+Artikel 27 Format og indhold af rapporten om gennemgangen af rammen for IKT-risikostyring
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Artikel 27 Format og indhold af rapporten om gennemgangen af rammen for IKT-risikostyring

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1. Oversigt

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Titel Regulering
Artikel 27 1.
Finansielle enheder indsender rapporten om gennemgangen af den ramme for IKT-risikostyring, der er omhandlet i artikel 6, stk. 5, i forordning (EU) 2022/2554, i et søgbart elektronisk format.
Artikel 27 2.

Finansielle enheder medtager alle følgende oplysninger i den i stk. 1 omhandlede rapport:

a) 

et indledende afsnit, der:

i) 

klart identificerer den finansielle enhed, der er genstand for rapporten, og beskriver dens koncernstruktur, hvis det er relevant

ii) 

beskriver konteksten for rapporten med hensyn til karakteren, omfanget og kompleksiteten af den finansielle enheds tjenester, aktiviteter og operationer, dens organisation, identificerede kritiske funktioner, strategi, store igangværende projekter eller aktiviteter, forbindelser og dens afhængighed af interne og kontraherede IKT-tjenester og -systemer eller de konsekvenser, som et samlet tab eller alvorlig forringelse af sådanne systemer ville have med hensyn til kritiske eller vigtige funktioner og markedseffektivitet

iii) 

sammenfatter de vigtigste ændringer i rammen for IKT-risikostyring siden den foregående indsendte rapport

iv) 

giver et sammendrag på ledelsesniveau af den nuværende og den kortsigtede IKT-risikoprofil, trusselsbilledet, den vurderede effektivitet af dens kontroller og den finansielle enheds sikkerhedsstatus

b) 

den dato, på hvilken den finansielle enheds ledelsesorgan godkendte rapporten

c) 

en beskrivelse af årsagen til gennemgangen af rammen for IKT-risikostyring i overensstemmelse med artikel 6, stk. 5, i forordning (EU) 2022/2554

d) 

gennemgangsperiodens start- og slutdato

e) 

en angivelse af, hvilken funktion der har ansvar for gennemgangen

f) 

en beskrivelse af de vigtigste ændringer og forbedringer af rammen for IKT-risikostyring siden den foregående gennemgang

g) 

et sammendrag af resultaterne af gennemgangen og en detaljeret analyse og vurdering af alvorligheden af svaghederne, manglerne og hullerne i rammen for IKT-risikostyring i gennemgangsperioden

h) 

en beskrivelse af foranstaltningerne til afhjælpning af konstaterede svagheder, mangler og huller, herunder alle følgende:

i) 

et sammendrag af de foranstaltninger, der er truffet for at udbedre konstaterede svagheder, mangler og huller

ii) 

en forventet dato for gennemførelse af foranstaltningerne og datoer vedrørende den interne kontrol af gennemførelsen, herunder oplysninger om status for gennemførelsen af disse foranstaltninger på datoen for udarbejdelsen af rapporten, idet der i givet fald redegøres for, om der er risiko for, at fristerne ikke overholdes

iii) 

de værktøjer, der skal anvendes, og identifikation af den funktion, der har ansvar for gennemførelsen af foranstaltningerne, med angivelse af, om værktøjerne og funktionerne er interne eller eksterne

iv) 

en beskrivelse af indvirkningen af de påtænkte ændringer af foranstaltningerne på den finansielle enheds budgetmæssige, menneskelige og materielle ressourcer, herunder de ressourcer, der er afsat til gennemførelsen af eventuelle korrigerende foranstaltninger

v) 

oplysninger om proceduren for underretning af den kompetente myndighed, hvis det er relevant

vi) 

hvis de konstaterede svagheder, mangler eller huller ikke er genstand for korrigerende foranstaltninger, en detaljeret redegørelse for de kriterier, der anvendes til at analysere virkningen af disse svagheder, mangler eller huller med henblik på at evaluere den dermed forbundne resterende IKT-risiko, og af de kriterier, der er anvendt til at acceptere den relaterede resterende risiko

i) 

oplysninger om den planlagte videre udvikling af rammen for IKT-risikostyring

j) 

konklusioner fra gennemgangen af rammen for IKT-risikostyring

k) 

oplysninger om tidligere gennemgange, herunder:

i) 

en liste over de hidtidige gennemgange

ii) 

hvis det er relevant, en status for gennemførelsen af de korrigerende foranstaltninger, der er angivet i den seneste rapport

iii) 

hvis de foreslåede korrigerende foranstaltninger i tidligere gennemgange har vist sig at være ineffektive eller har medført uventede udfordringer, en beskrivelse af, hvordan disse korrigerende foranstaltninger kan forbedres, eller af disse uventede udfordringer

l) 

informationskilder, der er anvendt ved udarbejdelsen af rapporten, herunder alle følgende:

i) 

for andre finansielle enheder end mikrovirksomheder, jf. artikel 6, stk. 6, i forordning (EU) 2022/2554, resultaterne af interne revisioner

ii) 

resultaterne af overensstemmelsesvurderingerne

iii) 

resultater af test af digital operationel modstandsdygtighed og, hvis det er relevant, resultaterne af avanceret test af IKT-værktøjer, -systemer og -processer baseret på trusselsbaseret penetrationstest (TLPT)

iv) 

eksterne kilder.

Med henblik på litra c) skal rapporten, hvis gennemgangen blev indledt efter tilsynsmæssige instrukser eller konklusioner udledt af relevante test- eller revisionsprocesser for digital operationel modstandsdygtighed, indeholde udtrykkelige henvisninger til sådanne instrukser eller konklusioner, som gør det muligt at identificere årsagen til at indlede revisionen. Hvis gennemgangen blev indledt efter IKT-relaterede hændelser, skal rapporten indeholde en liste over alle IKT-relaterede hændelser med analyser af de grundlæggende årsager til hændelser.

Med henblik på litra f) skal beskrivelsen indeholde en analyse af ændringernes indvirkning på den finansielle enheds strategi for digital operationel modstandsdygtighed, på den finansielle enheds ramme for intern IKT-kontrol og på den finansielle enheds forvaltning af IKT-risikostyring.

1.1 Referencer

1.2 Identificerede krav

1.3 Relaterede standarder

2. Identificerede krav

Krav
Kilde Krav

3. Relaterede standarder

Standarder
Kilde Krav
SCF Status Reporting To Governing Body

Description

Mechanisms exist to provide governance oversight reporting and recommendations enabling executives to make decisions about matters considered material to the organization's Security, Compliance & Resilience Program (SCRP).

Possible Solutions & Considerations

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

∙ Quarterly Business Review (QBR)
∙ Simple security status dashboard (spreadsheet or slide deck)
∙ Email status updates to owner/manager

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

∙ Quarterly Business Review (QBR)
∙ Structured security metrics report (incidents, patching status, training completion)
∙ Documented reporting cadence

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

∙ Quarterly Business Review (QBR)
∙ Formal security status reports to leadership
∙ KPI/KRI dashboard (e.g., Power BI, Tableau, or GRC tool reporting)

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

∙ Quarterly Business Review (QBR)
∙ Executive security dashboard with KPIs/KRIs
∙ Board-level reporting on material risk indicators
∙ Automated reporting via GRC platform

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

∙ Quarterly Business Review (QBR)
∙ Board and audit committee cybersecurity briefings
∙ Integrated GRC dashboard with real-time metrics
∙ SEC cybersecurity disclosure-ready reporting processes (if applicable)

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

SCR-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 Tracked

Cybersecurity & Data Protection Governance (GOV) 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 GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV 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 GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ Organizational leadership maintains an informal process to review and respond to trends.

Level 3 Well Defined

Cybersecurity & Data Protection Governance (GOV) 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 GOV 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 GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain GOV 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).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to provide governance oversight reporting and recommendations to those entrusted to make executive decisions about matters considered material to the organization's Security, Compliance & Resilience Program (SCRP).

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.
SCF Status Reporting To Governing Body

Description

Mechanisms exist to provide governance oversight reporting and recommendations enabling executives to make decisions about matters considered material to the organization's Security, Compliance & Resilience Program (SCRP).

Possible Solutions & Considerations

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

∙ Quarterly Business Review (QBR)
∙ Simple security status dashboard (spreadsheet or slide deck)
∙ Email status updates to owner/manager

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

∙ Quarterly Business Review (QBR)
∙ Structured security metrics report (incidents, patching status, training completion)
∙ Documented reporting cadence

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

∙ Quarterly Business Review (QBR)
∙ Formal security status reports to leadership
∙ KPI/KRI dashboard (e.g., Power BI, Tableau, or GRC tool reporting)

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

∙ Quarterly Business Review (QBR)
∙ Executive security dashboard with KPIs/KRIs
∙ Board-level reporting on material risk indicators
∙ Automated reporting via GRC platform

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

∙ Quarterly Business Review (QBR)
∙ Board and audit committee cybersecurity briefings
∙ Integrated GRC dashboard with real-time metrics
∙ SEC cybersecurity disclosure-ready reporting processes (if applicable)

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

SCR-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 Tracked

Cybersecurity & Data Protection Governance (GOV) 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 GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV 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 GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ Organizational leadership maintains an informal process to review and respond to trends.

Level 3 Well Defined

Cybersecurity & Data Protection Governance (GOV) 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 GOV 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 GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain GOV 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).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to provide governance oversight reporting and recommendations to those entrusted to make executive decisions about matters considered material to the organization's Security, Compliance & Resilience Program (SCRP).

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.
SCF Contacts With Authorities

Description

Mechanisms exist to identify and document appropriate contacts with relevant law enforcement and regulatory bodies.

Possible Solutions & Considerations

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

∙ Documented list of law enforcement and regulatory contacts (FBI, CISA, state AG)
∙ MS-ISAC free membership (https://www.cisecurity.org/ms-isac)

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

∙ Documented contacts with FBI Cyber Division, CISA, and relevant regulators
∙ MS-ISAC or sector-specific ISAC membership
∙ Pre-established law enforcement liaisons for incident response

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

∙ Integrated Security Incident Response Team (ISIRT) with defined authority contacts
∙ CISA Cyber Liaison and FBI Cyber Division contacts
∙ Sector ISAC membership (e.g., FS-ISAC, H-ISAC, E-ISAC)
∙ Regulatory notification contact list (e.g., FTC, OCR, state regulators)

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

∙ Integrated Security Incident Response Team (ISIRT) with pre-established authority relationships
∙ Formal engagement with law enforcement (FBI, USSS, CISA)
∙ Sector ISAC active membership with information sharing participation
∙ Regulatory breach notification contacts and documented procedures

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

∙ Dedicated government liaison program (FBI, CISA, NSA, sector regulators)
∙ Active ISAC membership with classified threat briefing access (where applicable)
∙ Pre-established breach notification workflows for all applicable regulators
∙ Integrated Security Incident Response Team (ISIRT) with 24/7 law enforcement contact protocols

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

Cybersecurity & Data Protection Governance (GOV) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with GOV domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Governance-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT/cybersecurity personnel.
▪ Cybersecurity and data protection governance is informally assigned as an additional duty to existing IT/cybersecurity personnel.
▪ Cybersecurity personnel identify and maintain contact information for local and national law enforcement (e.g., FBI field office) in case of cybersecurity incidents that require law enforcement involvement.

Level 2 Planned Tracked

Cybersecurity & Data Protection Governance (GOV) 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 GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV 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 GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.

Level 3 Well Defined

Cybersecurity & Data Protection Governance (GOV) 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 GOV 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 GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain GOV 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).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to identify and document appropriate contacts with relevant law enforcement and regulatory bodies.

Level 4 Quantitatively Controlled

Cybersecurity & Data Protection Governance (GOV) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

Level 5 Continuously Improving

Cybersecurity & Data Protection Governance (GOV) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.
▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
SCF Identify Critical Assets

Description

Mechanisms exist to identify and document the critical Technology Assets, Applications, Services and/or Data (TAASD) that support essential missions and business functions.

Possible Solutions & Considerations

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

∙ Business Impact Analysis (BIA)
∙ Criticality assessments

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

∙ Business Impact Analysis (BIA)
∙ Criticality assessments

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

∙ Business Impact Analysis (BIA)
∙ Criticality assessments

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

∙ Business Impact Analysis (BIA)
∙ Criticality assessments

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

∙ Business Impact Analysis (BIA)
∙ Criticality assessments

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

Business Continuity & Disaster Recovery (BCD) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with BCD domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Contingency management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Limited technologies exist to support near real-time network infrastructure failover (e.g., redundant ISPs and redundant power).
▪ IT and/or cybersecurity personnel develop limited Disaster Recovery Plans (DRP) to recover business-critical Technology Assets, Applications and/or Services (TAAS) and services.

Level 2 Planned Tracked

Business Continuity & Disaster Recovery (BCD) 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 BCD domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with BCD 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 BCD domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Business Continuity / Disaster Recovery (BC/DR)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ BC/DR may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Business stakeholders and process owners identify business-critical TAASD and External Service Providers (ESPs).
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to identify single points of failure from a TAASD perspective.
▪ Production TAASD support business-critical application and services failover.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to develop BC/DR plans to recover business-critical TAASD.
▪ Data/process owners conduct a Business Impact Analysis (BIA) at least annually, or after any major technology or process change, to identify TAASD that are critical to the business, as well as single points of failure.
▪ Business stakeholders and process owners define Recovery Time Objectives (RTOs) for business-critical TAASD.
▪ Business stakeholders and process owners define Recovery Point Objectives (RPOs) for business-critical TAASD.

Level 3 Well Defined

Asset Management (AST) 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 AST 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 AST domain capabilities are well-documented and kept current by process owners.
▪ An IT Asset Management (ITAM) team, or similar function, is appropriately staffed and supported to implement and maintain AST domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of ITAM operations (e.g., ITAM platform, (e.g., Configuration Management Database (CMBD) Asset Management solution).
▪ 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 AST 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 identify and document the critical TAASD that support essential missions and business functions.

Level 4 Quantitatively Controlled

Business Continuity & Disaster Recovery (BCD) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Contingency Plan Testing & Exercises

Description

Mechanisms exist to conduct tests and/or exercises to evaluate the contingency plan's effectiveness and the organization's readiness to execute the plan.

Possible Solutions & Considerations

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

∙ Tabletop exercises

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

∙ Tabletop exercises

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

∙ Tabletop exercises

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

∙ Tabletop exercises
∙ Simulated events

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

∙ Tabletop exercises
∙ Simulated events

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

Business Continuity & Disaster Recovery (BCD) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with BCD domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Contingency management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Limited technologies exist to support near real-time network infrastructure failover (e.g., redundant ISPs and redundant power).
▪ IT and/or cybersecurity personnel develop limited Disaster Recovery Plans (DRP) to recover business-critical Technology Assets, Applications and/or Services (TAAS) and services.

Level 2 Planned Tracked

Business Continuity & Disaster Recovery (BCD) 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 BCD domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with BCD 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 BCD domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Business Continuity / Disaster Recovery (BC/DR)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ BC/DR may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.

Level 3 Well Defined

Business Continuity & Disaster Recovery (BCD) 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 BCD 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 BCD domain capabilities are well-documented and kept current by process owners.
▪ A Business Continuity & Disaster Recovery (BC/DR) team, or similar function, is appropriately staffed and supported to implement and maintain BCD domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of BC/DR operations (e.g., BC/DR planning software, Disaster Recovery as a Service (DRaaS), Orchestration and Automation Tools).
▪ 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 BCD 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 conduct tests and/or exercises to evaluate the contingency plan's effectiveness and the organization's readiness to execute the plan.

Level 4 Quantitatively Controlled

Business Continuity & Disaster Recovery (BCD) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Conformity Monitoring

Description

Mechanisms exist to validate that Technology Assets, Applications, Services and/or Data (TAASD) conform to the organization's security, compliance and/or resilience policies, standards and other applicable requirements.

Possible Solutions & Considerations

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

∙ Information Assurance Program (IAP)
∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE)
∙ GRC solution (e.g., SCFConnect, SimpleRisk, etc.)

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

∙ Information Assurance Program (IAP)
∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE)
∙ GRC solution (e.g., SCFConnect, SimpleRisk, etc.)

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

∙ Information Assurance Program (IAP)
∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)

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

∙ Information Assurance Program (IAP)
∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)

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

∙ Information Assurance Program (IAP)
∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)

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

Compliance (CPL) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with CPL domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Compliance management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Compliance efforts are narrowly-limited to certain compliance requirements.
▪ IT and/or cybersecurity personnel use an informal process to govern statutory, regulatory and contractual compliance obligations.
▪ IT and/or cybersecurity personnel self-identify a set of controls that are used to conduct cybersecurity and data privacy control assessments.
▪ For specific statutory, regulatory and/or contractual obligations, stakeholders may contract with a third-party auditor/assessor to perform an independent assessment of cybersecurity and data protection controls.

Level 2 Planned Tracked

Compliance (CPL) 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 CPL domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CPL 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 CPL domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Compliance management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Compliance management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ External compliance requirements for cybersecurity and data privacy are identified and documented, based on applicable laws, regulations and contractual obligations.
▪ IT and/or cybersecurity personnel use an entity-defined set of controls to conduct cybersecurity and data protection control assessments.

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 validate that Technology Assets, Applications, Services and/or Data (TAASD) conform to the organization's security, compliance and/or resilience policies, standards and other applicable requirements.

Level 4 Quantitatively Controlled

Compliance (CPL) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Internal Audit Function

Description

Mechanisms exist to implement an internal audit function that is capable of providing executive management with insights into the overall management of the organization's security, compliance and resilience capabilities.

Possible Solutions & Considerations

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

∙ Internal audit program

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

∙ Internal audit program

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

∙ Internal audit program

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

∙ Internal audit program

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

∙ Internal audit program

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 implement an internal audit function that is capable of providing senior organization management with insights into the appropriateness of the organization's technology and information governance processes.

Level 4 Quantitatively Controlled

Compliance (CPL) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Security, Compliance & Resilience Status Reporting

Description

Mechanisms exist to submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

Possible Solutions & Considerations

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

∙ Maintain records for any required compliance filings

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

∙ Designate a compliance contact for required reporting
∙ Track reporting deadlines

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

∙ Compliance calendar for required submissions
∙ Documented reporting procedures

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

∙ Compliance tracking platform
∙ Dedicated compliance officer
∙ Standardized reporting templates

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

∙ Enterprise GRC platform for compliance reporting
∙ Dedicated compliance team
∙ Automated regulatory submission tracking
∙ Legal and compliance integration

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL 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 CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance 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 CPL 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 submit status reporting of the organization's security, compliance and/or resilience program to applicable statutory and/or regulatory authorities, as required.

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.
SCF Incident Tracking Repository

Description

Mechanisms exist to maintain a repository of cybersecurity events and incidents that documents:
(1) Details of the incident (e.g., category, severity and affected parties);
(2) Remediation actions taken through incident closure; and
(3) A summary from the Root Cause Analysis (RCA), if applicable.

Possible Solutions & Considerations

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

∙ Basic incident response plan
∙ Designate incident response contact

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

∙ Documented incident response plan
∙ Incident log
∙ Designated IR team

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

∙ Formal incident response program
∙ IR playbooks
∙ Tabletop exercises

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

∙ Enterprise incident response program
∙ 24/7 SOC monitoring
∙ SOAR platform

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

∙ Enterprise SOC with SIEM/SOAR (e.g., Splunk SOAR, Palo Alto XSOAR)
∙ IR retainer
∙ Threat hunting

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

SCR-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 Tracked

Incident Response (IRO) 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 IRO 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 IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 maintain a repository of cybersecurity events and incidents that documents:
(1) Details of the incident (e.g., category, severity and affected parties);
(2) Remediation actions taken through incident closure; and
(3) A summary from the Root Cause Analysis (RCA), if applicable.

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.
SCF Capabilities Deficiency Tracking

Description

Mechanisms exist to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Possible Solutions & Considerations

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

SCR-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 Tracked

Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

Level 3 Well Defined

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment software).
▪ 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 IAO 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 govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Level 4 Quantitatively Controlled

Information Assurance (IAO) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Capabilities Deficiency Tracking

Description

Mechanisms exist to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Possible Solutions & Considerations

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

SCR-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 Tracked

Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

Level 3 Well Defined

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment software).
▪ 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 IAO 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 govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Level 4 Quantitatively Controlled

Information Assurance (IAO) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Capabilities Deficiency Tracking

Description

Mechanisms exist to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Possible Solutions & Considerations

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

SCR-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 Tracked

Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

Level 3 Well Defined

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment software).
▪ 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 IAO 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 govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Level 4 Quantitatively Controlled

Information Assurance (IAO) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Capabilities Deficiency Tracking

Description

Mechanisms exist to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Possible Solutions & Considerations

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

SCR-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 Tracked

Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

Level 3 Well Defined

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment software).
▪ 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 IAO 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 govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Level 4 Quantitatively Controlled

Information Assurance (IAO) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Capabilities Deficiency Tracking

Description

Mechanisms exist to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Possible Solutions & Considerations

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

SCR-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 Tracked

Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

Level 3 Well Defined

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment software).
▪ 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 IAO 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 govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Level 4 Quantitatively Controlled

Information Assurance (IAO) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Capabilities Deficiency Tracking

Description

Mechanisms exist to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Possible Solutions & Considerations

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

SCR-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 Tracked

Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

Level 3 Well Defined

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment software).
▪ 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 IAO 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 govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Level 4 Quantitatively Controlled

Information Assurance (IAO) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Capabilities Deficiency Tracking

Description

Mechanisms exist to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Possible Solutions & Considerations

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

SCR-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 Tracked

Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

Level 3 Well Defined

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment software).
▪ 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 IAO 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 govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Level 4 Quantitatively Controlled

Information Assurance (IAO) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Capabilities Deficiency Tracking

Description

Mechanisms exist to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Possible Solutions & Considerations

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

∙ Plan of Action and Milestones (POA&M)
∙ Risk register

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

SCR-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 Tracked

Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

Level 3 Well Defined

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment software).
▪ 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 IAO 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 govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum:
(1) Deficiency tracking number;
(2) Applicable security, compliance and/or resilience control;
(3) Description of the deficiency(ies);
(4) Risk associated with the deficiency(ies);
(5) Source deficiency identification/detection;
(6) Temporary compensating controls, if applicable;
(7) Point of Contact (POC) (e.g., asset/process owner);
(8) Resources required to conduct remediation actions;
(9) Planned remedial actions to the deficiency(ies);
(10) Proposed remediation timeline; and
(11) Disposition statement (e.g., closeout summary).

Level 4 Quantitatively Controlled

Information Assurance (IAO) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Allocation of Resources

Description

Mechanisms exist to identify and allocate resources for management, operational, technical and data protection requirements within business process planning for projects / initiatives.

Possible Solutions & Considerations

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

∙ Include security tasks in project plans

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

∙ Security requirements in project planning
∙ Project security checklist

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

∙ Cybersecurity road map
∙ Prioritized list of cybersecurity expenses

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

∙ Cybersecurity road map
∙ Prioritized list of cybersecurity expenses

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

∙ Cybersecurity road map
∙ Prioritized list of cybersecurity expenses

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

Project & Resource Management (PRM) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with PRM domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Project management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Level 2 Planned Tracked

Project & Resource Management (PRM) 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 PRM domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with PRM 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 PRM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Project & Resource Management -related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Project & Resource Management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ The Chief Information Officer (CIO), or similar function, analyzes the organization's business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements.
▪ A Project Management Office (PMO), or project management function, enables the implementation of cybersecurity and data protection-related resource planning controls across the System Development Lifecycle (SDLC) for all high-value projects.
▪ The PM function enables project involvement for Information Assurance Program (IAP) as part of the organization's established project management processes to ensure both cybersecurity and data protection principles are identified and implemented.
▪ Quarterly Business Review (QBR), or similar status reporting, exists to provide recurring reports on the state of the cybersecurity and data protection program.

Level 3 Well Defined

Project & Resource Management (PRM) 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 PRM 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 PRM domain capabilities are well-documented and kept current by process owners.
▪ A Project Management Office (PMO), or similar function, is appropriately staffed and supported to implement and maintain PRM domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of project and resource management operations (e.g., project management solution).
▪ 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 PRM 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).
▪ The Chief Information Officer (CIO), or similar function, analyzes the organization's business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements.
▪ An implemented and operational capability exists to identify and allocate resources for management, operational, technical and data protection requirements within business process planning for projects / initiatives.

Level 4 Quantitatively Controlled

Project & Resource Management (PRM) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Risk Management Program

Description

Mechanisms exist to facilitate the implementation of strategic, operational and tactical risk management controls that are aligned with:
(1) The organization's Enterprise Risk Management (ERM); and
(2) Industry-recognized cybersecurity risk management practices.

Possible Solutions & Considerations

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

∙ Risk Management Program (RMP)

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

∙ Risk Management Program (RMP)

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

∙ Risk Management Program (RMP)

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

∙ Risk Management Program (RMP)

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

∙ Risk Management Program (RMP)

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

Risk Management (RSK) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with RSK domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Risk management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel use an informal process to identify, assess, remediate and report on risk.
▪ Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ Data/process owners are expected to self-manage risks associated with their Technology Assets, Applications, Services and/or Data (TAASD), based on the organization's published policies and standards, including the identification, remediation and reporting of risks.

Level 2 Planned Tracked

Risk Management (RSK) 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 RSK domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with RSK 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 RSK domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported.
▪ Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
▪ Business process owners (BPOs) are made aware of cybersecurity and data protection risk(s).

Level 3 Well Defined

Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 facilitate the implementation of strategic, operational and tactical risk management controls.

Level 4 Quantitatively Controlled

Risk Management (RSK) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Risk Tolerance

Description

Mechanisms exist to define organizational risk tolerance, the specified range of acceptable results.

Possible Solutions & Considerations

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

∙ Risk Management Program (RMP)
∙ Defined risk tolerance

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

∙ Risk Management Program (RMP)
∙ Defined risk tolerance

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

∙ Risk Management Program (RMP)
∙ Defined risk tolerance

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

∙ Risk Management Program (RMP)
∙ Defined risk tolerance

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

∙ Risk Management Program (RMP)
∙ Defined risk tolerance

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

SCR-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 Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 define organizational risk tolerance, the specified range of acceptable results.

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.
SCF Risk Owner

Description

Mechanisms exist to identify a risk owner for each item in the risk register to ensure clear accountability for unremediated risks.

Possible Solutions & Considerations

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

∙ Risk register with assigned owner column
∙ Designated security lead responsible for risk follow-up

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

∙ Risk register with mandatory owner assignment
∙ Regular risk owner check-ins on remediation progress

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

∙ Formal risk ownership assignment in risk register
∙ GRC platform with risk owner workflow
∙ Management accountability for open risk items

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

∙ GRC platform with risk ownership and accountability workflow
∙ Executive reporting on risk owner compliance
∙ Risk owner training and awareness

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

∙ Enterprise GRC platform with risk ownership management
∙ Automated risk owner escalation and reminders
∙ Board-level reporting on material risk accountability
∙ Risk ownership integrated into performance management

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

Risk Management (RSK) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with RSK domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Risk management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel use an informal process to identify, assess, remediate and report on risk.
▪ Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ Data/process owners are expected to self-manage risks associated with their Technology Assets, Applications, Services and/or Data (TAASD), based on the organization's published policies and standards, including the identification, remediation and reporting of risks.

Level 2 Planned Tracked

Risk Management (RSK) 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 RSK domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with RSK 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 RSK domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported.
▪ Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
▪ Business process owners (BPOs) are made aware of cybersecurity and data protection risk(s).

Level 3 Well Defined

Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 identify a risk owner for each item in the risk register to ensure clear accountability for unremediated risks.

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.
SCF Risk Response

Description

Mechanisms exist to ensure proper risk response actions were performed to remediate findings from security, compliance and/or resilience-related:
(1) Assessments;
(2) Audits; and/or
(3) Incidents.

Possible Solutions & Considerations

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

SCR-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 Tracked

Risk Management (RSK) 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 RSK domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with RSK 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 RSK domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported.
▪ Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
▪ Business process owners (BPOs) are made aware of cybersecurity and data protection risk(s).

Level 3 Well Defined

Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 ensure proper risk response actions were performed to remediate findings from security, compliance and/or resilience-related:
(1) Assessments;
(2) Audits; and/or
(3) Incidents.

Level 4 Quantitatively Controlled

Risk Management (RSK) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Risk Response

Description

Mechanisms exist to ensure proper risk response actions were performed to remediate findings from security, compliance and/or resilience-related:
(1) Assessments;
(2) Audits; and/or
(3) Incidents.

Possible Solutions & Considerations

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

SCR-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 Tracked

Risk Management (RSK) 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 RSK domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with RSK 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 RSK domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported.
▪ Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
▪ Business process owners (BPOs) are made aware of cybersecurity and data protection risk(s).

Level 3 Well Defined

Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 ensure proper risk response actions were performed to remediate findings from security, compliance and/or resilience-related:
(1) Assessments;
(2) Audits; and/or
(3) Incidents.

Level 4 Quantitatively Controlled

Risk Management (RSK) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Risk Treatment Options

Description

Mechanisms exist to select appropriate risk treatment options, based on applicable risk assessment findings, including:
(1) Mitigating the risk to an acceptable level;
(2) Avoiding the risk (e.g., terminating the project);
(3) Transferring the risk to a third party (e.g., insurance and service provider); or
(4) Accepting the risk.

Possible Solutions & Considerations

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

∙ Risk response decision policy (accept, mitigate, transfer, avoid)

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

∙ Risk response decision policy (accept, mitigate, transfer, avoid)

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

∙ Formal risk response options policy
∙ Documented criteria for each risk response type

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

∙ Enterprise risk response framework
∙ Risk committee decision-making process

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

∙ Enterprise GRC platform with risk response workflows
∙ Formal risk appetite and tolerance framework

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

SCR-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 Tracked

Risk Management (RSK) 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 RSK domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with RSK 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 RSK domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported.
▪ Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
▪ Business process owners (BPOs) are made aware of cybersecurity and data protection risk(s).

Level 3 Well Defined

Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 select appropriate risk treatment options, based on applicable risk assessment findings.

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.
SCF Risk Remediation

Description

Mechanisms exist to remediate risks to an acceptable level.

Possible Solutions & Considerations

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

∙ Risk Management Program (RMP)
∙ Risk register
∙ Plan of Action & Milestones (POA&M)

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

Risk Management (RSK) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with RSK domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Risk management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel use an informal process to identify, assess, remediate and report on risk.
▪ Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ Data/process owners are expected to self-manage risks associated with their Technology Assets, Applications, Services and/or Data (TAASD), based on the organization's published policies and standards, including the identification, remediation and reporting of risks.

Level 2 Planned Tracked

Risk Management (RSK) 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 RSK domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with RSK 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 RSK domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported.
▪ Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
▪ Business process owners (BPOs) are made aware of cybersecurity and data protection risk(s).

Level 3 Well Defined

Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 remediate risks to an acceptable level.

Level 4 Quantitatively Controlled

Risk Management (RSK) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.
SCF Risk Treatment Plan (RTP)

Description

Mechanisms exist to formalize a Risk Treatment Plan (RTP) that applicable stakeholders will utilize to remediate identified risks according to a defined timeline.

Possible Solutions & Considerations

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

∙ Get management sign-off when accepting risks

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

∙ Risk acceptance authorization policy
∙ Management approval for accepted risks

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

∙ Formal risk acceptance process with management authorization

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

∙ Enterprise risk acceptance workflow with executive authorization

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

∙ Enterprise GRC platform with risk acceptance workflow (e.g., RSA Archer, ServiceNow GRC)
∙ Automated approval routing

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

SCR-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 Tracked

Risk Management (RSK) 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 RSK domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with RSK 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 RSK domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported.
▪ Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
▪ Business process owners (BPOs) are made aware of cybersecurity and data protection risk(s).

Level 3 Well Defined

Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 formalize a Risk Treatment Plan (RTP) that applicable stakeholders will utilize to remediate identified risks according to a defined timeline.

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.
SCF Penetration Testing

Description

Mechanisms exist to conduct penetration testing on Technology Assets, Applications and/or Services (TAAS).

Possible Solutions & Considerations

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

∙ Annual external vulnerability scan; penetration test when required by customers/contracts

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

∙ Annual penetration test by qualified tester

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

∙ Annual penetration test by qualified third-party tester

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

∙ Enterprise penetration testing program
∙ Annual external and internal pen tests

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

∙ Enterprise penetration testing program
∙ Annual and event-driven pen tests
∙ Red team exercises
∙ Purple teaming

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

Vulnerability & Patch Management (VPM) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with VPM domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Attack Surface Management (ASM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.

Level 2 Planned Tracked

Vulnerability & Patch Management (VPM) 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 VPM domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with VPM 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 VPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Vulnerability management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Vulnerability management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel, or contracted professionals, conduct annual penetration testing on network segments hosting High Value Assets (HVAs).

Level 3 Well Defined

Vulnerability & Patch Management (VPM) 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 VPM 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 VPM domain capabilities are well-documented and kept current by process owners.
▪ A vulnerability management team, or similar function, is appropriately staffed and supported to implement and maintain VPM domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of vulnerability management operations (e.g., patch management solution and vulnerability scanning solution).
▪ 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 VPM 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 conduct penetration testing on Technology Assets, Applications and/or Services (TAAS).

Level 4 Quantitatively Controlled

Vulnerability & Patch Management (VPM) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.