Coordinated Vulnerability Disclosure

5.6.1 Understanding CVD

Coordinated Vulnerability Disclosure (CVD) is the process of working with security researchers who find vulnerabilities. FDA references ISO 29147:2018 and ISO 30111:2013 as standards for CVD.

Why CVD Matters

Benefits:

• Find vulnerabilities before attackers
• Build researcher relationships
• Demonstrate security maturity
• Improve products

Without CVD:

• Researchers go public immediately
• No time to develop patches
• Surprised by disclosures
• Reputation damage

5.6.2 Setting Up Your CVD Program

Essential Elements

Clear Reporting Channel:

security@manufacturer.com
https://manufacturer.com/security
PGP key for encrypted reports

Published Policy:

• Scope (what products)
• Process (what happens)
• Timeline (response times)
• Recognition (acknowledgments)

Example CVD Policy Structure:

# Coordinated Vulnerability Disclosure Policy

## Scope
This policy applies to all [Manufacturer] medical devices 
and associated software.

## Reporting
Email: security@manufacturer.com
PGP: [Key fingerprint]
Web: https://manufacturer.com/report-vulnerability

## Our Commitment
- Acknowledge receipt within 5 business days
- Provide severity assessment within 10 days
- Regular updates on progress
- Coordinate disclosure timing

## Recognition
- Public acknowledgment (with permission)
- Inclusion in security advisories
- Good faith commitment

## Out of Scope
- Physical attacks requiring device modification
- Social engineering of our staff
- Denial of service attacks

5.6.3 Managing Researcher Relationships

Initial Response Template:

Subject: Re: Vulnerability Report - [Device Name]

Thank you for your vulnerability report dated [date].

We confirm receipt and are beginning our assessment.

Tracking number: VULN-2024-001
Expected initial assessment: [date + 10 days]

We'll provide regular updates on our progress.

Best regards,
[Product Security Team]

Relationship Best Practices:

• Respond promptly
• Be professional
• Show appreciation
• Keep promises
• Give credit

5.6.4 Disclosure Timeline Negotiation

Work with researchers on disclosure timing:

Standard Timeline:

• 0 days: Report received
• 5 days: Acknowledgment
• 10 days: Initial assessment
• 30-120 days: Patch development
• X days: Coordinated disclosure

Factors Affecting Timeline:

• Vulnerability severity
• Exploit complexity
• Patch difficulty
• Deployment challenges
• Patient risk