DORA Ch. II Sec. II Art. 8 4.

NOREA

Risk Assessment
Identify all sources of ICT risk on a continuous basis, including risk exposure to and from other entities. Gather information, assess, and review at least on a yearly basis the cyber threats and ICT vulnerabilities relevant to business functions and assets. Evaluate the (potential) impact of these threats and vulnerabilities on the assets.

NOREA

Major change risk assessment
Perform a risk assessment upon each major change in the network, IT infrastructure, and the processes or procedures affecting business functions and assets.

NOREA

Legacy Systems risk assessment
Conduct specific risk assessments on all legacy ICT systems, applications, or systems at least yearly. Perform assessments before and after connecting legacy ICT systems, applications, or systems.

SCF

Asset Inventories

Description

Mechanisms exist to perform inventories of Technology Assets, Applications, Services and/or Data (TAASD) that:
(1) Accurately reflects the current TAASD in use;
(2) Identifies authorized software products, including business justification details;
(3) Is at the level of granularity deemed necessary for tracking and reporting;
(4) Includes organization-defined information deemed necessary to achieve effective property accountability; and
(5) Is available for review and audit by designated organizational personnel.

Possible Solutions & Considerations

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

∙ IT Asset Management (ITAM) program
∙ Spreadsheet-based asset inventory or Snipe-IT (free, https://snipeitapp.com)
∙ JAMF (https://jamf.com) for Apple device management
∙ Configuration Management Database (CMDB)

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

∙ IT Asset Management (ITAM) program
∙ ManageEngine AssetExplorer (https://manageengine.com)
∙ JAMF (https://jamf.com) or Microsoft Intune for device management
∙ Configuration Management Database (CMDB)

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

∙ IT Asset Management (ITAM) program
∙ ManageEngine AssetExplorer (https://manageengine.com)
∙ Ivanti (https://ivanti.com) or Microsoft Intune
∙ Configuration Management Database (CMDB)
∙ Lansweeper for network device discovery

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

∙ IT Asset Management (ITAM) program
∙ ManageEngine AssetExplorer or Ivanti (https://ivanti.com)
∙ Configuration Management Database (CMDB) (e.g., ServiceNow, Device42)
∙ Integration with network discovery tools (e.g., Nmap, Qualys Asset Inventory)

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

∙ IT Asset Management (ITAM) program
∙ Enterprise ITAM solution (e.g., Ivanti, Snow Software, Flexera)
∙ Configuration Management Database (CMDB) (e.g., ServiceNow CMDB)
∙ Automated asset discovery integrated with vulnerability management
∙ CIS Control 1 & 2 alignment

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

Asset Management (AST) 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 AST domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with AST 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 AST domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Asset management-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Asset 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 IT department establishes, maintains and updates an inventory that contains a listing of all organizational-owned TAASD, at a minimum covering common devices (e.g., laptops, workstations and servers).
▪ Inventories may be manual (e.g., spreadsheets) or automated.
▪ Data/process owners for business-critical assets are documented and are reviewed as part of the annual asset inventories.
▪ Software licensing is tracked as part of IT asset inventories.
▪ No structured process exists to review or share the results of the inventories.
▪ Annual IT asset inventories validate or update stakeholders /owners.

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, etc.).
▪ 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 perform inventories of TAASD that:
(1) Accurately reflects the current TAASD in use;
(2) Identifies authorized software products, including business justification details;
(3) Is at the level of granularity deemed necessary for tracking and reporting;
(4) Includes organization-defined information deemed necessary to achieve effective property accountability; and
(5) Is available for review and audit by designated organizational personnel.

Level 4 Quantitatively Controlled

Asset Management (AST) 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

Asset Management (AST) 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.

SCF

Network Diagrams & Data Flow Diagrams (DFDs)

Description

Mechanisms exist to maintain network architecture diagrams that:
(1) Contain sufficient detail to assess the security of the network's architecture;
(2) Reflect the current architecture of the network environment; and
(3) Document all sensitive/regulated data flows.

Possible Solutions & Considerations

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

∙ High-Level Diagram (HLD)
∙ Data Flow Diagram (DFD)
∙ draw.io (free, https://draw.io) or Microsoft Visio

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

∙ High-Level Diagram (HLD)
∙ Low-Level Diagram (LLD)
∙ Data Flow Diagram (DFD)
∙ draw.io (free) or Microsoft Visio

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

∙ High-Level Diagram (HLD)
∙ Low-Level Diagram (LLD)
∙ Data Flow Diagram (DFD)
∙ LucidChart (https://lucidchart.com) or Microsoft Visio
∙ Network documentation tool (e.g., NetBox, SolarWinds NTM)

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

∙ High-Level Diagram (HLD)
∙ Low-Level Diagram (LLD)
∙ Data Flow Diagram (DFD)
∙ Network topology tool (e.g., SolarWinds Network Topology Mapper, NetBox)
∙ Automated network diagram updates via discovery tools

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

∙ High-Level Diagram (HLD)
∙ Low-Level Diagram (LLD)
∙ Data Flow Diagram (DFD)
∙ Enterprise network documentation platform (e.g., NetBox, SolarWinds NTM)
∙ Automated network discovery and diagram generation
∙ Diagrams integrated with CMDB and change 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

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

Asset Management (AST) 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 AST domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with AST 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 AST domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Asset management-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Asset 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 IT department establishes, maintains and updates an inventory that contains a listing of all organizational-owned TAASD, at a minimum covering common devices (e.g., laptops, workstations and servers).
▪ IT and/or cybersecurity personnel work with process owners to generate and maintain Data Flow Diagrams (DFDs) and network diagrams to document the flow of data to create and maintain a map of systems where sensitive/regulated data is stored, transmitted or processed.

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, etc.).
▪ 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 maintain network architecture diagrams that:
(1) Contain sufficient detail to assess the security of the network's architecture;
(2) Reflect the current architecture of the network environment; and
(3) Document all sensitive/regulated data flows.

Level 4 Quantitatively Controlled

Asset Management (AST) 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

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, redundant power, etc.).
▪ 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, 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

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, etc.).
▪ 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 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

Third-Party Criticality Assessments

Description

Mechanisms exist to identify, prioritize and assess suppliers and partners of critical Technology Assets, Applications and/or Services (TAAS) using a supply chain risk assessment process relative to their importance in supporting the delivery of high-value services.