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+Minimize Visitor Personal Data (PD) |
Minimize Visitor Personal Data (PD)DescriptionMechanisms exist to minimize the collection of Personal Data (PD) contained in visitor access records.Possible Solutions & ConsiderationsMicro-Small Business (<10 staff) / BLS Firm Size Classes 1-2∙ Visitor log collects only name, company, host and timeSmall Business (10-49 staff) / BLS Firm Size Classes 3-4∙ Visitor log limited to necessary fields∙ No retention of ID copies Medium Business (50-249 staff) / BLS Firm Size Classes 5-6∙ Visitor management system configured for data minimization∙ Defined retention period for visitor records Large Business (250-999 staff) / BLS Firm Size Classes 7-8∙ Visitor management system with privacy-by-default configuration∙ Data Protection Impact Assessment (DPIA) for visitor processing ∙ Automated deletion after retention period Enterprise (> 1,000 staff) / BLS Firm Size Class 9∙ Enterprise visitor management with data minimization, retention automation and privacy notices∙ Privacy review of visitor data collection ∙ Regional configuration for jurisdictional requirements SCR-CMMLevel 0 Not PerformedPractices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.Level 1 Performed InformallySCR-CMM Level 1 criteria definitions are not available for this control:▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned TrackedPhysical & Environmental Security (PES) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:▪ Policies and standards associated with PES domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with PES domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with PES domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Physical security / facilities management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Physical security / facilities management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Physical security controls and technologies primarily focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. Level 3 Well DefinedPhysical & Environmental Security (PES) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:▪ Policies and standards associated with PES domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with PES domain capabilities are well-documented and kept current by process owners. ▪ A facilities management team, or similar function, is appropriately staffed and supported to implement and maintain NET domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of physical and environmental security operations (e.g., facility management solution, visitor log management automation and proximity badge access). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with PES domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to minimize the collection of Personal Data (PD) contained in visitor access records. Level 4 Quantitatively ControlledUtilize SCR-CMM Level 3 criteria definitions:▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define. Level 5 Continuously ImprovingUtilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define. 1. Přehled
1.1 Odkazy1.2 Identifikované požadavky1.3 Související regulace2. Identifikované požadavky
3. Související regulace
Propojené úkoly
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