Example Cybersecurity Standardized Operating Procedures 23 NYCRR 500
Example Cybersecurity Standardized Operating Procedures 23 NYCRR 500
PROCEDURES (SOP)
KEY TERMINOLOGY
With the Cybersecurity Standardized Operating Procedures (CSOP), it is important to understand a few key terms:
Procedure / Control Activity: Procedures represent an established way of doing something, such as a series of actions
conducted in a specified order or manner. Some organizations refer to procedures as “control activities” and the terms
essentially synonymous. In the CSOP, the terms procedure or control activity can be used interchangeably.
Process Owner: This is the name of the individual or team accountable for the procedure being performed. This identifies
the accountable party to ensure the procedure is performed. This role is more oversight and managerial.
o Example: The Security Operations Center (SOC) Supervisor is accountable for his/her team to collect log files,
perform analysis and escalate potential incidents for further investigation.
Process Operator: This is the name of the individual or team responsible to perform the procedure’s tasks. This identifies
the responsible party for actually performing the task. This role is a “doer” and performs tasks.
o Example: The SOC analyst is responsible for performing daily log reviews, evaluating anomalous activities and
responding to potential incidents in accordance with the organization’s Incident Response Plan (IRP).
OVERVIEW
The Cybersecurity Standardized Operating Procedures (CSOP) is a catalog of procedure/control activity statements. These are
templates that require slight modification to suit the specific needs of the organization,
CUSTOMIZATION GUIDANCE
The content of the CSOP does require a certain level of customization by
any organization, since every organization has some difference in
available people, processes or technology that can be leveraged to
perform these procedures/control activities.
Essentially, we’ve done the heavy lifting in developing the template and
pre-populating a significant amount of content. Our target is about 80%
of the content as part of the template that would leave the remaining 20%
for customization with specifics that only the organization would know,
such as the organization calls the change management group the Change
Advisory Board (CAB) instead of the Change Control Board (CCB). Those
little changes in roles, titles, department naming, technologies in use are
all content that just needs to be filled into the template to finalize the
procedures/control activities.
Note - The footnotes at the bottom of the page and the accompanying Excel spreadsheet provide mapping between the control
objectives, controls and leading frameworks, including statutory, regulatory and contractual obligations.
Procedures service a critical function in cybersecurity. Most other documentation produces evidence of due care considerations,
but procedures are unique where procedures generate evidence of due diligence.
From a due care and due diligence perspective, it can be thought of this way:
Certain standards require processes to exist (due care – evidence demonstrates standards exist).
Performing the activities outlined in a procedure and documenting the work that was performed satisfies the intent of the
standard (due diligence – evidence demonstrates the standard is operating effectively).
The diagram shown below helps visualize the linkages in documentation that involve written procedures:
CONTROL OBJECTIVES exist to support POLICIES;
STANDARDS are written to support CONTROL OBJECTIVES;
PROCEDURES are written to implement the requirements that STANDARDS establish;
CONTROLS exist as a mechanism to assess/audit both the existence of PROCEDURES / STANDARDS and how well their
capabilities are implemented and/or functioning; and
METRICS exist as a way to measure the performance of CONTROLS.
The CSOP uses the work roles identified in the NIST NICE Cybersecurity Workforce Framework to help make assigning the tasks
associated with procedures/control activities more efficient and manageable. Keep in mind these are merely recommendations and
are fully editable for every organization – this is just a helpful point in the right direction!
EXAMPLE
This example is a configuration procedure P-CFG-02 (System Hardening Through Baseline Configurations)
PLEASE NOTE THE PROCESS CRITERIA SECTION SHOWN BELOW CAN BE DELETED & IS NOT PART OF THE PROCEDURE
The process criteria sections exist only to be a useful tool to help build out the procedures by establishing criteria and creating a
working space to capture key components that impacts the procedure.
Process Criteria:
Process Owner: name of the individual or team accountable for the procedure being performed
o Example: The process owner for system hardening at ACME is the cybersecurity director, John Doe.
Process Operator: name of the individual or team responsible to perform the procedure’s tasks.
o Example: The process operator for system hardening at ACME is split between several teams:
Network gear is assigned to network admins.
Servers are assigned to server admins.
Laptops, desktops and mobile devices are assign to the End User Computing (EUC) team.
Occurrence: how often does the procedure need to be conducted? is it something that needs to be performed annually,
semi-annually, quarterly, monthly, bi-weekly, weekly, daily, continuous or as needed?
o Example: Generally, system hardening is an “as needed” process that happens when new operating systems are
released or when new technology is purchased. However, there should still be an annual review to ensure that
appropriate baseline configurations exist and are current to what is deployed at ACME.
Scope of Impact: what is the potential impact of the procedure? does it affect a system, application, process, team,
department, user, client, vendor, geographic region or the entire company?
o Example: The scope affects the entire company. Any deviations to the secure baselines are handled on an
individual basis.
Location of Additional Documentation: if applicable, is there a server, link or other repository where additional
documentation is stored or can be found
o Example: Baseline configurations, benchmarks and STIGs are located on server XYZ123 in the folder called “Secure
Baselines” and it is available for read-only for all users.
Performance Target: if applicable, is there a Service Level Agreement (SLA) or targeted timeline for the process to be
completed?
o Example: There are no SLAs associated with baseline configurations.
Technology in Use: if applicable, what is the name of the application/system/service used to perform the procedure?
o Example: The following classes of systems and applications are in scope for this procedure:
Server-Class Systems
Workstation-Class Systems
Network Devices
Databases
Control: Mechanisms exist to develop, document and maintain secure baseline configurations for technology platform that are
consistent with industry-accepted system hardening standards. [control wording comes directly from the Secure Controls Framework
(SCF) control #CFG-02. The SCF is a free resource that can be downloaded from https://www.securecontrolsframework.com]
Procedure / Control Activity: Systems Security Developer [SP-SYS-001], in conjunction with the Technical Support Specialist [OM-
STS-001] and Security Architect [SP-ARC-002]:
(1) Uses vendor-recommended settings and industry-recognized secure practices to ensure baseline system hardening
configuration for all ACME-owned or managed assets comply with applicable legal, statutory, and regulatory compliance
obligations.
(2) Where technically feasible, technology platforms align with industry-recommended hardening recommendations, including
but not limited to:
a. Center for Internet Security (CIS) benchmarks;
b. Defense Information Systems Agency (DISA) Secure Technical Implementation Guides (STIGs); or
c. Original Equipment Manufacturer (OEM) security configuration guides.
(3) Ensures that system hardening includes, but is not limited to:
a. Technology platforms that include, but are not limited to:
i. Server-Class Systems
1. Microsoft Server 2003
2. Microsoft Server 2008
3. Microsoft Server 2012
4. Microsoft Server 2016
5. Red Hat Enterprise Linux (RHEL)
6. Unix
7. Solaris
ii. Workstation-Class Systems
1. Microsoft XP
2. Microsoft 7
3. Microsoft 8
4. Microsoft 10
5. Apple
6. Fedora (Linux)
7. Ubuntu (Linux)
8. SuSe (Linux)
iii. Network Devices
1. Firewalls
2. Routers
3. Load balancers
4. Virtual Private Network (VPN) concentrators
5. Wireless Access Points (WAPs)
6. Wireless controllers
7. Printers
8. Multi-Function Devices (MFDs)
iv. Mobile Devices
1. Tablets
2. Mobile phones
3. Other portable electronic devices
v. Databases
1. MySQL
2. Windows SQL Server
3. Windows SQL Express
2NIST 800-53 rev4 CM-2 & CM-6 | FedRAMP | NIST 800-171 3.4.1 & 3.4.2 | PCI DSS 1.1 & 1.1.1 | NIST CSF PR.IP-1 | DFARS 252.204-7008 | CSC
3.1 | CCM GRM-01 & IVS-07 | COBIT5 BAI10.02 | NISPOM 8-202, 8-311 & 8-610
TEAM STRUCTURE
The [Company Name]’s cybersecurity department is made up of [insert #] distinct teams. Each team focuses on a specific area of
cybersecurity:
Team X
o [insert a description of what team x does (e.g., Governance, Risk & Compliance (GRC) team)]
o [insert headcount and geographical breakdown of team x]
o [insert who is the team lead / supervisor / manager of team x]
o [insert any other pertinent facts about team x that would be relevant to this document]
Team Y
o [insert a description of what team y does (e.g., Security Operations Center (SOC) team]
o [insert headcount and geographical breakdown of team y]
o [insert who is the team lead / supervisor / manager of team y]
o [insert any other pertinent facts about team y that would be relevant to this document]
Team Z
o [insert a description of what team z does (e.g., engineering & architecture team]
o [insert headcount and geographical breakdown of team z]
o [insert who is the team lead / supervisor / manager of team z]
o [insert any other pertinent facts about team z that would be relevant to this document]
MISSION
To … [insert mission statement here]
VALUE PROPOSITION
Our value to [Company Name] is based on… [insert value proposition here]
STATUTORY REQUIREMENTS
[fill-in applicable statutory requirements]
REGULATORY REQUIREMENTS
[fill-in applicable regulatory requirements]
CONTRACTUAL REQUIREMENTS
[fill-in applicable contractual requirements]
Management Intent: The purpose of the Digital Security Governance (GOV) procedures / control activities is to specify the
development, proactive management and ongoing review of [Company Name]’s security and privacy program.
Control Objective: The organization develops, implements and governs processes and documentation to facilitate the
implementation of an enterprise-wide digital security policy, as well as associated standards, controls and procedures. 3
Control: Mechanisms exist to facilitate the implementation of cybersecurity and privacy governance controls.
Procedure / Control Activity: Systems Security Manager [OV-MGT-001], in conjunction with Security Architect [SP-ARC-002] and
Executive Cyber Leadership [OV-EXL-001]:
(1) Develops an organization-wide digital security governance program to provide complete coverage for all cybersecurity and
privacy-related controls needed to address statutory, regulatory and contractual obligations, as well as to address possible
threats to data and or assets.
(2) Documents the [Company Name] digital security governance program in a single document, the Information Security
Program (ISP).
(3) On at least an annual basis, during the [1st, 2nd, 3rd, 4th] quarter of the calendar year, reviews the process for non-
conforming instances. As needed, revises processes to address necessary changes and evolving conditions. Whenever the
process is updated:
a. Distributes copies of the change to key personnel; and
b. Communicates the changes and updates to key personnel.
(4) If necessary, requests corrective action to address identified deficiencies.
(5) If necessary, validates corrective action occurred to appropriately remediate deficiencies.
(6) If necessary, documents the results of corrective action and notes findings.
(7) If necessary, requests additional corrective action to address unremediated deficiencies.
3NIST 800-53 rev4 PM-1 | ISO 27002 5.1.1 | GAPP 8.2.1 | GLBA 6801(b)(1) | PCI DSS 12.1 & 12.1.1 | MA201CMR17 17.03(1), 17.04 &
17.03(2)(b)(2) | DFARS 252.204-7008 | CCM AIS-04 & GRM-05 | COBIT5 APO13.01, APO13.02 | FINRA S-P (17 CFR §248.30) | NY DFS 500.2 |
NISPOM 8-100
Control Objective: The organization employs Demilitarized Zones (DMZs) to restrict inbound traffic to authorized devices on certain
services, protocols and ports. 383
Control: Mechanisms exist to utilize a Demilitarized Zone (DMZ) to restrict inbound traffic to authorized devices on certain services,
protocols and ports.
Procedure / Control Activity: Systems Security Developer [SP-SYS-001], in conjunction with System Administrator [OM-ADM-001]
and Security Architect [SP-ARC-002]:
(1) Uses vendor-recommended settings and industry-recognized secure practices to implement and configure Demilitarized
Zones (DMZs).
(2) On at least an annual basis, during the [1st, 2nd, 3rd, 4th] quarter of the calendar year, reviews the process for non-
conforming instances. As needed, revises processes to address necessary changes and evolving conditions. Whenever the
process is updated:
a. Distributes copies of the change to key personnel; and
b. Communicates the changes and updates to key personnel.
(3) If necessary, requests corrective action to address identified deficiencies.
(4) If necessary, validates corrective action occurred to appropriately remediate deficiencies.
(5) If necessary, documents the results of corrective action and notes findings.
(6) If necessary, requests additional corrective action to address unremediated deficiencies.
The example below shows a good amount of detail that can serve as a handy reference for writing cybersecurity procedures.
383 ISO 27002 13.1.3 | PCI DSS 1.3.1, 1.3.2 & 1.3.4
Note: The section below is purposely blank. It requires [Company Name] personnel to document the tools & services that are
available to operationalize the CSOP.
Consider this section a “living document” where it is expected to change, as business processes and technologies change. Think of
it as a cheat sheet to bring staff members up to speed quickly on what is available.
Note: The section below is purposely blank. It requires [Company Name] personnel to document who the key stakeholders for the
CSOP are – including departments and individuals.
Consider this section a “living document” where it is expected to change, as business processes change. Think of it as a cheat sheet
to bring staff members up to speed quickly on who the key players are for cybersecurity and privacy at [Company Name].
C-1: CYBERSECURITY
C-3.1: eCommerce
The primary contacts within this team are:
Name
C-3.2: Retail
The primary contacts within this team are:
Name
o Title
o Description of interaction.
Name
o Title
o Description of interaction.
C-4.1: Vendor 1
The primary contacts within this team are:
Name
o Title
o Description of interaction.
Name
o Title
o Description of interaction.
C-4.2: Vendor 2
The primary contacts within this team are:
Name
o Title
o Description of interaction.
Name
o Title
o Description of interaction.
C-5: LEGAL
C-5.2: Privacy
The primary contacts within this team are:
Name
o Title
o Description of interaction.
Name
o Title
o Description of interaction.
C-6: PROCUREMENT
C-6.1: Contracts
The primary contacts within this team are:
Name
o Title
o Description of interaction.
Name
o Title
o Description of interaction.