MON-14: Cross-Organizational Monitoring

There is no evidence of a capability to coordinate sanitized event logs among external organizations to identify anomalous events when event logs are shared across organizational boundaries, without giving away sensitive or critical business data.

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

• Generating event logs and the review of event logs is narrowly-focused to business-critical systems and/ or systems that store, processes and/ or transmit sensitive/regulated data.
• Secure baseline configurations generate logs that contain sufficient information to establish necessary details of activity and allow for forensics analysis.

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.
• A formal agreement exists between the organization and applicable third-parties that includes a Non-Disclosure Agreement (NDA) addressing shared sensitive data.
• the organization sets specific parameters on what type of audit information is permitted to be shared and what cannot be shared with third-parties, even with a NDA in place.

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.
• A formal agreement exists between the organization and applicable third-parties that includes a Non-Disclosure Agreement (NDA) addressing shared sensitive data.
• The organization sets specific parameters on what type of audit information is permitted to be shared and what cannot be shared with third-parties, even with a NDA in place.

See C|P-CMM3. There are no defined C|P-CMM4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to coordinate sanitized event logs among external organizations to identify anomalous events when event logs are shared across organizational boundaries, without giving away sensitive or critical business data.

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 coordinate sanitized event logs among external organizations to identify anomalous events when event logs are shared across organizational boundaries, without giving away sensitive or critical business data.