This phase typically requires the most work, as you must implement all required controls that are currently missing or incorrectly configured. The time required scales directly with the number of devices and users in your organisation.
Configure Boundary Firewalls
You must protect every device in scope with a correctly configured firewall. For all firewalls, you must: change default administrative passwords to a strong and unique password; prevent access to the administrative interface from the internet (unless protected by MFA or IP allow list with properly managed password authentication); block unauthenticated inbound connections by default; ensure inbound firewall rules are approved and documented; remove or disable unnecessary firewall rules.
Harden All Systems
You must proactively manage your computers and network devices. You must regularly: remove and disable unnecessary user accounts (such as guest accounts and administrative accounts that won’t be used); change any default or guessable account passwords; remove or disable unnecessary software; disable any auto-run feature which allows file execution without user authorisation; ensure users are authenticated before allowing them access to organisational data or services.
Implement Access Controls
Your organisation must: have in place a process to create and approve user accounts; authenticate users with unique credentials before granting access; remove or disable user accounts when they’re no longer required; implement MFA where available (authentication to cloud services must always use MFA); use separate accounts to perform administrative activities only (no emailing, web browsing or other standard user activities); remove or disable special access privileges when no longer required.
Deploy & Configure Malware Protection
You must make sure that a malware protection mechanism is active on all devices in scope. For Windows or MacOS devices using anti-malware software, it must be configured to: be updated in line with vendor recommendations; prevent malware from running; prevent the execution of malicious code; prevent connections to malicious websites over the internet.
Establish Patch Management
All software on in-scope devices must: be licensed and supported; be removed from devices when it becomes unsupported (or removed from scope); have automatic updates enabled where possible; be updated, including vulnerability fixes, within 14 days of release for critical or high risk vulnerabilities (CVSS v3 base score of 7 or above, or identified by vendor as critical/high risk).
Address Cloud Services
If your organisation’s data or services are hosted on cloud services, these services must be in scope. For cloud services, the applicant organisation is always responsible for ensuring all controls are implemented, but some controls can be implemented by the cloud service provider. You must make sure that the cloud provider has committed to implementing relevant controls via contractual clauses or documents referenced by contract.