CIP-003_Workbook_10152019

CIP-003-7 Supplemental Material

can be incorporated into a plan to mitigate the risk of malicious code. The SDT does not intend to obligate a Responsible Entity to conduct a review for every single connection of Removable Media, but rather to implement its plan(s) in a manner that protects all BES Cyber Systems where Removable Media may be used. The intent is to not require a log documenting each connection of Removable Media to a BES Cyber Asset. As a method to detect malicious code, entities may choose to use Removable Media with on- board malicious code detection tools. For these tools, the Removable Media are still used in conjunction with a Cyber Asset to perform the detection. For Section 5.3.1, the Cyber Asset used to perform the malicious code detection must be outside of the BES Cyber System. Requirement R3: The intent of CIP-003-7, Requirement R3 is effectively unchanged since prior versions of the standard. The specific description of the CIP Senior Manager has now been included as a defined term rather than clarified in the Reliability Standard itself to prevent any unnecessary cross-reference to this standard. It is expected that the CIP Senior Manager will play a key role in ensuring proper strategic planning, executive/board-level awareness, and overall program governance. Requirement R4: As indicated in the rationale for CIP-003-7, Requirement R4, this requirement is intended to demonstrate a clear line of authority and ownership for security matters. The intent of the SDT was not to impose any particular organizational structure, but, rather, the intent is to afford the Responsible Entity significant flexibility to adapt this requirement to its existing organizational structure. A Responsible Entity may satisfy this requirement through a single delegation document or through multiple delegation documents. The Responsible Entity can make use of the delegation of the delegation authority itself to increase the flexibility in how this applies to its organization. In such a case, delegations may exist in numerous documentation records as long as the collection of these documentation records shows a clear line of authority back to the CIP Senior Manager. In addition, the CIP Senior Manager could also choose not to delegate any authority and meet this requirement without such delegation documentation. The Responsible Entity must keep its documentation of the CIP Senior Manager and any delegations up-to-date. This is to ensure that individuals do not assume any undocumented authority. However, delegations do not have to be re-instated if the individual who delegated the task changes roles or the individual is replaced. For instance, assume that John Doe is named the CIP Senior Manager and he delegates a specific task to the Substation Maintenance Manager. If John Doe is replaced as the CIP Senior Manager, the CIP Senior Manager documentation must be updated within the specified timeframe, but the existing delegation to the Substation Maintenance Manager remains in effect as approved by the previous CIP Senior Manager, John Doe.

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