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  1. The illustrative procedures for control 0827.09m3Organizational.6 specify wireless networks have MAC address control. There are a few assumptions with this that makes this a very poor fit. This presumes that sensitive information is available directly on a wireless network. I think would be true of less than 5% of the entities we've assessed. Additionally, there are other type of controls that authenticate the machine beyond MAC filtering. Many orgs, especially non CE, have gone to a remote first model and/or SaaS models where systems are configured with appropriate controls and protections for delivery over untrusted networks.

    1 vote

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  2. Requirements which must be met by implemented controls or processes should be entirely contained within the requirement statement. Additional requirements should not be introduced in illustrative procedures.

    1 vote

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  3. 2 votes

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  4. Type: Organizational . Level: 1 . ID: 1828.08a1Organizational.12

    Missing word in policy portion under Illustrated Procedures: "Computers that store or process covered information are located in areas that are unattended and have unrestricted access by the public."

    Adjusted sentence would be "Computers that store or process covered information are never located in areas..."

    1 vote

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  5. Because we have a control maturity model that considers a written policy for each requirement, requirements focused on a single control maturity level should be avoided in v10. For example, the CSF currently contains some requirements about having a written policy, program, standard, guideline, etc. In those requirements, testing of both the "policy" and "implemented" control maturity levels are both test of a written policy (often the same one). Instead, requirements should be action-oriented (e.g. the org. does X) instead of policy oriented (e.g. the org. has a policy about X). Because of the control maturity model, the existence of…

    9 votes

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  6. In many information security, privacy, and financial auditing approaches, the audited customer needs to produce one piece/set of evidence per requirement. Each requirement needs distinct artifacts. This allows for simple data management - my list of requirements is X long and therefore my list of evidence artifacts/sets should be the same length. I can then track progress as an audited customer by measuring how much evidence I have produced, and how much is left to go. I can even set up workflows within project management tools and GRC tools easily to accommodate this. Put in data terms - my requirement…

    7 votes

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  7. Inclusion of The Personal Information Protection and Electronic Documents Act (PIPEDA)

    2 votes

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  8. 6 votes

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  9. 3 votes

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    1 comment  ·  Clarity  ·  Admin →
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  10. 4 votes

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  11. 4 votes

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  12. Assessors and assessed entities could benefit from something communicating the exact number of CSF implementation specifications present in the policy illustrative procedures. This could be through something like a number that precedes the policy illustrative procedure or even consistent use of roman numerals in the policy illustrative procedure. This would help everyone involved in preparing for, performing, and reviewing assessments ensure they are working with a generally understood denominator for scoring calculations.

    For example:
    Instead of saying "Inspect written policies to determine that they contain X, Y, and Z.", the policy illustrative procedure could display as,
    "Inspect written policies to…

    14 votes

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    Planned  ·  4 comments  ·  Clarity  ·  Admin →
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  13. When setting up a new assessment, only a subset of the 44 authoritative sources in the CSF today are selectable / optional regulatory factors. Instead, 44 authoritative sources should be made into optional (selectable) regulatory factors.

    2 votes

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  14. 3 votes

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    0 comments  ·  Clarity  ·  Admin →
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  15. 2 votes

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  16. In the requirement, "Risk designations are assigned for all positions in the organization", a scope of the whole organization is forced through the wording. In v10, no requirements should dictate scope in and of themselves and should instead be written in such a way that they can be tested to the assessment's scope.

    4 votes

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  17. 1 vote

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  18. 1 vote

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  19. 2 votes

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  20. 1 vote

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    Planned  ·  0 comments  ·  Clarity  ·  Admin →
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