is required to implement enhanced activity monitoring for individuals who have been identified as posing an increased level of risk.

Continuous Monitoring (MON) 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 Governs asset management that ensures compliance with requirements for asset management. o Leverages a Configuration Management Database (CMDB), or similar tool, as the authoritative source of IT assets. o Centrally collects logs and is protected according to the manufacturer’s security guidelines to protect the integrity of the event logs with cryptographic mechanisms. o Monitors the organization for Indicators of Compromise (IoC) and provides 24x7x365 near real-time alerting capability. o Is configured to alert incident response personnel of detected suspicious events such that incident responders can look to terminate suspicious events.

• An IT Asset Management (ITAM) function, or similar function:
• A Security Incident Event Manager (SIEM), or similar automated tool:
• Both inbound and outbound network traffic is monitored for unauthorized activities to identify prohibited activities and assist incident handlers with identifying potentially compromised systems.
• Human Resources (HR) and Legal departments determine what is legally-allowable to support enhanced monitoring for individuals who pose a greater risk to the organization, including privileged users.
• A Security Operations Center (SOC), or similar capability, configures monitoring technologies to implement the enhanced monitoring profiles for selected users and establish a reporting capability to designated personnel.

Continuous Monitoring (MON) 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.

Continuous Monitoring (MON) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions.
• Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.