3.0 How to Use the Framework

1. 3.1 Basic Review of Cybersecurity Practices
2. 3.3 Communicating Cybersecurity Requirements with Stakeholders
3. 3.4 Buying Decisions
4. 3.5 Identifying Opportunities for New or Revised Informative References
5. 3.6 Methodology to Protect Privacy and Civil Liberties

An organization can use the Framework as a key part of its systematic process for identifying, assessing, and managing cybersecurity risk. The Framework is not designed to replace existing processes; an organization can use its current process and overlay it onto the Framework to determine gaps in its current cybersecurity risk approach and develop a roadmap to improvement. Using the Framework as a cybersecurity risk management tool, an organization can determine activities that are most important to critical service delivery and prioritize expenditures to maximize the impact of the investment.

The Framework is designed to complement existing business and cybersecurity operations. It can serve as the foundation for a new cybersecurity program or a mechanism for improving an existing program. The Framework provides a means of expressing cybersecurity requirements to business partners and customers and can help identify gaps in an organization’s cybersecurity practices. It also provides a general set of considerations and processes for considering privacy and civil liberties implications in the context of a cybersecurity program.

The Framework can be applied throughout the life cycle phases of plan, design, build/buy, deploy, operate, and decommission. The plan phase begins the cycle of any system and lays the groundwork for everything that follows. Overarching cybersecurity considerations should be declared and described as clearly as possible. The plan should recognize that those considerations and requirements are likely to evolve during the remainder of the life cycle. The design phase should account for cybersecurity requirements as a part of a larger multi-disciplinary systems engineering process.(10) A key milestone of the design phase is validation that the system cybersecurity specifications match the needs and risk disposition of the organization as captured in a Framework Profile. The desired cybersecurity outcomes prioritized in a Target Profile should be incorporated when a) developing the system during the build phase and b) purchasing or outsourcing the system during the buy phase. That same Target Profile serves as a list of system cybersecurity features that should be assessed when deploying the system to verify all features are implemented. The cybersecurity outcomes determined by using the Framework then should serve as a basis for ongoing operation of the system. This includes occasional reassessment, capturing results in a Current Profile, to verify that cybersecurity requirements are still fulfilled. Typically, a complex web of dependencies (e.g., compensating and common controls) among systems means the outcomes documented in Target Profiles of related systems should be carefully considered as systems are decommissioned.

(10) NIST Special Publication 800- 160 Volume 1, System Security Engineering, Considerations for a Multidisciplinary Approach in the Engineering of Trustworthy Secure Systems, Ross et al, November 2016 (updated March 21, 2018), https://doi.org/10.6028/NIST.SP.800-160v1

The following sections present different ways in which organizations can use the Framework.

3.1 Basic Review of Cybersecurity Practices

The Framework can be used to compare an organization’s current cybersecurity activities with those outlined in the Framework Core. Through the creation of a Current Profile, organizations can examine the extent to which they are achieving the outcomes described in the Core Categories and Subcategories, aligned with the five high-level Functions: Identify, Protect, Detect, Respond, and Recover. An organization may find that it is already achieving the desired outcomes, thus managing cybersecurity commensurate with the known risk. Alternatively, an organization may determine that it has opportunities to (or needs to) improve. The organization can use that information to develop an action plan to strengthen existing cybersecurity practices and reduce cybersecurity risk. An organization may also find that it is overinvesting to achieve certain outcomes. The organization can use this information to reprioritize resources.

While they do not replace a risk management process, these five high-level Functions will provide a concise way for senior executives and others to distill the fundamental concepts of cybersecurity risk so that they can assess how identified risks are managed, and how their organization stacks up at a high level against existing cybersecurity standards, guidelines, and practices. The Framework can also help an organization answer fundamental questions, including “How are we doing?” Then they can move in a more informed way to strengthen their cybersecurity practices where and when deemed necessary.

3.2 Establishing or Improving a Cybersecurity Program

The following steps illustrate how an organization could use the Framework to create a new cybersecurity program or improve an existing program. These steps should be repeated as necessary to continuously improve cybersecurity.

Step 1: Prioritize and Scope. The organization identifies its business/mission objectives and high-level organizational priorities. With this information, the organization makes strategic decisions regarding cybersecurity implementations and determines the scope of systems and assets that support the selected business line or process. The Framework can be adapted to support the different business lines or processes within an organization, which may have different business needs and associated risk tolerance. Risk tolerances may be reflected in a target Implementation Tier.

Step 2: Orient. Once the scope of the cybersecurity program has been determined for the business line or process, the organization identifies related systems and assets, regulatory requirements, and overall risk approach. The organization then consults sources to identify threats and vulnerabilities applicable to those systems and assets.

Step 3: Create a Current Profile. The organization develops a Current Profile by indicating which Category and Subcategory outcomes from the Framework Core are currently being achieved. If an outcome is partially achieved, noting this fact will help support subsequent steps by providing baseline information.

Step 4: Conduct a Risk Assessment. This assessment could be guided by the organization’s overall risk management process or previous risk assessment activities. The organization analyzes the operational environment in order to discern the likelihood of a cybersecurity event and the impact that the event could have on the organization. It is important that organizations identify emerging risks and use cyber threat information from internal and external sources to gain a better understanding of the likelihood and impact of cybersecurity events.

Step 5: Create a Target Profile. The organization creates a Target Profile that focuses on the assessment of the Framework Categories and Subcategories describing the organization’s desired cybersecurity outcomes. Organizations also may develop their own additional Categories and Subcategories to account for unique organizational risks. The organization may also consider influences and requirements of external stakeholders such as sector entities, customers, and business partners when creating a Target Profile. The Target Profile should appropriately reflect criteria within the target Implementation Tier.

Step 6: Determine, Analyze, and Prioritize Gaps. The organization compares the Current Profile and the Target Profile to determine gaps. Next, it creates a prioritized action plan to address gaps – reflecting mission drivers, costs and benefits, and risks – to achieve the outcomes in the Target Profile. The organization then determines resources, including funding and workforce, necessary to address the gaps. Using Profiles in this manner encourages the organization to make informed decisions about cybersecurity activities, supports risk management, and enables the organization to perform cost-effective, targeted improvements.

Step 7: Implement Action Plan. The organization determines which actions to take to address the gaps, if any, identified in the previous step and then adjusts its current cybersecurity practices in order to achieve the Target Profile. For further guidance, the Framework identifies example Informative References regarding the Categories and Subcategories, but organizations should determine which standards, guidelines, and practices, including those that are sector specific, work best for their needs.

An organization repeats the steps as needed to continuously assess and improve its cybersecurity. For instance, organizations may find that more frequent repetition of the orient step improves the quality of risk assessments. Furthermore, organizations may monitor progress through iterative updates to the Current Profile, subsequently comparing the Current Profile to the Target Profile. Organizations may also use this process to align their cybersecurity program with their desired Framework Implementation Tier.

3.3 Communicating Cybersecurity Requirements with Stakeholders

The Framework provides a common language to communicate requirements among interdependent stakeholders responsible for the delivery of essential critical infrastructure products and services. Examples include:

• An organization may use a Target Profile to express cybersecurity risk management requirements to an external service provider (e.g., a cloud provider to which it is exporting data).

• An organization may express its cybersecurity state through a Current Profile to report results or to compare with acquisition requirements.

• A critical infrastructure owner/operator, having identified an external partner on whom that infrastructure depends, may use a Target Profile to convey required Categories and Subcategories.

• A critical infrastructure sector may establish a Target Profile that can be used among its constituents as an initial baseline Profile to build their tailored Target Profiles.

• An organization can better manage cybersecurity risk among stakeholders by assessing their position in the critical infrastructure and the broader digital economy using Implementation Tiers.

Communication is especially important among stakeholders up and down supply chains. Supply chains are complex, globally distributed, and interconnected sets of resources and processes between multiple levels of organizations. Supply chains begin with the sourcing of products and services and extend from the design, development, manufacturing, processing, handling, and delivery of products and services to the end user. Given these complex and interconnected relationships, supply chain risk management (SCRM) is a critical organizational function.(11)

Cyber SCRM is the set of activities necessary to manage cybersecurity risk associated with external parties. More specifically, cyber SCRM addresses both the cybersecurity effect an organization has on external parties and the cybersecurity effect external parties have on an organization.

A primary objective of cyber SCRM is to identify, assess, and mitigate “products and services that may contain potentially malicious functionality, are counterfeit, or are vulnerable due to poor manufacturing and development practices within the cyber supply chain(12) .” Cyber SCRM activities may include:

• Determining cybersecurity requirements for suppliers,

• Enacting cybersecurity requirements through formal agreement (e.g., contracts),

• Communicating to suppliers how those cybersecurity requirements will be verified and validated,

• Verifying that cybersecurity requirements are met through a variety of assessment methodologies, and

• Governing and managing the above activities.

(11) Communicating Cybersecurity Requirements (Section 3.3) and Buying Decisions (Section 3.4) address only two uses of the Framework for cyber SCRM and are not intended to address cyber SCRM comprehensively.

(12) NIST Special Publication 800-161 , Supply Chain Risk Management Practices for Federal Information Systems and Organizations, Boyens et al, April 2015, https://doi.org/10.6028/NIST.SP.800-161

As depicted in Figure 3, cyber SCRM encompasses technology suppliers and buyers, as well as non-technology suppliers and buyers, where technology is minimally composed of information technology (IT), industrial control systems (ICS), cyber-physical systems (CPS), and connected devices more generally, including the Internet of Things (IoT). Figure 3 depicts an organization at a single point in time. However, through the normal course of business operations, most organizations will be both an upstream supplier and downstream buyer in relation to other organizations or end users.

Figure 3: Cyber Supply Chain Relationships

The parties described in Figure 3 comprise an organization’s cybersecurity ecosystem. These relationships highlight the crucial role of cyber SCRM in addressing cybersecurity risk in critical infrastructure and the broader digital economy. These relationships, the products and services they provide, and the risks they present should be identified and factored into the protective and detective capabilities of organizations, as well as their response and recovery protocols.

In the figure above, “Buyer” refers to the downstream people or organizations that consume a given product or service from an organization, including both for-profit and not-for-profit organizations. “Supplier” encompasses upstream product and service providers that are used for an organization’s internal purposes (e.g., IT infrastructure) or integrated into the products or services provided to the Buyer. These terms are applicable for both technology-based and non-technology-based products and services.

Whether considering individual Subcategories of the Core or the comprehensive considerations of a Profile, the Framework offers organizations and their partners a method to help ensure the new product or service meets critical security outcomes. By first selecting outcomes that are relevant to the context (e.g., transmission of Personally Identifiable Information (PII), mission critical service delivery, data verification services, product or service integrity) the organization then can evaluate partners against those criteria. For example, if a system is being purchased that will monitor Operational Technology (OT) for anomalous network communication, availability may be a particularly important cybersecurity objective to achieve and should drive a Technology Supplier evaluation against applicable Subcategories (e.g., ID.BE-4, ID.SC-3, ID.SC-4, ID.SC-5, PR.DS-4, PR.DS-6, PR.DS-7, PR.DS-8, PR.IP-1, DE.AE-5).

3.4 Buying Decisions

Since a Framework Target Profile is a prioritized list of organizational cybersecurity requirements, Target Profiles can be used to inform decisions about buying products and services. This transaction varies from Communicating Cybersecurity Requirements with Stakeholders (addressed in Section 3.3) in that it may not be possible to impose a set of cybersecurity requirements on the supplier. The objective should be to make the best buying decision among multiple suppliers, given a carefully determined list of cybersecurity requirements. Often, this means some degree of trade-off, comparing multiple products or services with known gaps to the Target Profile.

Once a product or service is purchased, the Profile also can be used to track and address residual cybersecurity risk. For example, if the service or product purchased did not meet all the objectives described in the Target Profile, the organization can address the residual risk through other management actions. The Profile also provides the organization a method for assessing if the product meets cybersecurity outcomes through periodic review and testing mechanisms.

3.5 Identifying Opportunities for New or Revised Informative References

The Framework can be used to identify opportunities for new or revised standards, guidelines, or practices where additional Informative References would help organizations address emerging needs. An organization implementing a given Subcategory, or developing a new Subcategory, might discover that there are few Informative References, if any, for a related activity. To address that need, the organization might collaborate with technology leaders and/or standards bodies to draft, develop, and coordinate standards, guidelines, or practices.

3.6 Methodology to Protect Privacy and Civil Liberties

This section describes a methodology to address individual privacy and civil liberties implications that may result from cybersecurity. This methodology is intended to be a general set of considerations and processes since privacy and civil liberties implications may differ by sector or over time and organizations may address these considerations and processes with a range of technical implementations. Nonetheless, not all activities in a cybersecurity program engender privacy and civil liberties considerations. Technical privacy standards, guidelines, and additional best practices may need to be developed to support improved technical implementations.

Privacy and cybersecurity have a strong connection. An organization’s cybersecurity activities also can create risks to privacy and civil liberties when personal information is used, collected, processed, maintained, or disclosed. Some examples include: cybersecurity activities that result in the over-collection or over-retention of personal information; disclosure or use of personal information unrelated to cybersecurity activities; and cybersecurity mitigation activities that result in denial of service or other similar potentially adverse impacts, including some types of incident detection or monitoring that may inhibit freedom of expression or association.

The government and its agents have a responsibility to protect civil liberties arising from cybersecurity activities. As referenced in the methodology below, government or its agents that own or operate critical infrastructure should have a process in place to support compliance of cybersecurity activities with applicable privacy laws, regulations, and Constitutional requirements.

To address privacy implications, organizations may consider how their cybersecurity program might incorporate privacy principles such as: data minimization in the collection, disclosure, and retention of personal information material related to the cybersecurity incident; use limitations outside of cybersecurity activities on any information collected specifically for cybersecurity activities; transparency for certain cybersecurity activities; individual consent and redress for adverse impacts arising from use of personal information in cybersecurity activities; data quality, integrity, and security; and accountability and auditing.

As organizations assess the Framework Core in Appendix A, the following processes and activities may be considered as a means to address the above-referenced privacy and civil liberties implications:

Governance of cybersecurity risk

• An organization’s assessment of cybersecurity risk and potential risk responses considers the privacy implications of its cybersecurity program.
• Individuals with cybersecurity-related privacy responsibilities report to appropriate management and are appropriately trained.
• Process is in place to support compliance of cybersecurity activities with applicable privacy laws, regulations, and Constitutional requirements.
• Process is in place to assess implementation of the above organizational measures and controls.

Approaches to identifying, authenticating, and authorizing individuals to access organizational assets and systems

• Steps are taken to identify and address the privacy implications of identity management and access control measures to the extent that they involve collection, disclosure, or use of personal information.

Awareness and training measures

• Applicable information from organizational privacy policies is included in cybersecurity workforce training and awareness activities.

• Service providers that provide cybersecurity-related services for the organization are informed about the organization’s applicable privacy policies.

Anomalous activity detection and system and assets monitoring

• Process is in place to conduct a privacy review of an organization’s anomalous activity detection and cybersecurity monitoring.

Response activities, including information sharing or other mitigation efforts

• Process is in place to assess and address whether, when, how, and the extent to which personal information is shared outside the organization as part of cybersecurity information sharing activities.

• Process is in place to conduct a privacy review of an organization’s cybersecurity mitigation efforts.