Cybersecurity Assessment Matrix: Goal
Cybersecurity Assessment Matrix: Goal
SCOPE: The scope used for the definition of this matrix is Information Security (InfoSec).
REGULATIONS:
The applicable regulation in this matrix is:
M GDPR
a
n
d
a NISD
t
o
r
y MIFID II
V ISO/IEC 27001:2013
o
l
u
n CIS SANS TOP 20
t
a
r
y NIST CSF
MATRIX:
The columns contains the regulations and the lines contains the requirements to comply with the
regulations. If the regulation complies with the requirement, the number of the article, recital or
control of that regulation is placed where that requirement is contemplated.
Define a Risk
39 to 50, Assessment for
ID.RA-3 6º 171 16º 57, 58 Financial Instruments
Transactions
Information security risk assessment 6.1.2 NA
Design a DPIA (Data
ID.RA-4 24º 74 to 77 17º 59 to 69 Protection Impact
Assessment)
25º 78 47º -
32º 78, 83
ID.RA-5 75, 84, 90,
35º
91, 92
36º 94, 95, 96
Risk Treatment Process
Define a Risk Treatment
ID.GV-4 24º 74 to 77 14º 44, 46, 47 9º 53, 54 Process for Personal
Data Processing
2
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Information security risk treatment 6.1.3 NA
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
75, 84, 90,
ID.RM-2 35º 47º -
91, 92
ID.RM-3 36º 94, 95, 96
5º 39 14º 44, 46, 47 9º 53, 54
24º 74 to 77 16º 57, 58
Information security objectives and planning to achieve them 6.2 ID.GV-4 NA
32º 78, 83 17º 59 to 69
47º -
Support 7
24º 74 to 77 14º 44, 46, 47 9º 53, 54
16º 57, 58
64º 116
Resources 7.1 ID.AM-5 NA
65º 117 to 119
66º -
Records of Training, Skills,
PR.AT-1 32º 78, 83 14º 44, 46, 47 9º 53, 54 experience and qualifications
PR.AT-2 39º 97 16º 57, 58
Competence 7.2 CIS 17
PR.AT-3
PR.AT-4
PR.AT-5
PR.AT-1 32º 78, 83 14º 44, 46, 47 9º 53, 54
PR.AT-2 39º 97 16º 57, 58
Awareness 7.3 PR.AT-3 CIS 17
PR.AT-4
PR.AT-5
Define a Data Publishing
RC.CO-1 32º 78, 83 14º 44, 46, 47 9º 53, 54
Policy
RC.CO-2 39º 97 16º 57, 58
RC.CO-3 27º 91 to 98
Communication 7.4 RS.CO-3 NA 32º 69
58º 129
64º 116
RS.CO-4
65º 117 to 119
66º -
Documented information 7.5 - -
24º 74 to 77 14º 44, 46, 47 9º 53, 54
28º 81 15º 44, 46 16º 57, 58
General 7.5.1 - NA
30º 13, 82 17º 59 to 69
32º 78, 83
24º 74 to 77 14º 44, 46, 47 9º 53, 54
28º 81 15º 44, 46 16º 57, 58
Creating and updating 7.5.2 - NA
30º 13, 82 17º 59 to 69
32º 78, 83
5º 39 14º 44, 46, 47 9º 53, 54
24º 74 to 77 15º 44, 46 16º 57, 58
Control of documented information 7.5.3 - NA 28º 81 17º 59 to 69
30º 13, 82
32º 78, 83
Operation 8
5º 39 14º 44, 46, 47 9º 53, 54
24º 74 to 77 16º 57, 58
25º 78 17º 59 to 69
Operational planning and control 8.1 ID.RM-1 NA
3
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
Operational planning and control 8.1 ID.RM-1 NA
28º 81 47º -
30º 13, 82
32º 78, 83
PR.DS-1 5º 39 14º 44, 46, 47 9º 53, 54 Risk Assessment Report
39 to 50,
PR.DS-2 6º 16º 57, 58
171
PR.DS-3 24º 74 to 77 17º 59 to 69
PR.DS-4 25º 78 47º -
Information security risk assessment 8.2 PR.DS-5 NA 28º 81
PR.DS-6 30º 13, 82
PR.DS-7 32º 78, 83
35º 75, 84, 90,
PR.DS-8 91, 92
36º 94, 95, 96
ID.RM-1 24º 74 to 77 14º 44, 46, 47 9º 53, 54
ID.RM-2 25º 78 16º 57, 58
ID.RM-3 30º 13, 82 17º 59 to 69
Information security risk treatment 8.3 NA 32º 78, 83 47º -
75, 84, 90,
PR.IP-12 35º
91, 92
36º 94, 95, 96
Performance evaluation 9
Monitoring and Measurement
24º 74 to 77 14º 44, 46, 47 9º 53, 54 Results
Monitoring, measurement, analysis and evaluation 9.1 PR.IP-7 NA 26º 79 16º 57, 58
28º 81 17º 59 to 69
32º 78, 83
24º 74 to 77 14º 44, 46, 47 9º 53, 54 Internal Audit Program
32º 78, 83 16º 57, 58 Results of Internal Audits
Internal audit 9.2 PR.IP-7 NA
39º 97 17º 59 to 69
47º 97
ID.RM-1 24º 74 to 77 14º 44, 46, 47 9º 53, 54 Management Review Results
Management review 9.3 NA 32º 78, 83 16º 57, 58
PR.IP-7
17º 59 to 69
Improvement 10
PR.IP-7 24º 74 to 77 14º 44, 46, 47 9º 53, 54 Corrective Actions Results
RC.IM-1 16º 57, 58
RC.IM-2 17º 59 to 69
Nonconformity and corrective action 10.1 RS.IM-1 NA 64º 116
65º 117 to 119
RS.IM-2
66º -
PR.IP-7 24º 74 to 77 14º 44, 46, 47 9º 53, 54
RC.IM-1 16º 57, 58
Continual improvement 10.2 RC.IM-2 NA 17º 59 to 69
RS.IM-1
RS.IM-2
Information security policies A.5
Management direction for information security A.5.1
Define policies and Information Security Policy
24º 74 to 77 14º 44, 46, 47 9º 53, 54 procedures for Orders
Execution
4
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
Information Security Policy
Define policies and publication location and
procedures for accessibility
32º 78, 83 15º 44, 46 16º 57, 58 identify, manage and
disclose conflicts of
interest
18º 70 to 72
23º 56, 77
Policies for information security A.5.1.1 ID.GV-1 NA
email or other announcement
27º 91 to 98 showing communication of
information security policy changes
to employees and relevant external
parties
28º -
47º -
54º -
64º 116
65º 117 to 119
66º -
Procedures for information security
policy reviews, including the
changes to the policy when
24º 74 to 77 14º 44, 46, 47 9º 53, 54 significant changes to the
information security management
program occur
Review of the policies for information security A.5.1.2 - NA
Screenshot, copy of signed
document evidencing management
review, or change control evidence
32º 78, 83 15º 44, 46 16º 57, 58 within the information security
policy
5
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
32º 78, 83
Mobile devices and teleworking A.6.2
24º 74 to 77 14º 44, 46, 47 9º 53, 54 Mobile Device and Remote
Connection Policy
25º 78 16º 57, 58 Bring Your Own Device Policy
6
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
Terms and conditions of employment A.7.1.2 NA
Cybersecurity clauses included in
PR.IP-11 88º 155 16º 57, 58 contracts with employees and
contractors
During employment A.7.2
ID.GV-2 24º 74 to 77 14º 44, 46, 47 9º 53, 54 Information Security Users Policy
PR.AT-3 28º 81 16º 57, 58 Information Security Organization
Management responsibilities A.7.2.1 CIS 19 Chart
32º 78, 83
PR.IP-11
39º 97
Information security awareness
DE.DP-1 24º 74 to 77 14º 44, 46, 47 9º 53, 54 program
Formal records regarding
employees and contractors that
PR.AT-1 32º 78, 83 16º 57, 58 have been through information
security awareness training
7
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
Classification of information A.8.2.1 CIS 13
9º 46, 51 14º 44, 46, 47 16º 57, 58
PR.PT-2 24º 74 to 77
32º 78, 83
PR.DS-5 5º 39 2º - 9º 53, 54
Procedures for information labeling
Labelling of information A.8.2.2 NA
9º 46, 51 14º 44, 46, 47 16º 57, 58
PR.PT-2
32º 78, 83
PR.DS-1 5º 39 2º - 9º 53, 54 Data handling procedures
7º 32, 33, 42, 14º 44, 46, 47 16º 57, 58
PR.DS-2 43
PR.DS-3 9º 46, 51
PR.DS-5 10º 50
PR.IP-6 11º 57
58, 59, 60,
12º
73
13º 60, 61, 62
Handling of assets A.8.2.3 NA
14º 60, 61, 62
15º 63, 64
16º 65
17º 65, 66
PR.PT-2
18º 67
20º 68
25º 78
24º 74 to 77
32º 78, 83
Media handling A.8.3
8
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
PR.AC-4 CIS 1 24º 74 to 77 14º 44, 46, 47 9º 53, 54 Networks and Network Services
Policy
PR.DS-5 CIS 9 32º 78, 83 16º 57, 58
CIS 11 17º 59 to 69
Access to networks and network services A.9.1.2
64º 116
PR.PT-3
CIS 12 65º 117 to 119
66º -
User access management A.9.2
PR.AC-1 25º 78 14º 44, 46, 47 9º 53, 54 Password Policy
PR.AC-4 CIS 4 5º 39 14º 44, 46, 47 9º 53, 54 Logical access controls at the
application, system and menu level
24º 74 to 77 16º 57, 58
Information access restriction A.9.4.1
25º 78 64º 116
PR.DS-5 CIS 16
32º 78, 83 65º 117 to 119
66º -
PR.AC-1 CIS 4 32º 78, 83 14º 44, 46, 47 9º 53, 54 Secure log-on procedures for access
to systems and applications
Controls to hide identities, user IDs,
16º 57, 58 errors and help messages until
Secure log-on procedures A.9.4.2 successful authentication
PR.AC-7 CIS 16 64º 116 Controls to log authentication
(successful and failed) attempts
65º 117 to 119
66º -
PR.AC-1 CIS 4 32º 78, 83 14º 44, 46, 47 9º 53, 54 Password settings for all systems
16º 57, 58
64º 116
Password management system A.9.4.3
PR.AC-7 CIS 16
65º 117 to 119
66º -
11
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
Procedures for working in secure
PR.AC-2 32º 78, 83 14º 44, 46, 47 9º 53, 54 areas
16º 57, 58
Working in secure areas A.11.1.5 NA 64º 116
PR.DS-5
65º 117 to 119
66º -
Procedures to control access points
32º 78, 83 14º 44, 46, 47 9º 53, 54
16º 57, 58
Delivery and loading areas A.11.1.6 PR.AC-2 NA 64º 116
65º 117 to 119
66º -
Equipment A.11.2
PR.AC-2 32º 78, 83 14º 44, 46, 47 9º 53, 54 Procedures for the protection of
equipment
PR.DS-5 16º 57, 58
Equipment siting and protection A.11.2.1 NA 64º 116
PR.IP-5 65º 117 to 119
66º -
ID.BE-4 32º 78, 83 14º 44, 46, 47 9º 53, 54 Plan to protect equipments from
power failures
16º 57, 58
Supporting utilities A.11.2.2 NA 64º 116
PR.IP-5
65º 117 to 119
66º -
ID.BE-4 32º 78, 83 14º 44, 46, 47 9º 53, 54 Procedures to protect Power and
telecommunications cabling
PR.AC-2 16º 57, 58
Cabling security A.11.2.3 NA 64º 116
PR.IP-5 65º 117 to 119
66º -
PR.DS-8 32º 78, 83 14º 44, 46, 47 9º 53, 54 Plan for equipment maintenance
PR.MA-1 16º 57, 58
64º 116
Equipment maintenance A.11.2.4 NA
PR.MA-2 65º 117 to 119
66º -
PR.AC-2 32º 78, 83 14º 44, 46, 47 9º 53, 54 Procedures for removal of assets
PR.DS-3 16º 57, 58 Records of removal of assets
64º 116
Removal of assets A.11.2.5 NA
PR.MA-1 65º 117 to 119
66º -
ID.AM-4 32º 78, 83 14º 44, 46, 47 9º 53, 54 Procedures for the protection of
equipment taken offsite
PR.AC-2 16º 57, 58
Security of equipment and assets off-premises A.11.2.6 PR.AC-3 NA 64º 116
12
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
Security of equipment and assets off-premises A.11.2.6 NA
65º 117 to 119
PR.MA-1
66º -
Procedures for the retirement of
PR.AC-2 32º 78, 83 14º 44, 46, 47 9º 53, 54 assets and secure disposal
requirements
PR.DS-3 16º 57, 58
Secure disposal or re-use of equipment A.11.2.7 NA
64º 116
PR.IP-6 65º 117 to 119
66º -
32º 78, 83 14º 44, 46, 47 9º 53, 54 Procedures to protect unattended
equipment
16º 57, 58
Unattended user equipment A.11.2.8 PR.AC-2 CIS 16 64º 116
65º 117 to 119
66º -
32º 78, 83 14º 44, 46, 47 9º 53, 54 Clear Desk & Clear Screen Policy
16º 57, 58
64º 116
Clear desk and clear screen policy A.11.2.9 PR.PT-2 NA
65º 117 to 119
66º -
Operations security A.12
Operational procedures and responsibilities A.12.1
7º 32, 42, 43 14º 44, 46, 47 9º 53, 54 Operations Security Policy
8º 38 16º 57, 58 Operational Readiness Policy
58, 59, 60, Operating Procedures for IT
12º 17º 59 to 69 management
73
13º 60, 61, 62 48º 62 to 68
14º 60, 61, 62 64º 116
15º 63, 64 65º 117 to 119
16º 65 66º -
Documented operating procedures A.12.1.1 DE.AE-1 NA 17º 65, 66
18º 67
19º 66
20º 68
21º 69, 70
22º 71, 72, 91
24º 74 to 77
25º 78
30º 13, 82
32º 78, 83
DE.AE-1 19º 66 14º 44, 46, 47 9º 53, 54 Information Security Change
Management Policy
PR.IP-1 32º 78, 83 16º 57, 58 Information Security Release
Management Policy
17º 59 to 69 Change management procedures
Change management A.12.1.2 NA
48º 62 to 68
64º 116
PR.IP-3
13
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Change management Regulation A.12.1.2 NIST CSF NA20
CIS GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
PR.IP-3
65º 117 to 119
66º -
ID.BE-4 32º 78, 83 14º 44, 46, 47 9º 53, 54 Capacity management program
16º 57, 58
17º 59 to 69
48º 62 to 68
Capacity management A.12.1.3 NA
PR.DS-4 64º 116
65º 117 to 119
66º -
Separate environments for
32º 78, 83 14º 44, 46, 47 9º 53, 54 development, testing and
operational activities
32º 78, 83 14º 44, 46, 47 9º 53, 54 Controls to protect logging facilities
and log information against
tampering and unauthorized access
16º 57, 58
Protection of log information A.12.4.2 PR.PT-1 CIS 6 17º 59 to 69
48º 62 to 68
64º 116
65º 117 to 119
66º -
DE.CM-3 30º 13, 82 14º 44, 46, 47 9º 53, 54 Controls to prevent unauthorized
access to log repositories
PR.PT-1 32º 78, 83 16º 57, 58
17º 59 to 69
Administrator and operator logs A.12.4.3 CIS 6 48º 62 to 68
64º 116
RS.AN-1
65º 117 to 119
66º -
32º 78, 83 14º 44, 46, 47 9º 53, 54
16º 57, 58
17º 59 to 69
48º 62 to 68
Clock synchronisation A.12.4.4 PR.PT-1 CIS 6
64º 116
65º 117 to 119
66º -
Control of operational software A.12.5
DE.CM-5 32º 78, 83 14º 44, 46, 47 9º 53, 54 Bring Your Own Device Policy
ID.AM-2 16º 57, 58 Installation of software Policy
Controls to ensure that only
PR.DS-6 17º 59 to 69 administrators can make software
installations
Installation of software on operational systems A.12.5.1 CIS 2 Audit log for all updates to
PR.IP-1 48º 62 to 68
operation program libraries
64º 116
PR.IP-3 65º 117 to 119
66º -
Technical Vulnerability Management A.12.6
DE.CM-8 32º 78, 83 14º 44, 46, 47 9º 53, 54 Vulnerabilities Management
Process
ID.RA-1 16º 57, 58
ID.RA-5 17º 59 to 69
Control of technical vulnerabilities A.12.6.1 PR.IP-12 CIS 3 48º 62 to 68
64º 116
RS.MI-3
15
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS GDPR NISD MIFID II
Control of technical vulnerabilities A.12.6.1
ISO/IEC 27001:2013 CIS20
3 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
16
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
PR.AC-5 14º 60, 61, 62 14º 44, 46, 47 9º 53, 54 Controls to protect information
passed over public networks
PR.DS-2 32º 78, 83 16º 57, 58
PR.DS-5 17º 59 to 69
Securing application services on public networks A.14.1.2 CIS 9
64º 116
PR.DS-6 65º 117 to 119
66º -
18
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
DE.CM-6 32º 78, 83 14º 34 9º 53, 54 Supervise and monitor the activity
Outsourced software development A.14.2.7 CIS 18 of outsourced system development
16º 57, 58
DE.CM-7
17º 59 to 69
Test security functionality during
CIS 3 32º 78, 83 14º 44, 46, 47 9º 53, 54 the development of software and
systems
System security testing A.14.2.8 DE.DP-3 CIS 5 16º 57, 58
CIS 7 17º 59 to 69
CIS 18
CIS 20
Acceptance testing program that
32º 78, 83 14º 44, 46, 47 9º 53, 54 cover information security
System acceptance testing A.14.2.9 - NA requirements
16º 57, 58
17º 59 to 69
Test data A.14.3
32º 78, 83 14º 44, 46, 47 9º 53, 54 Controls to protect data used in
Protection of system test data A.14.3.1 - NA test environments
16º 57, 58
Supplier relationships A.15
Information security in supplier relationships A.15.1
ID.BE-1 5º 39 14º 44, 46, 47 9º 53, 54 Information Security Supplier
Relationships Policy
ID.GV-2 26º 79 16º 57, 58
Information security in supplier relationships A.15.1.1 ID.SC-1 NA 28º 81
ID.SC-3 32º 78, 83
44º 101, 102
PR.MA-2
46º 108, 109
ID.BE-1 5º 39 14º 44, 46, 47 9º 53, 54 Agreements with suppliers include
information security requirements
ID.SC-1 26º 79 16º 57, 58
Addressing security within supplier agreements A.15.1.2 NA 28º 81
32º 78, 83
ID.SC-3
44º 101, 102
46º 108, 109
ID.BE-1 5º 39 14º 44, 46, 47 9º 53, 54
ID.SC-1 26º 79 16º 57, 58
28º 81
Information and communication technology supply chain A.15.1.3 NA
32º 78, 83
ID.SC-3
44º 101, 102
46º 108, 109
Supplier service delivery management A.15.2
19
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
DE.CM-6 5º 39 14º 44, 46, 47 9º 53, 54 Monitor, review and audit supplier
services
DE.CM-7 26º 79 16º 57, 58
ID.BE-1 28º 81
Monitoring and review of supplier services A.15.2.1 NA
ID.SC-1 32º 78, 83
ID.SC-2 44º 101, 102
ID.SC-4 46º 108, 109
PR.MA-2
21
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
ID.SC-5 5º 39 14º 44, 46, 47 9º 53, 54 Test and review security continuity
controls
PR.IP-4 32º 78, 83 16º 57, 58
PR.IP-9 17º 59 to 69
Verify, review and evaluate information security continuity A.17.1.3 NA
64º 116
PR.IP-10 65º 117 to 119
66º -
Redundancies A.17.2
ID.BE-5 32º 78, 83 14º 44, 46, 47 9º 53, 54 Failover tests
PR.DS-4 16º 57, 58
17º 59 to 69
Availability of information processing facilities A.17.2.1 NA 64º 116
PR.PT-5
65º 117 to 119
66º -
Compliance A.18
Compliance with legal and contractual requirements A.18.1
13 to 21, 2º Information Security Compliance
2º - 9º 53, 54 Policy
27
Data Policy for Privacy and
5º 39 3º 6, 8 16º 57, 58 Protection of Personally Identifiable
Information
Process to track relevant statutory,
39 to 50 e 72 to 78, regulatory, and contractual
6º 4º 9, 12, 13 24º
171 81 to 84 requirements
22
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
88º 155
90º 164
96º -
23
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
17º 65, 66
18º 67
19º 66
20º 68
21º 69, 70
22º 71, 72, 91
24º 74 to 77
25º 78
26º 79
Privacy and protection of personally identifiable information A.18.1.4 NA 27º 80
28º 81
PR.AC-7 29º -
30º 13, 82
31º 82
32º 78, 83
33º 85, 87, 88
34º 86, 87, 88
75, 84, 89
35º
to 92
36º 94, 95, 96
37º 97
38º 97
39º 97
44º 101, 102
45º 103 to
107
46º 108, 109
47º 110
48º 115
111 to
49º
115
85º 153
86º 154
87º -
88º 155
89º 156 to
163
90º 164
5º 39 14º 44, 46, 47 9º 53, 54 List of cryptographic controls
6º 39, 49, 50 16º 57, 58
Regulation of cryptographic controls A.18.1.5 ID.GV-3 CIS 13 20º 68
25º 78
32º 78, 83
Information security reviews A.18.2
32º 78, 83 14º 44, 46, 47 9º 53, 54 Consult internal and external
information security advisers
- CIS 20
39º 97 16º 57, 58
Independent review of information security A.18.2.1 47º 110 64º 116
65º 117 to 119
66º -
24
ANEXO 3 - Cybersecurity Analysis and Assessment Matrix
Regulation NIST CSF CIS 20 GDPR NISD MIFID II
ISO/IEC 27001:2013 GUIDANCE Sufficient Evidence
Requirement v1.1 Controls v7.0 Article Recital Article Recital Article Recital
25
ISO 27001 Controls
ISO/IEC
27001:2013 Control Description
4 Context of the organization
The organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the
4.1 Understanding the organization and its context intended outcome(s) of its information security management system.
The organization shall determine:
4.2 Understanding the needs and expectations of interested parties a) interested parties that are relevant to the information security management system; and
b) the requirements of these interested parties relevant to information security.
The organization shall determine the boundaries and applicability of the information security management system to establish its
scope.
When determining this scope, the organization shall consider:
a) the external and internal issues referred to in 4.1;
4.3 Determining the scope of the information security management system b) the requirements referred to in 4.2; and
c) interfaces and dependencies between activities performed by the organization, and those that are performed by other
organizations.
The scope shall be available as documented information.
The organization shall establish, implement, maintain and continually improve an information security management system, in
4.4 Information security management system accordance with the requirements of this International Standard.
5 Leadership
Top management shall demonstrate leadership and commitment with respect to the information security management system by:
a) ensuring the information security policy and the information security objectives are established and are compatible with the
strategic direction of the organization;
b) ensuring the integration of the information security management system requirements into the organization’s processes;
c) ensuring that the resources needed for the information security management system are available;
5.1 Leadership and commitment d) communicating the importance of effective information security management and of conforming to the information security
management system requirements;
e) ensuring that the information security management system achieves its intended outcome(s);
f) directing and supporting persons to contribute to the effectiveness of the information security management system;
g) promoting continual improvement; and
h) supporting other relevant management roles to demonstrate their leadership as it applies to their areas of responsibility.
Top management shall ensure that the responsibilities and authorities for roles relevant to information security are assigned and
communicated. Top management shall assign the responsibility and authority for:
5.3 Organizational roles, responsibilities and authorities a) ensuring that the information security management system conforms to the requirements of this International Standard; and
b) reporting on the performance of the information security management system to top management.
6 Planning
6.1 Actions to address risks and opportunities
When planning for the information security management system, the organization shall consider the issues referred to in 4.1 and the
requirements referred to in 4.2 and determine the risks and opportunities that need to be addressed to:
a) ensure the information security management system can achieve its intended outcome(s);
b) prevent, or reduce, undesired effects; and
6.1.1 General c) achieve continual improvement.
The organization shall plan:
d) actions to address these risks and opportunities; and
e) how to
1) integrate and implement the actions into its information security management system processes; and
2) evaluate the effectiveness of these actions.
The organization shall define and apply an information security risk assessment process that:
a) establishes and maintains information security risk criteria that include:
1) the risk acceptance criteria; and
2) criteria for performing information security risk assessments;
b) ensures that repeated information security risk assessments produce consistent, valid and comparable results;
c) identifies the information security risks:
1) apply the information security risk assessment process to identify risks associated with the loss of confidentiality, integrity and
availability for information within the scope of the information security management system; and
6.1.2 Information security risk assessment 2) identify the risk owners;
d) analyses the information security risks:
1) assess the potential consequences that would result if the risks identified in 6.1.2 c) 1) were to materialize;
2) assess the realistic likelihood of the occurrence of the risks identified in 6.1.2 c) 1); and
3) determine the levels of risk;
e) evaluates the information security risks:
1) compare the results of risk analysis with the risk criteria established in 6.1.2 a); and
2) prioritize the analysed risks for risk treatment.
The organization shall retain documented information about the information security risk assessment process.
The organization shall define and apply an information security risk treatment process to:
a) select appropriate information security risk treatment options, taking account of the risk
assessment results;
b) determine all controls that are necessary to implement the information security risk treatment
option(s) chosen;
NOTE Organizations can design controls as required, or identify them from any source.
c) compare the controls determined in 6.1.3 b) above with those in AnnexA and verify that no necessary controls have been omitted;
NOTE 1 AnnexA contains a comprehensive list of control objectives and controls. Users of this International Standard are directed to
6.1.3 Information security risk treatment Annex A to ensure that no necessary controls are overlooked.
NOTE 2 Control objectives are implicitly included in the controls chosen. The control objectives and
controls listed in Annex A are not exhaustive and additional control objectives and controls may be needed.
d) produce a Statement of Applicability that contains the necessary controls (see 6.1.3 b) and c)) and justification for inclusions,
whether they are implemented or not, and the justification for exclusions of controls from Annex A;
e) formulate an information security risk treatment plan; and
f) obtain risk owners’ approval of the information security risk treatment plan and acceptance of the residual information security
risks.
The organization shall retain documented information about the information security risk treatment process.
The organization shall establish information security objectives at relevant functions and levels.
The information security objectives shall:
a) be consistent with the information security policy;
b) be measurable (if practicable);
c) take into account applicable information security requirements, and results from risk assessment and risk treatment;
d) be communicated; and
e) be updated as appropriate.
6.2 Information security objectives and planning to achieve them The organization shall retain documented information on the information security objectives.
When planning how to achieve its information security objectives, the organization shall determine:
f) what will be done;
g) what resources will be required;
h) who will be responsible;
i) when it will be completed; and
j) how the results will be evaluated.
7 Support
The organization shall determine and provide the resources needed for the establishment, implementation, maintenance and
7.1 Resources continual improvement of the information security management system.
Persons doing work under the organization’s control shall be aware of:
a) the information security policy;
7.3 Awareness b) their contribution to the effectiveness of the information security management system, including the benefits of improved
information security performance; and
c) the implications of not conforming with the information security management system requirements.
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The organization shall determine the need for internal and external communications relevant to the information security
management system including:
a) on what to communicate;
7.4 Communication b) when to communicate;
c) with whom to communicate;
d) who shall communicate; and
e) the processes by which communication shall be effected.
When creating and updating documented information the organization shall ensure appropriate:
7.5.2 Creating and updating a) identification and description (e.g. a title, date, author, or reference number);
b) format (e.g. language, software version, graphics) and media (e.g. paper, electronic); and
c) review and approval for suitability and adequacy
Documented information required by the information security management system and by this International Standard shall be
controlled to ensure:
a) it is available and suitable for use, where and when it is needed; and
b) it is adequately protected (e.g. from loss of confidentiality, improper use, or loss of integrity).
For the control of documented information, the organization shall address the following activities, as applicable:
7.5.3 Control of documented information c) distribution, access, retrieval and use;
d) storage and preservation, including the preservation of legibility;
e) control of changes (e.g. version control); and
f) retention and disposition.
Documented information of external origin, determined by the organization to be necessary for the planning and operation of the
information security management system, shall be identified as appropriate, and controlled.
8 Operation
The organization shall plan, implement and control the processes needed to meet information security requirements, and to
implement the actions determined in 6.1. The organization shall also implement plans to achieve information security objectives
determined in 6.2.
The organization shall keep documented information to the extent necessary to have confidence that the processes have been carried
8.1 Operational planning and control out as planned.
The organization shall control planned changes and review the consequences of unintended changes, taking action to mitigate any
adverse effects, as necessary.
The organization shall ensure that outsourced processes are determined and controlled.
The organization shall perform information security risk assessments at planned intervals or when significant changes are proposed or
8.2 Information security risk assessment occur, taking account of the criteria established in 6.1.2 a).
The organization shall retain documented information of the results of the information security risk assessments.
The organization shall implement the information security risk treatment plan.
8.3 Information security risk treatment The organization shall retain documented information of the results of the information security risk treatment.
9 Performance evaluation
The organization shall evaluate the information security performance and the effectiveness of the information security management
system.
The organization shall determine:
a) what needs to be monitored and measured, including information security processes and controls;
b) the methods for monitoring, measurement, analysis and evaluation, as applicable, to ensure valid results;
NOTE The methods selected should produce comparable and reproducible results to be considered valid.
9.1 Monitoring, measurement, analysis and evaluation c) when the monitoring and measuring shall be performed;
d) who shall monitor and measure;
e) when the results from monitoring and measurement shall be analysed and evaluated; and
f) who shall analyse and evaluate these results.
The organization shall retain appropriate documented information as evidence of the monitoring and
measurement results.
The organization shall conduct internal audits at planned intervals to provide information on whether the information security
management system:
a) conforms to
1) the organization’s own requirements for its information security management system; and
2) the requirements of this International Standard;
b) is effectively implemented and maintained.
The organization shall:
9.2 Internal audit c) plan, establish, implement and maintain an audit programme(s), including the frequency, methods, responsibilities, planning
requirements and reporting. The audit programme(s) shall take into consideration the importance of the processes concerned and the
results of previous audits;
d) define the audit criteria and scope for each audit;
e) select auditors and conduct audits that ensure objectivity and the impartiality of the audit process;
f) ensure that the results of the audits are reported to relevant management; and
g) retain documented information as evidence of the audit programme(s) and the audit results.
Top management shall review the organization’s information security management system at planned intervals to ensure its
continuing suitability, adequacy and effectiveness.
The management review shall include consideration of:
a) the status of actions from previous management reviews;
b) changes in external and internal issues that are relevant to the information security management system;
c) feedback on the information security performance, including trends in:
1) nonconformities and corrective actions;
2) monitoring and measurement results;
9.3 Management review 3) audit results; and
4) fulfilment of information security objectives;
d) feedback from interested parties;
e) results of risk assessment and status of risk treatment plan; and
f) opportunities for continual improvement.
The outputs of the management review shall include decisions related to continual improvement opportunities and any needs for
changes to the information security management system.
The organization shall retain documented information as evidence of the results of management reviews.
10 Improvement
10.2 Continual improvement The organization shall continually improve the suitability, adequacy and effectiveness of the information security management system.
A.6.1.2 Segregation of duties Conflicting duties and areas of responsibility shall be segregated to reduce opportunities for unauthorized or unintentional
modification or misuse of the organization’s assets.
A.6.1.3 Contact with authorities Appropriate contacts with relevant authorities shall be maintained.
A.6.1.4 Contact with special interest groups Appropriate contacts with special interest groups or other specialist security forums and professional associations shall be
maintained.
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A.6.1.5 Information security in project management Information security shall be addressed in project management, regardless of the type of the project.
A.6.2 Mobile devices and teleworking
A.6.2.1 Mobile device policy A policy and supporting security measures shall be adopted to manage the risks introduced by using mobile devices.
A.6.2.2 Teleworking A policy and supporting security measures shall be implemented to protect information accessed, processed or stored at
teleworking sites.
A.7 Human Resources Security
A.7.1 Prior to employment
Background verification checks on all candidates for employment shall be carried out in accordance with relevant laws, regulations
A.7.1.1 Screening and ethics and shall be proportional to the business requirements, the classification of the information to be accessed and the
perceived risks.
A.7.1.2 Terms and conditions of employment The contractual agreements with employees and contractors shall state their and the organization’s responsibilities for information
security.
A.7.2 During employment
A.7.2.1 Management responsibilities Management shall require all employees and contractors to apply information security in accordance with the established policies
and procedures of the organization.
A.7.2.2 Information security awareness, education and training All employees of the organization and, where relevant, contractors shall receive appropriate awareness education and training and
regular updates in organizational policies and procedures, as relevant for their job function.
A.7.2.3 Disciplinary process There shall be a formal and communicated disciplinary process in place to take action against employees who have committed an
information security breach.
A.7.3 Termination and change of employment
A.7.3.1 Termination or change of employment responsibilities Information security responsibilities and duties that remain valid after termination or change of employment shall be defined,
communicated to the employee or contractor and enforced.
A.8 Asset Management
A.8.1 Responsibility for assets
A.8.1.1 Inventory of assets Assets associated with information and information processing facilities shall be identified and an inventory of these assets shall be
drawn up and maintained.
A.8.1.2 Ownership of assets Assets maintained in the inventory shall be owned.
A.8.1.3 Acceptable use of assets Rules for the acceptable use of information and of assets associated with information and information processing facilities shall be
identified, documented and implemented.
A.8.1.4 Return of assets All employees and external party users shall return all of the organizational assets in their possession upon termination of their
employment, contract or agreement.
A.8.2 Information classification
A.8.2.1 Classification of information Information shall be classified in terms of legal requirements, value, criticality and sensitivity to unauthorised disclosure or
modification.
A.8.2.2 Labelling of information An appropriate set of procedures for information labelling shall be developed and implemented in accordance with the information
classification scheme adopted by the organization.
A.8.2.3 Handling of assets Procedures for handling assets shall be developed and implemented in accordance with the information classification scheme
adopted by the organization.
A.8.3 Media handling
A.8.3.1 Management of removeable media Procedures shall be implemented for the management of removable media in accordance with the classification scheme adopted by
the organization.
A.8.3.2 Disposal of media Media shall be disposed of securely when no longer required, using formal procedures.
A.8.3.3 Physical media transfer Media containing information shall be protected against unauthorized access, misuse or corruption during transportation.
A.9 Access Control
A.9.1 Business requirements of access control
A.9.1.1 Access control policy An access control policy shall be established, documented and reviewed based on business and information security requirements.
A.9.1.2 Access to networks and network services Users shall only be provided with access to the network and network services that they have been specifically authorized to use.
A.9.2.2 User access provisioning A formal user access provisioning process shall be implemented to assign or revoke access rights for all user types to all systems
and services.
A.9.2.3 Management of privileged access rights The allocation and use of privileged access rights shall be restricted and controlled.
A.9.2.4 Management of secret authentication information of users The allocation of secret authentication information shall be controlled through a formal management process.
A.9.2.5 Review of user access rights Asset owners shall review users’ access rights at regular intervals.
A.9.2.6 Removal or adjustment of access rights The access rights of all employees and external party users to information and information processing facilities shall be removed
upon termination of their employment, contract or agreement, or adjusted upon change.
A.9.3 User responsibilities
A.9.3.1 Use of secret authentication information Users shall be required to follow the organization’s practices in the use of secret authentication information.
A.9.4 System and application access control
A.9.4.1 Information access restriction Access to information and application system functions shall be restricted in accordance with the access control policy.
A.9.4.2 Secure log-on procedures Where required by the access control policy, access to systems and applications shall be controlled by a secure log-on procedure.
A.9.4.3 Password management system Password management systems shall be interactive and shall ensure quality passwords.
A.9.4.4 Use of privileged utility programs The use of utility programs that might be capable of overriding system and application controls shall be restricted and tightly
controlled.
A.9.4.5 Access control to program source code Access to program source code shall be restricted.
A.10 Cryptography
A.10.1 Cryptographic controls
A.10.1.1 Policy on the use of cryptographic controls A policy on the use of cryptographic controls for protection of information shall be developed and implemented.
A.10.1.2 Key management A policy on the use, protection and lifetime of cryptographic keys shall be developed and implemented through their whole
lifecycle.
A.11 Physical and Environmental Security
A.11.1 Secure Areas
A.11.1.1 Physical security perimeter Security perimeters shall be defined and used to protect areas that contain either sensitive or critical information and information
processing facilities.
A.11.1.2 Physical entry controls Secure areas shall be protected by appropriate entry controls to ensure that only authorized personnel are allowed access.
A.11.1.3 Securing offices, rooms and facilities Physical security for offices, rooms and facilities shall be designed and applied.
A.11.1.4 Protecting against external and environmental attacks Physical protection against natural disasters, malicious attack or accidents shall be designed and applied.
A.11.1.5 Working in secure areas Procedures for working in secure areas shall be designed and applied.
A.11.1.6 Delivery and loading areas Access points such as delivery and loading areas and other points where unauthorized persons could enter the premises shall be
controlled and, if possible, isolated from information processing facilities to avoid unauthorized access.
A.11.2 Equipment
A.11.2.1 Equipment siting and protection Equipment shall be sited and protected to reduce the risks from environmental threats and hazards, and opportunities for
unauthorized access.
A.11.2.2 Supporting utilities Equipment shall be protected from power failures and other disruptions caused by failures in supporting utilities.
A.11.2.3 Cabling security Power and telecommunications cabling carrying data or supporting information services shall be protected from interception,
interference or damage.
A.11.2.4 Equipment maintenance Equipment shall be correctly maintained to ensure its continued availability and integrity.
A.11.2.5 Removal of assets Equipment, information or software shall not be taken off-site without prior authorization.
A.11.2.6 Security of equipment and assets off-premises Security shall be applied to off-site assets taking into account the different risks of working outside the organization’s premises.
A.11.2.7 Secure disposal or re-use of equipment All items of equipment containing storage media shall be verified to ensure that any sensitive data and licensed software has been
removed or securely overwritten prior to disposal or re-use.
A.11.2.8 Unattended user equipment Users shall ensure that unattended equipment has appropriate protection.
A.11.2.9 Clear desk and clear screen policy A clear desk policy for papers and removable storage media and a clear screen policy for information processing facilities shall be
adopted.
A.12 Operations security
A.12.1 Operational procedures and responsibilities
A.12.1.1 Documented operating procedures Operating procedures shall be documented and made available to all users who need them.
A.12.1.2 Change management Changes to the organization, business processes, information processing facilities and systems that affect information security shall
be controlled.
A.12.1.3 Capacity management The use of resources shall be monitored, tuned and projections made of future capacity requirements to ensure the required
system performance.
A.12.1.4 Separation of development, testing and operational environments Development, testing, and operational environments shall be separated to reduce the risks of unauthorized access or changes to
the operational environment.
A.12.2 Protection from malware
A.12.2.1 Controls against malware Detection, prevention and recovery controls to protect against malware shall be implemented, combined with appropriate user
awareness.
A.12.3 Backup
A.12.3.1 Information backup Backup copies of information, software and system images shall be taken and tested regularly in accordance with an agreed backup
policy.
A.12.4 Logging and monitoring
A.12.4.1 Event logging Event logs recording user activities, exceptions, faults and information security events shall be produced, kept and regularly
reviewed.
A.12.4.2 Protection of log information Logging facilities and log information shall be protected against tampering and unauthorized access.
A.12.4.3 Administrator and operator logs System administrator and system operator activities shall be logged and the logs protected and regularly reviewed.
A.12.4.4 Clock synchronisation The clocks of all relevant information processing systems within an organization or security domain shall be synchronised to a
single reference time source.
A.12.5 Control of operational software
A.12.5.1 Installation of software on operational systems Procedures shall be implemented to control the installation of software on operational systems.
A.12.6 Technical Vulnerability Management
Information about technical vulnerabilities of information systems being used shall be obtained in a timely fashion, the
A.12.6.1 Control of technical vulnerabilities organization’s exposure to such vulnerabilities evaluated and appropriate measures taken to address the associated risk.
A.12.6.2 Restrictions on software installation Rules governing the installation of software by users shall be established and implemented.
A.12.7 Information systems audit controls
A.12.7.1 Information systems audit controls Audit requirements and activities involving verification of operational systems shall be carefully planned and agreed to minimise
disruptions to business processes.
A.13 Communications security
A.13.1 Network security management
A.13.1.1 Network controls Networks shall be managed and controlled to protect information in systems and applications.
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A.13.1.2 Security of network services Security mechanisms, service levels and management requirements of all network services shall be identified and included in
network services agreements, whether these services are provided in-house or outsourced.
A.13.1.3 Segregation in networks Groups of information services, users and information systems shall be segregated on networks.
A.13.2 Information transfer
A.13.2.1 Information transfer policies and procedures Formal transfer policies, procedures and controls shall be in place to protect the transfer of information through the use of all types
of communication facilities.
A.13.2.2 Agreements on information transfer Agreements shall address the secure transfer of business information between the organization and external parties.
A.13.2.3 Electronic messaging Information involved in electronic messaging shall be appropriately protected.
A.13.2.4 Confidentiality or non-disclosure agreements Requirements for confidentiality or non-disclosure agreements reflecting the organization’s needs for the protection of information
shall be identified, regularly reviewed and documented.
A.14 System acquisition, development and maintenance
A.14.1 Security requirements of information systems
A.14.1.1 Information security requirements analysis and specification The information security related requirements shall be included in the requirements for new information systems or enhancements
to existing information systems.
A.14.1.2 Securing application services on public networks Information involved in application services passing over public networks shall be protected from fraudulent activity, contract
dispute and unauthorized disclosure and modification.
A.14.1.3 Protecting application services transactions Information involved in application service transactions shall be protected to prevent incomplete transmission, mis-routing,
unauthorized message alteration, unauthorized disclosure, unauthorized message duplication or replay.
A.14.2 Security in development and support processes
A.14.2.1 Secure development policy Rules for the development of software and systems shall be established and applied to developments within the organization.
A.14.2.2 System change control procedures Changes to systems within the development lifecycle shall be controlled by the use of formal change control procedures.
A.14.2.3 Technical review of applications after operating platform changes When operating platforms are changed, business critical applications shall be reviewed and tested to ensure there is no adverse
impact on organizational operations or security.
A.14.2.4 Restrictions on changes to software packages Modifications to software packages shall be discouraged, limited to necessary changes and all changes shall be strictly controlled.
A.14.2.5 Secure system engineering principles Principles for engineering secure systems shall be established, documented, maintained and applied to any information system
implementation efforts.
A.14.2.6 Secure development environment Organizations shall establish and appropriately protect secure development environments for system development and integration
efforts that cover the entire system development lifecycle.
A.14.2.7 Outsourced software development The organization shall supervise and monitor the activity of outsourced system development.
A.14.2.8 System security testing Testing of security functionality shall be carried out during development.
A.14.2.9 System acceptance testing Acceptance testing programs and related criteria shall be established for new information systems, upgrades and new versions.
A.14.3 Test data
A.14.3.1 Protection of system test data Test data shall be selected carefully, protected and controlled.
A.15 Supplier relationships
A.15.1 Information security in supplier relationships
A.15.1.1 Information security in supplier relationships Information security requirements for mitigating the risks associated with supplier’s access to the organization’s assets shall be
agreed with the supplier and documented.
A.15.1.2 Addressing security within supplier agreements All relevant information security requirements shall be established and agreed with each supplier that may access, process, store,
communicate, or provide IT infrastructure components for, the organization’s information.
A.15.1.3 Information and communication technology supply chain Agreements with suppliers shall include requirements to address the information security risks associated with information and
communications technology services and product supply chain.
A.15.2 Supplier service delivery management
A.15.2.1 Monitoring and review of supplier services Organizations shall regularly monitor, review and audit supplier service delivery.
Changes to the provision of services by suppliers, including maintaining and improving existing information security policies,
A.15.2.2 Managing changes to supplier services procedures and controls, shall be managed, taking account of the criticality of business information, systems and processes
involved and re-assessment of risks.
A.16 Information security incident management
A.16.1 Management of information security incidents and improvements
A.16.1.1 Responsibilities and procedures Management responsibilities and procedures shall be established to ensure a quick, effective and orderly response to information
security incidents.
A.16.1.2 Reporting information security events Information security events shall be reported through appropriate management channels as quickly as possible.
A.16.1.3 Reporting information security weaknesses Employees and contractors using the organization’s information systems and services shall be required to note and report any
observed or suspected information security weaknesses in systems or services.
A.16.1.4 Assessment of and decision on information security events Information security events shall be assessed and it shall be decided if they are to be classified as information security incidents.
A.16.1.5 Response to information security incidents Information security incidents shall be responded to in accordance with the documented procedures.
A.16.1.6 Learning from information security incidents Knowledge gained from analysing and resolving information security incidents shall be used to reduce the likelihood or impact of
future incidents.
A.16.1.7 Collection of evidence The organization shall define and apply procedures for the identification, collection, acquisition and preservation of information,
which can serve as evidence.
A.17 Information security aspects of business continuity management
A.17.1 Information security continuity
A.17.1.1 Planning information security continuity The organization shall determine its requirements for information security and the continuity of information security management
in adverse situations, e.g. during a crisis or disaster.
A.17.1.2 Implementing information security continuity The organization shall establish, document, implement and maintain processes, procedures and controls to ensure the required
level of continuity for information security during an adverse situation.
The organization shall verify the established and implemented information security continuity controls at regular intervals in order
A.17.1.3 Verify, review and evaluate information security continuity to ensure that they are valid and effective during adverse situations.
A.17.2 Redundancies
A.17.2.1 Availability of information processing facilities Information processing facilities shall be implemented with redundancy sufficient to meet availability requirements.
A.18 Compliance
A.18.1 Compliance with legal and contractual requirements
A.18.1.1 Identification of applicable legislation and contractual requirements All relevant legislative statutory, regulatory, contractual requirements and the organization’s approach to meet these requirements
shall be explicitly identified, documented and kept up to date for each information system and the organization.
A.18.1.2 Intellectual property rights Appropriate procedures shall be implemented to ensure compliance with legislative, regulatory and contractual requirements
related to intellectual property rights and use of proprietary software products.
A.18.1.3 Protection of records Records shall be protected from loss, destruction, falsification, unauthorized access and unauthorized release, in accordance with
legislatory, regulatory, contractual and business requirements.
A.18.1.4 Privacy and protection of personally identifiable information Privacy and protection of personally identifiable information shall be ensured as required in relevant legislation and regulation
where applicable.
A.18.1.5 Regulation of cryptographic controls Cryptographic controls shall be used in compliance with all relevant agreements, legislation and regulations.
A.18.2 Information security reviews
The organization’s approach to managing information security and its implementation (i.e. Control objectives, controls, policies,
A.18.2.1 Independent review of information security processes and procedures for information security) shall be reviewed independently at planned intervals or when significant
changes occur.
A.18.2.2 Compliance with security policies and standards Managers shall regularly review the compliance of information processing and procedures within their area of responsibility with the
appropriate security policies, standards and any other security requirements.
A.18.2.3 Technical compliance review Information systems shall be regularly reviewed for compliance with the organization’s information security policies and standards.
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Function Category
IDENTIFY (ID)
PROTECT (PR)
RESPOND (RS)
Utilize an up-to-date SCAP-compliant vulnerability scanning tool to automatically scan all systems on the network
basis to identify all potential vulnerabilities on the organization's systems.
Perform authenticated vulnerability scanning with agents running locally on each system or with remote scanners
elevated rights on the system being tested.
Use a dedicated account for authenticated vulnerability scans, which should not be used for any other administra
tied to specific machines at specific IP addresses.
Deploy automated software update tools in order to ensure that the operating systems are running the most rece
by the software vendor.
Deploy automated software update tools in order to ensure that third-party software on all systems is running the
provided by the software vendor.
Regularly compare the results from back-to-back vulnerability scans to verify that vulnerabilities have been reme
Utilize a risk-rating process to prioritize the remediation of discovered vulnerabilities.
tive Privileges
Use automated tools to inventory all administrative accounts, including domain and local accounts, to ensure tha
have elevated privileges.
Before deploying any new asset, change all default passwords to have values consistent with administrative leve
Ensure that all users with administrative account access use a dedicated or secondary account for elevated activ
be used for administrative activities and not internet browsing, email, or similar activities.
Where multi-factor authentication is not supported (such as local administrator, root, or service accounts), accou
unique to that system.
Use multi-factor authentication and encrypted channels for all administrative account access.
Ensure administrators use a dedicated machine for all administrative tasks or tasks requiring administrative acce
segmented from the organization's primary network and not be allowed Internet access. This machine will not be
composing documents, or browsing the Internet.
Limit access to scripting tools (such as Microsoft PowerShell and Python) to only administrative or development
those capabilities.
Configure systems to issue a log entry and alert when an account is added to or removed from any group assign
Configure systems to issue a log entry and alert on unsuccessful logins to an administrative account.
dware and Software on Mobile Devices, Laptops, Workstations and Servers
Maintain documented, standard security configuration standards for all authorized operating systems and softwa
Maintain secure images or templates for all systems in the enterprise based on the organization's approved conf
system deployment or existing system that becomes compromised should be imaged using one of those images
Store the master images and templates on securely configured servers, validated with integrity monitoring tools,
changes to the images are possible.
Deploy system configuration management tools that will automatically enforce and redeploy configuration setting
scheduled intervals.
Utilize a Security Content Automation Protocol (SCAP) compliant configuration monitoring system to verify all se
catalog approved exceptions, and alert when unauthorized changes occur.
Analysis of Audit Logs
Use at least three synchronized time sources from which all servers and network devices retrieve time informatio
timestamps in logs are consistent.
Ensure that local logging has been enabled on all systems and networking devices.
Enable system logging to include detailed information such as a event source, date, user, timestamp, source add
addresses, and other useful elements.
Ensure that all systems that store logs have adequate storage space for the logs generated.
Ensure that appropriate logs are being aggregated to a central log management system for analysis and review.
Deploy Security Information and Event Management (SIEM) or log analytic tool for log correlation and analysis.
On a regular basis, review logs to identify anomalies or abnormal events.
On a regular basis, tune your SIEM system to better identify actionable events and decrease event noise.
Ensure that only fully supported web browsers and email clients are allowed to execute in the organization, ideal
of the browsers and email clients provided by the vendor.
Uninstall or disable any unauthorized browser or email client plugins or add-on applications.
Ensure that only authorized scripting languages are able to run in all web browsers and email clients.
Enforce network-based URL filters that limit a system's ability to connect to websites not approved by the organiz
enforced for each of the organization's systems, whether they are physically at an organization's facilities or not.
Subscribe to URL categorization services to ensure that they are up-to-date with the most recent website catego
Uncategorized sites shall be blocked by default.
Log all URL requests from each of the organization's systems, whether onsite or a mobile device, in order to iden
activity and assist incident handlers with identifying potentially compromised systems.
Use DNS filtering services to help block access to known malicious domains.
To lower the chance of spoofed or modified emails from valid domains, implement Domain-based Message Auth
Conformance (DMARC) policy and verification, starting by implementing the Sender Policy Framework (SPF) an
Mail(DKIM) standards.
Block all e-mail attachments entering the organization's e-mail gateway if the file types are unnecessary for the o
Use sandboxing to analyze and block inbound email attachments with malicious behavior.
Utilize centrally managed anti-malware software to continuously monitor and defend each of the organization's w
Ensure that the organization's anti-malware software updates its scanning engine and signature database on a r
Enable anti-exploitation features such as Data Execution Prevention (DEP) or Address Space Layout Randomiza
in an operating system or deploy appropriate toolkits that can be configured to apply protection to a broader set o
executables.
Configure devices so that they automatically conduct an anti-malware scan of removable media when inserted o
Ensure that only network ports, protocols, and services listening on a system with validated business needs, are
Perform automated port scans on a regular basis against all systems and alert if unauthorized ports are detected
Apply host-based firewalls or port filtering tools on end systems, with a default-deny rule that drops all traffic exce
that are explicitly allowed.
Place application firewalls in front of any critical servers to verify and validate the traffic going to the server. Any u
blocked and logged.
Ensure that all backups have at least one backup destination that is not continuously addressable through opera
All configuration rules that allow traffic to flow through network devices should be documented in a configuration
specific business reason for each rule, a specific individual’s name responsible for that business need, and an ex
Compare all network device configuration against approved security configurations defined for each network dev
deviations are discovered.
Install the latest stable version of any security-related updates on all network devices.
Manage all network devices using multi-factor authentication and encrypted sessions.
Ensure network engineers use a dedicated machine for all administrative tasks or tasks requiring elevated acces
segmented from the organization's primary network and not be allowed Internet access. This machine shall not b
composing documents, or surfing the Internet.
Manage the network infrastructure across network connections that are separated from the business use of that
VLANs or, preferably, on entirely different physical connectivity for management sessions for network devices.
Enable the collection of NetFlow and logging data on all network boundary devices.
Ensure that all network traffic to or from the Internet passes through an authenticated application layer proxy tha
unauthorized connections.
Decrypt all encrypted network traffic at the boundary proxy prior to analyzing the content. However, the organiza
allowed sites that can be accessed through the proxy without decrypting the traffic.
Require all remote login access to the organization's network to encrypt data in transit and use multi-factor authe
Scan all enterprise devices remotely logging into the organization's network prior to accessing the network to ens
organization's security policies has been enforced in the same manner as local network devices.
Maintain an inventory of all sensitive information stored, processed, or transmitted by the organization's technolo
located onsite or at a remote service provider.
Remove sensitive data or systems not regularly accessed by the organization from the network. These systems
alone systems (disconnected from the network) by the business unit needing to occasionally use the system or c
powered off until needed.
Deploy an automated tool on network perimeters that monitors for unauthorized transfer of sensitive information
while alerting information security professionals.
Only allow access to authorized cloud storage or email providers.
Monitor all traffic leaving the organization and detect any unauthorized use of encryption.
Utilize approved whole disk encryption software to encrypt the hard drive of all mobile devices.
If USB storage devices are required, enterprise software should be used that can configure systems to allow the
inventory of such devices should be maintained.
Configure systems not to write data to external removable media, if there is no business need for supporting suc
If USB storage devices are required, all data stored on such devices must be encrypted while at rest.
the Need to Know
Segment the network based on the label or classification level of the information stored on the servers, locate all
separated Virtual Local Area Networks (VLANs).
Enable firewall filtering between VLANs to ensure that only authorized systems are able to communicate with oth
their specific responsibilities.
Disable all workstation to workstation communication to limit an attacker's ability to move laterally and compromi
through technologies such as Private VLANs or microsegmentation.
Encrypt all sensitive information in transit.
Utilize an active discovery tool to identify all sensitive information stored, processed, or transmitted by the organi
including those located onsite or at a remote service provider and update the organization's sensitive information
Protect all information stored on systems with file system, network share, claims, application, or database specifi
controls will enforce the principle that only authorized individuals should have access to the information based on
information as a part of their responsibilities.
Use an automated tool, such as host-based Data Loss Prevention, to enforce access controls to data even when
Encrypt all sensitive information at rest using a tool that requires a secondary authentication mechanism not inte
system, in order to access the information.
Enforce detailed audit logging for access to sensitive data or changes to sensitive data (utilizing tools such as Fil
Security Information and Event Monitoring).
Maintain an inventory of authorized wireless access points connected to the wired network.
Configure network vulnerability scanning tools to detect and alert on unauthorized wireless access points connec
Use a wireless intrusion detection system (WIDS) to detect and alert on unauthorized wireless access points con
Disable wireless access on devices that do not have a business purpose for wireless access.
Configure wireless access on client machines that do have an essential wireless business purpose, to allow acce
networks and to restrict access to other wireless networks.
Disable peer-to-peer (adhoc) wireless network capabilities on wireless clients.
Leverage the Advanced Encryption Standard (AES) to encrypt wireless data in transit.
Ensure that wireless networks use authentication protocols such as Extensible Authentication Protocol-Transpor
that requires mutual, multi-factor authentication.
Disable wireless peripheral access of devices (such as Bluetooth and NFC), unless such access is required for a
Create a separate wireless network for personal or untrusted devices. Enterprise access from this network shoul
filtered and audited accordingly.
trol
Maintain an inventory of each of the organization's authentication systems, including those located onsite or at a
Configure access for all accounts through as few centralized points of authentication as possible, including netwo
systems.
Require multi-factor authentication for all user accounts, on all systems, whether managed onsite or by a third-pa
Encrypt or hash with a salt all authentication credentials when stored.
Ensure that all account usernames and authentication credentials are transmitted across networks using encrypt
Maintain an inventory of all accounts organized by authentication system.
Establish and follow an automated process for revoking system access by disabling accounts immediately upon
responsibilities of an employee or contractor . Disabling these accounts, instead of deleting accounts, allows pre
Disable any account that cannot be associated with a business process or business owner.
Automatically disable dormant accounts after a set period of inactivity.
Ensure that all accounts have an expiration date that is monitored and enforced.
Alert when users deviate from normal login behavior, such as time-of-day, workstation location and duration.
ess and Training Program
Perform a skills gap analysis to understand the skills and behaviors workforce members are not adhering to, usin
baseline education roadmap.
Deliver training to address the skills gap identified to positively impact workforce members' security behavior.
Create a security awareness program for all workforce members to complete on a regular basis to ensure they u
necessary behaviors and skills to help ensure the security of the organization. The organization's security aware
communicated in a continuous and engaging manner.
Ensure that the organization's security awareness program is updated frequently (at least annually) to address n
standards and business requirements.
Train workforce members on the importance of enabling and utilizing secure authentication.
Train the workforce on how to identify different forms of social engineering attacks, such as phishing, phone scam
Train workforce on how to identify and properly store, transfer, archive and destroy sensitive information.
Train workforce members to be aware of causes for unintentional data exposures, such as losing their mobile de
person due to autocomplete in email.
Train employees to be able to identify the most common indicators of an incident and be able to report such an in
Establish secure coding practices appropriate to the programming language and development environment being
For in-house developed software, ensure that explicit error checking is performed and documented for all input, i
and acceptable ranges or formats.
Verify that the version of all software acquired from outside your organization is still supported by the developer o
based on developer security recommendations.
Only use up-to-date and trusted third-party components for the software developed by the organization.
Ensure that all software development personnel receive training in writing secure code for their specific developm
responsibilities.
Apply static and dynamic analysis tools to verify that secure coding practices are being adhered to for internally d
Establish a process to accept and address reports of software vulnerabilities, including providing a means for ext
security group.
Maintain separate environments for production and nonproduction systems. Developers should not have unmoni
environments.
Protect web applications by deploying web application firewalls (WAFs) that inspect all traffic flowing to the web a
application attacks. For applications that are not web-based, specific application firewalls should be deployed if s
given application type. If the traffic is encrypted, the device should either sit behind the encryption or be capable
analysis. If neither option is appropriate, a host-based web application firewall should be deployed.
For applications that rely on a database, use standard hardening configuration templates. All systems that are pa
processes should also be tested.
Ensure that there are written incident response plans that defines roles of personnel as well as phases of inciden
Assign job titles and duties for handling computer and network incidents to specific individuals and ensure trackin
throughout the incident through resolution.
Designate management personnel, as well as backups, who will support the incident handling process by acting
Devise organization-wide standards for the time required for system administrators and other workforce member
to the incident handling team, the mechanisms for such reporting, and the kind of information that should be inclu
notification.
Assemble and maintain information on third-party contact information to be used to report a security incident, suc
relevant government departments, vendors, and ISAC partners.
Publish information for all workforce members, regarding reporting computer anomalies and incidents to the incid
information should be included in routine employee awareness activities.
Plan and conduct routine incident response exercises and scenarios for the workforce involved in the incident res
and comfort in responding to real world threats. Exercises should test communication channels, decision making
technical capabilities using tools and data available to them.
Create incident scoring and prioritization schema based on known or potential impact to your organization. Utilize
status updates and escalation procedures.
eam Exercises
Establish a program for penetration tests that includes a full scope of blended attacks, such as wireless, client-ba
attacks.
Conduct regular external and internal penetration tests to identify vulnerabilities and attack vectors that can be u
systems successfully.
Perform periodic Red Team exercises to test organizational readiness to identify and stop attacks or to respond
Include tests for the presence of unprotected system information and artifacts that would be useful to attackers, i
configuration files, older penetration test reports, e-mails or documents containing passwords or other informatio
Create a test bed that mimics a production environment for specific penetration tests and Red Team attacks aga
typically tested in production, such as attacks against supervisory control and data acquisition and other control s
Use vulnerability scanning and penetration testing tools in concert. The results of vulnerability scanning assessm
starting point to guide and focus penetration testing efforts.
Wherever possible, ensure that Red Teams results are documented using open, machine-readable standards (e
method for determining the results of Red Team exercises so that results can be compared over time.
Any user or system accounts used to perform penetration testing should be controlled and monitored to make su
legitimate purposes, and are removed or restored to normal function after testing is over.