Control Validation Testing
The Control Validation Testing (CVT) is focused on pre-production testing. ComplianceForge's CVT is based on established processes used by the US Government (e.g., FISMA, DIACAP, DIARMF) to validate the existence and functionality of controls, prior to a system, application or service going into production. In US Government language, this is commonly referred to as Information Assurance (IA) or Security Testing & Evaluation (ST&E). We "civilianized" this concept of IA/ST&E to create a method to enable cybersecurity and privacy personnel to work with your organization's existing System Development Life Cycle (SDLC) / Project Development Life Cycle (PDLC) to ensure privacy and cybersecurity principles are designed and built-into your systems, applications and services!
The end state with Control Validation Testing is:
- Removal of "security roadblocks" by embedding cybersecurity and privacy into the SDLC/PDLC from project kick-off through the "go live" data.
- Having evidence of both cybersecurity and privacy principles being identified and implemented by design (e.g., EU GDPR compliance)
- Utilizing a customized control sets that defines Minimum Security Requirements (MSR) specific to the project undergoing review.
- A data-centric view across systems, applications, services and third-parties that enables situational awareness of both cybersecurity and privacy risks.
- A Project Risk Register (PRR) that tracks risks and the associated remediation actions (e.g., Plan of Action & Milestones (POA&M)).
- A formal method of getting stakeholder accountability for residual risk.
Why Should I Buy The CVT? What Actually Requires "Pre-Production Testing" To Be Performed?
As a CISO or CPO, performing CVT is not only the right thing to do from a security and privacy perspective, but it is serious job security. When things go bad and fingers get pointed, do you have a "get out of jail free card" that you can use? If not, keep reading.
A CISO or CPO should never make the decision to "sign off" and own risk, since it is ultimately a business decision and that director/VP of the business unit should be accepting the risk for their projects, services and vendors needed to operate. It is the responsibility of the CISO and CPO to have a data-centric view of risk from the application, system, service and supply chain perspective. With this understanding of the risks, the CISO and CPO need to educate the business process owners if minimum security requirements are/are not met and if the risk falls within the organization's risk appetite. This is where the CRO role defines what is acceptable risk and works with the business units to get them to hopefully make the correct GO/NO GO decision. If they do choose to do something outside of the risk appetite, the CRO/CISO/CPO has evidence to demonstrate due care in their analysis. A lot of this requires a mature pre-production control validation testing process, which is absent in many organizations beyond a rudimentary security gate for change control.
The following are common statutory, regulatory and contractual requirements that expect “pre-production testing” or "information assurance" activities to be performed:
- ISO 27002 – 14.2.8
- European Union General Data Protection Regulation (EU GDPR) – Article 25
- NIST 800-171 – 3.12.1, 3.12.3 & Non-Federal Organization (NFO)
- NIST Cybersecurity Framework – PR.IP-2, PR.IP-5 & DE.DP-3
- Federal Risk and Authorization Management Program (FedRAMP) – Security Assessment & Authorization (CA) controls
- AICPA Trust Services Principles (TSP) SOC2 – CC7.4
- Center for Internet Security Critical Security Controls (CIS CSC) – 18.2, 18.4 & 18.8
- Cloud Security Alliance Cloud Controls Matrix (CSA CCM) – CCC-03
- Cloud Computing Compliance Controls Catalogue (C5) – BEI-02
- Monitory Authority of Singapore Technology Risk Management (MAS TRM) Guidelines - 6.0.1, 6.2.2, 6.2.3, 6.2.4, 6.3.4, 6.4.2, 6.4.3, 6.4.4, A.1.1 & A.1.2
- European Union Agency for Network and Information Security (ENISA) Technical Guideline of Security Measures – SO23
- National Industry Security Program Operating Manual (NISPOM) – 8-610 & 8-302
- Criminal Justice Information Services (CJIS) Security Policy – 184.108.40.206, 220.127.116.11, 18.104.22.168, 5.11.2 & 22.214.171.124
- Massachusetts MA 201 CMR 17.00 – 17.03(2)(d)(B)(i) & 17.03(2)(h)
- New York Department of Financial Services (23 NYCRR 500) – 500.02
- Oregon Consumer Identity Theft Protection Act (OCITPA) – 622(2)(B)(i)-(iv)
- Underwriters Laboratories (UL) 2900-1 – Section 12
- Payment Card Industry Data Security Standard (PCI DSS) – Requirement 6
- Motion Picture Association of America (MPAA) Content Security Program – MS-2.0
Product Example - CVT
The CVT is based on leading security engineering practices, including NIST 800-160 and NIST 800-37. You get fully-editable Microsoft Word and Excel documents that you can customize for your specific needs. Please review the examples below to see for yourself:
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Cost Savings Estimate - Control Validation Testing (CVT)
When you look at the costs associated with either (1) hiring an external consultant to write cybersecurity documentation for you or (2) tasking your internal staff to write it, the cost comparisons paint a clear picture that buying from ComplianceForge is the logical option. Compared to hiring a consultant, you can save months of wait time and tens of thousands of dollars. Whereas, compared to writing your own documentation, you can potentially save hundreds of work hours and the associated cost of lost productivity. Purchasing from ComplianceForge offers these fundamental advantages when compared to the other options for obtaining quality cybersecurity documentation:
- For your internal staff to generate comparable documentation, it would take them an estimated 200 internal staff work hours, which equates to a cost of approximately $15,000 in staff-related expenses. This is about 3-6 months of development time where your staff would be diverted from other work. This assumes you have staff that has performed IA/ST&E work who can even develop this documentation.
- If you hire a consultant to generate this documentation, it would take them an estimated 110 contractor work hours, which equates to a cost of approximately $33,000. This is about 2-3 months of development time for a contractor to provide you with the deliverable.
- It is approximately 9% of the cost for a consultant or 21% of the cost of your internal staff to generate equivalent documentation.
- We process most orders the same business day so you can potentially start working with the documentation the same day you place your order.
The process of writing cybersecurity documentation can take an internal team many months and it involves pulling your most senior and experienced cybersecurity experts away from operational duties to assist in the process, which is generally not the most efficient use of their time. In addition to the immense cost of hiring a cybersecurity consultant at $300/hr+ to write this documentation for you, the time to schedule a consultant, provide guidance and get the deliverable product can take months. Even when you bring in a consultant, this also requires involvement from your internal team for quality control and answering questions, so the impact is not limited to just the consultant's time being consumed.
What Problem Does The CVT Solve?
- Lack of In House Security Experience - Writing security documentation is a skill that many good cybersecurity professionals simple are not proficient at and avoid the task at all cost. Tasking your security analysts and engineers to write comprehensive documentation means you are actively taking them away from protecting and defending your network, which is not a wise use of their time. The CVT is an efficient method to obtain comprehensive system hardening documentation.
- Compliance Requirements - There are numerous requirements (several listed at the top of this page) that require pre-production security testing to be performed and documented. The CVT is designed with compliance in mind, since it focuses on leading "best practices" for ensuring systems, applications and services are verified to address reasonably-expected requirements for cybersecurity and privacy exist and function accordingly.
- Audit Failures - A lack of documented pre-production security testing is a common audit failure. The CVT covers traditional SDLC/PDLC models that include Agile, Waterfall and other approaches to project management. This is designed to integrate with your existing processes to bake in cybersecurity and privacy principles.
- Vendor Requirements - It is getting more common for clients and partners to request evidence of secure processes, including SDLC/PDLC security and privacy efforts. The CVT provides this evidence!
How Does the CVT Solve It?
- Clear Documentation - The CVT provides comprehensive cybersecurity and privacy pre-production testing to prove that your security is more than just a set of policies and standards.
- Time Savings - The CVT can provide your organization with a semi-customized solution that requires minimal resources to fine tune for your organization's specific needs.
- Alignment With Leading Practices - The CVT is written to align your organization with leading practices for secure engineering processes.
What Does the CVT Come With?
The CVT comes with everything you need to stand up a process to do pre-production security & privacy testing:
- Core Word document that is the program-level guidance on the Control Validation Testing (CVT) program at your organization;
- Editable Excel spreadsheets that contain mappings to leading practices and other helpful charts to clarify requirements;
- Security & Privacy Test Plan (SPTP) template to document the plan to perform CVT for a specific project;
- Security & Privacy Plan (SPP) is essentially a traditional System Security Plan (SSP) with privacy added into it;
- Project Risk Register (PRR) template to document risks and remediation actions; and
- Security & Privacy Assessment Report (SPAR) template to write up the overall risk report for the project.
All of these documents come together to enable you to hit the ground running with CVT operations!
What Controls Does the CVT Rely On?
The CVT is very flexible for the control set that you might want to use for CVT. Assuming you do not have something to use "out of the box" we have that covered with the ability to use the Secure Controls Framework (SCF). If you are not familiar with the SCF, it is a robust set of cybersecurity and privacy controls that maps to over 100 statutory, regulatory and contractual frameworks, so it is a great, free tool for businesses to use! The CVT comes with instructions on paring down the SCF to define just the right "level of effort" for the control set, based on the pertinent compliance needs and risk appetite of your organization.
If you have any questions on the CVT, please contact us since we are happy to do a demo or answer your questions in greater detail.