+Sensitive / Regulated Data Access Mapping

Sensitive / Regulated Data Access Mapping

Description

Mechanisms exist to leverage data-specific Access Control Lists (ACL) or Interconnection Security Agreements (ISAs) to generate a logical map of the parties with whom sensitive and/or regulated data is shared.

Possible Solutions & Considerations

Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2

∙ Access Control Lists (ACL)
∙ Interconnection Security Agreements (ISAs)

Small Business (10-49 staff) / BLS Firm Size Classes 3-4

∙ Access Control Lists (ACL)
∙ Interconnection Security Agreements (ISAs)

Medium Business (50-249 staff) / BLS Firm Size Classes 5-6

∙ Access Control Lists (ACL)
∙ Interconnection Security Agreements (ISAs)

Large Business (250-999 staff) / BLS Firm Size Classes 7-8

∙ Access Control Lists (ACL)
∙ Interconnection Security Agreements (ISAs)

Enterprise (> 1,000 staff) / BLS Firm Size Class 9

∙ Access Control Lists (ACL)
∙ Interconnection Security Agreements (ISAs)

SCR-CMM

Level 0 Not Performed

Practices 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 Informally

Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Limited media handling guidance exists for users.

Level 2 Planned Tracked

Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to document where sensitive/regulated data is stored, transmitted and/or processed.

Level 3 Well Defined

Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners.
▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform).
▪ 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 DCH 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 leverage data-specific Access Control Lists (ACL) or Interconnection Security Agreements (ISAs) to generate a logical map of the parties with whom sensitive/regulated data is shared.

Level 4 Quantitatively Controlled

Utilize 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 Improving

Utilize 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 Odkazy

1.2 Identifikované požadavky

1.3 Související regulace

2. Identifikované požadavky

Požadavky

3. Související regulace

Regulace

Propojené úkoly

Vazby
is related to Annual
is related to relative Control Weighting = 10
is related to Data
is related to Protect
is related to SCRM Focus Tier 2 OPERATIONAL
is related to SCRM Focus Tier 3 TACTICAL
blocks Loss of Accountability / Attribution
blocks Unauthorized Access
blocks Loss, Theft or Damage of Assets
blocks Unauthorized Modification / Loss of System Integrity
blocks Unauthorized Retention / Inability to Dispose of Data
blocks Business / Service Interruption
blocks Data Loss / Integrity Compromise
blocks Reduced Operational Productivity
blocks System / Data Compromise (Technical Vector)
blocks System / Data Compromise (Non-Technical Vector)
blocks Revenue Loss
blocks Contractual Default / Termination
blocks Loss of Competitive Advantage
blocks Reputational Harm / Loss of Stakeholder Trust
blocks Regulatory / Legal / Contractual Financial Liability
blocks Exposure from Unaddressed Vulnerabilities
blocks System / Service Compromise
blocks Failure to Support Business / Mission Objectives
blocks Unaddressed Security / Compliance Exposure
blocks Unperformed / Unowned Control Responsibilities
blocks Uncontrolled Internal Security / Privacy Exposure
blocks Uncontrolled Third-Party Security / Privacy Exposure
blocks Loss of Investigative / Evidentiary Capability
blocks Incident Persistence / Recurrence
blocks Incident Response / Recovery Cost
blocks Undetected / Delayed Detection of Adverse Activity
is related to Semi-Annual
is related to relative Control Weighting = 09
is related to Identify
is related to SCRM Focus Tier 1 STRATEGIC
blocks Loss of Authorization / Certification / License
blocks Lack of oversight of third-party controls
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Unreliable Assurance / Decision Information
blocks Delayed Containment / Increased Incident Impact
blocks Third-Party Cybersecurity Compromise / Exposure
blocks Sub-Tier / Fourth-Party Supply Chain Exposure
blocks Loss of Confidentiality
blocks Privacy Harm / Unauthorized Processing
blocks Drought & Water Shortage
blocks Earthquakes
blocks Fire & Wildfires
blocks Floods
blocks Hurricanes & Tropical Storms
blocks Landslides & Debris Flow
blocks Pandemic (Disease) Outbreaks
blocks Severe Weather
blocks Space Weather
blocks Thunderstorms & Lightning
blocks Tornadoes
blocks Tsunamis
blocks Volcanoes
blocks Winter Storms & Extreme Cold
blocks Malicious Cyber Activity
blocks Dysfunctional Management Practices
blocks Human Error
blocks Technical / Mechanical Failure
blocks Statutory / Regulatory / Contractual Change
blocks Data Quality Degradation / Data Poisoning
blocks Fraud, Corruption and/or Intentional Criminal Conduct
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
is blocked by DCH-09 Sensitive / Regulated Data Access Mapping – Assessment Procedure
blocks 03.01.03 Information Flow Enforcement
blocks 03.01.20 Use of External Systems
blocks 03.12.05 Information Exchange
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