VPM-04.2: Flaw Remediation with Personal Data (PD)

There is no evidence of a capability to identify and correct flaws related to the collection, usage, processing or dissemination of Personal Data (PD).

C|P-CMM1 is N/A, since a structured process is required to identify and correct flaws related to the collection, usage, processing or dissemination of Personal Data (PD).

Vulnerability & Patch Management (VPM) 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 to address applicable statutory, regulatory and contractual requirements for ASM. o Apply software patches and other vulnerability remediation efforts.

• Attack Surface Management (ASM) is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
• IT/cybersecurity personnel:
• Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Vulnerability & Patch Management (VPM) 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 Defines the scope of ASM activities. 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 with regards to ASM. o Provides oversight of ASM activities to centrally manage the flaw remediation process as part of the organization's overall Patch& Vulnerability & Patch Management Program (VPMP). o Manages the identification, tracking and remediation of vulnerabilities. o Utilizes a Security Incident Event monitor (SIEM), or similar automated tool, to monitor for unauthorized activities, accounts, connections, devices and software according to organization-specific Indicators of Compromise (IoC), including feeds from applications, hosts, network devices and vulnerability scanners.

• 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 Governance, Risk & Compliance (GRC) function, or similar function:
• A Security Operations Center (SOC), or similar function:
• Asset custodians install the latest stable version of security-related updates on all systems within the organization-defined time requirements.

Vulnerability & Patch Management (VPM) 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.

Vulnerability & Patch Management (VPM) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions.
• Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.