TDA-09: Cybersecurity & Data Protection Testing Throughout Development

There is no evidence of a capability to require system developers/integrators consult with cybersecurity and data protection personnel to: (1) Create and implement a Security Testing and Evaluation (ST&E) plan, or similar capability; (2) Implement a verifiable flaw remediation process to correct weaknesses and deficiencies identified during the security testing and evaluation process; and (3) Document the results of the security testing/evaluation and flaw remediation processes.

Technology Development & Acquisition (TDA) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• IT personnel use an informal process to govern technology development and acquisition.
• Secure development practices loosely conform to industry-recognized standards for secure engineering (e.g., OWASP, NIST SP 800-218, NIST SP 800-160, etc.).
• IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Technology Development & Acquisition (TDA) 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:

• Development and acquisition management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
• IT/cybersecurity personnel identify cybersecurity and data protection controls to address applicable statutory, regulatory and contractual requirements for technology development and acquisition management.
• IT/cybersecurity personnel implement secure practices to protect the confidentiality, integrity, availability and safety of the organization's technology assets, data and network(s).
• Secure development practices mostly conform to industry-recognized standards for secure engineering (e.g., OWASP, NIST SP 800-218, NIST SP 800-160, etc.).
• Procurement practices require third-party developers of systems, system components or services to follow secure engineering practices.
• A Project Management Office (PMO), or project management function, enables the implementation of cybersecurity and data protection-related resource planning controls across the System Development Lifecycle (SDLC) for all high-value projects.

Technology Development & Acquisition (TDA) 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 Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity and data protection controls to protect the confidentiality, integrity, availability and safety of the organization's applications, systems, services and data for technology development and acquisition. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity and data protection controls as part of “business as usual” pre-production testing. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats.

• Secure development practices conform to industry-recognized standards for secure engineering (e.g., OWASP, NIST SP 800-218, NIST SP 800-160, etc.).
• A procurement team, or similar function, ensures that third party development and/ or acquisitions meet, or exceed, the organization's business, cybersecurity and data protection requirements to have secure and resilient systems, applications, services and processes.
• A Software Assurance Maturity Model (SAMM) governs a secure development lifecycle for the development of systems, applications and services.
• Administrative processes exist and technologies are configured to implement secure configuration settings by default to reduce the likelihood of software being deployed with weak security settings, putting the asset at a greater risk of compromise.
• An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.
• A formal Change Management (CM) program help to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently.
• A Governance, Risk & Compliance (GRC) function, or similar function;
• A Project Management Office (PMO), or project management function, enables IAP pre-production testing of cybersecurity and data protection controls as part of the organization's established project management processes.

Technology Development & Acquisition (TDA) 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 require system developers/integrators consult with cybersecurity and data protection personnel to: (1) Create and implement a Security Testing and Evaluation (ST&E) plan, or similar capability; (2) Implement a verifiable flaw remediation process to correct weaknesses and deficiencies identified during the security testing and evaluation process; and (3) Document the results of the security testing/evaluation and flaw remediation processes.