Safeguard 11.4: Establish and Maintain an Isolated Instance of Recovery Data

Safeguard 11.4 requires you to keep at least one instance of your recovery data isolated from your production environment so ransomware, credential misuse, or admin tooling in production can’t corrupt or delete your backups. Operationalize it by implementing an immutable or offline backup copy with separate access controls, then prove it through recurring evidence of isolation, retention, and recovery testing. (CIS Controls v8; CIS Controls Navigator v8)

Key takeaways:

• Isolation means your recovery copy must be protected from routine production admin paths, not just stored in another folder or account. (CIS Controls v8; CIS Controls Navigator v8)
• Build the control around access separation, immutability/offline characteristics, and repeatable restore validation. (CIS Controls v8; CIS Controls Navigator v8)
• Audits fail on evidence gaps, unclear scope, and backups that are “separate” but still deletable by compromised production credentials. (CIS Controls v8; CIS Controls Navigator v8)

Safeguard 11.4: establish and maintain an isolated instance of recovery data requirement is one of the fastest ways to reduce the blast radius of ransomware and destructive insider activity. If an attacker gains administrative control over production systems, the next move is often to encrypt, delete, or silently corrupt backups. 11.4 pushes you to design recovery so at least one copy is outside the control plane the attacker already holds. (CIS Controls v8; CIS Controls Navigator v8)

For a Compliance Officer, CCO, or GRC lead, the challenge is rarely “do we back up data?” The challenge is proving isolation in a way that stands up to an assessor’s questions about identity, access paths, and deletion rights. You need a scoped inventory of “recovery data,” a clear isolation method (offline, immutable, vaulted, or logically isolated with separate admin), and operational runbooks that demonstrate the control works under stress. (CIS Controls v8; CIS Controls Navigator v8)

This page gives requirement-level implementation guidance: who owns what, what to configure, which decisions matter, what evidence to collect on a recurring schedule, and the exam questions that trigger findings.

Regulatory text

Excerpt (provided): “CIS Controls v8 safeguard 11.4 implementation expectation (Establish and Maintain an Isolated Instance of Recovery Data).” (CIS Controls v8; CIS Controls Navigator v8)

Operator meaning: You must maintain a recovery-data copy that is isolated from production so compromise of production systems and credentials does not automatically grant the ability to delete, encrypt, or tamper with that recovery copy. “Maintain” implies the isolation remains true as infrastructure, identities, and backup platforms change, and you can show recurring evidence that it remains isolated. (CIS Controls v8; CIS Controls Navigator v8)

Plain-English interpretation

An “isolated instance” is a backup/recovery copy that sits behind a different set of controls than production. In practice, assessors will look for at least one of these patterns:

• Immutability: Backups cannot be modified or deleted for a defined retention period, even by typical backup administrators.
• Offline/air-gapped copy: A copy is stored offline or in a mode that is not continuously reachable from production networks and admin tooling.
• Separate identity/control plane: Recovery storage and backup management are in a separate tenant/account/subscription with tightly limited, distinct admin roles.
• Vaulted access: Any privileged action against the recovery copy requires additional approval steps, break-glass workflow, or time-bound access. (CIS Controls v8; CIS Controls Navigator v8)

Isolation is not satisfied by “a second copy in the same environment” if the same production admin credentials can delete it, encrypt it, or change retention.

Who it applies to

Entities: Enterprises and technology organizations adopting CIS Controls v8. (CIS Controls v8; CIS Controls Navigator v8)

Operational contexts where 11.4 is usually in scope:

• Centralized backup platforms (on-prem or cloud-managed)
• Endpoint and server backups (including VM snapshots if used as recovery data)
• Cloud storage backups, database backups, SaaS backups
• Critical configuration recovery data (infrastructure-as-code state, secrets recovery materials, identity system exports, key recovery mechanisms) (CIS Controls v8; CIS Controls Navigator v8)

Teams typically involved:

• Infrastructure/Platform (backup tooling, storage, identity boundaries)
• Security (ransomware threat model, privileged access management)
• Application owners (RTO/RPO expectations, restore validation)
• GRC/Compliance (scope, control narrative, evidence cadence)
• Third-party management (if backups are performed by a third party)

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

1) Define scope: what counts as “recovery data”

Create a scoped list of systems and datasets that require recoverability, and map each to its recovery mechanism. Include:

• Production systems and tiering (critical, important, standard)
• Backup sources (servers, endpoints, databases, SaaS)
• Backup destinations (repositories, storage accounts, tape, vaults)
• Retention expectations and owners (CIS Controls v8; CIS Controls Navigator v8)

Deliverable: “Recovery Data Inventory” with system owner sign-off.

2) Choose your isolation pattern (and document the decision)

Pick at least one isolation pattern for the required recovery copy, based on your environment:

• Cloud-heavy: Immutable backups in a dedicated backup vault plus separate admin roles.
• On-prem heavy: Offline copy (tape or offline repository) plus restricted physical/logical access.
• Hybrid: Immutable cloud vault for core systems and offline copy for crown-jewel datasets.

Document:

• What is isolated (which copy)
• What “isolated” means in your design (e.g., separate tenant + MFA + no standing delete permissions)
• Threats addressed (ransomware, credential compromise, malicious admin) (CIS Controls v8; CIS Controls Navigator v8)

Deliverable: Control design record (one page) tied to 11.4.

3) Implement access separation for the isolated copy

Isolation fails most often at identity boundaries. Minimum expectations you can operationalize:

• Separate admin roles for production vs backup-vault administration
• No standing permissions to delete or reduce retention on the isolated copy for production administrators
• MFA enforced for backup administration
• Break-glass accounts are vaulted, monitored, and tested (CIS Controls v8; CIS Controls Navigator v8)

Test you should be able to pass: A compromised production admin account cannot delete, encrypt, or shorten retention of the isolated recovery copy.

4) Implement immutability and/or offline controls

Pick the mechanism that is auditable and operationally realistic:

• Immutable storage controls (e.g., WORM/immutable object lock concepts): document retention settings and who can change them.
• Offline copy controls: document how media is disconnected, stored, and reconnected; include chain-of-custody and access logs.
• Network isolation: restrict management endpoints and storage access to dedicated subnets, firewall rules, or private endpoints; keep the recovery plane separate from production where feasible. (CIS Controls v8; CIS Controls Navigator v8)

Control objective: Even if an attacker can run commands in production, they cannot readily reach or alter the isolated copy.

5) Validate restores from the isolated instance

“Isolated” without “recoverable” is a bad day during an incident. Build a restore validation routine that proves:

• Backups complete successfully
• The isolated copy is present for in-scope systems
• A restore from the isolated copy works for representative systems (apps, databases, file shares)
• Restores follow approved runbooks and access controls (CIS Controls v8; CIS Controls Navigator v8)

Keep this practical: select representative systems and document results consistently.

6) Operationalize ongoing maintenance

Add 11.4 to change management and periodic review:

• New systems must be added to the recovery inventory
• Backup platform changes require a re-check of isolation (roles, retention, delete rights)
• Privileged access reviews include backup-vault roles
• Exceptions are time-bound, risk-accepted, and tracked to closure (CIS Controls v8; CIS Controls Navigator v8)

7) Map the requirement to control operation and recurring evidence capture

Treat evidence as a product, not a scramble. A lightweight way:

• One control narrative
• One evidence checklist
• One recurring collection cadence aligned to your audit cycle Daydream can help by mapping Safeguard 11.4 to your documented control operation and setting up recurring evidence capture so you can answer assessor questions quickly with consistent artifacts. (CIS Controls v8; CIS Controls Navigator v8)

Required evidence and artifacts to retain

Keep evidence tied to three questions: What is isolated, how is it isolated, and can you restore it?

Core artifacts (high value in audits):

• Recovery Data Inventory (systems, owners, backup method, isolated-copy location)
• Architecture diagram showing production vs recovery plane separation
• IAM role matrix: production admin vs backup admin vs restore operator
• Configuration evidence for immutability/offline controls (screenshots/exports of retention/lock settings, vault policies, or offline procedures)
• Restore test records (ticket, runbook used, scope, result, approvals)
• Exception register entries for any systems without an isolated copy (with compensating controls and closure date) (CIS Controls v8; CIS Controls Navigator v8)

Common exam/audit questions and hangups

Expect these questions, and pre-build answers:

1. “Show me the isolated instance.” Be ready to point to the exact repository/vault/media and the controls that make it isolated.
2. “Can a production admin delete it?” Auditors often ask for a permissions walk-through.
3. “Who can change retention or immutability settings?” This is where “separate control plane” matters.
4. “Prove you can restore from the isolated copy.” Provide restore evidence tied to the isolated instance, not a convenient local snapshot.
5. “What’s in scope?” If your inventory is incomplete, the finding writes itself. (CIS Controls v8; CIS Controls Navigator v8)

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	How to avoid
Backups stored “elsewhere” but controlled by same production admin identities	Compromised creds can delete/encrypt backups	Split admin roles; remove standing delete/retention-change rights; enforce MFA for backup admin (CIS Controls v8; CIS Controls Navigator v8)
Relying on snapshots as the isolated copy without hard deletion protections	Snapshots can be deleted quickly if permissions allow	Use immutability or offline copy for at least one instance; document deletion protections (CIS Controls v8; CIS Controls Navigator v8)
No restore testing from the isolated instance	You don’t know if recovery works	Run repeatable restore tests; retain tickets and outputs (CIS Controls v8; CIS Controls Navigator v8)
Unclear scope for SaaS and third-party hosted systems	“We thought the provider handled it”	Contractually confirm backup/restore responsibilities; inventory SaaS recovery data and isolation approach
Evidence exists but is not recurring	Point-in-time proof goes stale	Set a recurring evidence capture workflow; tie it to change management (CIS Controls v8; CIS Controls Navigator v8)

Enforcement context and risk implications

CIS Controls v8 is a framework, not a regulator, and no public enforcement cases were provided in the source catalog for this safeguard. (CIS Controls v8; CIS Controls Navigator v8)

Risk still materializes in examinations and incident post-mortems: inability to demonstrate isolated recovery data is a common root cause of extended outages and unsuccessful ransomware recovery. For GRC, the main exposure is control failure due to weak identity separation, missing scope, and lack of restore validation evidence. (CIS Controls v8; CIS Controls Navigator v8)

Practical 30/60/90-day execution plan

First 30 days (Immediate: design and scope)

• Stand up a Recovery Data Inventory for critical systems and key business services.
• Decide and document the isolation pattern for the required isolated instance.
• Identify identity/control-plane gaps (who can delete backups, who can change retention).
• Draft the control narrative and evidence checklist for safeguard 11.4. (CIS Controls v8; CIS Controls Navigator v8)

Days 31–60 (Near-term: implement and harden)

• Implement access separation: distinct backup-vault roles, MFA, and removal of standing delete rights where feasible.
• Configure immutability/offline workflow for the isolated copy and document configuration states.
• Update incident response and disaster recovery runbooks to include restore-from-isolated procedures.
• Pilot a restore test from the isolated copy for representative systems; capture evidence. (CIS Controls v8; CIS Controls Navigator v8)

Days 61–90 (Operationalize: repeatability and audit readiness)

• Expand scope coverage from critical systems to remaining in-scope systems per your inventory tiering.
• Implement recurring evidence capture (config exports, access reviews, restore-test records).
• Add 11.4 checks to change management for backup platform and IAM changes.
• If you use Daydream, configure the control mapping and recurring evidence requests so your audit packet assembles cleanly each cycle. (CIS Controls v8; CIS Controls Navigator v8)

Frequently Asked Questions

Does “isolated” require an air gap?

No specific method is mandated in the provided excerpt, but you need a design where production compromise does not grant easy tampering with the recovery copy. Many teams meet this with immutability plus separate admin roles. (CIS Controls v8; CIS Controls Navigator v8)

Can I meet safeguard 11.4 with a separate cloud account/tenant?

Yes, if the separation is real: distinct identities, tight cross-account access, and no standing permissions for production admins to delete or alter retention. Document the boundary and prove it with IAM evidence. (CIS Controls v8; CIS Controls Navigator v8)

Are backups handled by a third party still in scope?

Yes. Treat the provider as a third party and confirm the isolation characteristics contractually and operationally, then retain evidence that the isolated instance exists and is protected from production credentials. (CIS Controls v8; CIS Controls Navigator v8)

What evidence do assessors want most often?

They typically ask for the recovery inventory, proof of isolation (IAM/retention configs), and proof you can restore from the isolated copy. Missing recurring evidence is a frequent failure mode. (CIS Controls v8; CIS Controls Navigator v8)

How do we handle exceptions for legacy systems?

Create a time-bound exception with risk acceptance, compensating controls, and a migration plan to a platform that supports a true isolated recovery copy. Track the exception to closure and keep it with the 11.4 evidence packet. (CIS Controls v8; CIS Controls Navigator v8)

What’s the cleanest way to keep this audit-ready all year?

Define one control owner, standardize the evidence checklist, and collect the same artifacts on a recurring cadence tied to change events. Tools like Daydream help by mapping 11.4 to control operation and automating recurring evidence capture. (CIS Controls v8; CIS Controls Navigator v8)