CIS Excel Compliance Overview
CIS Excel Compliance Overview
                                                                                      Actively manage (inventory, track, and correct) all enterprise assets (end-user devices, including
                                                                                      portable and mobile; network devices; non-computing/Internet of Things (IoT) devices; and servers)
                                                 Inventory and Control of
  1                                                                                   connected to the infrastructure physically, virtually, remotely, and those within cloud environments, to
                                                 Enterprise Assets
                                                                                      accurately know the totality of assets that need to be monitored and protected within the enterprise. This
                                                                                      will also support identifying unauthorized and unmanaged assets to remove or remediate.
                                                                                      Establish and maintain an accurate, detailed, and up-to-date inventory of all enterprise assets with the potential to
                                                                                      store or process data, to include: end-user devices (including portable and mobile), network devices, non-
                                                                                      computing/IoT devices, and servers. Ensure the inventory records the network address (if static), hardware
                                                                                      address, machine name, enterprise asset owner, department for each asset, and whether the asset has been
                                                 Establish and Maintain Detailed
  1          1,1      Devices         Identify                                        approved to connect to the network. For mobile end-user devices, MDM type tools can support this process,                    x     x     x
                                                 Enterprise Asset Inventory
                                                                                      where appropriate. This inventory includes assets connected to the infrastructure physically, virtually, remotely,
                                                                                      and those within cloud environments. Additionally, it includes assets that are regularly connected to the
                                                                                      enterprise’s network infrastructure, even if they are not under control of the enterprise. Review and update the
                                                                                      inventory of all enterprise assets bi-annually, or more frequently.
                                                                                      Ensure that a process exists to address unauthorized assets on a weekly basis. The enterprise may choose to
  1          1,2      Devices         Respond    Address Unauthorized Assets          remove the asset from the network, deny the asset from connecting remotely to the network, or quarantine the                 x     x     x
                                                                                      asset.
                                                                                      Utilize an active discovery tool to identify assets connected to the enterprise’s network. Configure the active
  1          1,3      Devices          Detect    Utilize an Active Discovery Tool                                                                                                                                        x     x
                                                                                      discovery tool to execute daily, or more frequently.
                                                 Use Dynamic Host Configuration    Use DHCP logging on all DHCP servers or Internet Protocol (IP) address management tools to update the
   1         1,4      Devices         Identify   Protocol (DHCP) Logging to Update enterprise’s asset inventory. Review and use logs to update the enterprise’s asset inventory weekly, or more                          x     x
                                                 Enterprise Asset Inventory        frequently.
                                                                                      Use a passive discovery tool to identify assets connected to the enterprise’s network. Review and use scans to
   1         1,5      Devices          Detect    Use a Passive Asset Discovery Tool                                                                                                                                            x
                                                                                      update the enterprise’s asset inventory at least weekly, or more frequently.
                                                                                   Actively manage (inventory, track, and correct) all software (operating systems and applications) on the
                                                 Inventory and Control of Software
  2                                                                                network so that only authorized software is installed and can execute, and that unauthorized and
                                                 Assets
                                                                                   unmanaged software is found and prevented from installation or execution.
                                                                                      Establish and maintain a detailed inventory of all licensed software installed on enterprise assets. The software
                                                 Establish and Maintain a Software    inventory must document the title, publisher, initial install/use date, and business purpose for each entry; where
  2          2,1      Applications    Identify                                                                                                                                                                     x     x     x
                                                 Inventory                            appropriate, include the Uniform Resource Locator (URL), app store(s), version(s), deployment mechanism, and
                                                                                      decommission date. Review and update the software inventory bi-annually, or more frequently.
                                                                                      Ensure that only currently supported software is designated as authorized in the software inventory for enterprise
                                                                                      assets. If software is unsupported, yet necessary for the fulfillment of the enterprise’s mission, document an
                                                 Ensure Authorized Software is
  2          2,2      Applications    Identify                                        exception detailing mitigating controls and residual risk acceptance. For any unsupported software without an                x     x     x
                                                 Currently Supported
                                                                                      exception documentation, designate as unauthorized. Review the software list to verify software support at least
                                                                                      monthly, or more frequently.
                                                                                      Ensure that unauthorized software is either removed from use on enterprise assets or receives a documented
  2          2,3      Applications    Respond    Address Unauthorized Software                                                                                                                                     x     x     x
                                                                                      exception. Review monthly, or more frequently.
                                                 Utilize Automated Software           Utilize software inventory tools, when possible, throughout the enterprise to automate the discovery and
   2         2,4      Applications     Detect                                                                                                                                                                            x     x
                                                 Inventory Tools                      documentation of installed software.
                                                                                      Use technical controls, such as application allowlisting, to ensure that only authorized software can execute or be
  2          2,5      Applications    Protect    Allowlist Authorized Software                                                                                                                                           x     x
                                                                                      accessed. Reassess bi-annually, or more frequently.
                                                                                       Use technical controls to ensure that only authorized software libraries, such as specific .dll, .ocx, .so, etc., files,
  2          2,6      Applications    Protect    Allowlist Authorized Libraries       are allowed to load into a system process. Block unauthorized libraries from loading into a system process.                        x     x
                                                                                      Reassess bi-annually, or more frequently.
                                                                                      Use technical controls, such as digital signatures and version control, to ensure that only authorized scripts, such
   2         2,7      Applications    Protect    Allowlist Authorized Scripts         as specific .ps1, .py, etc., files, are allowed to execute. Block unauthorized scripts from executing. Reassess bi-                      x
                                                                                      annually, or more frequently.
                                                                                      Develop processes and technical controls to identify, classify, securely handle, retain, and dispose of
   3                                             Data Protection
                                                                                      data.
                                                                                      Establish and maintain a data management process. In the process, address data sensitivity, data owner, handling
                                                 Establish and Maintain a Data        of data, data retention limits, and disposal requirements, based on sensitivity and retention standards for the
  3          3,1      Data            Identify                                                                                                                                                                     x     x     x
                                                 Management Process                   enterprise. Review and update documentation annually, or when significant enterprise changes occur that could
                                                                                      impact this Safeguard.
                                                 Establish and Maintain a Data        Establish and maintain a data inventory, based on the enterprise’s data management process. Inventory sensitive
  3          3,2      Data            Identify                                                                                                                                                                     x     x     x
                                                 Inventory                            data, at a minimum. Review and update inventory annually, at a minimum, with a priority on sensitive data.
                                                                                     Configure data access control lists based on a user’s need to know. Apply data access control lists, also known as
  3          3,3      Data            Protect    Configure Data Access Control Lists                                                                                                                               x     x     x
                                                                                     access permissions, to local and remote file systems, databases, and applications.
                                                                                     Retain data according to the enterprise’s data management process. Data retention must include both minimum
  3          3,4      Data            Protect    Enforce Data Retention                                                                                                                                            x     x     x
                                                                                     and maximum timelines.
                                                                                     Securely dispose of data as outlined in the enterprise’s data management process. Ensure the disposal process
  3          3,5      Data            Protect    Securely Dispose of Data                                                                                                                                          x     x     x
                                                                                     and method are commensurate with the data sensitivity.
                                                                                     Encrypt data on end-user devices containing sensitive data. Example implementations can include: Windows
  3          3,6      Devices         Protect    Encrypt Data on End-User Devices             ®                 ®        ®                                                                                         x     x     x
                                                                                     BitLocker , Apple FileVault , Linux dm-crypt.
                                                                                      Establish and maintain an overall data classification scheme for the enterprise. Enterprises may use labels, such
                                                 Establish and Maintain a Data
  3          3,7      Data            Identify                                        as “Sensitive,” “Confidential,” and “Public,” and classify their data according to those labels. Review and update                 x     x
                                                 Classification Scheme
                                                                                      the classification scheme annually, or when significant enterprise changes occur that could impact this Safeguard.
                                                                                      Document data flows. Data flow documentation includes service provider data flows and should be based on the
   3         3,8      Data            Identify   Document Data Flows                  enterprise’s data management process. Review and update documentation annually, or when significant                                x     x
                                                                                      enterprise changes occur that could impact this Safeguard.
  3          3,9      Data            Protect    Encrypt Data on Removable Media      Encrypt data on removable media.                                                                                                   x     x
                                                                                      Encrypt sensitive data in transit. Example implementations can include: Transport Layer Security (TLS) and Open
  3         3,10      Data            Protect    Encrypt Sensitive Data in Transit                                                                                                                                       x     x
                                                                                      Secure Shell (OpenSSH).
                                                                                      Encrypt sensitive data at rest on servers, applications, and databases containing sensitive data. Storage-layer
  3         3,11      Data            Protect    Encrypt Sensitive Data at Rest       encryption, also known as server-side encryption, meets the minimum requirement of this Safeguard. Additional                      x     x
                                                                                      encryption methods may include application-layer encryption, also known as client-side encryption, where access
                                                                                      to the data storage device(s) does not permit access to the plain-text data.
                                                 Segment Data Processing and          Segment data processing and storage based on the sensitivity of the data. Do not process sensitive data on
   3        3,12      Network         Protect                                                                                                                                                                            x     x
                                                 Storage Based on Sensitivity         enterprise assets intended for lower sensitivity data.
                                                                                      Implement an automated tool, such as a host-based Data Loss Prevention (DLP) tool to identify all sensitive data
                                                 Deploy a Data Loss Prevention
  3         3,13      Data            Protect                                         stored, processed, or transmitted through enterprise assets, including those located onsite or at a remote service                       x
                                                 Solution
                                                                                      provider, and update the enterprise's sensitive data inventory.
   3        3,14      Data             Detect    Log Sensitive Data Access            Log sensitive data access, including modification and disposal.                                                                          x
                                                                                      Establish and maintain the secure configuration of enterprise assets (end-user devices, including
                                                 Secure Configuration of
  4                                                                                   portable and mobile; network devices; non-computing/IoT devices; and servers) and software (operating
                                                 Enterprise Assets and Software
                                                                                      systems and applications).
                                                                                      Establish and maintain a secure configuration process for enterprise assets (end-user devices, including portable
                                                 Establish and Maintain a Secure      and mobile, non-computing/IoT devices, and servers) and software (operating systems and applications). Review
  4          4,1      Applications    Protect                                                                                                                                                                      x     x     x
                                                 Configuration Process                and update documentation annually, or when significant enterprise changes occur that could impact this
                                                                                      Safeguard.
                                                 Establish and Maintain a Secure
                                                                                      Establish and maintain a secure configuration process for network devices. Review and update documentation
  4          4,2      Network         Protect    Configuration Process for Network                                                                                                                                 x     x     x
                                                                                      annually, or when significant enterprise changes occur that could impact this Safeguard.
                                                 Infrastructure
                                                                                      Configure automatic session locking on enterprise assets after a defined period of inactivity. For general purpose
                                                 Configure Automatic Session
  4          4,3      Users           Protect                                         operating systems, the period must not exceed 15 minutes. For mobile end-user devices, the period must not                   x     x     x
                                                 Locking on Enterprise Assets
                                                                                      exceed 2 minutes.
                                                 Implement and Manage a Firewall      Implement and manage a firewall on servers, where supported. Example implementations include a virtual
  4          4,4      Devices         Protect                                                                                                                                                                      x     x     x
                                                 on Servers                           firewall, operating system firewall, or a third-party firewall agent.
                                                 Implement and Manage a Firewall      Implement and manage a host-based firewall or port-filtering tool on end-user devices, with a default-deny rule
  4          4,5      Devices         Protect                                                                                                                                                                      x     x     x
                                                 on End-User Devices                  that drops all traffic except those services and ports that are explicitly allowed.
                                                                                   Securely manage enterprise assets and software. Example implementations include managing configuration
                                                 Securely Manage Enterprise Assets
  4          4,6      Network         Protect                                      through version-controlled-infrastructure-as-code and accessing administrative interfaces over secure network                   x     x     x
                                                 and Software
                                                                                   protocols, such as Secure Shell (SSH) and Hypertext Transfer Protocol Secure (HTTPS). Do not use insecure
                                                                                   management protocols, such as Telnet (Teletype Network) and HTTP, unless operationally essential.
                                     Manage Default Accounts on             Manage default accounts on enterprise assets and software, such as root, administrator, and other pre-configured
4   4,7    Users          Protect                                                                                                                                                                  x   x   x
                                     Enterprise Assets and Software         vendor accounts. Example implementations can include: disabling default accounts or making them unusable.
                                     Uninstall or Disable Unnecessary
                                                                            Uninstall or disable unnecessary services on enterprise assets and software, such as an unused file sharing
4   4,8    Devices        Protect    Services on Enterprise Assets and                                                                                                                                 x   x
                                                                            service, web application module, or service function.
                                     Software
                                     Configure Trusted DNS Servers on       Configure trusted DNS servers on enterprise assets. Example implementations include: configuring assets to use
4   4,9    Devices        Protect                                                                                                                                                                      x   x
                                     Enterprise Assets                      enterprise-controlled DNS servers and/or reputable externally accessible DNS servers.
                                                                            Enforce automatic device lockout following a predetermined threshold of local failed authentication attempts on
                                     Enforce Automatic Device Lockout       portable end-user devices, where supported. For laptops, do not allow more than 20 failed authentication
4   4,10   Devices        Respond                                                                                                                                                                      x   x
                                     on Portable End-User Devices           attempts; for tablets and smartphones, no more than 10 failed authentication attempts. Example implementations
                                                                            include Microsoft® InTune Device Lock and Apple® Configuration Profile maxFailedAttempts.
                                     Enforce Remote Wipe Capability on Remotely wipe enterprise data from enterprise-owned portable end-user devices when deemed appropriate such
4   4,11   Devices        Protect                                                                                                                                                                      x   x
                                     Portable End-User Devices         as lost or stolen devices, or when an individual no longer supports the enterprise.
                                                                       Ensure separate enterprise workspaces are used on mobile end-user devices, where supported. Example
                                     Separate Enterprise Workspaces on
4   4,12   Devices        Protect                                      implementations include using an Apple® Configuration Profile or Android™ Work Profile to separate enterprise                       x
                                     Mobile End-User Devices
                                                                       applications and data from personal applications and data.
                                                                            Use processes and tools to assign and manage authorization to credentials for user accounts, including
5                                    Account Management
                                                                            administrator accounts, as well as service accounts, to enterprise assets and software.
                                                                            Establish and maintain an inventory of all accounts managed in the enterprise. The inventory must include both
                                     Establish and Maintain an Inventory    user and administrator accounts. The inventory, at a minimum, should contain the person’s name, username,
5   5,1    Users          Identify                                                                                                                                                                 x   x   x
                                     of Accounts                            start/stop dates, and department. Validate that all active accounts are authorized, on a recurring schedule at a
                                                                            minimum quarterly, or more frequently.
                                                                            Use unique passwords for all enterprise assets. Best practice implementation includes, at a minimum, an 8-
5   5,2    Users          Protect    Use Unique Passwords                                                                                                                                          x   x   x
                                                                            character password for accounts using MFA and a 14-character password for accounts not using MFA.
5   5,3    Users          Respond    Disable Dormant Accounts               Delete or disable any dormant accounts after a period of 45 days of inactivity, where supported.                       x   x   x
                                                                            Restrict administrator privileges to dedicated administrator accounts on enterprise assets. Conduct general
                                     Restrict Administrator Privileges to
5   5,4    Users          Protect                                           computing activities, such as internet browsing, email, and productivity suite use, from the user’s primary, non-      x   x   x
                                     Dedicated Administrator Accounts
                                                                            privileged account.
                                                                            Establish and maintain an inventory of service accounts. The inventory, at a minimum, must contain department
                                     Establish and Maintain an Inventory
5   5,5    Users          Identify                                          owner, review date, and purpose. Perform service account reviews to validate that all active accounts are                  x   x
                                     of Service Accounts
                                                                            authorized, on a recurring schedule at a minimum quarterly, or more frequently.
5   5,6    Users          Protect    Centralize Account Management          Centralize account management through a directory or identity service.                                                     x   x
                                                                            Use processes and tools to create, assign, manage, and revoke access credentials and privileges for
6                                    Access Control Management
                                                                            user, administrator, and service accounts for enterprise assets and software.
                                     Establish an Access Granting           Establish and follow a process, preferably automated, for granting access to enterprise assets upon new hire,
6   6,1    Users          Protect                                                                                                                                                                  x   x   x
                                     Process                                rights grant, or role change of a user.
                                                                            Establish and follow a process, preferably automated, for revoking access to enterprise assets, through disabling
                                     Establish an Access Revoking
6   6,2    Users          Protect                                           accounts immediately upon termination, rights revocation, or role change of a user. Disabling accounts, instead of     x   x   x
                                     Process
                                                                            deleting accounts, may be necessary to preserve audit trails.
                                     Require MFA for Externally-Exposed Require all externally-exposed enterprise or third-party applications to enforce MFA, where supported. Enforcing
6   6,3    Users          Protect                                                                                                                                                                  x   x   x
                                     Applications                       MFA through a directory service or SSO provider is a satisfactory implementation of this Safeguard.
                                     Require MFA for Remote Network
6   6,4    Users          Protect                                           Require MFA for remote network access.                                                                                 x   x   x
                                     Access
                                     Require MFA for Administrative         Require MFA for all administrative access accounts, where supported, on all enterprise assets, whether managed
6   6,5    Users          Protect                                                                                                                                                                  x   x   x
                                     Access                                 on-site or through a third-party provider.
                                     Establish and Maintain an Inventory    Establish and maintain an inventory of the enterprise’s authentication and authorization systems, including those
6   6,6    Users          Identify   of Authentication and Authorization    hosted on-site or at a remote service provider. Review and update the inventory, at a minimum, annually, or more           x   x
                                     Systems                                frequently.
6   6,7    Users          Protect    Centralize Access Control              Centralize access control for all enterprise assets through a directory service or SSO provider, where supported.          x   x
                                                                            Define and maintain role-based access control, through determining and documenting the access rights necessary
                                     Define and Maintain Role-Based         for each role within the enterprise to successfully carry out its assigned duties. Perform access control reviews of
6   6,8    Data           Protect                                                                                                                                                                          x
                                     Access Control                         enterprise assets to validate that all privileges are authorized, on a recurring schedule at a minimum annually, or
                                                                            more frequently.
                                                                            Develop a plan to continuously assess and track vulnerabilities on all enterprise assets within the
                                     Continuous Vulnerability
7                                                                           enterprise’s infrastructure, in order to remediate, and minimize, the window of opportunity for attackers.
                                     Management
                                                                            Monitor public and private industry sources for new threat and vulnerability information.
                                     Establish and Maintain a               Establish and maintain a documented vulnerability management process for enterprise assets. Review and update
7   7,1    Applications   Protect                                                                                                                                                                  x   x   x
                                     Vulnerability Management Process       documentation annually, or when significant enterprise changes occur that could impact this Safeguard.
                                     Establish and Maintain a               Establish and maintain a risk-based remediation strategy documented in a remediation process, with monthly, or
7   7,2    Applications   Respond                                                                                                                                                                  x   x   x
                                     Remediation Process                    more frequent, reviews.
                                     Perform Automated Operating            Perform operating system updates on enterprise assets through automated patch management on a monthly, or
7   7,3    Applications   Protect                                                                                                                                                                  x   x   x
                                     System Patch Management                more frequent, basis.
                                     Perform Automated Application          Perform application updates on enterprise assets through automated patch management on a monthly, or more
7   7,4    Applications   Protect                                                                                                                                                                  x   x   x
                                     Patch Management                       frequent, basis.
                                     Perform Automated Vulnerability        Perform automated vulnerability scans of internal enterprise assets on a quarterly, or more frequent, basis.
7   7,5    Applications   Identify                                                                                                                                                                     x   x
                                     Scans of Internal Enterprise Assets    Conduct both authenticated and unauthenticated scans, using a SCAP-compliant vulnerability scanning tool.
                                     Perform Automated Vulnerability
                                                                            Perform automated vulnerability scans of externally-exposed enterprise assets using a SCAP-compliant
7   7,6    Applications   Identify   Scans of Externally-Exposed                                                                                                                                       x   x
                                                                            vulnerability scanning tool. Perform scans on a monthly, or more frequent, basis.
                                     Enterprise Assets
                                                                            Remediate detected vulnerabilities in software through processes and tooling on a monthly, or more frequent,
7   7,7    Applications   Respond    Remediate Detected Vulnerabilities                                                                                                                                x   x
                                                                            basis, based on the remediation process.
                                                                            Collect, alert, review, and retain audit logs of events that could help detect, understand, or recover from
8                                    Audit Log Management
                                                                            an attack.
                                                                         Establish and maintain an audit log management process that defines the enterprise’s logging requirements. At a
                                     Establish and Maintain an Audit Log
8   8,1    Network        Protect                                        minimum, address the collection, review, and retention of audit logs for enterprise assets. Review and update             x   x   x
                                     Management Process
                                                                         documentation annually, or when significant enterprise changes occur that could impact this Safeguard.
                                                                            Collect audit logs. Ensure that logging, per the enterprise’s audit log management process, has been enabled
8   8,2    Network        Detect     Collect Audit Logs                                                                                                                                            x   x   x
                                                                            across enterprise assets.
                                                                            Ensure that logging destinations maintain adequate storage to comply with the enterprise’s audit log management
8   8,3    Network        Protect    Ensure Adequate Audit Log Storage                                                                                                                             x   x   x
                                                                            process.
                                                                            Standardize time synchronization. Configure at least two synchronized time sources across enterprise assets,
8   8,4    Network        Protect    Standardize Time Synchronization                                                                                                                                  x   x
                                                                            where supported.
                                                                            Configure detailed audit logging for enterprise assets containing sensitive data. Include event source, date,
8   8,5    Network        Detect     Collect Detailed Audit Logs            username, timestamp, source addresses, destination addresses, and other useful elements that could assist in a             x   x
                                                                            forensic investigation.
8   8,6    Network        Detect     Collect DNS Query Audit Logs           Collect DNS query audit logs on enterprise assets, where appropriate and supported.                                        x   x
8   8,7    Network        Detect     Collect URL Request Audit Logs         Collect URL request audit logs on enterprise assets, where appropriate and supported.                                      x   x
                                                                                                                                                                                       ®
                                                                            Collect command-line audit logs. Example implementations include collecting audit logs from PowerShell ,
8   8,8    Devices        Detect     Collect Command-Line Audit Logs              ™
                                                                                                                                                                                                       x   x
                                                                            BASH , and remote administrative terminals.
8    8,9   Network        Detect     Centralize Audit Logs                  Centralize, to the extent possible, audit log collection and retention across enterprise assets.                           x   x
8   8,10   Network        Protect    Retain Audit Logs                      Retain audit logs across enterprise assets for a minimum of 90 days.                                                       x   x
                                                                            Conduct reviews of audit logs to detect anomalies or abnormal events that could indicate a potential threat.
8   8,11   Network        Detect     Conduct Audit Log Reviews                                                                                                                                         x   x
                                                                            Conduct reviews on a weekly, or more frequent, basis.
                                                                            Collect service provider logs, where supported. Example implementations include collecting authentication and
8   8,12   Data           Detect     Collect Service Provider Logs                                                                                                                                         x
                                                                            authorization events, data creation and disposal events, and user management events.
                                     Email and Web Browser                  Improve protections and detections of threats from email and web vectors, as these are opportunities for
9
                                     Protections                            attackers to manipulate human behavior through direct engagement.
                                     Ensure Use of Only Fully Supported Ensure only fully supported browsers and email clients are allowed to execute in the enterprise, only using the
9   9,1    Applications   Protect                                                                                                                                                                  x   x   x
                                     Browsers and Email Clients         latest version of browsers and email clients provided through the vendor.
9   9,2    Network        Protect    Use DNS Filtering Services             Use DNS filtering services on all enterprise assets to block access to known malicious domains.                        x   x   x
                                                                            Enforce and update network-based URL filters to limit an enterprise asset from connecting to potentially malicious
                                     Maintain and Enforce Network-
9   9,3    Network        Protect                                           or unapproved websites. Example implementations include category-based filtering, reputation-based filtering, or           x   x
                                     Based URL Filters
                                                                            through the use of block lists. Enforce filters for all enterprise assets.
                                       Restrict Unnecessary or
                                                                             Restrict, either through uninstalling or disabling, any unauthorized or unnecessary browser or email client plugins,
9     9,4    Applications   Protect    Unauthorized Browser and Email                                                                                                                                     x   x
                                                                             extensions, and add-on applications.
                                       Client Extensions
                                                                             To lower the chance of spoofed or modified emails from valid domains, implement DMARC policy and verification,
9     9,5    Network        Protect    Implement DMARC                       starting with implementing the Sender Policy Framework (SPF) and the DomainKeys Identified Mail (DKIM)                       x   x
                                                                             standards.
9     9,6    Network        Protect    Block Unnecessary File Types          Block unnecessary file types attempting to enter the enterprise’s email gateway.                                             x   x
                                       Deploy and Maintain Email Server
9     9,7    Network        Protect                                          Deploy and maintain email server anti-malware protections, such as attachment scanning and/or sandboxing.                        x
                                       Anti-Malware Protections
                                                                             Prevent or control the installation, spread, and execution of malicious applications, code, or scripts on
10                                     Malware Defenses
                                                                             enterprise assets.
                                       Deploy and Maintain Anti-Malware
10   10,1    Devices        Protect                                          Deploy and maintain anti-malware software on all enterprise assets.                                                      x   x   x
                                       Software
                                       Configure Automatic Anti-Malware
10   10,2    Devices        Protect                                          Configure automatic updates for anti-malware signature files on all enterprise assets.                                   x   x   x
                                       Signature Updates
                                       Disable Autorun and Autoplay for
10   10,3    Devices        Protect                                          Disable autorun and autoplay auto-execute functionality for removable media.                                             x   x   x
                                       Removable Media
                                       Configure Automatic Anti-Malware
10   10,4    Devices        Detect                                           Configure anti-malware software to automatically scan removable media.                                                       x   x
                                       Scanning of Removable Media
                                                                             Enable anti-exploitation features on enterprise assets and software, where possible, such as Microsoft® Data
10   10,5    Devices        Protect    Enable Anti-Exploitation Features     Execution Prevention (DEP), Windows® Defender Exploit Guard (WDEG), or Apple® System Integrity Protection                    x   x
                                                                             (SIP) and Gatekeeper™.
                                       Centrally Manage Anti-Malware
10   10,6    Devices        Protect                                          Centrally manage anti-malware software.                                                                                      x   x
                                       Software
                                       Use Behavior-Based Anti-Malware
10   10,7    Devices        Detect                                           Use behavior-based anti-malware software.                                                                                    x   x
                                       Software
                                                                             Establish and maintain data recovery practices sufficient to restore in-scope enterprise assets to a pre-
11                                     Data Recovery
                                                                             incident and trusted state.
                                                                             Establish and maintain a data recovery process. In the process, address the scope of data recovery activities,
                                       Establish and Maintain a Data
11   11,1    Data           Recover                                          recovery prioritization, and the security of backup data. Review and update documentation annually, or when              x   x   x
                                       Recovery Process
                                                                             significant enterprise changes occur that could impact this Safeguard.
                                                                             Perform automated backups of in-scope enterprise assets. Run backups weekly, or more frequently, based on the
11   11,2    Data           Recover    Perform Automated Backups                                                                                                                                      x   x   x
                                                                             sensitivity of the data.
                                                                             Protect recovery data with equivalent controls to the original data. Reference encryption or data separation, based
11   11,3    Data           Protect    Protect Recovery Data                                                                                                                                          x   x   x
                                                                             on requirements.
                                       Establish and Maintain an Isolated    Establish and maintain an isolated instance of recovery data. Example implementations include, version controlling
11   11,4    Data           Recover                                                                                                                                                                   x   x   x
                                       Instance of Recovery Data             backup destinations through offline, cloud, or off-site systems or services.
11   11,5    Data           Recover    Test Data Recovery                   Test backup recovery quarterly, or more frequently, for a sampling of in-scope enterprise assets.                             x   x
                                       Network Infrastructure               Establish, implement, and actively manage (track, report, correct) network devices, in order to prevent
12
                                       Management                           attackers from exploiting vulnerable network services and access points.
                                                                            Ensure network infrastructure is kept up-to-date. Example implementations include running the latest stable
                                       Ensure Network Infrastructure is Up-
12   12,1    Network        Protect                                         release of software and/or using currently supported network-as-a-service (NaaS) offerings. Review software               x   x   x
                                       to-Date
                                                                            versions monthly, or more frequently, to verify software support.
                                       Establish and Maintain a Secure      Establish and maintain a secure network architecture. A secure network architecture must address segmentation,
12   12,2    Network        Protect                                                                                                                                                                       x   x
                                       Network Architecture                 least privilege, and availability, at a minimum.
                                       Securely Manage Network              Securely manage network infrastructure. Example implementations include version-controlled-infrastructure-as-
12   12,3    Network        Protect                                                                                                                                                                       x   x
                                       Infrastructure                       code, and the use of secure network protocols, such as SSH and HTTPS.
                                       Establish and Maintain Architecture   Establish and maintain architecture diagram(s) and/or other network system documentation. Review and update
12   12,4    Network        Identify                                                                                                                                                                      x   x
                                       Diagram(s)                            documentation annually, or when significant enterprise changes occur that could impact this Safeguard.
                                                                             Operate processes and tooling to establish and maintain comprehensive network monitoring and
13                                     Network Monitoring and Defense
                                                                             defense against security threats across the enterprise’s network infrastructure and user base.
                                                                             Centralize security event alerting across enterprise assets for log correlation and analysis. Best practice
13   13,1    Network        Detect     Centralize Security Event Alerting    implementation requires the use of a SIEM, which includes vendor-defined event correlation alerts. A log analytics           x   x
                                                                             platform configured with security-relevant correlation alerts also satisfies this Safeguard.
                                       Deploy a Host-Based Intrusion
13   13,2    Devices        Detect                                           Deploy a host-based intrusion detection solution on enterprise assets, where appropriate and/or supported.                   x   x
                                       Detection Solution
                                                                             Deploy a network intrusion detection solution on enterprise assets, where appropriate. Example implementations
                                       Deploy a Network Intrusion
13   13,3    Network        Detect                                           include the use of a Network Intrusion Detection System (NIDS) or equivalent cloud service provider (CSP)                    x   x
                                       Detection Solution
                                                                             service.
                                       Perform Traffic Filtering Between
13   13,4    Network        Protect                                          Perform traffic filtering between network segments, where appropriate.                                                       x   x
                                       Network Segments
                                                                        Manage access control for assets remotely connecting to enterprise resources. Determine amount of access to
                                       Manage Access Control for Remote
13   13,5    Devices        Protect                                     enterprise resources based on: up-to-date anti-malware software installed, configuration compliance with the                      x   x
                                       Assets
                                                                        enterprise’s secure configuration process, and ensuring the operating system and applications are up-to-date.
13 13,6 Network Detect Collect Network Traffic Flow Logs Collect network traffic flow logs and/or network traffic to review and alert upon from network devices. x x
                                                                              Deploy a host-based intrusion prevention solution on enterprise assets, where appropriate and/or supported.
                                       Deploy a Host-Based Intrusion
13   13,7    Devices        Protect                                          Example implementations include use of an Endpoint Detection and Response (EDR) client or host-based IPS                         x
                                       Prevention Solution
                                                                             agent.
                                       Deploy a Network Intrusion            Deploy a network intrusion prevention solution, where appropriate. Example implementations include the use of a
13   13,8    Network        Protect                                                                                                                                                                           x
                                       Prevention Solution                   Network Intrusion Prevention System (NIPS) or equivalent CSP service.
                                                                             Deploy port-level access control. Port-level access control utilizes 802.1x, or similar network access control
13   13,9    Devices        Protect    Deploy Port-Level Access Control                                                                                                                                       x
                                                                             protocols, such as certificates, and may incorporate user and/or device authentication.
                                                                             Perform application layer filtering. Example implementations include a filtering proxy, application layer firewall, or
13   13,10   Network        Protect    Perform Application Layer Filtering                                                                                                                                    x
                                                                             gateway.
                                       Tune Security Event Alerting
13   13,11   Network        Detect                                           Tune security event alerting thresholds monthly, or more frequently.                                                             x
                                       Thresholds
                                       Security Awareness and Skills         Establish and maintain a security awareness program to influence behavior among the workforce to be
14
                                       Training                              security conscious and properly skilled to reduce cybersecurity risks to the enterprise.
                                                                             Establish and maintain a security awareness program. The purpose of a security awareness program is to
                                       Establish and Maintain a Security     educate the enterprise’s workforce on how to interact with enterprise assets and data in a secure manner.
14   14,1    N/A            Protect                                                                                                                                                                   x   x   x
                                       Awareness Program                     Conduct training at hire and, at a minimum, annually. Review and update content annually, or when significant
                                                                             enterprise changes occur that could impact this Safeguard.
                                       Train Workforce Members to
14   14,2    N/A            Protect    Recognize Social Engineering          Train workforce members to recognize social engineering attacks, such as phishing, pre-texting, and tailgating.          x   x   x
                                       Attacks
                                       Train Workforce Members on            Train workforce members on authentication best practices. Example topics include MFA, password composition,
14   14,3    N/A            Protect                                                                                                                                                                   x   x   x
                                       Authentication Best Practices         and credential management.
                                                                             Train workforce members on how to identify and properly store, transfer, archive, and destroy sensitive data. This
                                       Train Workforce on Data Handling      also includes training workforce members on clear screen and desk best practices, such as locking their screen
14   14,4    N/A            Protect                                                                                                                                                                   x   x   x
                                       Best Practices                        when they step away from their enterprise asset, erasing physical and virtual whiteboards at the end of meetings,
                                                                             and storing data and assets securely.
                                       Train Workforce Members on
                                                                             Train workforce members to be aware of causes for unintentional data exposure. Example topics include mis-
14   14,5    N/A            Protect    Causes of Unintentional Data                                                                                                                                   x   x   x
                                                                             delivery of sensitive data, losing a portable end-user device, or publishing data to unintended audiences.
                                       Exposure
                                       Train Workforce Members on
14   14,6    N/A            Protect    Recognizing and Reporting Security Train workforce members to be able to recognize a potential incident and be able to report such an incident.                   x   x   x
                                       Incidents
                                       Train Workforce on How to Identify Train workforce to understand how to verify and report out-of-date software patches or any failures in automated
14   14,7    N/A            Protect    and Report if Their Enterprise      processes and tools. Part of this training should include notifying IT personnel of any failures in automated                 x   x   x
                                       Assets are Missing Security Updates processes and tools.
                                       Train Workforce on the Dangers of
                                                                             Train workforce members on the dangers of connecting to, and transmitting data over, insecure networks for
                                       Connecting to and Transmitting
14   14,8    N/A            Protect                                          enterprise activities. If the enterprise has remote workers, training must include guidance to ensure that all users        x   x   x
                                       Enterprise Data Over Insecure
                                                                             securely configure their home network infrastructure.
                                       Networks
                                                                             Conduct role-specific security awareness and skills training. Example implementations include secure system
                                       Conduct Role-Specific Security
14   14,9    N/A            Protect                                          administration courses for IT professionals, OWASP® Top 10 vulnerability awareness and prevention training for                  x   x
                                       Awareness and Skills Training
                                                                             web application developers, and advanced social engineering awareness training for high-profile roles.
                                                                             Develop a process to evaluate service providers who hold sensitive data, or are responsible for an
15                                     Service Provider Management           enterprise’s critical IT platforms or processes, to ensure these providers are protecting those platforms
                                                                             and data appropriately.
                                                                             Establish and maintain an inventory of service providers. The inventory is to list all known service providers,
                                       Establish and Maintain an Inventory
15   15,1    N/A            Identify                                         include classification(s), and designate an enterprise contact for each service provider. Review and update the             x   x   x
                                       of Service Providers
                                                                             inventory annually, or when significant enterprise changes occur that could impact this Safeguard.
                                                                             Establish and maintain a service provider management policy. Ensure the policy addresses the classification,
                                       Establish and Maintain a Service
15   15,2    N/A            Identify                                         inventory, assessment, monitoring, and decommissioning of service providers. Review and update the policy                       x   x
                                       Provider Management Policy
                                                                             annually, or when significant enterprise changes occur that could impact this Safeguard.
                                                                             Classify service providers. Classification consideration may include one or more characteristics, such as data
15   15,3    N/A            Identify   Classify Service Providers            sensitivity, data volume, availability requirements, applicable regulations, inherent risk, and mitigated risk. Update          x   x
                                                                             and review classifications annually, or when significant enterprise changes occur that could impact this Safeguard.
                                                                             Ensure service provider contracts include security requirements. Example requirements may include minimum
                                                                             security program requirements, security incident and/or data breach notification and response, data encryption
                                       Ensure Service Provider Contracts
15   15,4    N/A            Protect                                          requirements, and data disposal commitments. These security requirements must be consistent with the                            x   x
                                       Include Security Requirements
                                                                             enterprise’s service provider management policy. Review service provider contracts annually to ensure contracts
                                                                             are not missing security requirements.
                                                                             Assess service providers consistent with the enterprise’s service provider management policy. Assessment scope
                                                                             may vary based on classification(s), and may include review of standardized assessment reports, such as Service
15   15,5    N/A            Identify   Assess Service Providers              Organization Control 2 (SOC 2) and Payment Card Industry (PCI) Attestation of Compliance (AoC), customized                          x
                                                                             questionnaires, or other appropriately rigorous processes. Reassess service providers annually, at a minimum, or
                                                                             with new and renewed contracts.
                                                                             Monitor service providers consistent with the enterprise’s service provider management policy. Monitoring may
15   15,6    Data           Detect     Monitor Service Providers             include periodic reassessment of service provider compliance, monitoring service provider release notes, and dark                   x
                                                                             web monitoring.
                                       Securely Decommission Service         Securely decommission service providers. Example considerations include user and service account deactivation,
15   15,7    Data           Protect                                                                                                                                                                              x
                                       Providers                             termination of data flows, and secure disposal of enterprise data within service provider systems.
                                                                             Manage the security life cycle of in-house developed, hosted, or acquired software to prevent, detect,
16                                     Application Software Security
                                                                             and remediate security weaknesses before they can impact the enterprise.
                                                                           Establish and maintain a secure application development process. In the process, address such items as: secure
                                       Establish and Maintain a Secure
16   16,1    Applications   Protect                                        application design standards, secure coding practices, developer training, vulnerability management, security of                  x   x
                                       Application Development Process
                                                                           third-party code, and application security testing procedures. Review and update documentation annually, or when
                                                                           significant enterprise changes occur that could impact this Safeguard.
                                                                           Establish and maintain a process to accept and address reports of software vulnerabilities, including providing a
                                                                           means for external entities to report. The process is to include such items as: a vulnerability handling policy that
                                                                           identifies reporting process, responsible party for handling vulnerability reports, and a process for intake,
                                                                           assignment, remediation, and remediation testing. As part of the process, use a vulnerability tracking system that
                                       Establish and Maintain a Process to
                                                                           includes severity ratings, and metrics for measuring timing for identification, analysis, and remediation of
16   16,2    Applications   Protect    Accept and Address Software                                                                                                                                           x   x
                                                                           vulnerabilities. Review and update documentation annually, or when significant enterprise changes occur that
                                       Vulnerabilities
                                                                           could impact this Safeguard.
                                                                             Third-party application developers need to consider this an externally-facing policy that helps to set expectations
                                                                             for outside stakeholders.
                                                                             Perform root cause analysis on security vulnerabilities. When reviewing vulnerabilities, root cause analysis is the
                                       Perform Root Cause Analysis on
16   16,3    Applications   Protect                                          task of evaluating underlying issues that create vulnerabilities in code, and allows development teams to move                  x   x
                                       Security Vulnerabilities
                                                                             beyond just fixing individual vulnerabilities as they arise.
                                                                             Establish and manage an updated inventory of third-party components used in development, often referred to as a
                                       Establish and Manage an Inventory
                                                                             “bill of materials,” as well as components slated for future use. This inventory is to include any risks that each third-
16   16,4    Applications   Protect    of Third-Party Software                                                                                                                                               x   x
                                                                             party component could pose. Evaluate the list at least monthly to identify any changes or updates to these
                                       Components
                                                                             components, and validate that the component is still supported.
                                                                             Use up-to-date and trusted third-party software components. When possible, choose established and proven
                                       Use Up-to-Date and Trusted Third-
16   16,5    Applications   Protect                                          frameworks and libraries that provide adequate security. Acquire these components from trusted sources or                       x   x
                                       Party Software Components
                                                                             evaluate the software for vulnerabilities before use.
                                                                             Establish and maintain a severity rating system and process for application vulnerabilities that facilitates prioritizing
                                       Establish and Maintain a Severity     the order in which discovered vulnerabilities are fixed. This process includes setting a minimum level of security
16   16,6    Applications   Protect    Rating System and Process for         acceptability for releasing code or applications. Severity ratings bring a systematic way of triaging vulnerabilities           x   x
                                       Application Vulnerabilities           that improves risk management and helps ensure the most severe bugs are fixed first. Review and update the
                                                                             system and process annually.
                                                                             Use standard, industry-recommended hardening configuration templates for application infrastructure
                                       Use Standard Hardening
                                                                             components. This includes underlying servers, databases, and web servers, and applies to cloud containers,
16   16,7    Applications   Protect    Configuration Templates for                                                                                                                                           x   x
                                                                             Platform as a Service (PaaS) components, and SaaS components. Do not allow in-house developed software to
                                       Application Infrastructure
                                                                             weaken configuration hardening.
                                       Separate Production and Non-
16   16,8    Applications   Protect                                          Maintain separate environments for production and non-production systems.                                                       x   x
                                       Production Systems
                                                                             Ensure that all software development personnel receive training in writing secure code for their specific
                                       Train Developers in Application
                                                                             development environment and responsibilities. Training can include general security principles and application
16   16,9    Applications   Protect    Security Concepts and Secure                                                                                                                                          x   x
                                                                             security standard practices. Conduct training at least annually and design in a way to promote security within the
                                       Coding
                                                                             development team, and build a culture of security among the developers.
                                                                             Apply secure design principles in application architectures. Secure design principles include the concept of least
                                                                             privilege and enforcing mediation to validate every operation that the user makes, promoting the concept of "never
                                       Apply Secure Design Principles in     trust user input." Examples include ensuring that explicit error checking is performed and documented for all input,
16   16,10   Applications   Protect                                                                                                                                                                          x   x
                                       Application Architectures             including for size, data type, and acceptable ranges or formats. Secure design also means minimizing the
                                                                             application infrastructure attack surface, such as turning off unprotected ports and services, removing
                                                                             unnecessary programs and files, and renaming or removing default accounts.
                                                                             Leverage vetted modules or services for application security components, such as identity management,
                                                                             encryption, and auditing and logging. Using platform features in critical security functions will reduce developers’
                                       Leverage Vetted Modules or
                                                                             workload and minimize the likelihood of design or implementation errors. Modern operating systems provide
16   16,11   Applications   Protect    Services for Application Security                                                                                                                                     x   x
                                                                             effective mechanisms for identification, authentication, and authorization and make those mechanisms available to
                                       Components
                                                                             applications. Use only standardized, currently accepted, and extensively reviewed encryption algorithms.
                                                                             Operating systems also provide mechanisms to create and maintain secure audit logs.
                                       Implement Code-Level Security         Apply static and dynamic analysis tools within the application life cycle to verify that secure coding practices are
16   16,12   Applications   Protect                                                                                                                                                                              x
                                       Checks                                being followed.
                                                                             Conduct application penetration testing. For critical applications, authenticated penetration testing is better suited
                                       Conduct Application Penetration       to finding business logic vulnerabilities than code scanning and automated security testing. Penetration testing
16   16,13   Applications   Protect                                                                                                                                                                              x
                                       Testing                               relies on the skill of the tester to manually manipulate an application as an authenticated and unauthenticated
                                                                             user.
                                                                             Conduct threat modeling. Threat modeling is the process of identifying and addressing application security design
                                                                             flaws within a design, before code is created. It is conducted through specially trained individuals who evaluate the
16   16,14   Applications   Protect    Conduct Threat Modeling                                                                                                                                                   x
                                                                             application design and gauge security risks for each entry point and access level. The goal is to map out the
                                                                             application, architecture, and infrastructure in a structured way to understand its weaknesses.
                                                                             Establish a program to develop and maintain an incident response capability (e.g., policies, plans,
17                                     Incident Response Management          procedures, defined roles, training, and communications) to prepare, detect, and quickly respond to an
                                                                             attack.
                                                                       Designate one key person, and at least one backup, who will manage the enterprise’s incident handling process.
                                                                       Management personnel are responsible for the coordination and documentation of incident response and recovery
                                 Designate Personnel to Manage
17   17,1   N/A       Respond                                          efforts and can consist of employees internal to the enterprise, third-party vendors, or a hybrid approach. If using a   x   x   x
                                 Incident Handling
                                                                       third-party vendor, designate at least one person internal to the enterprise to oversee any third-party work. Review
                                                                       annually, or when significant enterprise changes occur that could impact this Safeguard.
                                                                      Establish and maintain contact information for parties that need to be informed of security incidents. Contacts may
                                 Establish and Maintain Contact
                                                                      include internal staff, third-party vendors, law enforcement, cyber insurance providers, relevant government
17   17,2   N/A       Respond    Information for Reporting Security                                                                                                                             x   x   x
                                                                      agencies, Information Sharing and Analysis Center (ISAC) partners, or other stakeholders. Verify contacts
                                 Incidents
                                                                      annually to ensure that information is up-to-date.
                                                                      Establish and maintain an enterprise process for the workforce to report security incidents. The process includes
                                 Establish and Maintain an Enterprise reporting timeframe, personnel to report to, mechanism for reporting, and the minimum information to be
17   17,3   N/A       Respond                                                                                                                                                                   x   x   x
                                 Process for Reporting Incidents      reported. Ensure the process is publicly available to all of the workforce. Review annually, or when significant
                                                                      enterprise changes occur that could impact this Safeguard.
                                                                      Establish and maintain an incident response process that addresses roles and responsibilities, compliance
                                 Establish and Maintain an Incident
17   17,4   N/A       Respond                                         requirements, and a communication plan. Review annually, or when significant enterprise changes occur that                    x   x
                                 Response Process
                                                                      could impact this Safeguard.
                                                                      Assign key roles and responsibilities for incident response, including staff from legal, IT, information security,
                                 Assign Key Roles and
17   17,5   N/A       Respond                                         facilities, public relations, human resources, incident responders, and analysts, as applicable. Review annually, or          x   x
                                 Responsibilities
                                                                      when significant enterprise changes occur that could impact this Safeguard.
                                                                      Determine which primary and secondary mechanisms will be used to communicate and report during a security
                                 Define Mechanisms for
                                                                      incident. Mechanisms can include phone calls, emails, or letters. Keep in mind that certain mechanisms, such as
17   17,6   N/A       Respond    Communicating During Incident                                                                                                                                      x   x
                                                                      emails, can be affected during a security incident. Review annually, or when significant enterprise changes occur
                                 Response
                                                                      that could impact this Safeguard.
                                                                   Plan and conduct routine incident response exercises and scenarios for key personnel involved in the incident
                                 Conduct Routine Incident Response
17   17,7   N/A       Recover                                      response process to prepare for responding to real-world incidents. Exercises need to test communication                         x   x
                                 Exercises
                                                                   channels, decision making, and workflows. Conduct testing on an annual basis, at a minimum.
                                                                      Conduct post-incident reviews. Post-incident reviews help prevent incident recurrence through identifying lessons
17   17,8   N/A       Recover    Conduct Post-Incident Reviews                                                                                                                                      x   x
                                                                      learned and follow-up action.
                                                                      Establish and maintain security incident thresholds, including, at a minimum, differentiating between an incident
                                 Establish and Maintain Security      and an event. Examples can include: abnormal activity, security vulnerability, security weakness, data breach,
17   17,9   N/A       Recover                                                                                                                                                                           x
                                 Incident Thresholds                  privacy incident, etc. Review annually, or when significant enterprise changes occur that could impact this
                                                                      Safeguard.
                                                                      Test the effectiveness and resiliency of enterprise assets through identifying and exploiting weaknesses
18                               Penetration Testing                  in controls (people, processes, and technology), and simulating the objectives and actions of an
                                                                      attacker.
                                                                      Establish and maintain a penetration testing program appropriate to the size, complexity, and maturity of the
                                                                      enterprise. Penetration testing program characteristics include scope, such as network, web application,
                                 Establish and Maintain a Penetration
18   18,1   N/A       Identify                                        Application Programming Interface (API), hosted services, and physical premise controls; frequency; limitations,              x   x
                                 Testing Program
                                                                      such as acceptable hours, and excluded attack types; point of contact information; remediation, such as how
                                                                      findings will be routed internally; and retrospective requirements.
                                                                      Perform periodic external penetration tests based on program requirements, no less than annually. External
                                 Perform Periodic External            penetration testing must include enterprise and environmental reconnaissance to detect exploitable information.
18   18,2   Network   Identify                                                                                                                                                                      x   x
                                 Penetration Tests                    Penetration testing requires specialized skills and experience and must be conducted through a qualified party.
                                                                      The testing may be clear box or opaque box.
                                 Remediate Penetration Test
18   18,3   Network   Protect                                         Remediate penetration test findings based on the enterprise’s policy for remediation scope and prioritization.                x   x
                                 Findings
                                                                      Validate security measures after each penetration test. If deemed necessary, modify rulesets and capabilities to
18   18,4   Network   Protect    Validate Security Measures                                                                                                                                             x
                                                                      detect the techniques used during testing.
                                 Perform Periodic Internal            Perform periodic internal penetration tests based on program requirements, no less than annually. The testing
18   18,5   N/A       Identify                                                                                                                                                                          x
                                 Penetration Tests                    may be clear box or opaque box.