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Title page 1

Contents 4

Acknowledgments 6

Abbreviations and Acronyms 7

Introduction 8

Overview of Cybersecurity in Mongolia 10

Assessment of Health Sector Cybersecurity Maturity in Mongolia 12

Using the SCMM to assess the health sector in Mongolia 13

Findings on Cybersecurity Maturity from the Assessment 16

Finding 1: Implementation of Cybersecurity Law 2021 in the health sector is limited 19

Finding 2: The Cybersecurity Law's requirements for CIIs are insufficient for fully protecting critical systems in the health sector 20

Finding 3: Gaps in risk management within the health sector reduce the effectiveness of cybersecurity measures 21

Finding 4: All the assessed CII entities have procedures detailing their organizational cybersecurity measures 22

Finding 5: Health sector ICT procurement lacks consistent evaluation and standardized guidance, resulting in cybersecurity gaps 24

Finding 6: Cybersecurity authorities offer training to health sector stakeholders, but gaps remain 24

Finding 7: HCWs have low cybersecurity awareness and poor cyber hygiene practices 25

Finding 8: The health sector relies on CSIRTs, but response may be suboptimal 26

Finding 9: CSIRTs do not consistently share information on cyber incidents, limiting health sector authorities' ability to learn from incidents 27

Recommendations for Maturing Cybersecurity 29

Action path 1: Improve the governance and management of cybersecurity in the health sector by strengthening the role and mandate... 29

Action path 2: Strengthen the MoH's understanding of the cybersecurity risk landscape across the health sector and develop policy and... 39

Action path 3: Support health sector organizations in strengthening their cyber resilience by adopting best practice measures and aid... 45

Action path 4: Expand the existing approach to training by providing tailored and more regular cybersecurity training across different... 51

Summary of the action paths and recommendations 56

References 59

Annex A. List of resources for further reading 63

Annex B. Recommendations Structured According to the SCMM Dimensions 65

Annex C. Theory of change for each recommendation 67

Tables 12

Table 1. SCMM Layers of Assessment, Dimensions, and Factors 12

Table 2. Description of Participating Stakeholders across the SCMM Layers of Assessment 14

Table 3. Cybersecurity Maturity Matrix of Mongolia's Health Sector 16

Table 4. Overview of the Key Findings 17

Table 5. Topics Covered by CII Entity Information Security Procedures 22

Table 6. Example Line Items in Budgets for Cybersecurity 33

Table 7. Strategic Planning Document Interactions 50

Table 8. Focus Areas of the Proposed Training 55

Table 9. Summary of Action Paths and Recommendations 56

Figures 19

Figure 1. National Institute of Standards and Technology Cybersecurity Framework 2.0 19

Figure 2. Lessons from the National Institute of Standards and Technology Cybersecurity Framework 28

Figure 3. The Four Action Paths 29

Figure 4. Theory of Change Related to Implementation of Recommendation 1 30

Figure 5. Theory of Change Related to Implementation of Recommendation 2 35

Figure 6. Theory of Change Related to Implementation of Recommendation 3 36

Figure 7. Theory of Change Related to Implementation of Recommendation 4 38

Figure 8. Theory of Change Related to Implementation of Recommendation 5 40

Figure 9. Theory of Change Related to Implementation of Recommendation 6 41

Figure 10. Inexhaustive List of Cyber Risk Categories 42

Figure 11. Theory of Change Related to Implementation of Recommendation 7 44

Figure 12. National Institute of Standards and Technology Incident Response Life Cycle 45

Figure 13. Theory of Change Related to Implementation of Recommendation 8 46

Figure 14. Theory of Change Related to Implementation of Recommendation 9 52

Boxes 12

Box 1. Maturity Levels 12

Box 2. Measures to Respond to Cyberattacks and Violations, as Mandated in the Common Procedure 27

Box 3. Approaches to Managing Health Sector Emergency and Incident Response: A Health Sector-Specific Computer Emergency... 32

Box 4. Connecting Recommendation 1 to the Assessment Findings 34

Box 5. Connecting Recommendation 2 to the Assessment Findings 36

Box 6. Connecting Recommendation 3 to the Assessment Findings 37

Box 7. Connecting Recommendation 4 to the Assessment Findings 39

Box 8. Connecting Recommendation 5 to the Assessment Findings 40

Box 9. Connecting Recommendation 6 to the Assessment Findings 43

Box 10. Connecting Recommendation 7 to the Assessment Findings 45

Box 11. Development of Minimum Cybersecurity Standards Designed to Assist Organizations in Managing Security Risks and Their Impact... 47

Box 12. Connecting Recommendation 8 to the Assessment Findings 51

Box 13. Approach to Building Cybersecurity Awareness and Skills among Health Care Providers in Estonia 54

Box 14. Connecting Recommendation 9 to the Assessment Findings 56

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