+Άρθρο 38 Διαχείριση έργων και αλλαγών ΤΠΕ
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Άρθρο 38 Διαχείριση έργων και αλλαγών ΤΠΕ

1. Επισκόπηση

,
Άρθρο 38 1.
Οι χρηματοοικονομικές οντότητες που αναφέρονται στο άρθρο 16 παράγραφος 1 του κανονισμού (ΕΕ) 2022/2554 αναπτύσσουν, τεκμηριώνουν και εφαρμόζουν διαδικασία διαχείρισης έργων ΤΠΕ και καθορίζουν τους ρόλους και τις αρμοδιότητες για την υλοποίησή της. Η εν λόγω διαδικασία καλύπτει όλα τα στάδια των έργων ΤΠΕ από την έναρξή τους έως το κλείσιμό τους.
Άρθρο 38 2.
Οι χρηματοοικονομικές οντότητες που αναφέρονται στην παράγραφο 1 αναπτύσσουν, τεκμηριώνουν και εφαρμόζουν διαδικασία διαχείρισης αλλαγών ΤΠΕ για να διασφαλίζουν ότι όλες οι αλλαγές στα συστήματα ΤΠΕ καταγράφονται, δοκιμάζονται, αξιολογούνται, εγκρίνονται, εφαρμόζονται και επαληθεύονται με ελεγχόμενο τρόπο και με επαρκείς διασφαλίσεις για τη διατήρηση της ψηφιακής επιχειρησιακής ανθεκτικότητας της χρηματοοικονομικής οντότητας.

1.1 Παραπομπές

1.2 Εντοπισμένες απαιτήσεις

1.3 Σχετικά πρότυπα

2. Εντοπισμένες απαιτήσεις

Απαιτήσεις

3. Σχετικά πρότυπα

Πρότυπα
SCF Change Management Program

Description

Mechanisms exist to facilitate the implementation of a change management program.

Possible Solutions & Considerations

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

∙ VisibleOps (https://itpi.org)
∙ ITIL 4 (https://axelos.com)

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

∙ VisibleOps (https://itpi.org)
∙ ITIL 4 (https://axelos.com)

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

∙ VisibleOps (https://itpi.org)
∙ ITIL 4 (https://axelos.com)

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

∙ VisibleOps (https://itpi.org)
∙ ITIL 4 (https://axelos.com)

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

∙ VisibleOps (https://itpi.org)
∙ ITIL 4 (https://axelos.com)

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

Change Management (CHG) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with CHG domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Change management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Documented change control processes are either informal or do not exist.

Level 2 Planned Tracked

Change Management (CHG) 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 CHG domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CHG 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 CHG domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Change management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Change management 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 ensure changes to Technology Assets, Applications and/or Services (TAAS) within the System Development Lifecycle (SDLC) are controlled through formal change control procedures.
▪ A Change Advisory Board (CAB), or similar function, exists to govern Requests For Change (RFC) to TAAS to ensure security, compliance and resilience.
▪ The CAB includes a function to review RFCs for cybersecurity and data protection ramifications.
▪ The CAB notifies affected stakeholders to ensure awareness of the impact of proposed changes.

Level 3 Well Defined

Change Management (CHG) 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 CHG 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 CHG domain capabilities are well-documented and kept current by process owners.
▪ A centralized Change Management Office (CMO), or similar function, is appropriately staffed and supported to implement and maintain CHG domain capabilities.
▪ Technical procedures (e.g., ITIL change enablement) are utilized along with change management governance capabilities (e.g., Change Advisory Board (CAB)) to ensure successful, efficient and secure change management operations.
▪ 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 CHG 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 a change management program.

Level 4 Quantitatively Controlled

Change Management (CHG) 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 Configuration Change Control

Description

Mechanisms exist to govern the technical configuration change control processes.

Possible Solutions & Considerations

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

∙ Change Control Board (CCB)
∙ Configuration Management Database (CMDB)
∙ VisibleOps (https://itpi.org)
∙ ITIL 4 (https://axelos.com)

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

∙ Change Control Board (CCB)
∙ Configuration Management Database (CMDB)
∙ VisibleOps (https://itpi.org)
∙ ITIL 4 (https://axelos.com)

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

∙ Change Control Board (CCB)
∙ Configuration Management Database (CMDB)
∙ VisibleOps (https://itpi.org)
∙ ITIL 4 (https://axelos.com)

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

∙ Change Control Board (CCB)
∙ Configuration Management Database (CMDB)
∙ VisibleOps (https://itpi.org)
∙ ITIL 4 (https://axelos.com)

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

∙ Change Control Board (CCB)
∙ Configuration Management Database (CMDB)
∙ VisibleOps (https://itpi.org)
∙ ITIL 4 (https://axelos.com)

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

Change Management (CHG) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with CHG domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Change management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Requests for Change (RFC) are submitted to IT and/or cybersecurity personnel.
▪ Documented change control processes are either informal or do not exist.

Level 2 Planned Tracked

Change Management (CHG) 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 CHG domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CHG 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 CHG domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Change management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Change management 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 ensure changes to Technology Assets, Applications and/or Services (TAAS) within the System Development Lifecycle (SDLC) are controlled through formal change control procedures.
▪ Configuration management practices prevent unauthorized changes by limiting and reviewing permissions to modify TAAS components within a production/operational environment
▪ A Change Advisory Board (CAB), or similar function, exists to govern Requests For Change (RFC) to TAAS to ensure security, compliance and resilience.
▪ The CAB includes a function to review RFCs for cybersecurity and data protection ramifications.
▪ The CAB notifies affected stakeholders to ensure awareness of the impact of proposed changes.
▪ Unauthorized configuration changes are responded to in accordance with an Incident Response Plan (IRP) to determine if the unauthorized configuration is malicious in nature.

Level 3 Well Defined

Change Management (CHG) 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 CHG 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 CHG domain capabilities are well-documented and kept current by process owners.
▪ A centralized Change Management Office (CMO), or similar function, is appropriately staffed and supported to implement and maintain CHG domain capabilities.
▪ Technical procedures (e.g., ITIL change enablement) are utilized along with change management governance capabilities (e.g., Change Advisory Board (CAB)) to ensure successful, efficient and secure change management operations.
▪ 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 CHG 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 the technical configuration change control processes.

Level 4 Quantitatively Controlled

Change Management (CHG) 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 Protection Portfolio Management

Description

Mechanisms exist to facilitate the implementation of resource planning controls that provide a portfolio management approach to achieve security, compliance and resilience objectives.

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

∙ Security integrated into project management methodology
∙ Security gates

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

∙ Enterprise project management with security integration (e.g., Jira, MS Project)

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

∙ Enterprise PPM platform with security integration
∙ Dedicated security architects
∙ Security portfolio risk 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

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.
▪ 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 facilitate the implementation of resource planning controls that provide a portfolio management approach to achieve security, compliance and resilience objectives.

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 In Project Management

Description

Mechanisms exist to assess security, compliance and resilience controls as part of Technology Assets, Applications and/or Services (TAAS) project development to determine whether controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting requirements.

Possible Solutions & Considerations

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

∙ Product / project management

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

∙ Product / project management

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

∙ Product / project management

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

∙ Product / project management
∙ Program Management Office (PMO)

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

∙ Product / project management
∙ Program Management Office (PMO)

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.

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 assess security, compliance and resilience controls in system project development to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting the requirements.

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.