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Secure Controls Framework
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IAO-05: Plan of Action and Milestones (POA&M)
IAO-05: Does the organization generate a Plan of Action and Milestones (POA&M), or similar risk register, to document planned remedial actions to correct weaknesses or deficiencies noted during the assessment of the security controls and to reduce or eliminate known vulnerabilities?

Mechanisms exist to generate a Plan of Action and Milestones (POA&M), or similar risk register, to document planned remedial actions to correct weaknesses or deficiencies noted during the assessment of the security controls and to reduce or eliminate known vulnerabilities.

C|P - CMM 0: Not performed - This level of maturity is defined as “non-existence practices,” where the control is not being performed: - Practices are non-existent, where a reasonable person would conclude the control is not being performed. - Evidence of due care and due diligence do not exist to demonstrate compliance with applicable statutory, regulatory and/or contractual obligations.
C|P - CMM 1: Performed Informally - This level of maturity is defined as “ad hoc practices,” where the control is being performed, but lacks completeness & consistency: - Practices are “ad hoc” where the intent of a control is not met due to a lack consistency and formality. - When the control is met, it lacks consistency and formality (e.g., rudimentary practices are performed informally). - A reasonable person would conclude the control is not consistently performed in a structured manner. - Performance depends on specific knowledge and effort of the individual performing the task(s), where the performance of these practices is not proactively governed. - Limited evidence of due care and due diligence exists, where it would be difficult to legitimately disprove a claim of negligence for how cybersecurity/privacy controls are implemented and maintained.
C|P - CMM 2: Planned and Tracked - Practices are “requirements-driven” where the intent of control is met in some circumstances, but not standardized across the entire organization: - Practices are “requirements-driven” (e.g., specified by a law, regulation or contractual obligation) and are tailored to meet those specific compliance obligations (e.g., evidence of due diligence). - Performance of a control is planned and tracked according to specified procedures and work products conform to specified standards (e.g., evidence of due care). - Controls are implemented in some, but not all applicable circumstances/environments (e.g., specific enclaves, facilities or locations). - A reasonable person would conclude controls are “compliance-focused” to meet a specific obligation, since the practices are applied at a local/regional level and are not standardized practices across the enterprise. - Sufficient evidence of due care and due diligence exists to demonstrate compliance with specific statutory, regulatory and/or contractual obligations.
C|P - CMM 3: Well Defined - This level of maturity is defined as “enterprise-wide standardization,” where the practices are well-defined and standardized across the organization: - Practices are standardized “enterprise-wide” where the control is well-defined and standardized across the entire enterprise. - Controls are implemented in all applicable circumstances/environments (deviations are documented and justified). - Practices are performed according to a well-defined process using approved, tailored versions of standardized processes. - Performance of a control is according to specified well-defined and standardized procedures. - Control execution is planned and managed using an enterprise-wide, standardized methodology. - A reasonable person would conclude controls are “security-focused” that address both mandatory and discretionary requirements. Compliance could reasonably be viewed as a “natural byproduct” of secure practices. - Sufficient evidence of due care and due diligence exists to demonstrate compliance with specific statutory, regulatory and/or contractual obligations. - The Chief Information Security Officer (CISO) , or similar function, develops a security-focused Concept of Operations (CONOPS) that documents organization-wide management, operational and technical measures to apply defense-in- depth techniques (note - in this context, a CONOPS is a verbal or graphic statement of intent and assumptions regarding operationalizing the identified tasks to achieve the CISO’s stated objectives. The result of the CONOPS is operating the organization’s cybersecurity and data protection program so that it meets business objectives). Control or domain-specific CONOPS may be incorporated as part of a broader operational plan for the cybersecurity and data privacy program (e.g., cybersecurity-specific business plan).
C|P - CMM 4: Quantitatively Controlled - This level of maturity is defined as “metrics-driven practices,” where in addition to being well-defined and standardized practices across the organization, there are detailed metrics to enable governance oversight: - Practices are “metrics-driven” and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations, and identify areas for improvement. - Practices build upon established L3 maturity criteria and have detailed metrics to enable governance oversight. - Detailed measures of performance are collected and analyzed. This leads to a quantitative understanding of process capability and an improved ability to predict performance. - Performance is objectively managed, and the quality of work products is quantitatively known.
C|P - CMM 5: Continuously Improving - This level of maturity is defined as “world-class practices,” where the practices are not only well-defined and standardized across the organization, as well as having detailed metrics, but the process is continuously improving: - Practices are “world-class” capabilities that leverage predictive analysis. - Practices build upon established L4 maturity criteria and are time-sensitive to support operational efficiency, which likely includes automated actions through machine learning or Artificial Intelligence (AI). - Quantitative performance goals (targets) for process effectiveness and efficiency are established, based on the business goals of the organization. - Process improvements are implemented according to “continuous improvement” practices to affect process changes.
Description

Mechanisms exist to generate a Plan of Action and Milestones (POA&M), or similar risk register, to document planned remedial actions to correct weaknesses or deficiencies noted during the assessment of the security controls and to reduce or eliminate known vulnerabilities.