Safeguard 11.3: Protect Recovery Data

Safeguard 11.3: protect recovery data requirement is where backup programs often fail under real pressure. Many teams can show that backups “exist,” but cannot prove those backups are protected from the same threats that hit production, especially ransomware, credential theft, or malicious insiders. CIS Controls v8 calls out protecting recovery data because recovery is your last line of defense when preventive controls fail. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing this safeguard is to convert it into a single control that has: a clear owner, defined systems in scope (backup platforms, backup repositories, snapshot systems, DR replicas), a minimum security baseline (encryption, access restrictions, segmentation/isolation, monitoring), and recurring tests that produce evidence. If you can’t show the control runs on a cadence and generates artifacts, you will struggle in audits and customer security reviews, even if your engineers “know” the backups are fine.

This page gives you a practical implementation blueprint, an evidence bundle, common audit questions, and a phased execution plan you can run with your infrastructure and security teams. ²

Regulatory text

Framework excerpt: “CIS Controls v8 safeguard 11.3 implementation expectation (Protect Recovery Data).” ²

Operator interpretation: You must secure the confidentiality and integrity of backup and recovery data so an attacker (or unauthorized admin) cannot discover it, encrypt it, delete it, or silently modify it. In practice, auditors expect you to address:

• Access control: tightly limit who and what can access backup platforms and backup data.
• Protection from tampering/deletion: reduce the chance that compromised credentials can destroy recovery points.
• Confidentiality: prevent backup copies from becoming an easy data exfiltration source.
• Recoverability: prove that protected recovery data can still restore critical services. ¹

Plain-English requirement (what “protect recovery data” means)

Recovery data includes backups, snapshots, replicated volumes, database dumps, golden images, and DR site copies. “Protect” means you apply security controls that match the threat model: ransomware targets backup catalogs and repositories; credential theft targets backup admins; insiders target “delete” and “expire” functions; and misconfigurations expose backup storage to the internet.

If you can answer these three questions with evidence, you are usually in good shape:

1. Who can access or administer recovery data, and is that access least-privilege?
2. Can a compromised production credential delete or encrypt backups?
3. Can you restore from protected recovery points in a reasonable time, and have you proven it? ¹

Who it applies to (entity + operational context)

Applies to: Enterprises and technology organizations adopting CIS Controls v8 as a security baseline. ²

Operational scope (typical):

• Backup and recovery tooling (SaaS backup, on-prem backup servers, backup agents, backup orchestration).
• Storage that holds recovery data (object storage buckets, backup appliances, NAS, tape, cold storage).
• Snapshots and replication systems (hypervisor snapshots, storage snapshots, database replication backups).
• DR environments and “break glass” recovery accounts.
• Third parties that store or manage your backups (cloud providers, managed service providers). “Third party” is in scope because access paths and custody matter. ¹

What you actually need to do (step-by-step)

Use this as a runbook for implementing the safeguard 11.3: protect recovery data requirement.

Step 1: Define “recovery data” and map it to systems and owners

• Inventory where recovery data exists (platform + storage + account/subscription/project).
• Assign an owner for each recovery domain (e.g., endpoint backups, server backups, SaaS backups, database backups).
• Classify recovery data sensitivity based on what it contains (production data often ends up inside backups).
  Output: Recovery Data Register (system, location, owner, data type, retention). ¹

Step 2: Establish a minimum security baseline for recovery data repositories

Set a baseline your engineers can implement consistently:

• Encryption in transit and at rest for backup data and backup metadata where supported.
• Administrative access controls: restrict console/API access to backup systems; enforce MFA where supported; use SSO/IdP groups.
• Service-to-service permissions: backup agents should not have delete privileges for backup repositories unless required, and even then tightly scoped.
• Network isolation: keep backup admin interfaces off the public internet; limit inbound management access.
• Logging: collect audit logs from backup platforms and storage (admin actions, delete events, policy changes).
  Output: “Recovery Data Protection Standard” (one-page baseline + exceptions). ¹

Step 3: Reduce ransomware blast radius with separation and tamper resistance

You are trying to prevent “single credential compromise = lost backups.”

• Separate backup administrative identities from day-to-day production admin identities.
• Use storage features that prevent or delay deletion/modification where feasible (for example, immutable storage modes or write-once patterns supported by your environment).
• Segment backup storage accounts/projects/subscriptions from production accounts when possible.
• Protect backup encryption keys (limit key admins; log key use; consider separate key custody from backup admins when feasible).
  Output: Documented architecture decisions + IAM separation model. ¹

Step 4: Protect the backup control plane

Most ransomware campaigns go after the backup system first (catalog, policies, schedules).

• Harden backup servers or management appliances (patching, EDR coverage, restricted admin access).
• Restrict who can change retention policies, delete jobs, or disable protections.
• Alert on high-risk events (mass deletion, retention reduced, immutability disabled, new admin added).
  Output: Backup platform hardening checklist + alert list and routing. ¹

Step 5: Validate restore viability and integrity on a defined cadence

Protection without restorability is a paper control.

• Define restore test scenarios for critical systems (at least one from each major recovery method: file restore, VM restore, database restore, SaaS restore).
• Include integrity checks where possible (hash/checksum verification or application-level validation).
• Track failed tests to closure with remediation owners and due dates.
  Output: Restore test reports + remediation tickets with closure evidence. ¹

Step 6: Convert this into an auditable control (control card + evidence bundle)

This is where GRC teams win time:

• Write a requirement-level control card: objective, scope, owner, frequency, inputs, steps, exception process.
• Define the “minimum evidence bundle” that must be produced each cycle.
• Run periodic control health checks and record results.
  If you use Daydream, store the control card, map systems in scope, and standardize evidence requests so backup owners don’t reinvent artifacts every audit. ¹

Required evidence and artifacts to retain

Auditors and customers will ask for proof across design and operating effectiveness. Keep:

• Recovery Data Register (systems, repositories, owners, retention).
• Access control evidence: role/group listings, screenshots/exports of admin roles, MFA/SSO enforcement proof, break-glass account list and approvals.
• Encryption evidence: configuration evidence for encryption at rest/in transit; key management ownership and access lists.
• Isolation/tamper-resistance evidence: architecture diagrams, storage policy settings, immutability/WORM settings where applicable, segmentation notes.
• Logging/monitoring evidence: sample audit logs (admin actions), alert rules, alert tickets.
• Restore test evidence: test plan, execution records, results, and remediation tracking.
• Exception register: approved deviations with compensating controls and expiry dates. ¹

Common exam/audit questions and hangups

Use these to prep stakeholders before fieldwork:

• “Show me who can delete backups or change retention. How is that approved and logged?”
• “Are backup admins separate from production admins? How do you prevent credential reuse?”
• “Where are backups stored, and are they accessible from production networks?”
• “Do you encrypt backups, and who can access the keys?”
• “Show recent restore tests and evidence the restored system worked.”
• “If your primary domain/IdP is compromised, how do you access recovery data safely?” ¹

Frequent implementation mistakes and how to avoid them

• Mistake: Treating backup storage as low sensitivity. Backups frequently contain the crown jewels. Apply data protection controls equal to production.
  • Avoid: classify recovery data as sensitive by default; document deviations.
• Mistake: Shared admin accounts across production and backups.
  • Avoid: separate roles and credentials; tightly control “delete” and “policy change” rights.
• Mistake: “We back up” without proof of “we can restore.”
  • Avoid: schedule restore tests and store results in a consistent evidence folder or GRC system.
• Mistake: One-time implementation with no operating cadence.
  • Avoid: a control card with trigger events (new backup platform, new repository, M&A, major environment change) and periodic health checks. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this safeguard, so this page does not list cases.

Risk-wise, failure to protect recovery data typically shows up as:

• Longer outages because recovery points were deleted, encrypted, or untrusted.
• Breach amplification because backups expose historical sensitive data.
• Audit findings that escalate quickly because backup weaknesses undermine incident response and business continuity claims. ¹

Practical 30/60/90-day execution plan

Use phased milestones rather than exact day counts if your environment is complex; the goal is to produce evidence early and then expand coverage.

First 30 days (stabilize and define)

• Name an owner for Safeguard 11.3 and backup domain owners.
• Build the Recovery Data Register for your highest-criticality systems.
• Draft the Recovery Data Protection Standard (access, encryption, logging, isolation expectations).
• Identify top gaps: who can delete backups, whether admin roles are separated, and where logs go. ¹

Days 31–60 (implement guardrails + evidence)

• Implement least-privilege roles for backup admins and backup operators; enforce MFA/SSO where supported.
• Turn on or validate encryption settings and key access restrictions.
• Centralize logging for backup administrative actions and set alerting for destructive events.
• Publish the control card and minimum evidence bundle; run the first control health check. ¹

Days 61–90 (prove recoverability + harden against ransomware paths)

• Implement stronger isolation/tamper-resistance measures feasible in your stack (segmentation, separate accounts, immutability modes).
• Run restore tests for representative critical systems; track remediation to closure.
• Validate third-party backup providers: access model, logging availability, and deletion protections.
• Create an exception register for anything you cannot meet yet, with compensating controls and an end date. ¹

Frequently Asked Questions

Does “recovery data” include snapshots and replicas, or only traditional backups?

Treat snapshots, replicas, database dumps, golden images, and DR copies as recovery data if you would use them to restore operations. Scope it explicitly in your Recovery Data Register so audits do not turn into a terminology debate. ¹

What’s the minimum access control expectation for backup administrators?

Limit backup admin rights to named roles, enforce strong authentication where supported, and restrict who can delete backups or change retention. Keep an export or screenshot of role assignments and admin activity logs as evidence. ¹

How do I handle third-party managed backup services under this safeguard?

Require clarity on who can access, export, or delete your backups, and how actions are logged. Document the shared responsibility model and keep the third party’s control evidence with your own (for example, access model and audit logs availability). ¹

If we encrypt backups, is that sufficient to satisfy the safeguard?

Encryption addresses confidentiality but does not prevent deletion, policy tampering, or restore failure. Pair encryption with least privilege, tamper resistance, and restore testing evidence. ¹

What evidence do auditors accept for restore testing?

Provide a restore test plan, execution record (who/when/what was restored), outcome validation, and remediation tickets for failures. A “successful job” report alone rarely proves the data can restore into a working service. ¹

We have legacy systems that can’t meet the baseline. What’s the right exception pattern?

Log an exception with scope, business justification, compensating controls (extra monitoring, restricted network paths, manual approvals), and an expiry or review date. Auditors generally react better to time-bound exceptions than undocumented gaps. ¹

Footnotes

1. CIS Controls v8

2. CIS Controls v8; CIS Controls Navigator v8