Vulnerability Management Policy Template

Company Name	[Company Name]
Effective Date	[Date]
Version	[Version Number, e.g., 1.0]
Policy Owner	[CISO/IT Director]
Document Classification	Confidential / Internal Use Only
Parent Policy	Information Security Policy

---

Purpose

This policy establishes the framework for proactively identifying, assessing, prioritizing, remediating, and monitoring security vulnerabilities across [Company Name]'s information technology infrastructure and applications. The purpose is to reduce the organization's attack surface, minimize the risk of exploitation that could compromise the confidentiality, integrity, or availability of sensitive data (including but not limited to Cardholder Data - CHD), ensure operational stability, and maintain compliance with regulatory requirements, including PCI DSS 4.0.1.

---

Scope

This policy applies to all company-owned or managed IT assets, including servers (physical and virtual), workstations, laptops, mobile devices (accessing company resources), network devices, operating systems, databases, applications (developed in-house, commercial off-the-shelf, cloud-based SaaS/PaaS), and IoT devices. It covers all environments including production, development, testing, and disaster recovery, with specific attention to systems within or impacting the Cardholder Data Environment (CDE). All employees, contractors, consultants, and relevant third parties involved in managing, developing, or securing these assets are subject to this policy.

---

Roles and Responsibilities

Role/Group	Key Responsibilities
Executive Management	Provide oversight and ensure adequate resources for the vulnerability management program; Understand and accept residual risks related to vulnerabilities.
CISO/IT Director	Own and approve this policy; Oversee the vulnerability management program's effectiveness and compliance; Establish remediation timelines and risk acceptance criteria.
Information Security Team	Develop and manage the vulnerability management program (scanning, testing, analysis); Operate vulnerability scanning tools; Analyze scan results; Prioritize vulnerabilities; Track remediation; Manage ASV/Pen Test engagements; Report on program status.
IT Operations/System Administrators	Remediate identified vulnerabilities on infrastructure/systems (patching, configuration changes); Provide support for scanning activities; Implement compensating controls where necessary.
Network Engineering Team	Remediate identified vulnerabilities on network devices; Assist with network scanning and penetration testing activities.
Application Development Team	Remediate identified vulnerabilities in bespoke/custom applications; Incorporate secure coding practices to minimize vulnerabilities; Support application scanning and penetration testing.
System/Application Owners	Understand vulnerabilities affecting their assets; Assist in prioritizing remediation based on business impact; Approve remediation plans and related changes.
Cloud Engineering/Operations Team	Remediate vulnerabilities within the scope of responsibility in cloud environments (OS, configurations); Coordinate with CSPs for platform-level vulnerabilities.
Compliance/Audit Team	Independently verify compliance with this policy and remediation timelines; Review scan results, penetration test reports, and remediation evidence.
Change Advisory Board (CAB)	Review and approve significant changes required for vulnerability remediation, especially those impacting critical systems or the CDE.

---

Policy Requirements

1. Vulnerability Identification

• Internal Vulnerability Scanning: Conduct authenticated internal vulnerability scans across all internal assets (servers, workstations, network devices, etc.) at least quarterly and after any significant change in the environment. Scans must be performed by qualified personnel using up-to-date tools configured to identify current threats (PCI DSS Req 11.3.1).
• External Vulnerability Scanning: Conduct external vulnerability scans targeting all externally facing IP addresses and domains at least quarterly and after any significant change. External scans related to the CDE must be performed by a PCI DSS Approved Scanning Vendor (ASV) (PCI DSS Req 11.3.2).
• Penetration Testing:
  • Conduct external and internal penetration testing at least annually and after any significant infrastructure or application upgrade or modification.
  • Testing must cover network and application layers, including tests for segmentation controls (every six months for CDE segmentation).
  • Testing must be performed by qualified internal resources (if organizationally separate) or qualified external third parties, using a documented methodology (e.g., NIST SP 800-115, PTES) (PCI DSS Req 11.4).
• Threat Intelligence Integration: Utilize threat intelligence feeds and sources to identify emerging threats, zero-day vulnerabilities, and exploits relevant to the organization's technology stack. This intelligence informs risk assessment and prioritization.
• Bespoke and Custom Software: Implement processes to identify and address vulnerabilities in all bespoke and custom software, including secure development practices, code reviews, and application security testing (e.g., SAST, DAST) (PCI DSS Req 6.3.2). Maintain an inventory of such software (PCI DSS Req 6.3.1).

2. Risk Assessment and Prioritization

• Vulnerability Analysis: Analyze identified vulnerabilities using industry-standard scoring systems (e.g., Common Vulnerability Scoring System - CVSS) and contextual information.
• Risk Rating: Assign a risk rating (e.g., Critical, High, Medium, Low) to each identified vulnerability based on:
  • CVSS score and temporal/environmental metrics.
  • Exploitability (e.g., availability of exploit code, attacker skill required).
  • Potential impact (considering asset criticality and data sensitivity, especially for CDE assets).
  • Effectiveness of existing compensating controls.
  • Relevant threat intelligence. (PCI DSS Req 6.3.1 requires risk ranking).
• Prioritization: Prioritize remediation efforts based on the assigned risk rating, focusing on Critical and High-risk vulnerabilities, especially those on internet-facing systems, critical infrastructure, and systems within the CDE.

3. Remediation Process

• Responsibility Assignment: Assign responsibility for remediating specific vulnerabilities to the appropriate team (e.g., IT Ops for OS patches, App Dev for code flaws, Network Team for firewall config).
• Remediation Timelines: Establish and adhere to defined timelines for remediating vulnerabilities based on their risk rating:
  • Critical: e.g., within 15-30 days (PCI DSS Req 6.3.3 mandates addressing promptly, often interpreted as 30 days for CDE)
  • High: e.g., within 60-90 days
  • Medium: e.g., within 120-180 days
  • Low: Address during next maintenance cycle or based on resource availability. (Note: Specific timelines must be formally defined and approved).
• Remediation Methods: Remediation may include applying patches, implementing configuration changes, upgrading software/hardware, modifying code, implementing workarounds, or implementing compensating controls (if direct remediation is not feasible and formally accepted).
• Change Management: All remediation actions involving changes to production systems must follow the [Company Name] Change Management Policy.
• Patch Management Integration: Vulnerability remediation involving patches must align with the Patch Management section of the System & Configuration Management Policy.

4. Verification and Closure

• Remediation Validation: After remediation actions are completed, perform verification scans or tests to confirm the vulnerability has been effectively addressed (PCI DSS Req 11.3.1.1, Req 11.3.3).
• Documentation: Document all remediation actions taken, verification results, and dates within the vulnerability tracking system or associated tickets.
• Closure: Formally close tracked vulnerabilities only after successful verification.

5. Exception Management and Risk Acceptance

• Justification: If a vulnerability cannot be remediated within the defined timeline due to legitimate technical constraints or business reasons, a formal exception request must be submitted.
• Compensating Controls: The exception request must include details of any implemented compensating controls designed to mitigate the risk associated with the unremediated vulnerability.
• Risk Acceptance: The residual risk must be formally documented and approved according to the Risk Acceptance Documentation procedure defined in the Governance & Compliance Policy. Risk acceptance must be time-bound and reviewed regularly (at least quarterly for high/critical vulnerabilities).
• Tracking: Maintain a register of all approved exceptions and accepted risks related to vulnerabilities.

6. Reporting and Metrics

• Regular Reporting: Provide regular reports on the status of the vulnerability management program to relevant stakeholders, including IT management, Information Security, and Executive Management. Reports should include scan coverage, number of open vulnerabilities by severity, remediation progress against timelines, overdue vulnerabilities, and approved exceptions.
• Key Metrics: Track key performance indicators (KPIs) such as:
  • Time to detect vulnerabilities.
  • Time to remediate vulnerabilities (by severity).
  • Percentage of assets scanned.
  • Number of overdue vulnerabilities.
  • Number of approved exceptions.
• Audit Records: Maintain comprehensive records of all vulnerability scans, penetration tests, risk assessments, remediation actions, verification results, and exception approvals for audit purposes (minimum one year).

7. Tool Management and Scanner Qualification

• Tool Configuration: Ensure vulnerability scanning tools are configured correctly, kept up-to-date (scanning engine, vulnerability checks), and run with appropriate credentials for authenticated scanning.
• ASV Management: Manage the relationship with the PCI DSS Approved Scanning Vendor (ASV), ensure scan scopes are accurate, review ASV scan reports, and address findings according to ASV program guidelines.
• Personnel Qualification: Ensure personnel performing vulnerability scans and analyzing results are adequately trained and qualified (PCI DSS Req 11.3.1.2). Ensure penetration testers (internal or external) are qualified and maintain organizational independence (PCI DSS Req 11.4.1, Req 11.4.2).

---

Enforcement

• Failure to comply with this Vulnerability Management Policy, particularly regarding remediation timelines for critical systems, may result in disciplinary action, up to and including termination of employment or contract, in accordanceance with established HR policies.
• Systems with persistent critical vulnerabilities that violate this policy may be subject to network quarantine or restricted access until remediated.
• Non-compliance identified through audits will require documented corrective action plans with tracked resolution.
• Exceptions to this policy require formal approval through the Risk Acceptance process detailed in the Governance & Compliance Policy.

---

Revision History

Version	Date	Author	Change Details
1.0	[Date]	[Author Name]	Initial policy release
[Ver #]	[Date]	[Author Name]	[Summary of changes]

---

Approval

Name	Title	Signature	Date
[Exec Name]	[Executive Title, e.g., CIO]		[Date]
[CISO Name]	[CISO/IT Director Title]		[Date]

---

Appendix A: Vulnerability Management Lifecycle Flow

graph TD
    A["Identify Assets (Inventory)"] --> B[Scan, Test, Intel Gathering]
    B --> C{Vulnerability Identified?}
    C --|No|--> B
    C --|Yes|--> D["Analyze and Risk Rate (CVSS, Context)"]
    D --> E{Prioritize Vulnerability}
    E --> F[Assign Remediation Owner]
    F --> G{Remediate: Patch, Config, Code Fix}
    G --> H{Verify Remediation: Re-scan}
    H --|Verified|--> I[Document and Close]
    H --|Not Verified|--> G
    G --|Cannot Remediate|--> J{Request Exception or Risk Acceptance}
    J --> K{Implement Compensating Controls?}
    K --> L[Formal Risk Acceptance Process]
    L --> I
    I --> M[Report Status and Metrics]
    M --> B

    subgraph Identification_Analysis
        A
        B
        C
        D
        E
    end

    subgraph Remediation_Verification
        F
        G
        H
        I
        J
        K
        L
    end

    subgraph Reporting
        M
    end

Appendix B: Vulnerability Risk Rating Matrix - Example

This matrix combines CVSS Base Score with Asset Criticality and Threat Context (simplified).

CVSS Base Score	Asset Criticality	Threat Context (Exploit Available? Actively Targeted?)	Calculated Risk Rating	Example Remediation Timeline
9.0 - 10.0 (Critical)	Critical (e.g., CDE, Domain Controller)	Yes - High Threat	Critical	15-30 Days
9.0 - 10.0 (Critical)	High (e.g., Prod App Server)	Yes - High Threat	Critical	30 Days
9.0 - 10.0 (Critical)	Medium/Low OR No/Low Threat	---	High	60-90 Days
7.0 - 8.9 (High)	Critical	Yes - High Threat	Critical	30 Days
7.0 - 8.9 (High)	High/Critical	Moderate/Low Threat	High	60-90 Days
7.0 - 8.9 (High)	Medium/Low	Any	Medium	120-180 Days
4.0 - 6.9 (Medium)	Critical/High	Yes - High Threat	High	90 Days
4.0 - 6.9 (Medium)	Any	Moderate/Low Threat	Medium	120-180 Days
0.1 - 3.9 (Low)	Any	Any	Low	>180 Days / Opportunistic

Note: This is a simplified example. The actual rating process should be more detailed and formally documented, potentially using CVSS Temporal and Environmental metrics.

Appendix C: Penetration Testing Scope - Key Areas

Penetration tests should cover (as applicable):

• External Network: Attempting to breach the perimeter from the internet. Includes testing firewalls, VPN endpoints, web applications, mail servers, DNS.
• Internal Network: Attempting to escalate privileges and move laterally within the internal network from a standard user or compromised system perspective. Includes testing internal servers, workstations, network segmentation, access controls.
• Wireless Networks: Attempting to gain unauthorized access via corporate or guest wireless networks. Includes testing encryption, authentication, segmentation.
• Web Applications: In-depth testing of web application security (e.g., OWASP Top 10 vulnerabilities like Injection, XSS, Broken Authentication, Misconfigurations).
• Cloud Environments: Testing configurations, access controls (IAM), network security (Security Groups), and hosted applications within the cloud provider's environment (within allowed scope).
• Segmentation Testing: Specifically verifying that network segments (especially the CDE) are properly isolated and that controls prevent unauthorized traffic flow between segments.
• Social Engineering: Testing personnel awareness and response to phishing, pretexting, or physical access attempts (scope to be carefully defined and approved).

Appendix D: PCI DSS 4.0.1 Vulnerability Management Requirements Mapping

PCI DSS Requirement	Relevant Policy Section(s)	Key Controls Covered
Req 5 (Malware)	(Related - EPP policy covers anti-malware)	Anti-malware helps mitigate risks from vulnerabilities being exploited.
Req 6 (Secure Systems)	Policy Req 1 (Bespoke/Custom), Req 3 (Patch Mgmt), Req 2 (Prioritization)	Secure software development practices, Addressing vulnerabilities in bespoke/custom software, Patch management, Risk ranking of vulns.
6.3.1	Policy Req 1 (Bespoke/Custom), Req 2 (Risk Rating)	Maintain inventory of bespoke/custom software; Identify and risk rank vulnerabilities.
6.3.2	Policy Req 1 (Bespoke/Custom), Req 3 (Remediation Methods)	Address vulnerabilities in bespoke/custom software (secure coding, patches, configuration).
6.3.3	Policy Req 3 (Remediation Timelines)	Address critical/high vulnerabilities promptly according to risk ranking (e.g., 30 days for CDE).
Req 11 (Test Security)	Policy Req 1 (Scanning, Pen Testing), Req 4 (Verification), Req 5 (Exceptions), Req 7 (Tool Mgmt/ASV)	Regular vulnerability scanning (internal/external), Penetration testing, Remediation verification, Exception handling, ASV usage.
11.3 (Incl 11.3.1-11.3.3)	Policy Req 1 (Internal/External Scanning), Req 4 (Verification), Req 7 (Tool Mgmt/ASV)	Internal/External scans (quarterly/post-change), Authenticated scans, Qualified personnel, Rescans, ASV usage, Remediation tracking.
11.4 (Incl 11.4.1-11.4.7)	Policy Req 1 (Penetration Testing)	Pen testing methodology, Frequency (annual/post-change), Scope (internal/external, app/network, segmentation), Remediation/Re-testing.
12.2	Policy Req 2 (Risk Assessment/Prioritization), Req 1 (Threat Intel)	Risk assessment process includes identifying threats and vulnerabilities.
12.3.1	Policy Req 2 (Prioritization), Req 3 (Timelines)	Define usage policies for critical technologies; Includes addressing vulnerabilities per risk ranking.