3.14.1 has a weight of -5 points

Assessment Points:

1. Check that system flaws are identified on time using the IT ticketing system logs.
2. Ensure the Incident Response Plan clearly states the reporting timeframe for system flaws.
3. Verify system flaws are reported on time by reviewing IT service ticket logs and audit results.
4. Confirm that system flaws are fixed within the set period by examining the IT ticketing system and audit processes.

1. Misconfigured Cloud Storage:

   • Example: A cloud storage bucket (like AWS S3) is inadvertently set to “public”, allowing anyone with the link to access its contents.
   • Implication: Unauthorized individuals might access or download CUI.

2. Inadequate Access Controls:

   • Example: Default or overly permissive access controls on cloud resources allow more users than necessary to access sensitive data.
   • Implication: Employees or cloud users without a genuine need to access CUI could potentially view or alter this sensitive information.

3. Unencrypted Data Transmission:

   • Example: Data being transferred to or from the cloud is not encrypted.
   • Implication: If intercepted, CUI could be accessed and compromised by malicious actors.

4. Lack of Multi-Factor Authentication (MFA):

   • Example: Users can access cloud services containing CUI using just a password, without a second factor of authentication.
   • Implication: If a password is compromised, unauthorized users could access CUI without any additional security barriers.

5. Outdated Cloud Service Software:

   • Example: The software or services running in your cloud environment aren’t regularly updated, leaving known vulnerabilities unpatched.
   • Implication: Attackers could exploit known vulnerabilities to gain unauthorized access to CUI.

6. Insufficient Logging and Monitoring:

   • Example: Cloud access logs aren’t closely monitored or stored securely.
   • Implication: Suspicious activities or unauthorized data access might go unnoticed, prolonging potential exposure of CUI.

7. Shared Tenancy Vulnerabilities:

   • Example: Using shared cloud resources without proper isolation could lead to data leakage between tenants.
   • Implication: Another user of the same cloud service might accidentally or maliciously gain access to your CUI.

8. Lack of Data Backup:

   • Example: Not having a backup strategy for cloud-stored CUI.
   • Implication: If there’s a data loss incident, CUI could be irretrievably lost.

9. Weak API Security:

   • Example: Cloud services and integrations utilize APIs which aren’t securely designed or protected.
   • Implication: Malicious actors could exploit weak API security to access or manipulate CUI.

• 1. Policy Statement:
     Our organization commits to the diligent identification, reporting, and correction of system flaws. We understand that safeguarding Controlled Unclassified Information (CUI) demands prompt action and adherence to best practices, as defined by our Service Level Agreement (SLA) and guidance from industry standards.

      

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     Implementation Details:

     Implementation Details:

     1. SLA for Remediation Efforts:

     Any system flaw which may affect CUI will have a service level agreement of 60 minutes or less to initiate remediation efforts.

     2. Identification of System Flaws:

     • Procedure: System flaws are determined within the specified timeframe through our proactive monitoring processes.
     • Implementation: During information intake, IT ticket creation is triggered in our IT ticketing system. This ensures that flaws are logged and queued for immediate attention.

     3. Reporting of System Flaws:

     • Procedure: A specified timeframe is set for reporting system flaws to ensure timely resolution.
     • Implementation: Our Incident Response Plan dictates the mechanisms and timelines for flaw reporting. The IT service ticket system facilitates the reporting process, and the ticket review audit process, in conjunction with the risk management standard operating procedure, ensures compliance with reporting timelines.

     4. Correction of System Flaws:

     • Procedure: Identified system flaws must be corrected within a specified timeframe to reduce vulnerabilities.
     • Implementation: The IT service ticketing system, the ticket review audit process, and the risk management SOP oversee and guide the flaw correction process. Each of these mechanisms ensures that flaws are addressed promptly and according to organizational standards.          5. Security-Relevant Updates:
• • We prioritize and apply security-relevant updates like patches, service packs, hot fixes, and anti-virus signatures promptly.
  • Such updates are vital for addressing known vulnerabilities and deterring potential exploitation.

  6. Flaw Correction Process:

  • Our organization swiftly addresses and rectifies flaws detected during security assessments, continuous monitoring, incident response activities, and system error handling.

  7. Use of Available Resources:

  • In rectifying flaws found in our systems, we refer to the Common Weakness Enumeration (CWE) database and Common Vulnerabilities and Exposures (CVE) database.
  • These databases facilitate comprehension of the flaws’ nature and the suggested remediation steps.

  8. Organization-Defined Time Periods:

  • Timeframes for updating security-relevant software and firmware take  into account factors like the update’s urgency and the vulnerability’s severity linked to the discovered flaw.

  9. Flaw Remediation Testing:

  • Our organization undertakes  testing to ascertain the efficacy of flaw remediation steps before their comprehensive deployment. This ensures that the implemented solutions don’t cause further disruptions.

  10. Guidance from [SP 800-40]:

  • Our organization aligns with the guidance from [SP 800-40] for efficient and secure patch management, bolstering our defense against vulnerabilities.

  11. Continuous Improvement:

  • Drawing from lessons of incident response activities and security assessments, we are committed to refining our approach to flaw management. This ensures we are aptly fortified against emerging threats.

  .

Plan of Action and Milestones (POA&M)

Title: System Flaw Identification, Reporting, and Remediation

1. Introduction: This POA&M provides a structured approach for addressing the identification, reporting, and correction of system flaws within the organization. The document outlines milestones, responsible entities, and estimated completion dates for each action item, ensuring adherence to our policy and continuous improvement.

2. Milestones:

a. SLA for Remediation Efforts

• Action: Review and enforce the SLA, ensuring all teams are aware.
• Responsible Entity: IT Management Team
• Estimated Completion: [Date]

b. Identification of System Flaws

• Action: Integrate monitoring tools with the IT ticketing system.
• Responsible Entity: IT Operations Team
• Estimated Completion: [Date]

c. Reporting of System Flaws

• Action: Train staff on the Incident Response Plan and reporting mechanisms.
• Responsible Entity: IT Security Team
• Estimated Completion: [Date]

d. Correction of System Flaws

• Action: Develop and implement an audit process for the IT ticketing system.
• Responsible Entity: IT Audit Team
• Estimated Completion: [Date]

e. Security-Relevant Updates

• Action: Implement automated patch management solutions for timely updates.
• Responsible Entity: IT Operations Team
• Estimated Completion: [Date]

f. Flaw Correction Process

• Action: Review and refine current correction processes based on feedback.
• Responsible Entity: IT Security Team
• Estimated Completion: [Date]

g. Use of Available Resources

• Action: Integrate CWE and CVE databases with our security tools.
• Responsible Entity: IT Security Team
• Estimated Completion: [Date]

h. Organization-Defined Time Periods

• Action: Define and document specific timeframes for each category of updates.
• Responsible Entity: IT Management Team
• Estimated Completion: [Date]

i. Flaw Remediation Testing

• Action: Set up a dedicated environment for testing flaw remediation steps.
• Responsible Entity: QA Team
• Estimated Completion: [Date]

j. Guidance from [SP 800-40]

• Action: Organize workshops to align IT practices with [SP 800-40] guidance.
• Responsible Entity: IT Security Team
• Estimated Completion: [Date]

k. Continuous Improvement

• Action: Regularly review and update the system flaw management process.
• Responsible Entity: IT Security and Management Teams
• Estimated Completion: [Date]

3. Review: This POA&M will be reviewed on a [quarterly/semi-annual/annual] basis to ensure timely completion of milestones and to update based on changing requirements.

4. Approval: [Name, Title, Date]

Incident Response Plan (IRP): Timeframe for Reporting System Flaws

1. Introduction: This Incident Response Plan (IRP) establishes the required procedures for reporting system flaws upon detection in a timely manner, ensuring that all stakeholders are promptly informed and can take the necessary corrective actions.

2. Objective: To ensure that system flaws are identified, reported, and escalated within the organization to allow for swift remediation.

3. Identification and Classification of System Flaws: a. Critical Flaws: Direct and immediate threat to the system, data, or operations. b. High-Priority Flaws: Potential to escalate to a critical threat if not addressed. c. Medium-Priority Flaws: Impact system performance but not immediate operations. d. Low-Priority Flaws: Minimal immediate impact, mostly quality-of-life or non-urgent issues.

4. Reporting Timeframes Based on Flaw Classification: a. Critical Flaws: Should be reported immediately upon identification, no later than 30 minutes. b. High-Priority Flaws: Within 2 hours of identification. c. Medium-Priority Flaws: Within 8 hours of identification. d. Low-Priority Flaws: Within 24 hours of identification.

5. Reporting Procedure: a. Immediate Notification: Use the internal communication tool (e.g., email, ticketing system) to notify the IT and Security teams. b. Details Required: Describe the flaw, its apparent impact, any potential data compromised, and any steps taken post-discovery. c. Confirmation: A member of the IT or Security team will acknowledge receipt of the notification.

6. Escalation Procedures: a. Critical Flaws: Immediate escalation to the Head of IT, CISO, and relevant department heads. b. High-Priority Flaws: Notify the CISO and IT management team. c. Medium-Priority Flaws: Escalate to the IT manager. d. Low-Priority Flaws: Log for review during the next IT department meeting.

7. Communication: Ensure that relevant internal stakeholders are informed, and if necessary, prepare a communication for external stakeholders, including partners, customers, or the public, especially if the flaw poses potential risks to them.

8. Review and Lessons Learned: Once the incident has been managed, conduct a post-incident review to understand its cause, how it was handled, and how future occurrences can be prevented or better managed.

9. Continuous Improvement: Based on the post-incident review, update and improve the IRP and other relevant procedures to enhance the organization’s resilience against future incidents