MON-06.1: Query Parameter Audits of Personal Data (PD)

There is no evidence of a capability to provide and implement the capability for auditing the parameters of user query events for data sets containing Personal Data (PD).

C|P-CMM1 is N/A, since a structured process is required to provide and implement the capability for auditing the parameters of user query events for data sets containing Personal Data (PD).

Continuous Monitoring (MON) 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 situational awareness management. o Configure alerts for critical or sensitive data that is stored, transmitted and processed on assets. o Use a structured process to review and analyze logs.

• Situational awareness management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
• Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis.
• IT/cybersecurity personnel:
• A log aggregator, or similar automated tool, provides an event log report generation capability to aid in detecting and assessing anomalous activities on business-critical systems.

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.

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.

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 provide and implement the capability for auditing the parameters of user query events for data sets containing Personal Data (PD).