Crosswalk pair
NIST SP 800-171 and PCI DSS, control by control
25 canonical controls in Keel’s library satisfy clauses of both NIST SP 800-171 and PCI DSS. Implement each once, attach the evidence once, and it counts toward each standard. The overlap is the work you don’t repeat.
The overlap
What the two libraries have in common
Every figure here counts canonical controls in Keel’s library, not clauses of either standard. Each standard’s own authored count is on its framework page.
25
Controls that satisfy both
Canonical controls that crosswalk to at least one clause of each.
41
In Keel’s library for NIST SP 800-171
61% of them also map to PCI DSS.
38
In Keel’s library for PCI DSS
66% of them also map to NIST SP 800-171.
108
Evidence artifacts expected
Across the shared controls, from Keel’s evidence guidance. Gathered once.
-
NIST SP 800-171 61%
25 controls of 41 in Keel’s library for NIST SP 800-171 also map to PCI DSS.
-
PCI DSS 66%
25 controls of 38 in Keel’s library for PCI DSS also map to NIST SP 800-171.
The mapping
Controls that satisfy both
Each row is one control in Keel’s library and the clauses it answers on each side. Do the work once; both columns are then evidenced by the same artifacts.
| Canonical control | NIST SP 800-171 clauses | PCI DSS clauses |
|---|---|---|
| Governance & Risk | ||
| Acceptable use of information and assets Rules for how information and the assets that hold, process or transmit it may be used are written down, communicated to everyone who works for or with the organization, and acknowledged before access is given. The rules state what is permitted rather than only what is forbidden: what business use covers, what personal use of an organization asset is allowed and where that ends, whether personally owned devices may be used and under which conditions, and what must never be done - installing unapproved software, bypassing a security control, moving information to a personal account or service, or letting somebody else use a credential or a device issued to you. Handling expectations follow the classification of the information rather than the seniority of the person holding it, and the rules reach every stage the asset is in - in use, in transit, in storage, and at return or disposal. Contractors, temporary staff and third parties working on the organization’s behalf are bound by the same rules through the arrangement that engages them. Where use of an asset is monitored, the rules say so and say what is monitored, so monitoring is disclosed rather than discovered. Breaking the rules has a stated consequence that is actually applied, and the rules themselves are reviewed when technology, working patterns or legal obligations change - and where they change materially, the acknowledgment is taken again rather than relying on the one given against an earlier version. The rules also govern EXTERNAL systems: those the organization neither owns nor controls - a personal computer, a home network, a partner’s or customer’s equipment, a public terminal, a consumer service somebody signed up for - and they state the terms on which such a system may be used to access, process or store the organization’s information, or prohibit its use for that purpose where the risk warrants. Where use is permitted, it is permitted only after the organization has verified that the required controls are actually implemented on that system, or has a connection or processing agreement with whoever runs it; permission is not granted on the strength of a request. Behavior on external sites and services is covered explicitly: what may and may not be posted about the organization on social media and other public platforms, and the prohibition on presenting a credential issued by the organization to any external site or application that is not an approved one. The end-user technologies the rules govern are named rather than left to the reader - the laptops and workstations, the remote-access services, the removable media and portable storage devices, the wireless and mobile equipment, and any personally owned device permitted - and each is approved by an authorized role before it is used, recorded as an approved product or service, and used only for the purposes and by the people the rules state. | 3.1.20 | 12.2 |
| Risk assessment & treatment A documented process to identify, analyze, evaluate, and treat information security risks on a defined cadence, and again whenever a significant change is proposed or has happened - a new system, a new supplier, a reorganization, a serious incident - so the picture is refreshed by events and not only by the calendar. The process is repeatable: the criteria for accepting risk and for deciding when an assessment is performed are set in advance and applied the same way each time, so repeated assessments produce consistent, comparable and valid results rather than a different answer depending on who ran it. Every risk has a named owner who approves how it will be treated and accepts what is left afterwards. The assessment covers risks and vulnerabilities to the confidentiality, the integrity and the availability of the data the organization holds - all three, not confidentiality alone - and is accurate and thorough enough to be relied on by the decisions taken from it. Treatment brings each risk down to a level that is reasonable and appropriate for this organization, which is the target the process is judged against rather than merely recording that a risk exists. Each assessment and its results are retained as documented information. The process is set down as a documented risk assessment policy with supporting procedures, issued to the roles it binds, owned by a named role, and reviewed and updated on a defined cadence and after an event that changes how the organization assesses risk. The criteria are stated as risk appetite and risk tolerance: how much risk the organization is willing to seek in pursuit of its objectives, and how much variation around that it will tolerate - written down, communicated to the people who take risk decisions, and maintained as the organization and its environment change rather than set once and inherited. The method itself is standardized and communicated: how a risk is calculated, how it is documented, which category it falls into and how it is prioritized against the others, so two people assessing the same thing produce the same rating. What the assessment works from is recorded rather than assumed. The threats to the organization, internal as well as external, are identified and written down. The impacts each could have, and how likely each is, are identified and recorded against them. And the threats, the vulnerabilities, the likelihoods and the impacts are then used together to understand the risk as it stands before any treatment is applied, and to decide which responses are taken first. | 3.11.1 | 12.3 |
| Access Control | ||
| Access control policy Rules for granting, reviewing, and revoking access to systems and data based on business need and least privilege; anyone who works with sensitive data, or in a place from which it can be reached, is individually authorized for that work or supervised while doing it; and a documented emergency route exists to obtain the data when the normal access path is unavailable, with every use of that route recorded and reviewed afterwards. The rules also settle the opposite question: which actions, if any, a person may take on a system without identifying or authenticating themselves at all. Those actions are identified rather than left as whatever the system happens to permit, they are limited to what the organization’s business actually requires, and each one is documented in the system’s security plan together with the reasoning that justifies it, so an unauthenticated path is a decision somebody made and can be asked about. The rules are enforced by access control lists set on the data itself, not only by what an application chooses to show: permissions on local and remote file systems, on databases and inside applications are configured to the holder’s need to know, so information a role has no business reading is unreachable rather than merely unadvertised. What an authorized user may DO is limited on the same terms as what they may read: the types of transaction and function each role is permitted to execute are decided in advance and enforced by the system, so holding access to an application does not carry the right to run every operation inside it, and an action outside the permitted set is refused rather than merely unadvertised in the interface. Enforcement is centralized wherever the systems support it - access decisions for enterprise assets are made by a single directory service or single sign-on provider rather than by each system keeping its own list - and the systems that make those decisions are themselves known: an inventory of the organization’s authentication and authorization systems is maintained, including those run by a service provider on its behalf, and reviewed on a defined cadence. | 3.1.1, 3.1.2, 3.1.5 | 7.1, 7.2, 7.3 |
| Multi-factor authentication Documented procedures verify that a person or system seeking access to sensitive data is the one it claims to be, on every path by which that data can be reached - and multi-factor authentication is the enforced mechanism for remote access, administrative access, and access to sensitive systems and data. The multi-factor mechanism itself is configured so it cannot be bypassed, so the factors it uses are genuinely independent of one another - one factor’s success granting no knowledge of and no route around another - and so access is refused unless every factor required has succeeded. The requirement is not confined to the accounts that carry privilege: every account is covered, privileged and non-privileged alike, because an ordinary account is the usual way into a privileged one. The mechanisms chosen are resistant to replay, so an authentication captured on the wire or lifted from a log cannot be presented again to gain access. Authentication is not a single event at the start of a session either: the person is required to authenticate again when the organization’s defined circumstances arise - a change of role or of the authenticators themselves, an escalation to privilege, a session that has run beyond its defined life, or a request to perform an action the organization has designated as requiring fresh proof. | 3.5.2, 3.5.3, 3.5.4 | 8.4, 8.5 |
| Password & credential management Rules for the authentication credentials themselves: passwords are unique per account and meet a defined strength standard, a new or changed password is screened against a list of commonly used, expected and compromised passwords and refused if it appears there, a credential issued for first use must be replaced immediately, reuse of previous passwords is refused, changes follow a defined procedure, repeated failed authentication attempts lock the account for a defined period, and passwords, keys and other authentication secrets are stored and transmitted only in protected form. The rules are a documented policy with supporting procedures covering identification and authentication as a whole - who and what must be identified, to what assurance, and by which mechanisms - issued to the people and roles it applies to, owned by a named role, and reviewed and updated on a defined cadence and after a change that affects it. Repeated failure is handled to a stated rule rather than to a default: a limit is set on consecutive invalid authentication attempts within a defined time window, and when that limit is exceeded the system responds automatically in a way the organization has chosen and configured - locking the account for a defined period, delaying further attempts by a defined algorithm, or notifying a defined role - rather than continuing to accept attempts. What is displayed back to the person authenticating is obscured while they do it, so a credential cannot be read off the screen or recovered from the feedback the system gives. The protection an authenticator receives is proportionate to the sensitivity of what its use unlocks, so a credential granting access to the most sensitive information is stored, transmitted, issued and revoked under stronger handling than one that opens a low-impact system. | 3.1.8, 3.5.7, 3.5.8, 3.5.9, 3.5.10, 3.5.11 | 8.1, 8.3 |
| Privileged access & administrative tooling Access that can change a system rather than merely use it is treated as a separate class from ordinary access, and so are the tools that carry that power. Privileged rights are allocated through a documented process on an event-by-event basis rather than standing by default: they are requested against a stated need, approved by somebody other than the requester, granted for a defined period and withdrawn when it ends. They are held on an identity distinct from the person’s everyday account, so routine work does not run with administrative rights, and they require strong authentication including a second factor. Who holds what privilege is reviewed on a cadence and immediately on a role change or departure. Privileged sessions are logged in a way the privileged user cannot alter, and the log is reviewed. Emergency or break-glass access exists as a documented route, and every use is recorded and reviewed afterwards. Separately, UTILITY PROGRAMS capable of overriding system or application controls - system tools, database and configuration editors, debuggers, packet capture, recovery and imaging utilities - are inventoried, removed or disabled where they are not needed, restricted to a named authorized few, kept apart from application software, protected against being reintroduced by a user, and logged when used; anyone holding ordinary application access does not get them by default. Which personnel and roles may hold a privileged account at all is a decided and recorded list rather than an accumulation, and access to the system’s security functions and to security-relevant information - the audit configuration, the access rules, the cryptographic settings, the security tooling itself - is authorized explicitly per role rather than arriving as a side effect of an administrative grant. The periodic review asks whether the privilege is still needed for the work the holder actually does now, and reassigns or removes it where it is not. The technical controls match the rules: a user without privileges is prevented from executing a privileged function rather than only forbidden from doing so, and every execution of a privileged function is written to the log. Where privileged commands or access to security-relevant information are exercised over a remote connection, that is permitted only for needs the organization has documented and only in a form that can be audited afterwards. The separation extends to the machine and not only to the account: administrative work is performed from computing resources dedicated to it and separated physically or logically from the estate used for everyday work, segmented away from the organization’s primary network and without general internet access, so a browser or a mail client is never one process away from the session that administers the environment. ACCOUNTS THAT ARE NOT PEOPLE are governed as their own class rather than as a quiet exception to the rules above: every account used by a system, a service or an application is inventoried with the function it exists for and a named human owner, interactive login by a person is prevented on it unless a specific need is documented and authorized, its credentials are held in a managed secret store rather than in a file, a script, a scheduler or somebody’s memory, they are changed on a defined cadence and whenever a person who could have known them leaves, and they are neither shared between accounts nor reused from one environment to the next. | 3.1.6, 3.1.7, 3.1.15 | 8.6 |
| User provisioning & deprovisioning Joiner/mover/leaver process to grant, change, and promptly remove access across systems, in which every person is issued an account of their own carrying a unique name or number, so an action in a log traces back to one named individual rather than to a shared or generic login. Each person’s right of access is recorded when it is established and reviewed on a schedule thereafter, as well as granted and changed - so what someone holds is a documented position that has been looked at again, not the accumulated residue of past requests - and what may be granted follows the organization’s access authorization rules rather than the judgment of whoever processes the request. Identity is managed as a lifecycle in its own right and not only as the access hung off it: an identity is created only after the person or the thing behind it has been verified to a stated standard, is linked to a single accountable human owner, and is disabled and then retired on a defined path rather than deleted where the record has to survive for an audit trail. A shared or generic identity exists only where there is a reason it cannot be individual, and then it is authorized, given an owner who answers for what is done with it, and reviewed. Identities issued to services, applications, devices and automation are registered on the same terms as human ones, with an owner, a purpose and a review date, because an unowned machine identity outlives every person who knew what it was for. Dormant identities are detected and removed rather than waiting for a leaver process that was never triggered. The lifecycle is run by automated mechanisms wherever the systems allow it: accounts are provisioned and deprovisioned from an authoritative source of record, and each act of creating, modifying, enabling, disabling or removing an account generates an audit record automatically rather than depending on the administrator to note it. An account issued for a temporary or emergency purpose carries an expiry from the moment it is created and is disabled or removed automatically when that expiry passes, so a route opened for one situation does not stay open after it. An account is disabled within a defined period when it has expired, when it is no longer associated with any individual, when it is in violation of the organization’s policy, or when it has been inactive beyond a defined period - and where an individual is found to pose a significant risk, within a defined period of that discovery rather than at the next scheduled review. Identifiers are managed as an object in their own right: an identifier is authorized before it is assigned, is selected to a defined convention, is never reused for a different person or entity, and is issued on the same terms whether it names an individual, a group, a role, a service or a device - and where the organization needs to distinguish one class of person from another, such as an employee from a contractor or a vendor, the identifier or its record carries that status rather than leaving it to be inferred. Identity proofing is performed to the assurance level the access warrants: the applicant is resolved to a single unique individual, is required to present identity evidence to whoever registers them, and that evidence is validated and verified by methods the organization has defined rather than accepted on sight, with an address of record confirmed through an out-of-band channel where the assurance level calls for it. All of it is answerable from one INVENTORY OF ACCOUNTS rather than from each system in turn: every account the organization manages is listed - ordinary user, administrator and service alike - with the person or function behind it, the account name, the dates it starts and stops, the department or owner it belongs to and the privilege it carries, and the list is validated against what is actually active on a defined recurring schedule, so an account nobody can account for is found by the review rather than by an incident. Accounts are managed centrally through a directory or identity service wherever a system can be brought into one, because an account that lives only inside an application is the one a leaver process misses. | 3.1.1, 3.5.1, 3.5.5, 3.5.6, 3.9.2 | 8.2 |
| Data Protection & Privacy | ||
| Cryptographic key management Wherever the organization uses cryptography, the keys behind it are managed to written requirements rather than to whatever the tool defaulted to - because a strong algorithm on a badly held key protects nothing. The requirements state, for each class of key, how it is generated and to what strength, how it is distributed to the parties that need it and how they prove they are entitled to it, where and how it is stored, how it is used and by what, how often it is rotated, how it is revoked and destroyed when it is compromised or retired, and how it is recovered or escrowed where the information would otherwise become unreadable. A key’s life is bounded and its retirement is planned, so rotation is a scheduled act rather than a crisis. Private keys are held so that only the entity they identify can use them, and access to them is enforced technically rather than by convention. PUBLIC KEY CERTIFICATES are issued under a certificate policy the organization has approved, or obtained from a service provider it has approved, and only trust anchors it has approved are present in the trust stores and certificate stores it manages - a store nobody has curated is a list of parties allowed to impersonate anybody. Where the organization relies on public key authentication, an authenticated certificate is mapped to the account of the individual or group it belongs to rather than accepted as an identity in itself, certificates are validated by building and verifying a certification path to an accepted trust anchor including a check of revocation status, and revocation data is cached locally so that path discovery and validation still work when the source of that data cannot be reached. Authentication to the cryptographic modules themselves - the hardware security module, the key vault, the token, the software module - uses mechanisms that satisfy the laws, standards and guidelines that apply to it, rather than a shared operator password. Key material is inventoried, its owner recorded, and its use logged, so the question of what a compromised key opened is answered from a record. Where the keys protect payment or account data the storage rules are tighter and are stated rather than inferred: keys are held in the fewest locations and by the fewest custodians the operation can run with, a key that encrypts another key is protected at least as strongly as the key it wraps and is kept apart from it, key material at rest is held only in a form the organization has approved in advance - inside a secure cryptographic device, split into components or shares that no single custodian holds in full, or encrypted under a separate key-encrypting key - and every custodian acknowledges the responsibilities of the role in writing before taking it on. | 3.13.10 | 3.6, 3.7 |
| Data classification & handling Information is classified and handled per its sensitivity, with rules for labeling and protection - including the everyday handling rules that stop it being seen, overheard or picked up by people with no business reading it, so exposure that happens incidentally alongside legitimate work is limited rather than accepted. The handling rules are written to cover disclosure that nobody intended as much as disclosure that somebody chose, they say what an unauthorized disclosure is against the organization’s own privacy and confidentiality rules rather than leaving that to judgment in the moment, and they reach every medium the information travels in - spoken, on paper, on a screen and in a system - because the incidental exposure they exist to limit does not respect the boundary between an administrative, a physical and a technical safeguard. Labeling is the procedure that makes the classification visible, and it is defined rather than left to habit: there is a label for each level of the scheme, a rule for how the label is applied in each form the information takes - a document, an email, a file, a database field, a screen, a report, a piece of removable media, a printed page - and, where a system supports it, the label is carried in metadata so it can be acted on automatically rather than only read. The person who creates or receives the information applies the label at that point rather than later, the label travels with the information when it is copied, extracted, exported or transferred so a copy does not arrive unclassified, and information derived from or aggregated out of classified sources is labeled for what the combination is worth rather than for what the least sensitive input was. Where a label would itself disclose something, an agreed alternative is used and recorded, and the procedure covers what to do when unlabeled information is found. On storage media the marking carries more than the level: it states the distribution limitations that apply and any handling caveats that travel with the contents, so somebody who picks the item up knows what they may do with it without having to ask. Where the organization exempts a class of media from marking because it never leaves a controlled area, that exemption is defined and recorded as a decision rather than practiced as an omission. Underneath the scheme sits a documented DATA MANAGEMENT PROCESS that the classification and the handling rules are derived from: it states how sensitivity is decided, who owns each category of data, how each category is handled, the retention limits that apply to it and what disposal it requires, and it is reviewed and updated on a defined cadence and whenever a change to the organization would alter it. That process is also what the DATA FLOWS are documented against - where each category of information originates, which systems and processes it moves between, and where it crosses out to a service provider - recorded as documentation somebody maintains rather than reconstructed when a question is asked, and reviewed on the same cadence. | 3.8.4 | 3.1 |
| Data retention & secure disposal Data is retained per policy and securely destroyed when no longer needed. Retention periods are set against the purpose the data was collected for and any legal or contractual obligation to keep it, recorded per category of data rather than left to whoever is looking at the record, and enforced when they run out - data goes because its period ended, not because somebody finally objected to keeping it. Destruction leaves it unrecoverable rather than merely removed from an index, and what was destroyed, when, by what method and on whose authority is recorded. The hardware and media that held it reach a defined final disposition at end of life, by a route the organization has decided in advance rather than by whatever happens to the box; and any media that stays in service is cleared of that data before it is reused, reassigned, or passed to anyone else. Disposal is not confined to data and media: the documentation, the tools and the system components the organization has defined as needing it are disposed of by techniques and methods it has approved in advance - so a decommissioned appliance, a retired build server, a set of network diagrams or a licensed utility leaves the organization by a route somebody chose, and the route is recorded on the same terms as a data destruction. A retention period has two ends and both are stated: the minimum the organization must keep the data for, and the maximum beyond which it may not be kept - so retention is bounded in the direction of keeping too long as well as of destroying too early. | 3.8.3 | 3.2 |
| Encryption in transit & at rest Strong cryptography protects sensitive data in transit over public networks and at rest in storage. The mechanisms are chosen to do two things and are judged against both: prevent unauthorized disclosure of the information, and prevent or detect unauthorized change to it - in transit, so a message altered between sender and receiver is caught rather than delivered, and at rest, so a stored record cannot be modified undetectably by somebody with access to the storage but not to the key. Which information is protected at rest, and on which system components, is decided and recorded rather than left to whatever the platform encrypts by default. The scope named explicitly reaches the end-user device as well as the server: data held on laptops, desktops and other end-user devices that carry sensitive information is encrypted at the device or volume level, so a device that leaves the building is an object somebody lost rather than a disclosure. And data in transit is encrypted wherever it is sensitive, not only where it crosses a public network - a session between two internal systems is protected on the same terms when what it carries warrants it. Where a law, a regulation or a contract requires the cryptography to be VALIDATED rather than merely strong, the organization uses a cryptographic module that carries the validation that instrument names, and it confirms that validation against the specific module, version and operating mode actually deployed rather than inferring it from the product’s name - because a validated module run outside the configuration it was validated in is not a validated module, and the certificate that proves the point is held as evidence rather than assumed to exist. | 3.13.8, 3.13.11, 3.13.16 | 3.5, 4.1, 4.2 |
| Infrastructure & Operations | ||
| Asset inventory An inventory of hardware, software, and information assets with assigned owners, in which the movement of equipment and removable media into, out of, and within the organization’s premises is recorded against the person responsible for it. The record is maintained by the acts that change it rather than by a periodic sweep: installing a component, removing one, or updating a system updates the inventory as part of that work, and the estate is scanned for hardware, software and firmware that is present but not authorized, with the response to an unauthorized component - disable its network access, isolate it, remove it, notify a defined role - decided in advance. The inventory answers WHERE INFORMATION IS as well as what exists: for the categories of information the organization has defined as sensitive, it records where that information is processed and stored, which system components host it, and which users and roles can reach it, and it is updated when any of those change - with automated tools used to locate that information across components and to confirm the required protections are actually in place there, rather than relying on what a system was designed to hold. Each asset also carries its support status: the date vendor support ends is recorded, and a component that reaches end of support is replaced, or is covered by an alternative source of continued support that the organization has arranged and recorded, rather than left in service because it still runs. The inventory is kept current by discovery as well as by the acts that change it: an active discovery tool interrogates the network on a defined frequency, a passive tool identifies assets from the traffic they generate, the DHCP and address-management logs are read on a defined cadence so an address issued to something nobody registered surfaces, and automated software-inventory tooling documents what is installed across the estate rather than relying on a manual return. Support status decides authorization rather than merely being recorded: only software the vendor still supports is designated authorized in the inventory, and software that is unsupported and carries no documented exception setting out its mitigating controls and the residual risk somebody accepted is designated unauthorized, so the process that removes unauthorized software picks it up. What the register holds about those categories of information is itself a DATA INVENTORY: for each data type the organization has designated, the record carries the metadata that makes it usable - what the data is, who owns it, how it is classified, where it came from, what it is retained for and for how long - so the question of what data exists is answered from the register rather than from the systems one at a time. And the register tracks lifecycle STATE as well as existence: each system, device, piece of software, service and data set carries where it has reached in its life - requested, acquired, deployed, in service, superseded, withdrawn, disposed of - with the acts that move it between those states recorded against it, so an asset is managed from acquisition through operation to disposal rather than entered once and forgotten. | 3.4.1 | 12.5 |
| Change management Changes to systems and software are requested, reviewed, tested, approved, and tracked. Each request is explicitly approved OR DISAPPROVED by a role authorized to decide it, rather than proceeding because nobody objected, and the decision, the reason behind it and the change itself are written to a durable record - so the log shows what was refused as well as what shipped, and a change that went in without a decision is visible as one. A proposed change is analyzed for what it would do to security and privacy BEFORE it is approved, so the decision is taken with that answer in hand rather than reported afterwards; where the change is significant, the analysis is recorded and the roles who own the affected controls see it. Change control is a body rather than a queue: security and privacy representatives are members of the group that approves changes, so the question is asked in the room instead of by exception. A change is tested, validated and documented before it is finalized and moved into the running system, in an environment that resembles the one it is going to. After it lands, the controls it touched are verified to be implemented correctly, still operating as intended, and still producing the result the organization’s security and privacy requirements call for - verified, not assumed from the fact that the deployment succeeded. Who may make a change at all is restricted: the physical and logical access needed to alter a system is defined, documented, approved and enforced, and it is a narrower set than the people who may use the system. EXCEPTIONS are managed on the same terms as changes: a departure from a standard, a baseline or a policy is requested, assessed for the risk it creates, approved by a role authorized to accept that risk, recorded with a scope and an expiry, and tracked to closure or to a deliberate renewal - so an exception is a change somebody decided rather than a state nobody revisits. | 3.4.3, 3.4.4, 3.4.5 | 6.5 |
| Logging & monitoring Security-relevant events - including successful and failed log-in attempts - are logged, protected, retained, and reviewed for anomalies, and the discrepancies that review finds are reported to the people who act on them. The review runs on a defined cadence and covers the records of system activity as a set - the audit logs, the reports of who accessed what, and the record of security incidents - rather than the log stream alone. For those records to be correlated into one sequence of events, the systems producing them agree on the time: every in-scope system synchronizes its clock to a single approved reference source, the source and the tolerance the organization will accept are specified rather than left to defaults, and timestamps are recorded in an unambiguous form so a reader does not have to infer a time zone. Synchronization is monitored in its own right - a system that drifts beyond tolerance or loses its source raises an alert, because a clock that is wrong makes an investigation reach the wrong conclusion rather than no conclusion - and where equipment cannot be synchronized, its offset is known and recorded so its records can still be placed. Timestamps are generated from the system’s own clock, expressed in Coordinated Universal Time or a recorded offset from it, and cut to a granularity the organization has stated rather than to whatever the platform defaults to. All of this rests on a documented audit and accountability policy with supporting procedures, aligned with the laws and obligations that apply to the organization, issued to the roles it binds, owned by a named role, and reviewed on a defined cadence. WHAT A RECORD CONTAINS is specified rather than accepted: every audit record establishes what type of event occurred, when it occurred, where it occurred, the source it came from, the outcome - success or failure - and the identity of any individual, subject or object associated with it, plus whatever further fields the organization has decided it needs to reconstruct an event afterwards. Because every person holds an account of their own, the identity a record carries resolves to one named individual rather than to a shared or generic login, so an action can be traced to whoever actually took it and that person can be held accountable for it - which is the whole reason the identity field is mandatory rather than useful. WHICH EVENTS ARE LOGGED is decided and then kept under review rather than configured once: the set of event types selected for logging is agreed with the roles who investigate, is reviewed on a defined cadence and again after an incident that showed the set was wrong, and is updated as a result - so the log answers the questions being asked now instead of the ones somebody anticipated at build. Storage is sized for that: enough capacity is allocated to hold the volume produced for the retention period the organization has set, and records are retained for that period specifically so an investigation after the fact is possible and so regulatory and internal obligations are met, rather than for as long as the disk happens to last. When the logging process itself fails - the pipeline stops, the store fills, a source goes silent - a defined role is alerted within a defined time and the organization takes the response it decided on in advance, because a logging failure is the one failure the logs cannot tell you about. REVIEW AND ANALYSIS are supported by machinery rather than by reading. Automated mechanisms integrate the review, analysis and reporting of audit records into a single process, and records drawn from separate repositories are correlated so the organization sees one organization-wide picture of activity instead of several partial ones. A reduction and reporting capability supports on-demand review, analysis and reporting and the investigation of an incident, and it does so without altering the original records or their ordering; it lets an analyst filter, sort and search records by the criteria the organization has defined, so events of interest surface in time to matter. THE RECORDS THEMSELVES ARE PROTECTED as an asset. Audit information and the logging tools that produce it are protected from unauthorized access, modification and deletion, a defined role is alerted when evidence of tampering is detected, and the ability to manage the logging function - what is collected, what is retained, what is deleted - is restricted to a named subset of privileged users rather than being available to every administrator whose activity it records. MONITORING runs on top of the record. The organization monitors its systems to detect attack and indicators of potential attack, unauthorized local, network and remote connections, and use that is outside what it has authorized; it identifies that use against defined criteria for what unusual looks like. Inbound and outbound communications traffic is watched for those conditions specifically, because exfiltration and command traffic look ordinary unless somebody has said what ordinary is. Automated tools and mechanisms support analysis close to real time rather than at the next review, and when the system produces an indication of compromise or potential compromise a defined role is alerted. What monitoring finds is reported to the people who act on it, at the frequency the organization has set. WHICH SOURCES ARE COLLECTED is decided rather than left to whatever a platform emits by default. Access to information the organization has classified as sensitive is logged, including modification and disposal and not only reading. DNS queries, URL requests and command-line activity are collected where the asset supports it, because those three are what an investigation reconstructs an intrusion from, and network traffic flow records are collected from the network devices so that movement between systems can be reviewed and alerted on. Logs from the service providers the organization depends on are collected too, so authentication, user-management and data-lifecycle events that happen outside its own estate sit inside the same record. Collection and retention are centralized so far as the estate allows, into a platform that correlates sources rather than storing them side by side, and security event alerting is centralized on top of it so that a pattern spanning two sources raises one alert to one place. The alerting thresholds are tuned on a defined cadence rather than set once, because an alert stream nobody can read is the same as no alerting at all. Time synchronization uses more than one source: at least two reference sources are configured wherever an asset supports it, so losing one does not silently leave the estate drifting. WHAT IS WATCHED includes people as well as machines: the activity of personnel and their use of the organization’s technology are monitored against what has been authorized for them and against what the organization has told them is monitored, so misuse and a compromised account surface from the same record. Analysis goes past the alert to the activity behind it - what else the same account, host or address did before and after, and whether the separate events form one sequence - so a potentially adverse event is understood rather than merely counted. And each such event is scoped before it is handed on: the estimated impact and the reach of it - which systems, which data, which accounts, over what period - is established from the correlated record and carried into the incident assessment rather than left for the responder to rebuild. | 3.3.1, 3.3.2, 3.3.3, 3.3.4, 3.3.5, 3.3.6, 3.3.7, 3.3.8, 3.3.9, 3.14.6, 3.14.7 | 10.1, 10.2, 10.3, 10.4, 10.5, 10.6, 10.7 |
| Malware protection Anti-malware controls prevent, detect, and respond to malicious software on endpoints and servers, and detections are reported to the people who act on them. The mechanism is kept live rather than merely installed: signatures, definitions and detection engines update automatically as the vendor issues them rather than on someone remembering to apply them, what it detects and what it does about it is logged, and it runs where an ordinary user cannot switch it off, uninstall it or exclude their way around it - only a documented, authorized change may disable it, and then for a stated period. UNSOLICITED MESSAGES are handled by the same program rather than treated as a nuisance: spam protection is deployed at the system entry and exit points - the mail gateway, the web gateway, the remote access path and the mobile devices - to detect unsolicited messages and to act on them, and its mechanisms and signatures update automatically at a defined frequency and as new releases are issued, on the same terms as the anti-malware engine, because a spam filter running last quarter’s rules is where the phishing message that starts an incident gets through. The estate is managed from one place rather than device by device: policy, exclusions, engine versions and detections are administered centrally, so what is deployed and what it found are answerable without visiting a machine. Detection is not signature-only - behavior-based detection runs alongside the signature engine to catch what no definition describes yet - and it extends into host-based intrusion detection and prevention on enterprise assets: an agent that watches for and blocks malicious ACTIVITY on the host rather than only files it recognizes as malware. The operating system’s own anti-exploitation features are enabled wherever the platform provides them, because a protection already built into the system and left switched off is the cheapest gap in the estate. REMOVABLE MEDIA are handled as an entry route: automatic execution on insertion is disabled, and the media are scanned automatically when they are connected rather than at the holder’s discretion. The EMAIL PATH carries anti-malware in its own right - the mail server or gateway scans attachments and detonates what it cannot judge by inspection alone - and file types the organization has no business need to receive are blocked at that gateway before anybody has to make a decision about them. SCANNING RUNS ON TWO SCHEDULES rather than one, because they catch different things. The estate is scanned in full on a defined periodic cadence, so a file that was clean when it landed is re-examined against what is known today. And files arriving from outside the organization are scanned in real time as they are downloaded, opened or executed - at the moment of use rather than at the next sweep - so nothing waits for a scheduled scan to be caught. | 3.14.2, 3.14.4, 3.14.5 | 5.1, 5.2, 5.3 |
| Network security controls Firewalls/segmentation and network controls restrict traffic to and from sensitive environments. The networks themselves are managed as assets with owners: what exists is documented, traffic is permitted by rule rather than by default, the rules are reviewed and the ones nobody can justify are removed, and devices connecting are authenticated rather than trusted for being on the wire. NETWORK SERVICES are treated as a separate question from the network itself, and the same question is asked whether the service is run in-house or bought: for each one - connectivity and transit, remote access, name resolution, filtering, load balancing and delivery, wireless, voice and real-time communications - the organization identifies the security mechanisms it must apply, the service levels it must meet and the management requirements that come with it, and writes them into the agreement with the provider or into the internal service definition before anything depends on it. That includes what authentication, encryption and connection controls the service enforces, the availability and capacity it commits to, who may connect and how that is decided, what it monitors and reports and to whom, and the organization’s right to verify that what was agreed is what is delivered. Services are reviewed against those terms on a cadence, and a service that cannot demonstrate them is treated as a recorded risk rather than as a working arrangement. All of it rests on a documented system and communications protection policy with supporting procedures, issued to the roles it binds, owned by a named role and reviewed on a defined cadence. THE BOUNDARY is drawn narrowly and deliberately: the number of external connections into the organization’s systems is limited rather than allowed to accumulate, each external telecommunications service terminates on a managed interface that enforces the organization’s traffic flow policy, and any exception granted to that policy is documented with the need it serves, the systems it applies to and a duration, and is reviewed and removed when the need ends. Connections BETWEEN the organization’s own system components are governed on the same terms rather than trusted for being internal: each is individually authorized, its interface characteristics, security requirements and the nature of the information communicated are documented, the conditions under which it will be terminated are stated in advance, and its continued need is reviewed on a cadence. A network connection is torn down at the end of the session it serves, or after a defined period of inactivity, rather than left open until something else closes it. Components the public can reach - the website, the mail and web gateways, the API front end, anything published to the internet - sit on subnetworks physically or logically separated from the internal network, so reaching a public component does not place the caller inside the estate behind it. WHERE INFORMATION ITSELF MAY TRAVEL is controlled as well as the traffic that carries it: the flows permitted for each classification of information - between internal systems, out to an external party, from a more trusted zone into a less trusted one, and out of the organization altogether - are decided in advance and recorded as approved authorizations, and the enforcement points are configured to those authorizations rather than to a general instruction to be careful, so an unapproved flow is blocked by a rule somebody wrote instead of being permitted because nobody wrote one. VOICE AND REAL-TIME COMMUNICATIONS are governed as a service in their own right rather than as ordinary traffic: usage restrictions and implementation guidance are written for Voice over IP and the conferencing and messaging platforms beside it, a deployment is authorized before it carries a call, and its use is monitored and controlled - because a softphone, a conferencing bridge or a SIP trunk is a path for audio out of a room and a route into the network, not only a convenience. Availability is defended as well as confidentiality: the effects of denial-of-service events - the types the organization has decided it must withstand - are limited or absorbed by controls chosen for that purpose, with the capacity and the protective mechanisms sized against a stated expectation rather than against the traffic seen so far. NAME AND ADDRESS RESOLUTION is treated as security infrastructure. Where the organization is authoritative for a namespace, its responses carry data origin authentication and integrity verification artifacts so a resolver can validate them, and the security status of each child zone is published along with the material needed to verify the chain when a child zone is operated separately. Where the organization resolves names, its resolvers request and verify those artifacts on the responses they receive from authoritative sources rather than accepting an answer because it arrived. The resolution service itself is architected for fault tolerance and separates its internal and external roles, so an outage or a compromise on one side does not carry to the other. THE NETWORK ESTATE IS MAINTAINED as an asset in its own right. Devices run releases the vendor still supports, and their versions are reviewed on a defined cadence so end of support arrives as a planned replacement; their configuration is held as version-controlled infrastructure-as-code and their management interfaces are reached only over protocols that authenticate and encrypt the session; authentication, authorization and accounting for network access are centralized rather than held device by device; and the protocols used for management and for carrying traffic are chosen from those still considered sound rather than from those the equipment happens to default to. Architecture diagrams and the supporting network documentation are maintained and reviewed on a defined cadence rather than drawn once at build. Name resolution is pointed somewhere trusted: assets resolve through resolvers the organization controls or has decided are reputable, rather than through whatever a network hands them. DETECTION AND ENFORCEMENT sit in the path as well as beside it. Intrusion detection watches network traffic for malicious activity; intrusion prevention blocks it where the organization has decided blocking is appropriate; traffic is filtered at the application layer through a proxy, application-layer firewall or gateway where a port-and-address decision is not enough; and access is controlled at the port a device connects to, the device authenticating by 802.1X or an equivalent before it is on the network rather than being trusted for having reached a socket. The documentation is kept as an explicit REPRESENTATION of what is authorized: the network communication the organization permits, and the data flows inside its own estate and across its boundary to external parties, are drawn and maintained as a current picture rather than reconstructed from firewall rules when somebody asks for one. The networks and the network services running on them are monitored on the same terms, so a potentially adverse event - an unexpected flow, a service behaving unlike its baseline, traffic to somewhere nothing should be talking to - is found by watching rather than reported by its consequences. TRUSTED AND UNTRUSTED is a boundary with two directions rather than one: traffic entering the estate from any network the organization does not control is admitted only where a rule allows it, traffic leaving for such a network is restricted on the same terms rather than permitted for having originated inside, and a packet arriving from outside that claims an internal source address is discarded at the boundary rather than routed on the strength of what it says about itself. | 3.1.3, 3.13.1, 3.13.5, 3.13.6, 3.13.9, 3.13.14 | 1.1, 1.2, 1.3, 1.4, 11.5 |
| Secure configuration & baselines What a secure configuration IS is defined before anything is deployed, and drift away from it is detected rather than discovered. Baselines are written for each class of hardware, software, service and network component the organization runs, covering the settings that carry security consequence: vendor defaults changed, default and unused accounts removed or disabled, unnecessary services, ports, features and sample content removed, logging and time settings enabled, authentication and encryption settings set, and the administrative interfaces restricted. Baselines are derived from a stated hardening source and from the organization’s own requirements, are version-controlled, are approved before use, and are reviewed when the product changes, when a new threat makes a previous setting inadequate, or on a defined cadence. What is actually deployed is compared against the baseline automatically and on a schedule, and a difference raises an alert to somebody who either corrects it or records an approved exception with a reason, an owner and an expiry. Configuration is applied by an automated, repeatable mechanism wherever possible, so a rebuilt system comes back hardened rather than as somebody remembers it. A change to a baseline goes through the change process, and the record of what a system’s configuration was at a given time is retained - previous versions are kept deliberately and for a stated number of generations, so a system can be rolled back to a known-good configuration rather than rebuilt from memory. The settings themselves are set to the most restrictive mode consistent with what the system has to do, and any deviation from that is approved, documented with the operational requirement behind it, and monitored rather than left implicit. LEAST FUNCTIONALITY is the rule the baseline expresses: a system provides only the capabilities its purpose requires, and the functions, ports, protocols, software and services that purpose does not require are disabled, restricted or removed. That is not a one-time act at build - the estate is reviewed on a defined cadence to find functions, ports, protocols, software and services that have become unnecessary or are insecure by current understanding, and what the review finds is disabled or removed. Two artifacts sit alongside the baselines. A configuration management plan states the roles and responsibilities for the process, the process itself, the configuration items that are placed under configuration management and how they are identified, and it is protected against unauthorized disclosure and modification in its own right because it maps the estate. And the documentation for each product is obtained or written at acquisition rather than assumed to be findable later, in two parts. Administrator documentation covers secure configuration, installation and operation, the effective use and maintenance of the security and privacy functions, and the known vulnerabilities in how the administrative and privileged functions are configured and used. User documentation covers the security and privacy functions a user can reach and how to use them effectively, the ways of interacting with the system that keep it secure and protect individual privacy, and what the user is responsible for. Both are kept current, protected, and distributed to the administrators and users who need them. Where documentation is unavailable or does not exist, the attempts to obtain it are recorded and the organization takes a decided response - writing what it needs itself, or treating the gap as a risk. The process itself is a document and not only a set of files: how a baseline is written, approved, applied and reviewed is recorded and re-approved on a defined cadence and whenever a change to the organization would alter it - and network infrastructure carries its own such process rather than being covered by the one written for servers and end-user devices, because the devices, the settings and the people who change them are different. HOW assets are managed is part of the configuration: configuration is held as version-controlled infrastructure-as-code wherever the platform allows, and administrative interfaces are reached only over protocols that authenticate and encrypt the session - an insecure management protocol is not used unless it is operationally unavoidable, and then as a recorded exception. The hardening source is industry-recommended rather than invented here, and the templates reach the whole of an application’s infrastructure - the operating system under it, the database, the web server, the container image, and the platform and software services it is assembled from - so software written in-house cannot weaken the configuration it is deployed onto. The written process is issued as well as held: the hardening policy and the procedures under it go to the people who build, deploy and maintain the components they govern, so the standard is in use by the people it binds rather than merely current in a repository, and each part of it names the role answerable for carrying it out. | 3.4.2, 3.4.6, 3.4.7 | 2.1, 2.2 |
| Storage media lifecycle management Storage media are managed for their whole life rather than only at the point data is written to them, and the scope is both digital and non-digital: the disks, tapes, flash devices and optical media that hold the information, and equally the paper records, printed output, forms and microform that carry the same information in a form no system can wipe. Each is physically controlled and stored securely - held in a place with a stated protection level rather than left where it was last used, and known to be there - so the protection does not depend on the medium happening to be one an access control list can reach. Which types of media are permitted is decided rather than left to what people happen to own, and removable media are registered when issued so the organization knows what exists and who holds it. Taking media off site requires authorization and is recorded. Media carrying sensitive information are encrypted, so a lost item is a lost object rather than a disclosure, and are transported in packaging that resists physical damage and reveals tampering, with delivery confirmed. Media are stored in conditions the manufacturer specifies, and where information must remain readable for longer than the media are rated to last, it is transferred to fresh media before degradation makes that impossible - and where the technology needed to read it is being retired, the ability to read it is retained or the information migrated. More than one copy is held where the information could not be reconstructed from anywhere else. At end of life, media are securely erased to a standard that makes recovery infeasible, or physically destroyed where erasure is not dependable, and what was destroyed, when, by what method and on whose authority is recorded - including for media returned to a supplier or leased equipment being handed back. All of this is written as a documented media protection policy with supporting procedures, issued to the roles it binds, owned by a named role and reviewed and updated on a defined cadence. Access to media is restricted to the personnel and roles the organization has authorized for each type, rather than to whoever can reach the cupboard. Media awaiting sanitization or destruction remain physically controlled and stored in a protected area for that whole period, because the interval between "finished with" and "destroyed" is where media are most often lost. Media that no owner can be identified for are not used at all, and a portable storage device found without an identifiable owner is treated as untrusted rather than plugged in. Media the organization controls may be used on external systems only on terms the organization has set in advance and recorded, rather than at the holder’s discretion. Removable media are encrypted as a class rather than case by case: data written to a removable device is encrypted whether or not somebody has judged that particular item to carry sensitive information, because the judgment is made at the moment of writing and the device is what leaves the building. Each item is recorded against what it holds and how sensitive that is, so the handling it needs, the approval required to move it and the destruction it must eventually receive follow from a register somebody maintains rather than from whoever last touched the medium. | 3.1.21, 3.8.1, 3.8.2, 3.8.5, 3.8.6, 3.8.7, 3.8.8 | 9.4 |
| Vulnerability management Regular scanning, prioritization, and remediation of vulnerabilities across systems and applications, fed by current information about threats and weaknesses collected from outside the organization as well as from its own scans - vendor and industry security advisories for the software actually in use, and the threat feeds, bulletins and sector reporting that describe how systems like these are being attacked now - which is gathered continuously rather than at the next scan, evaluated for whether it applies here, and used to decide what is looked for and what is fixed first. The set of vulnerabilities the scanner actually looks for is updated on a defined cadence and whenever new ones are identified and reported, so a scan reflects what is known today rather than what the tool shipped with. Scans that need to see inside a system are given the privileged access to do so, granted deliberately to the scanning activity for the components that require it rather than left to run blind and report clean. Whether a fix is actually present is confirmed by automated mechanisms that report, per component, which security-relevant software and firmware updates are installed - so remediation is evidenced by the estate rather than by a closed ticket. The organization also runs a PUBLIC intake: a reporting channel that anybody outside the organization can find and use to report a vulnerability they have discovered in its systems or products, with a stated scope, a stated way to report, an acknowledgment, and a route into the same triage and remediation process everything else uses. All of this rests on a documented system and information integrity policy with supporting procedures, issued to the roles it binds, owned by a named role and reviewed on a defined cadence. The scanning and the fixing are each defined rather than assumed. Internal assets are scanned automatically on a defined cadence, both with credentials and without, because the two find different things - one shows what is installed, the other shows what somebody with no account can see. Externally exposed assets are scanned on their own cadence, which is at least as frequent, because they are reachable by everyone. Patching is automated for operating systems and, on the same terms and cadence, for the applications running on them, so an application left to be updated by whoever notices is not the gap. Remediation runs to a documented, risk-based strategy - what is fixed first, within what period, and who may approve an exception - reviewed on a defined cadence rather than written once. The public intake is governed by a written vulnerability handling policy that names how to report, who is responsible for handling a report, and the steps from intake through assignment and remediation to remediation testing, with reports tracked in a system that records a severity rating and the timing of identification, analysis and remediation, so how long the organization takes is a measured number rather than an impression. | 3.11.2, 3.11.3, 3.14.1 | 6.3, 11.1, 11.3 |
| Wireless network security Wireless access to the organization’s systems is a decided arrangement rather than an emergent one. Each TYPE of wireless access it permits - the corporate network, a guest network, a point-to-point link, a device-to-device pairing, a wireless management interface on a piece of equipment - carries written configuration requirements, connection requirements and implementation guidance, and is authorized as a type before any connection is allowed under it. Access is protected by authentication of the user or the device together with encryption, using mechanisms current enough to still be worth having, and the network is designed so that a client on it is not thereby inside anything it should not reach. What is broadcast is decided too: the identifiers, the coverage that spills beyond the premises, and whether a network needs to be discoverable at all. Rogue and unauthorized access points are looked for rather than reported by accident, and what happens when one is found is decided in advance. Wireless capability that the organization does not intend to use is disabled in system components before they are issued and deployed - the radio built into a server, a printer, a camera, an industrial controller or a laptop that will never need it is turned off at build rather than left enabled because nobody configured it. Guest and untrusted wireless is separated from everything else, and the arrangement is reviewed on a cadence and when the estate or the technology changes. VENDOR DEFAULTS on the wireless estate are replaced before the network carries anything: the default encryption keys and passphrases, the default administrative credentials on access points and controllers, the default network names, and the default management community strings are changed at commissioning, and changed again when somebody who knew them leaves. The search for what nobody authorized is scheduled rather than occasional: a current list of the access points the organization has authorized is maintained with the location and the owner of each, a sweep for wireless access points runs on a stated recurring cadence and after a change to the estate, and anything found that is not on the list is investigated and then removed or authorized as a recorded decision rather than left because it works. | 3.1.16, 3.1.17 | 2.3, 11.2 |
| Resilience & Continuity | ||
| Incident response A documented, tested plan to detect, triage, contain, remediate, and communicate security incidents, and to mitigate - so far as is practicable - the harmful effect of a use or disclosure of personal data the organization knows breached its own policies or the law. Each incident is recorded together with its outcome - what happened, what was done about it and how it ended - as a record of that incident, which is a different artifact from the plan being documented. The mitigation duty runs to violations by the organization itself AND to violations by the processors, vendors and other parties handling that data on its behalf: the plan reaches an incident somebody else caused with the organization’s data, so learning of one triggers the same containment and remediation as an incident inside its own walls rather than a request that the other party deal with it. Where an incident carries a duty to tell someone outside the organization, the plan discharges it on the clock the applicable law sets - and, where the organization has itself committed to a timeframe for telling people, on that commitment too, whether or not a statute stands behind it - rather than whenever the investigation happens to conclude: whether an incident is notifiable is decided against written criteria rather than argued after the fact, the regulator or supervisory authority is notified inside the deadline that regime states and inside any shorter or additional timeframe the organization has committed to, the people whose data is affected are told where the risk to them warrants it and, independently of that threshold, wherever the organization’s own privacy commitments say they will be told - so individual notification is never conditioned solely on a statutory risk test - and any other party that law or those commitments require to be notified is told on the same terms, and where a deadline is missed the notification itself explains the delay instead of passing over it. What a notification carries is fixed in advance rather than composed under pressure: to a regulator it describes at least the nature of what happened, including where possible the categories and the approximate number of people affected and of records involved; names a contact point - the data protection officer where there is one, otherwise whoever can answer - from whom more can be obtained; describes the likely consequences; and describes the measures taken or proposed to address it, including where appropriate the measures that will mitigate its adverse effects. Where all of that cannot honestly be given at once, it is given in phases without further undue delay rather than held back until the picture is complete, and each phase says what is still outstanding. The communication to the people affected describes what happened in clear and plain language and carries the same contact point, likely consequences and measures. Every compromise of personal data is documented whether or not it turned out to be notifiable - the facts of it, its effects, and the remedial action taken - in enough detail that a regulator reviewing the file can verify for itself that the notification decision was the right one. Recovery is part of the plan rather than something that follows it: service and data are restored to a state the organization has established is clean, the restoration is verified before the system is handed back to use, the cause is determined rather than inferred from the symptom, and the weakness the incident exposed is fixed - with the plan itself updated for what the incident showed about it. Between the report and the response sits an assessment step that is a duty of its own: every reported event is assessed against written categorization and prioritization criteria by people competent to apply them, and the decision - whether this event is an incident, and at what severity - is recorded with the reasoning, so two assessors reach the same answer and an event judged not to be an incident is a decision somebody made rather than a report that went quiet. Learning is treated as a duty separate from fixing the incident in front of you: the types, volumes and costs of incidents are quantified and reviewed as a set for what the pattern says, and what is learned is pushed back into the controls, the risk assessment, the awareness material and the assessment criteria themselves rather than staying in the report of the incident that produced it. The plan is a documented incident response policy with supporting procedures, issued to the roles it binds, owned by a named role, and reviewed and updated on a defined cadence. The people the plan assigns roles to are trained for them: within a defined period of taking the role, again when the system or the plan changes in a way that affects it, and on a defined cadence thereafter, with the content revised for what exercises and real incidents have shown. The capability is TESTED rather than assumed - on a defined cadence, using tests the organization has chosen for the purpose, such as a tabletop, a walkthrough, a simulation or a live exercise - and that testing is coordinated with the organizational elements that own the related plans, incident response and contingency planning in particular, so the two do not each assume the other. Handling and reporting are supported by automated mechanisms rather than run by hand at the worst moment: detection, triage, tracking, evidence collection and the routing of a report are automated so far as the organization’s systems allow, and the reports that must go outside are produced and sent by mechanism rather than composed under pressure. The roles the plan assigns are named across the functions an incident actually needs and not security alone - legal, IT, information security, facilities, communications, human resources, the responders and the analysts - and the assignment is reviewed on a defined cadence. So are the CHANNELS: a primary and a secondary mechanism for communicating and reporting during an incident are chosen in advance, on the understanding that the ordinary one may be the thing that is unavailable or compromised, and both are reviewed on the same cadence. The plan reaches the parties outside the organization that an incident actually involves: the suppliers and other third parties whose services, staff or systems would be part of the response are named in it, take part in the planning and the exercises, and are called on during response and recovery on terms agreed in advance rather than negotiated during the event. ESCALATION is a defined step and not a judgment call - the plan states the conditions under which an incident is escalated or elevated, whether by severity, by elapsed time, by the functions it has reached or by the obligations it triggers, who it goes to at each step, and what changes when it gets there. The analysis establishes what actually took place during the incident as well as why it happened, and the incident’s magnitude - how many systems, records and people it reached, and over what period - is estimated as the investigation proceeds and then VALIDATED against the evidence rather than left at the first number anybody said out loud. Notification runs to internal stakeholders as well as external ones, so the functions inside the organization that have to act on an incident are told on the same defined terms as the parties outside it. And containment is followed by ERADICATION as a separate act: the malicious code, the unauthorized access and the persistence left behind are removed and their removal is confirmed, so a contained incident is not mistaken for a finished one. | 3.6.1, 3.6.2, 3.6.3 | 12.10 |
| People & Culture | ||
| Personnel security (HR) Background screening, confidentiality agreements, and onboarding/offboarding security steps. Before a person is given access to sensitive data, and again whenever their role changes, a documented determination is made that the access their work calls for is appropriate to it - the screening informs that decision but is not the decision. What screening may ask is itself bounded: inquiries about a candidate’s health, disability or medical history are not made, and medical examinations are not required, before a conditional offer of the role has been made, and where such inquiries or examinations are made after an offer they are applied to everyone entering that role rather than to the individuals somebody chose to ask. Access is ended when their employment, or any other arrangement under which they worked for the organization, comes to an end, and whenever that determination says they should no longer hold it. The security responsibilities a person carries are stated in the terms under which they are engaged - in the employment contract or the equivalent agreement for a contractor or temporary worker - together with the organization’s own obligations to them, the duties that continue after the engagement ends and for how long, and what happens if the terms are broken; the terms are accepted before access is given. At the end of an engagement, and on a change of role that removes the need, every asset the person holds is returned and the return is recorded against the inventory rather than assumed - devices, media, tokens and keys, documents and any organization information held on equipment they own - and where information exists only on equipment the organization is not taking back, its transfer and deletion are performed and confirmed before the person leaves. The practice is governed by a documented personnel security policy with supporting procedures, issued to the roles it binds, owned by a named role and reviewed on a defined cadence. Security and privacy responsibilities are written into the POSITION DESCRIPTION for each role rather than only into the contract everybody signs, so what a particular job is accountable for is visible when it is advertised, filled, evaluated and re-scoped - and the descriptions are revised when the responsibilities change. | 3.9.1 | 12.7 |
| Remote and off-site working Working away from the organization’s premises - at home, at a customer site, while traveling, or anywhere else - is authorized rather than assumed, and the conditions attached to it are written down and communicated to the people it applies to. The rules address the place as well as the equipment: whether the physical surroundings allow sensitive information to be seen, overheard or picked up, what may be printed and how it is stored and destroyed, and who else in the household or building may come into contact with the device or the information. They address how the organization’s systems are reached, requiring an authenticated encrypted channel and treating any network the worker does not control as hostile. They address what the worker may use, whether personally owned equipment is permitted and on what conditions, and what happens to the organization’s information held on it when the arrangement ends. Support and incident reporting work the same way off site as on it, so a remote worker is not slower to report because the route is unclear. The authorization is revocable, is reviewed when the role or the risk changes, and covers what must be returned or removed when remote working stops. Each TYPE of remote access the organization permits - a virtual private network, a published application or desktop, a management console reached over the internet, a supplier’s support tunnel - carries its own written usage restrictions, configuration and connection requirements, and is authorized as a type before any individual connection is allowed under it. Remote access is monitored and controlled by automated mechanisms rather than by inspection after the fact, and every remote connection is routed through a limited and managed set of access control points the organization operates, rather than terminating wherever a service happens to expose itself. On the device side, split tunneling is prevented so a remote session cannot bridge the organization’s network to an uncontrolled one, unless the split is provisioned deliberately by a means the organization has approved. The places people are permitted to work from are named rather than left open: the alternate work sites the organization allows are documented, the security controls required at each are stated and their effectiveness is assessed rather than assumed, and a worker at one of them can reach security or incident staff at the moment they need to. The order is fixed rather than incidental: a user authenticates to the organization’s own managed VPN and authentication services BEFORE reaching any enterprise resource, so remote access is granted by infrastructure the organization runs rather than by each service deciding for itself. How much a remotely connecting asset may reach is decided on the state of that asset and not only on who is holding it - whether its anti-malware is current, whether its configuration still matches the organization’s secure configuration baseline, and whether its operating system and applications are up to date - and an asset that fails those checks gets reduced access or none rather than the access its user would ordinarily hold. A device that can reach an untrusted network and a sensitive environment in the same working day is treated as the bridge it could otherwise become: the configuration required of it is specified rather than left to its user, malware protection runs on it actively, its security settings cannot be altered by the person using it unless the change is documented and authorized by a named role for a stated period, and it is checked against those requirements before it is allowed to connect rather than after. | 3.1.12, 3.1.13, 3.1.14, 3.10.6, 3.13.7 | 1.5 |
| Security awareness training Ongoing security and data-handling awareness training for all personnel, with completion tracking, and periodic security updates - reminders, bulletins and alerts - issued to the workforce between training cycles. New joiners are trained within a defined period of starting, anyone whose work is affected is retrained within a defined period after a material change to the policies or procedures, and every completion is recorded. The program itself rests on a documented awareness and training policy with supporting procedures, issued to the people and roles it binds, owned by a named role, and reviewed and updated on a defined cadence rather than at whatever point somebody notices it is stale. The curriculum names two threats explicitly, because both are answered by a person rather than by a system. The first is INSIDER THREAT: what the potential indicators look like - unexplained access outside a role, bulk copying, hostility after a disciplinary or a passed-over promotion, working around a control rather than raising it - and where to report a concern about a colleague, without the reporter being asked to conclude anything. The second is SOCIAL ENGINEERING AND SOCIAL MINING: the phishing message, the pretext phone call, the urgent request from an apparent executive, the person following somebody through a door, and the slower pattern of harmless-seeming questions that assembles into an answer nobody would have given at once - together with the instruction to report both the attempts that worked and those that did not. The curriculum is stated as a set of topics rather than left to whoever assembles the material. AUTHENTICATION: how multi-factor authentication works and why it is required, what makes a passphrase strong, and how credentials are stored and never shared. DATA HANDLING: how to identify sensitive information and how to store, transfer, archive and destroy it, together with the clear screen and clear desk habits that go with it - locking a screen on standing up, clearing a whiteboard at the end of a meeting, and putting paper and portable media away rather than leaving them out. UNINTENTIONAL EXPOSURE: the ways data leaves by accident, such as a message sent to the wrong recipient, a portable device left behind, or a file published to a wider audience than intended. INCIDENTS: how to recognize that something may be an incident and how to report it without first establishing that it is. MISSING UPDATES: how to tell that an asset is not receiving its security updates, and to report a failure of an automated patching tool rather than assume somebody is watching it. INSECURE NETWORKS: the risk of connecting to and sending organizational data over networks the organization does not control, including what is expected of a home network where people work from one. And beyond the common curriculum, ROLE-SPECIFIC training is given where a role carries specific risk - system administration, secure development, and the roles most likely to be targeted directly. | 3.2.1, 3.2.2, 3.2.3 | 12.6 |
| Physical & Environmental | ||
| Physical security Physical access to facilities and equipment holding sensitive data is restricted and monitored, and a person’s access is validated against the role or function that justifies it rather than only logged; visitors are controlled as a case of their own, and so is access to software programs held for testing and revision. The facility and the equipment in it are safeguarded against tampering and theft as well as against unauthorized entry, and so is the SUPPORT INFRASTRUCTURE the systems depend on - the power feed and its distribution, the cabling and patching, the cooling and environmental plant, the fire detection and suppression, and the points at which communications enter the building - which is protected and monitored on the same terms rather than treated as building services somebody else owns, because a system is stopped as surely by reaching its power or its cooling as by reaching its data. The people who have to reach the site and the equipment when a continuity or recovery plan is invoked can still get in, by a route that is planned rather than improvised; and repairs and modifications to the physical security components of a facility - doors, locks, walls, and the hardware that controls entry - are recorded. The offices, rooms and facilities themselves are designed and fitted for that job rather than simply occupied: rooms holding sensitive information or the equipment that processes it are sited away from public access and from routes people pass through for other reasons, the building’s signage, directories and public information do not advertise where sensitive processing happens, doors, windows, walls and any shared boundary with another tenant are specified against the risk the room actually carries, and a room is locked and checked when it is unoccupied rather than left secured by whoever was last out. Monitoring is continuous rather than periodic: the premises are watched for unauthorized physical access by detection suited to the site - intruder alarms, cameras, contact and motion detection, staffed reception or patrols - covering every way in including delivery and fire doors and including the hours nobody is there, with an alarm going to somebody who responds and a stated response. The monitoring system is protected in its own right, so its configuration, its coverage and its recordings cannot be altered or read by the people it is watching, and recordings are retained and handled under the privacy rules that apply to them. The detection is specified rather than generic: intrusion alarms and surveillance equipment are employed as the means of monitoring physical access, and what they cover, what raises an alarm and who responds is decided in advance. Visitors are escorted for the whole time they are inside a controlled area and their activity while there is monitored, rather than being signed in at a desk and then left to move around; that applies to contractors, delivery and service personnel and auditors alike, and where somebody is authorized to work unaccompanied that is a recorded decision rather than a courtesy. Visitors leave a record: who came, who they were visiting, when they arrived and left, and the identification presented; the record is retained for a defined period, reviewed on a defined cadence rather than only after an incident, and anomalies in it are reported to a designated role. Deliveries and removals are controlled as a class - system components and equipment entering or leaving the facility are authorized before they move, the movement is monitored, and a record of what came in and what went out is kept - and the delivery area itself is arranged so that a delivery does not become unescorted access to the interior. PHYSICAL ACCESS IS LOGGED and not only permitted: entry to the facility and to each controlled area inside it is recorded - who entered, which area, and when - by the entry system, the staffed reception, the visitor register or a combination of them, and the log is retained for a defined period and reviewed on a defined cadence, so a person can be placed in a room at a time and matched against what the systems in it recorded. PHYSICAL ACCESS DEVICES are managed as a controlled inventory rather than handed out: the keys, locks, combinations, badges, cards, fobs and biometric enrollments that open a door are listed with the holder of each, issue and return are recorded against that person, the inventory is reconciled on a defined cadence, and combinations are changed and locks re-keyed when a device is lost or stolen, when a holder leaves or moves, and on the cadence the organization has set rather than only after an incident. All of this rests on a documented physical and environmental protection policy with supporting procedures, issued to the roles it binds, owned by a named role and reviewed on a defined cadence. | 3.10.1, 3.10.2, 3.10.3, 3.10.4, 3.10.5 | 9.1, 9.2, 9.3 |
Beyond the pair
Where else this work counts
A framework is lit when a shared control above also maps to it. Unlit means none of them do — an absence, not a judgment about that standard.
Also reached by these 25 controls
- AI Governance Essentials not reached
- Amazon Appstore Child-Directed Apps not reached
- Apple App Store Kids Category not reached
- CIS Critical Security Controls also reached
- COPPA also reached
- ESG Essentials also reached
- EU AI Act not reached
- GDPR also reached
- Google Play Families not reached
- HIPAA also reached
- ISO 9001 not reached
- ISO/IEC 27001 also reached
- ISO/IEC 42001 not reached
- NIST AI Risk Management Framework not reached
- NIST Cybersecurity Framework also reached
- NIST SP 800-53 also reached
- PIPEDA also reached
- SOC 2 also reached
- SOX (Sarbanes-Oxley) Section 404 also reached
- US Employment Law - Federal Baseline also reached
Nearby pairs
- NIST SP 800-171 and NIST SP 800-53 41 shared controls
- NIST SP 800-171 and ISO/IEC 27001 35 shared controls
- PCI DSS and NIST SP 800-53 29 shared controls
- PCI DSS and ISO/IEC 27001 27 shared controls
- NIST SP 800-171 and CIS Critical Security Controls 25 shared controls
- PCI DSS and CIS Critical Security Controls 22 shared controls
The thesis
Why this is one project, not two
On a crosswalk-native model, PCI DSS mostly lights up controls you already built for NIST SP 800-171. You’re not re-uploading the same screenshot for a second audit. You apply the framework and see the genuine delta worth working. That’s the whole idea behind collect once, comply everywhere.
Next step
Add PCI DSS to the work you already did
Apply both frameworks in one workspace and see the overlap measured against the controls you already hold.