Here’s a draft Vulnerability Remediation Policy tailored for Method13 that aligns with PCI DSS requirements (especially PCI DSS v4.0 requirements 6.3.3, 6.3.4, 6.4.1, and 11.3.1) and also reflects your desired remediation timelines.


Vulnerability Remediation Policy

1. Purpose

The purpose of this policy is to establish standardized requirements for identifying, assessing, prioritizing, and remediating security vulnerabilities across Method13 systems, applications, and networks. This policy ensures compliance with industry best practices and regulatory obligations, including PCI DSS.

2. Scope

This policy applies to all Method13 information systems, networks, applications, and services that process, store, or transmit company or customer data. It covers production, development, test, and cloud environments where Method13 has management responsibility.

3. Policy Statement

All security vulnerabilities must be identified, assessed for severity, prioritized for remediation, and remediated within defined timelines to reduce the risk of exploitation. Method13 uses industry-standard scoring mechanisms (CVSS v3.1 or vendor severity ratings) to categorize vulnerabilities.

4. Roles and Responsibilities

  • InfoSec / Security Team: Responsible for monitoring vulnerability feeds, performing regular scanning, assessing severity, assigning remediation timelines, and verifying closure.

  • System Owners / Administrators: Responsible for applying patches, fixes, and configuration changes within the timelines defined by this policy.

  • Change Management Team: Ensures remediation activities follow approved change management processes.

  • Executive Management: Provides resources and ensures business units adhere to remediation requirements.

5. Vulnerability Classification & Remediation Timelines

Vulnerabilities will be classified using CVSS v3.1 base scores or vendor-provided severity. Method13 requires the following timelines for remediation:

Severity Definition Remediation Timeline
Critical (CVSS 9.0–10.0 or vendor critical) Vulnerabilities that are actively exploited, allow remote code execution, privilege escalation, or directly affect PCI scope systems. As soon as functionally reasonable, but no later than 7 days from identification. Emergency patching may be required.
High (CVSS 7.0–8.9) Vulnerabilities that pose significant risk, including potential unauthorized access or exposure of sensitive data. Within 30 days of identification.
Medium (CVSS 4.0–6.9) Vulnerabilities with moderate impact that could facilitate attacks when combined with other flaws. Within 30 days of identification.
Low (CVSS 0.1–3.9) Vulnerabilities with minimal impact or low likelihood of exploitation. Remediated as available or addressed in the normal patch cycle (e.g., 90 days).

6. PCI DSS Compliance Alignment

To maintain compliance with PCI DSS requirements, Method13 will:

  1. Perform Vulnerability Identification: Regular internal and external vulnerability scans, plus penetration testing, to identify vulnerabilities (PCI DSS Req. 11.3.1, 11.4).

  2. Prioritize Based on Risk: Severity ratings will drive remediation timelines (PCI DSS Req. 6.3.3).

  3. Apply Patches and Fixes: Critical and high vulnerabilities in system components and applications will be addressed within industry-accepted timeframes (PCI DSS Req. 6.3.3, 6.3.4).

  4. Verification and Retesting: All remediated vulnerabilities will be validated through rescans or penetration testing where required (PCI DSS Req. 11.3.1).

  5. Documentation and Exceptions: All remediation efforts, delays, or exceptions must be documented, approved by management, and include compensating controls if applicable (PCI DSS Req. 6.3.4).

7. Exception Management

If remediation within the defined timelines is not feasible due to operational impact, a formal risk acceptance and mitigation plan must be documented. Exceptions require:

  • Written business justification.

  • Approval from the Security Team and Executive Management.

  • Implementation of compensating controls to reduce risk until remediation is complete.

8. Monitoring and Reporting

  • Vulnerability scanning will occur at least quarterly and after any significant changes to systems.

  • Status reports on outstanding vulnerabilities will be reviewed by management monthly.

  • All vulnerabilities and remediation efforts will be logged and retained in accordance with Method13’s record retention policy.

9. Enforcement

Employees or contractors who fail to comply with this policy may face disciplinary action, up to and including termination of employment or contract, as well as possible legal action.

10. Review and Updates

This policy will be reviewed at least annually, or whenever PCI DSS requirements change, to ensure continued compliance and effectiveness.


 

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