MON-04.1: System-Wide / Time-Correlated Audit Trail

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

Continuous Monitoring (MON) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with MON domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with MON domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MON domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Continuous monitoring-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Continuous monitoring may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis. ▪ SBC enforce logging to link system access to individual users or service accounts using a non-repudiation capability to protect against an individual falsely denying having performed a particular action. ▪ SBC enforce local security event logging and forward those logs to a centralized log repository to provide an alternate audit capability in the event of a failure in the primary audit capability.

Continuous Monitoring (MON) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with MON domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Cybersecurity personnel use a structured process via Standardized Operating Procedures (SOP) to review and analyze logs. ▪ A Security Operations Center (SOC) team, or similar function, is appropriately staffed and supported to implement and maintain MON domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of continuous monitoring operations (e.g., Security Incident Event Manager (SIEM)). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MON domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ Secure Baseline Configurations (SBC) enforce security event logging to contain sufficient information to establish necessary details of activity and allow for forensics analysis. ▪ An implemented and operational capability exists to automatically compile audit records into an organization-wide audit trail that is time-correlated.

Continuous Monitoring (MON) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational. ▪ 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. ▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

Continuous Monitoring (MON) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes. ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.