+Measures of Performance
---+Key Performance Indicators (KPIs)
---+Key Risk Indicators (KRIs)
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Measures of Performance
Description
Mechanisms exist to develop, report and monitor Security, Compliance & Resilience Program (SCRP) measures of performance.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Manually-generated metrics (spreadsheet-based dashboard)
∙ Basic security scorecard (patch %, training completion %, incident count)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Manually-generated metrics with structured reporting template
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Simple security dashboard (e.g., Power BI free tier, Google Looker Studio)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Automated metrics via GRC or security tool integrations
∙ Security dashboard with defined KPIs/KRIs (e.g., Power BI, GRC platform reporting)
∙ 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
∙ GRC platform with integrated metrics and dashboards
∙ Automated data collection from security tools (SIEM, vulnerability scanner, etc.)
∙ Defined measurement cadence aligned with board reporting schedule
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise GRC platform with automated metrics collection and reporting
∙ Security metrics integrated with business intelligence platform (e.g., Tableau, Power BI)
∙ Automated benchmarking against industry standards (e.g., CIS Benchmarks, CISA metrics)
∙ Real-time security posture dashboards for executive and board reporting
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, procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ Basic metrics are developed to provide operational oversight of a limited scope of cybersecurity and data protection controls.
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 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 develop, report and monitor Security, Compliance & Resilience Program (SCRP) measures of performance.
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.
1. Übersicht
| Bezeichnung |
Standard |
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Key Performance Indicators (KPIs)
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Description
Mechanisms exist to develop, report and monitor Key Performance Indicators (KPIs) to assist organizational management in performance monitoring and trend analysis of the Security, Compliance & Resilience Program (SCRP).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Manually-generated metrics (spreadsheet)
∙ Key security KPIs: patch compliance %, training completion %, incident count, open vulnerability age
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Manually-generated metrics with defined KPI thresholds
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Monthly/quarterly KPI reporting to leadership
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Defined security KPI library (CIS, CISA, or custom)
∙ Automated KPI collection via GRC or SIEM integration
∙ 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
∙ Formal KPI program with defined targets, thresholds, and owners
∙ GRC platform with automated KPI dashboards (e.g., SCFConnect, Cyturus, etc.)
∙ Board-level security KPI reporting cadence
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise KPI program aligned to NIST, CIS, or custom security frameworks
∙ Automated KPI collection and reporting via GRC/SIEM integration
∙ Board and audit committee KPI reporting with trend analysis
∙ KPIs mapped to business risk appetite and strategic objectives
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
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 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 develop, report and monitor Key Performance Indicators (KPIs) to assist organizational management in performance monitoring and trend analysis of the Security, Compliance & Resilience Program (SCRP).
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.
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Key Risk Indicators (KRIs)
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Description
Mechanisms exist to develop, report and monitor Key Risk Indicators (KRIs) to assist senior management in performance monitoring and trend analysis of the Security, Compliance & Resilience Program (SCRP).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Manually-generated metrics (spreadsheet)
∙ Basic risk indicators: critical unpatched vulnerabilities, failed logins, open security incidents
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Manually-generated KRI tracking with alert thresholds
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Documented risk tolerance thresholds
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Defined KRI library tied to organizational risk register
∙ Automated KRI monitoring via GRC platform or SIEM (e.g., Splunk, Microsoft Sentinel)
∙ 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
∙ Formal KRI program with defined risk appetite thresholds
∙ Automated KRI monitoring with escalation triggers
∙ GRC platform with KRI dashboards linked to risk register
∙ Regular KRI reporting to risk committee
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise KRI program integrated with risk management framework
∙ Automated real-time KRI monitoring with AI-assisted anomaly detection
∙ Board-level risk indicator reporting with trend analysis
∙ KRIs linked to enterprise risk appetite and materiality thresholds
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.
▪ Organizational leadership maintains an informal process to review and respond to observed trends.
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
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 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 develop, report and monitor Key Risk Indicators (KRIs) to assist senior management in performance monitoring and trend analysis of the Security, Compliance & Resilience Program (SCRP).
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.
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1.1 Referenzen
1.2 Identifizierte Anforderungen
1.3 Related Regulations
2. Identifizierte Anforderungen
Anforderungen
| Source |
Anforderung |
3. Related Regulations
Regulations
| Source |
Regulierung |
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DORA
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DORA Ch. II Sec. II Art. 13 4.
4. Financial entities shall monitor the effectiveness of the implementation of their digital operational resilience strategy set out in Article 6(8). They shall map the evolution of ICT risk over time, analyse the frequency, types, magnitude and evolution of ICT-related incidents, in particular cyber-attacks and their patterns, with a view to understanding the level of ICT risk exposure, in particular in relation to critical or important functions, and enhance the cyber maturity and preparedness of the financial entity.
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EULAW
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Article 21 Cybersecurity risk-management measures
Article 21
Cybersecurity risk-management measures
1.
Member States shall ensure that essential and important entities take appropriate and proportionate technical, operational and organisational measures to manage the risks posed to the security of network and information systems which those entities use for their operations or for the provision of their services, and to prevent or minimise the impact of incidents on recipients of their services and on other services.
Taking into account the state-of-the-art and, where applicable, relevant European and international standards, as well as the cost of implementation, the measures referred to in the first subparagraph shall ensure a level of security of network and information systems appropriate to the risks posed. When assessing the proportionality of those measures, due account shall be taken of the degree of the entity’s exposure to risks, the entity’s size and the likelihood of occurrence of incidents and their severity, including their societal and economic impact.
2.
The measures referred to in paragraph 1 shall be based on an all-hazards approach that aims to protect network and information systems and the physical environment of those systems from incidents, and shall include at least the following:
(a)
policies on risk analysis and information system security;
(c)
business continuity, such as backup management and disaster recovery, and crisis management;
(d)
supply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers;
(e)
security in network and information systems acquisition, development and maintenance, including vulnerability handling and disclosure;
(f)
policies and procedures to assess the effectiveness of cybersecurity risk-management measures;
(g)
basic cyber hygiene practices and cybersecurity training;
(h)
policies and procedures regarding the use of cryptography and, where appropriate, encryption;
(i)
human resources security, access control policies and asset management;
(j)
the use of multi-factor authentication or continuous authentication solutions, secured voice, video and text communications and secured emergency communication systems within the entity, where appropriate.
3.
Member States shall ensure that, when considering which measures referred to in paragraph 2, point (d), of this Article are appropriate, entities take into account the vulnerabilities specific to each direct supplier and service provider and the overall quality of products and cybersecurity practices of their suppliers and service providers, including their secure development procedures. Member States shall also ensure that, when considering which measures referred to in that point are appropriate, entities are required to take into account the results of the coordinated security risk assessments of critical supply chains carried out in accordance with Article 22(1).
4.
Member States shall ensure that an entity that finds that it does not comply with the measures provided for in paragraph 2 takes, without undue delay, all necessary, appropriate and proportionate corrective measures.
5.
By 17 October 2024, the Commission shall adopt implementing acts laying down the technical and the methodological requirements of the measures referred to in paragraph 2 with regard to DNS service providers, TLD name registries, cloud computing service providers, data centre service providers, content delivery network providers, managed service providers, managed security service providers, providers of online market places, of online search engines and of social networking services platforms, and trust service providers.
The Commission may adopt implementing acts laying down the technical and the methodological requirements, as well as sectoral requirements, as necessary, of the measures referred to in paragraph 2 with regard to essential and important entities other than those referred to in the first subparagraph of this paragraph.
When preparing the implementing acts referred to in the first and second subparagraphs of this paragraph, the Commission shall, to the extent possible, follow European and international standards, as well as relevant technical specifications. The Commission shall exchange advice and cooperate with the Cooperation Group and ENISA on the draft implementing acts in accordance with Article 14(4), point (e).
Those implementing acts shall be adopted in accordance with the examination procedure referred to in Article 39(2).
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Linked Issues
- Secure Controls Framework -
"The SCF is the Common Controls Framework™ (CCF), the world's most comprehensive cybersecurity and data privacy metaframework - it is also free to use. The entire concept is building secure, compliant and resilient capabilities in the most efficient and cost-effective manner possible.
The SCF is more than just a unified control catalog, since its included content creates a playbook for Governance, Risk & Compliance (GRC) capabilities. Used globally by organizations of every size, the SCF is a robust and scalable solution for security, compliance and resilience controls. As a comprehensive security framework, the SCF maps 1,400+ controls across 200+ laws, regulations, and industry frameworks so you can implement once and comply everywhere.
Like it or not, cybersecurity is a protracted war on an asymmetric battlefield, where the threats are everywhere and as defenders we have to make the effort to work together to help improve cybersecurity and data privacy practices, since we all suffer when massive data breaches occur or when cyber attacks have physical impacts. Hackers share information on attack methods with other hackers, so why shouldn’t the good guys share information on how to best protect an organization? We decided to take action and make a difference, since we feel it is too important to wait for someone else to fix the problems that exist.
The SCF is made up of volunteers, mainly specialists within the cybersecurity profession, who focus on GRC and the cybersecurity side of data privacy. These are auditors, engineers, architects, incident responders, consultants and other specialists who live and breathe these topics on a daily basis. The end product is "expert-derived content" that makes up the SCF." https://securecontrolsframework.com/
Terms & Conditions
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