A well-structured Coordinated Vulnerability Disclosure (CVD) policy, grounded in international standards like ISO/IEC 29147 and ISO/IEC 30111, and compliant with regulatory requirements such as the NIS 2 Directive, ensures that organizations can manage vulnerabilities effectively while fostering trust with the security community. By following this structured approach, organizations can not only protect their assets but also contribute to the broader goal of enhancing global cybersecurity.
The structure of our Coordinated Vulnerability Disclosure (CVD) policy is informed by various international standards and legal regulations, including ISO/IEC 29147 and ISO/IEC 30111, as well as the NIS 2 Directive in the European Union. Below is a detailed breakdown of the recommended structure, including the purpose of each section and its regulatory origins.
1. Introduction
- Purpose: Provides an overview of the CVD policy, outlining the organization’s commitment to managing and disclosing vulnerabilities in a coordinated manner.
- Source: The general principles of ISO/IEC 29147, which emphasize the importance of transparency and collaboration in vulnerability disclosure.
2. Scope
- Purpose: Defines what types of vulnerabilities are covered by the policy and identifies the systems, services, or products that fall within its purview.
- Source: ISO/IEC 29147 recommends clearly defining the scope to ensure clarity for both internal and external stakeholders.
3. Submission Guidelines
- Purpose: Details the process for reporting vulnerabilities, including the preferred communication channels (e.g., a dedicated email address or web portal), the format for submissions, and any necessary encryption methods.
- Source: ISO/IEC 29147 emphasizes the need for clear guidelines to facilitate secure and effective vulnerability reporting.
4. Eligibility and Scope of Reports
- Purpose: Clarifies what constitutes an eligible vulnerability report, including the inclusion and exclusion criteria for reported issues (e.g., in-scope vs. out-of-scope vulnerabilities).
- Source: Derived from both ISO/IEC 29147 and ISO/IEC 30111, which provide guidance on classifying and handling different types of vulnerabilities.
5. Acknowledgment and Response Process
- Purpose: Outlines the timeline and process for acknowledging receipt of a vulnerability report, as well as the steps involved in responding to the report, such as initial triage, risk assessment, and the communication of remediation actions.
- Source: This section aligns with the response process detailed in ISO/IEC 30111, which provides a framework for addressing vulnerabilities once they have been reported.
6. Disclosure Policy
- Purpose: Describes the organization’s policy on public disclosure, including conditions under which vulnerabilities will be disclosed, the timeline for disclosure, and how the organization collaborates with the reporting party and other stakeholders.
- Source: The NIS 2 Directive in the EU mandates coordinated vulnerability disclosure, emphasizing that entities must have clear policies for managing and disclosing vulnerabilities in a responsible manner.
7. Legal and Safe Harbor Provisions
- Purpose: Ensures that researchers are protected from legal action when they report vulnerabilities in good faith, provided they comply with the CVD policy. This section may also cover the organization’s legal obligations and any relevant jurisdictional considerations.
- Source: Many jurisdictions, including those under the NIS 2 Directive, require organizations to offer legal protection to researchers acting in good faith. This concept is also supported by ISO/IEC 29147.
8. Communication and Coordination
- Purpose: Details how the organization will coordinate with external entities, such as vendors, customers, and regulatory bodies, during the vulnerability disclosure process.
- Source: Coordinated communication is a key principle of ISO/IEC 29147, which stresses the importance of collaboration between all parties involved in the disclosure process.
9. Remediation and Mitigation
- Purpose: Describes how vulnerabilities will be addressed, including the development and deployment of patches or other mitigation strategies, and how these actions will be communicated to affected users.
- Source: ISO/IEC 30111 provides guidelines on the remediation process, ensuring that vulnerabilities are effectively mitigated.
10. Review and Improvement
- Purpose: Establishes a process for regularly reviewing and updating the CVD policy to reflect changes in technology, law, and best practices.
- Source: Continuous improvement is a principle embedded in both ISO/IEC 29147 and ISO/IEC 30111, ensuring that the policy remains effective and up-to-date.