3.6.3 has a weight of -1 points

System Security Plan (SSP) for Control 3.6.3: Test the Organizational Incident Response Capability

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Policy Statement:
Our organization is committed to conducting regular testing of its incident response capability to assess its effectiveness, identify weaknesses, and address potential deficiencies.

Purpose of Incident Response Testing:
The primary objective of incident response testing is to evaluate the effectiveness of our organization’s incident response capabilities in handling security incidents. Through testing, we aim to identify and address any weaknesses or deficiencies in our incident response procedures and protocols.

Testing Mechanism:

1. Routine Testing:
   For every IT and security-related event, as well as physical premises incidents, the organizational incident response procedures are immediately activated and executed. This ensures the incident response mechanism is continuously tested and improved upon.

2. Permissions Request Testing:
   Any permissions request change is also an opportunity to test the incident response mechanism by cycling through its procedures.

Testing Methods:
Incident response testing encompasses various methods, including:

• Use of checklists to ensure adherence to all necessary steps during incident response.
• Walk-through or tabletop exercises involving scenario discussions and evaluation of incident response strategies.
• Simulations, such as parallel exercises, to simulate incident scenarios without actual interruption, and full interrupt exercises with real-time responses to simulated incidents.
• Comprehensive exercises covering multiple aspects of incident response testing.

Determining Effects on Organizational Operations:
During incident response testing, we assess the impact of security incidents on our organizational operations, including potential reductions in mission capabilities. We also consider the effects of incident response on organizational assets and individuals.

Performance Review:

1. Quarterly Risk Management Meetings:
   During these meetings, there is a thorough review of past incident response actions to gauge the response capability and effectiveness of the organization.

2. Feedback Loop:
   Lessons learned and areas of improvement identified in these meetings are communicated back to the relevant departments for implementation.

Guidance and Standards:
Our incident response testing aligns with the guidance provided in [SP 800-84], ensuring compliance with testing programs for information technology capabilities.

Testing Frequency:
Incident response testing is conducted on a regular basis in accordance with our incident response plan and risk management strategies. The frequency of testing is determined based on our risk profile and operational requirements and may occur annually, semi-annually, or at defined intervals.

Incident Response Improvement:
Findings and lessons learned from incident response testing serve as valuable inputs to enhance our incident response procedures and update the incident response plan. We take corrective actions to address identified weaknesses and deficiencies, improving our incident response capabilities.

Involvement of Incident Response Teams:
Our dedicated incident response teams actively participate in incident response testing exercises, providing valuable feedback and insights for continuous improvement.

Annual Testing:
Managers, in collaboration with department heads, conduct an annual test to simulate a likely event that the organization might face. The chosen scenario is briefed to the participants. The test is then executed, and results are compiled and discussed among all participants.

Responsibilities:

• Managers: Facilitate the annual test, review quarterly performance, and ensure the effectiveness of the incident response mechanism.
• Department Heads: Participate in the annual tests and contribute to the review and improvement processes.
• Incident Response Teams: Participate in testing exercises and provide feedback for improvement.
• FSO: Maintain all test results, documentation, and oversee the implementation of improvements to the incident response procedures.

Continuous Improvement:
Our organization fosters a culture of continuous improvement, regularly evaluating and enhancing our incident response capability by incorporating best practices and industry standards.

Approval:
This plan is subject to the approval of the senior management of the organization. Upon approval, it will be communicated to all relevant departments for implementation.

 

Plan of Action and Milestones (POA&M) for Control 3.6.2

1. Action Item: Routine Testing Mechanism Enhancement

• Description: Ensure the constant validation of incident response procedures through routine testing mechanisms.
• Responsible Party: Incident Response Teams.
• Expected Completion Date: [Date].
• Status: [e.g., Not Started/In Progress/Completed].
• Milestones:
  • Refine testing scenarios for IT and security-related events.
  • Monitor effectiveness after every incident.

2. Action Item: Permissions Request Testing Improvement

• Description: Establish protocols to utilize every permissions request change as a testing opportunity.
• Responsible Party: IT Department Heads.
• Expected Completion Date: [Date].
• Status: [Status].
• Milestones:
  • Train staff on the new testing procedures.
  • Review and gather feedback after every permissions request change.

3. Action Item: Quarterly Risk Management Meetings Optimization

• Description: Enhance the review process during the quarterly meetings for more accurate gauging of the incident response capabilities.
• Responsible Party: Managers.
• Expected Completion Date: [Date].
• Status: [Status].
• Milestones:
  • Define metrics for measuring incident response effectiveness.
  • Establish a standardized feedback loop for departments.

4. Action Item: Annual Test Procedure Update

• Description: Refinement of the annual testing process to ensure relevance to potential realistic incidents.
• Responsible Party: Managers and Department Heads.
• Expected Completion Date: [Date].
• Status: [Status].
• Milestones:
  • Select relevant incident scenarios.
  • Schedule and conduct an annual test.
  • Review results and identify areas of improvement.

5. Action Item: Documentation & Continuous Improvement

• Description: Maintain up-to-date documentation of all tests and implement continuous improvement mechanisms.
• Responsible Party: FSO.
• Expected Completion Date: [Date].
• Status: [Status].
• Milestones:
  • Update documentation procedures.
  • Implement a review schedule to ensure regular updates.

6. Action Item: Aligning with NIST SP 800-84

• Description: Ensure full alignment and compliance with the guidance provided in NIST SP 800-84.
• Responsible Party: Incident Response Teams and IT Department.
• Expected Completion Date: [Date].
• Status: [Status].
• Milestones:
  • Review the guidelines of SP 800-84.
  • Adjust procedures to align with the guidance.
  • Conduct training sessions for staff on the updated procedures.

7. Action Item: Foster Continuous Improvement Culture

• Description: Launch initiatives to embed a continuous improvement culture throughout the organization.
• Responsible Party: Senior Management.
• Expected Completion Date: [Date].
• Status: [Status].
• Milestones:
  • Organize workshops on best practices and industry standards.
  • Reward departments/teams showcasing notable improvements.

8. Action Item: Approval & Implementation Communication

• Description: Gain approval for the SSP and communicate its implementation to all departments.
• Responsible Party: Senior Management.
• Expected Completion Date: [Date].
• Status: [Status].
• Milestones:
  • Present the SSP for approval.
  • Organize communication sessions for all departments post-approval.

A Tabletop Exercise (TTX) is a discussion-based exercise often used to test and validate policies, plans, and procedures, without the need for an actual real-world event or deployment of resources. Instead, participants “talk” through a hypothetical scenario and the steps they would take in response, allowing for a detailed examination of the incident response process in a controlled setting.

Here’s a breakdown of a Tabletop Exercise:

1. Purpose: Tabletop exercises are designed to:

• Validate policies, plans, and procedures.
• Test the knowledge and understanding of participants.
• Improve coordination and communication among teams and departments.
• Identify gaps or weaknesses in current response strategies.

2. Participants: Typically, a TTX includes a mix of:

• Decision-makers
• Key personnel involved in incident response
• Representatives from different departments or agencies as applicable

3. Scenario Development:

• A hypothetical scenario is created to mimic a realistic and challenging situation that the organization may face.
• The scenario should be tailored to test specific aspects of the response plan and may be based on risk assessments or previous real-life incidents.

4. Execution:

• The facilitator presents the scenario and guides the discussion.
• Participants talk through their roles, responsibilities, and decision-making processes as the scenario unfolds.
• The facilitator may introduce new “injects” (additional information or twists) to further challenge the participants and explore various outcomes.

5. Discussion:

• A key part of a TTX is the discussion. As each phase of the scenario unfolds, participants discuss how they would respond, ensuring alignment with organizational policies and plans.
• The group explores potential challenges, resource needs, communication strategies, and coordination efforts.

6. Documentation:

• A recorder (or several) captures key points, decisions, issues, and recommendations that arise during the discussion.
• This documentation serves as a basis for after-action reports and improvement plans.

7. After-Action Review & Improvement Planning:

• After the exercise, findings and recommendations are compiled into an after-action report.
• This report identifies strengths to be maintained and built upon, as well as areas for improvement.
• An improvement plan is developed to address the gaps and weaknesses identified.

8. Benefits:

• Cost-effective: TTX doesn’t require a significant financial investment or resource deployment.
• Time-saving: Can be completed in a few hours to a day.
• Builds confidence: Helps teams and individuals understand their roles and responsibilities better.
• Promotes inter-departmental communication and cooperation.
• Identifies areas for improvement without the risks and stresses of a real incident.

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TT&E stands for Test, Training, and Exercise. Let’s break down what a TT&E Program entails:

1. Test: This involves the evaluation of systems, procedures, and capabilities to determine if they function as expected. In the context of IT and cybersecurity, this could mean assessing whether a backup solution works correctly or if a newly installed firewall effectively blocks certain threats. Tests are typically focused, short-term events aiming to validate specific functions.

2. Training: Training is about ensuring that personnel are equipped with the necessary knowledge and skills to perform their duties effectively. In IT, this might involve training staff on how to use new software or educating them about cybersecurity threats and best practices. Training ensures that when an incident or a crisis occurs, the staff knows what to do and how to do it.

3. Exercise: Exercises simulate real-life situations or crises to see how well the organization and its staff would respond in the event of an actual incident. They can range from tabletop exercises, where teams verbally walk through a scenario, to full-scale exercises that replicate real-world events. Exercises not only test the effectiveness of policies and procedures but also the coordination and decision-making capabilities of teams and individuals.

In summary, a TT&E Program is a structured approach that organizations use to:

• Validate their capabilities (through Tests).
• Educate and prepare their staff (through Training).
• Simulate and assess their response to real-life scenarios (through Exercises).

Here’s a breakdown of the key guidance provided in NIST SP 800-84: