+Risk Remediation
---+Risk Treatment Plan (RTP)
---+Documented Alternatives

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.

1. Overview

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.
Documented Alternatives

Description

Mechanisms exist to document alternative courses of action to ensure executive leadership is reasonably informed of options to manage material risks, including potential:
(1) Benefits;
(2) Drawbacks (including technical limitations);
(3) Costs; and
(4) Timelines.

Possible Solutions & Considerations

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

∙ Review security measures after major incidents

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

∙ Post-incident security review process

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

∙ Formal post-incident security review and lessons learned program

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

∙ Enterprise post-incident review program
∙ Formal corrective action tracking

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

∙ Enterprise incident management and continuous improvement platform
∙ Automated post-incident review triggers

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 document alternative courses of action to ensure executive leadership is reasonably informed of options to manage material risks, including potential:
(1) Benefits;
(2) Drawbacks (including technical limitations);
(3) Costs; and
(4) Timelines.

Level 4 Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Level 5 Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

1.1 References

1.2 Identified Requirements

1.3 Related Regulations

2. Identified Requirements

Requirements

3. Related Regulations

Regulations
EULAW Article 9 Risk management system
-
EULAW Article 3 ICT risk management

Article 3

ICT risk management

Financial entities shall develop, document, and implement ICT risk management policies and procedures that shall contain all of the following:

(a) 

an indication of the approval of the risk tolerance level for ICT risk established in accordance with Article 6(8), point (b), of Regulation (EU) 2022/2554;

(b) 

a procedure and a methodology to conduct the ICT risk assessment, identifying:

(i) 

vulnerabilities and threats that affect or may affect the supported business functions, the ICT systems and ICT assets supporting those functions;

(ii) 

the quantitative or qualitative indicators to measure the impact and likelihood of the vulnerabilities and threats referred to in point (i);

(c) 

the procedure to identify, implement, and document ICT risk treatment measures for the ICT risks identified and assessed, including the determination of ICT risk treatment measures necessary to bring ICT risk within the risk tolerance level referred to in point (a);

(d) 

for the residual ICT risks that are still present following the implementation of the ICT risk treatment measures referred to in point (c):

(i) 

provisions on the identification of those residual ICT risks;

(ii) 

the assignment of roles and responsibilities regarding:

(1) 

the acceptance of the residual ICT risks that exceed the financial entity’s risk tolerance level referred to in point (a);

(2) 

for the review process referred to in point (iv) of this point (d);

(iii) 

the development of an inventory of the accepted residual ICT risks, including a justification for their acceptance;

(iv) 

provisions on the review of the accepted residual ICT risks at least once a year, including:

(1) 

the identification of any changes to the residual ICT risks;

(2) 

the assessment of available mitigation measures;

(3) 

the assessment of whether the reasons justifying the acceptance of residual ICT risks are still valid and applicable at the date of the review;

(e) 

provisions on the monitoring of:

(i) 

any changes to the ICT risk and cyber threat landscape;

(ii) 

internal and external vulnerabilities and threats:

(iii) 

ICT risk of the financial entity that enables promp detection of changes that could affect its ICT risk profile;

(f) 

provisions on a process to ensure that any changes to the business strategy and the digital operational resilience strategy of the financial entity are taken into account.

For the purposes of the first paragraph, point (c), the procedure referred to in that point shall ensure:

(a) 

the monitoring of the effectiveness of the ICT risk treatment measures implemented;

(b) 

the assessment of whether the established risk tolerance levels of the financial entity have been attained;

(c) 

the assessment of whether the financial entity has taken actions to correct or improve those measures where necessary.
EULAW Article 27 Format and content of the report on the review of the ICT risk management framework
-
EULAW Article 29 Information security policy and measures
-
EULAW Article 31 ICT risk management
-
EULAW Article 36 ICT security testing
-
EULAW Article 21 Cybersecurity risk-management measures
-
EULAW Article 21 Cybersecurity risk-management measures
-

Linked Issues

Issuelinks
is related to Semi-Annual
is related to relative Control Weighting = 10
is related to Process
is related to Identify
is related to SCRM Focus Tier 1 STRATEGIC
is related to SCRM Focus Tier 2 OPERATIONAL
is related to SCRM Focus Tier 3 TACTICAL
blocks Regulatory / Legal / Contractual Financial Liability
blocks Exposure from Unaddressed Vulnerabilities
blocks Failure to Achieve Strategic / Mission Objectives
blocks Loss of Authorization / Certification / License
blocks Failure to Support Business / Mission Objectives
blocks Unaddressed Security / Compliance Exposure
blocks Unperformed / Unowned Control Responsibilities
blocks Uncontrolled Internal Security / Privacy Exposure
blocks Uncontrolled Third-Party Security / Privacy Exposure
blocks Lack of oversight of internal controls
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Unreliable Assurance / Decision Information
blocks Incident Persistence / Recurrence
blocks Drought & Water Shortage
blocks Earthquakes
blocks Fire & Wildfires
blocks Floods
blocks Hurricanes & Tropical Storms
blocks Landslides & Debris Flow
blocks Pandemic (Disease) Outbreaks
blocks Severe Weather
blocks Space Weather
blocks Thunderstorms & Lightning
blocks Tornadoes
blocks Tsunamis
blocks Volcanoes
blocks Winter Storms & Extreme Cold
blocks Dysfunctional Management Practices
blocks Human Error
blocks Technical / Mechanical Failure
blocks Statutory / Regulatory / Contractual Change
blocks Data Quality Degradation / Data Poisoning
blocks Fraud, Corruption and/or Intentional Criminal Conduct
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Economic Shock / Market Disruption
blocks Foreign Ownership, Control, or Influence (FOCI)
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
blocks OIS-09.01B
blocks OIS-09.03B
blocks SP-03.02B
blocks DEV-06.02B
blocks Regulatory / Legal / Contractual Financial Liability
blocks Exposure from Unaddressed Vulnerabilities
blocks Failure to Achieve Strategic / Mission Objectives
blocks Loss of Authorization / Certification / License
blocks Failure to Support Business / Mission Objectives
blocks Unaddressed Security / Compliance Exposure
blocks Unperformed / Unowned Control Responsibilities
blocks Uncontrolled Internal Security / Privacy Exposure
blocks Uncontrolled Third-Party Security / Privacy Exposure
blocks Lack of oversight of internal controls
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Unreliable Assurance / Decision Information
blocks Incident Persistence / Recurrence
blocks Drought & Water Shortage
blocks Earthquakes
blocks Fire & Wildfires
blocks Floods
blocks Hurricanes & Tropical Storms
blocks Landslides & Debris Flow
blocks Pandemic (Disease) Outbreaks
blocks Severe Weather
blocks Space Weather
blocks Thunderstorms & Lightning
blocks Tornadoes
blocks Tsunamis
blocks Volcanoes
blocks Winter Storms & Extreme Cold
blocks Dysfunctional Management Practices
blocks Human Error
blocks Technical / Mechanical Failure
blocks Statutory / Regulatory / Contractual Change
blocks Data Quality Degradation / Data Poisoning
blocks Fraud, Corruption and/or Intentional Criminal Conduct
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Economic Shock / Market Disruption
blocks Foreign Ownership, Control, or Influence (FOCI)
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
blocks OIS-09.01B
blocks OIS-09.03B
blocks SP-03.02B
blocks DEV-06.02B
is blocked by RSK-17 Risk Remediation – Assessment Procedure
blocks 03.11.02 Vulnerability Monitoring and Scanning
blocks 03.12.02 Plan of Action and Milestones
blocks GV.RM-04 Strategic direction that describes appropriate risk response options is established and communicated
blocks ID.RA-05 Threats, vulnerabilities, likelihoods, and impacts are used to understand inherent risk and inform risk response prioritization
blocks ID.RA-06 Risk responses are chosen, prioritized, planned, tracked, and communicated
  • Secure Controls Framework -

    The Secure Controls Framework® (SCF)

    "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/ 

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