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QTS-05: Harvest Now, Decrypt Later (HNDL) Mitigation

QTS 7 — High Protect

Mechanisms exist to mitigate Harvest Now, Decrypt Later (HNDL) risk by minimizing an adversary's ability to collect long-lived data through Zero Trust Network Architecture (ZTNA) that enforces: (1) Continuous authentication; (2) Data microsegmentation; (3) Least privilege; and (4) Identity-based access control.

Control Question: Does the organization mitigate Harvest Now, Decrypt Later (HNDL) risk by minimizing an adversary's ability to collect long-lived data through Zero Trust Network Architecture (ZTNA) that enforces: (1) Continuous authentication; (2) Data microsegmentation; (3) Least privilege; and (4) Identity-based access control?

Capability Maturity Model

Level 0 — Not Performed

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.

Level 1 — Performed Informally

Quantum Security (QTS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with QTS domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Risk management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.

Level 2 — Planned & Tracked

SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 — Well Defined

Quantum Security (QTS) 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 QTS domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with QTS domain capabilities are well-documented and kept current by process owners. ▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain QTS domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool). ▪ 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 QTS 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). ▪ An implemented and operational capability exists to mitigate Harvest Now, Decrypt Later (HNDL) risk by minimizing an adversary's ability to collect long-lived data through Zero Trust Network Access (ZTNA) that enforces: (1) Continuous authentication; (2) Data microsegmentation; (3) Least privilege; and (4) Identity-based access control.

Level 4 — Quantitatively Controlled

Quantum Security (QTS) 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.

Level 5 — Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

Assessment Objectives

  1. QTS-05_A01 Harvest Now, Decrypt Later (HNDL) risk is mitigated through Zero Trust Network Architecture (ZTNA).
  2. QTS-05_A02 ZTNA enforces continuous authentication.
  3. QTS-05_A03 ZTNA enforces data microsegmentation.
  4. QTS-05_A04 ZTNA enforces least privilege.
  5. QTS-05_A05 ZTNA enforces identity-based access control.

Evidence Requirements

E-QTS-09 Zero Trust Network Architecture (ZTNA)

Documented evidence of Zero Trust Network Architecture (ZTNA) (e.g., architecture diagrams, segmentation matrices, access policies, etc.).

Quantum Security

Technology Recommendations

Micro/Small

  • Ensure TLS 1.3 is enforced for sensitive data in transit
  • Note: Full HNDL mitigation via ZTNA is typically not feasible at this size

Small

  • Enforce TLS 1.3 for all sensitive communications
  • Minimize external exposure of long-lived sensitive data

Medium

  • TLS 1.3 enforcement across all external-facing services
  • Data access minimization practices
  • Zero Trust Network Architecture (ZTNA) planning

Large

  • Zero Trust Network Architecture (ZTNA) implementation
  • TLS 1.3 enforcement with forward secrecy
  • Identity-based access controls for sensitive data
  • Data microsegmentation

Enterprise

  • Enterprise ZTNA platform (e.g., Zscaler, Netskope, Palo Alto Prisma Access)
  • Continuous authentication enforcement
  • Data microsegmentation with identity-aware access
  • HNDL risk monitoring and response program

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