+Data Classification & Handling
---+Data Protection
------+Data Stewardship
------+Sensitive / Regulated Data Protection
------+Sensitive / Regulated Media Records
------+Defining Access Authorizations for Sensitive / Regulated Data
---+Data & Asset Classification
------+Highest Classification Level
---+Media Access
------+Disclosure of Information
------+Masking Displayed Data
------+Controlled Release
---+Media Marking
------+Automated Marking
---+Cybersecurity & Data Protection Attributes
------+Dynamic Attribute Association
------+Attribute Value Changes By Authorized Individuals
------+Maintenance of Attribute Associations By System
------+Association of Attributes By Authorized Individuals
------+Attribute Displays for Output Devices
------+Data Subject Attribute Associations
------+Consistent Attribute Interpretation
------+Identity Association Techniques & Technologies
------+Attribute Reassignment
------+Attribute Configuration By Authorized Individuals
------+Audit Changes
---+Media Storage
------+Physically Secure All Media
------+Sensitive Data Inventories
------+Periodic Scans for Sensitive / Regulated Data
------+Making Sensitive Data Unreadable In Storage
------+Storing Authentication Data
---+Media Transportation
------+Custodians
------+Encrypting Data In Storage Media
---+Physical Media Disposal
---+System Media Sanitization
------+System Media Sanitization Documentation
------+Equipment Testing
------+Sanitization of Personal Data (PD)
------+First Time Use Sanitization
------+Dual Authorization for Sensitive Data Destruction
---+Media Use
------+Limitations on Use
------+Prohibit Use Without Owner
---+Data Reclassification
---+Removable Media Security
---+Use of External Technology Assets, Applications and/or Services (TAAS)
------+Limits of Authorized Use
------+Portable Storage Devices
------+Protecting Sensitive / Regulated Data on External Technology Assets, Applications and/or Services (TAAS)
------+Non-Organizationally Owned Technology Assets, Applications and/or Services (TAAS)
---+Information Sharing
------+Information Search & Retrieval
------+Transfer Authorizations
------+Data Access Mapping
---+Publicly Accessible Content
---+Data Mining Protection
---+Ad-Hoc Transfers
---+Media & Data Retention
------+Minimize Sensitive / Regulated Data
------+Limit Sensitive / Regulated Data In Testing, Training & Research
------+Temporary Files Containing Personal Data (PD)
---+Geographic Location of Data
---+Archived Data Sets
---+Information Disposal
---+Data Quality Operations
------+Updating & Correcting Personal Data (PD)
------+Data Tags
------+Primary Source Personal Data (PD) Collection
---+De-Identification (Anonymization)
------+De-Identify Dataset Upon Collection
------+Archiving
------+Release
------+Removal, Masking, Encryption, Hashing or Replacement of Direct Identifiers
------+Statistical Disclosure Control
------+Differential Data Privacy
------+Automated De-Identification of Sensitive Data
------+Motivated Intruder
------+Code Names
---+Information Location
------+Automated Tools to Support Information Location
---+Transfer of Sensitive and/or Regulated Data
------+Transfer Activity Limits
---+Data Localization
---+Data Rights Management (DRM)

Data Classification & Handling

Security, Compliance & Resilience (SCR) Principles

Enforce a standardized data classification methodology to objectively determine the sensitivity and criticality of all data and technology assets so that proper handling and disposal requirements can be followed.

Principle Intent

Organizations ensure that technology assets, both electronic and physical, are properly classified and measures implemented to protect the organization's data from unauthorized disclosure, or modification, regardless if it is being transmitted or stored. Applicable statutory, regulatory and contractual compliance requirements dictate the minimum safeguards that must be in place to protect the confidentiality, integrity and availability of data.

1. Overview

Summary	Standard
Data Protection	Description Mechanisms exist to facilitate the implementation of data protection controls. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Logical Access Control (LAC) ∙ Physical Access Control (PAC) Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Logical Access Control (LAC) ∙ Physical Access Control (PAC) Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Logical Access Control (LAC) ∙ Physical Access Control (PAC) ∙ Data governance program Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Logical Access Control (LAC) ∙ Physical Access Control (PAC) ∙ Data governance program ∙ Chief Data Officer (CDO) Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Logical Access Control (LAC) ∙ Physical Access Control (PAC) ∙ Data governance program ∙ Chief Data Officer (CDO) 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 Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ A basic data classification process exists to identify categories of sensitive/regulated data for compliance-related protection requirements. ▪ Data protection controls are primarily administrative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ TAASD are categorized according to data classification and business criticality. ▪ Data classification and handling criteria govern requirements protect sensitive/regulated regardless of where it is stored, processed and/or transmitted. ▪ The data retention process is manual and IT and/or cybersecurity personnel work with business stakeholders and process owners to manage the process. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 data protection controls. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Data & Asset Classification	Description Mechanisms exist to ensure data and assets are categorized in accordance with applicable statutory, regulatory and contractual requirements. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data classification program ∙ IT Asset Management (ITAM) program Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data classification program ∙ IT Asset Management (ITAM) program Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data classification program ∙ IT Asset Management (ITAM) program ∙ Data governance program Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Data classification program ∙ IT Asset Management (ITAM) program ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Data classification program ∙ IT Asset Management (ITAM) program ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ TAASD are categorized according to data classification and business criticality. ▪ Data classification and handling criteria govern requirements protect sensitive/regulated regardless of where it is stored, processed and/or transmitted. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to categorize data in accordance with organizational policies and standards. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to document where sensitive/regulated data is stored, transmitted and/or processed. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to ensure data and assets are categorized in accordance with applicable statutory, regulatory and contractual requirements. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Media Access	Description Mechanisms exist to control and restrict access to digital and non-digital media to authorized individuals. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Logical Access Control (LAC) ∙ Physical Access Control (PAC) Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Logical Access Control (LAC) ∙ Physical Access Control (PAC) Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Logical Access Control (LAC) ∙ Physical Access Control (PAC) ∙ Data governance program Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Logical Access Control (LAC) ∙ Physical Access Control (PAC) ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Logical Access Control (LAC) ∙ Physical Access Control (PAC) ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 control and restrict access to digital and non-digital media to authorized individuals. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Media Marking	Description Mechanisms exist to mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data classification program ∙ Metadata tagging ∙ IT Asset Management (ITAM) program Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data classification program ∙ Metadata tagging ∙ IT Asset Management (ITAM) program Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data classification program ∙ Metadata tagging ∙ IT Asset Management (ITAM) program ∙ Data governance program Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Data classification program ∙ Metadata tagging ∙ IT Asset Management (ITAM) program ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Data classification program ∙ Metadata tagging ∙ IT Asset Management (ITAM) program ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 mark media in accordance with data protection requirements so that personnel are alerted to distribution limitations, handling caveats and applicable security requirements. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Cybersecurity & Data Protection Attributes	Description Mechanisms exist to bind cybersecurity and data protection attributes to information as it is stored, transmitted and processed. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data classification program ∙ Metadata tagging Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data classification program ∙ Metadata tagging Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data classification program ∙ Metadata tagging ∙ Data governance program Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Data classification program ∙ Metadata tagging ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Data classification program ∙ Metadata tagging ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts). Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 bind cybersecurity and data protection attributes to information as it is stored, transmitted and processed. 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.
Media Storage	Description Mechanisms exist to: (1) Physically control and securely store digital and non-digital media within controlled areas using organization-defined security measures; and (2) Protect system media until the media are destroyed or sanitized using approved equipment, techniques and procedures. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Physical Access Control (PAC) Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Physical Access Control (PAC) Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Physical Access Control (PAC) Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Physical Access Control (PAC) ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Physical Access Control (PAC) ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Data protection controls are primarily administrative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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: (1) Physically control and securely store digital and non-digital media within controlled areas using organization-defined security measures; and (2) Protect system media until the media are destroyed or sanitized using approved equipment, techniques and procedures. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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 Data Classification & Handling (DCH) 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.
Media Transportation	Description Mechanisms exist to protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Assigned couriers Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Assigned couriers Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Assigned couriers Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Assigned couriers Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Assigned couriers 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 Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ Data classification and handling criteria govern user behavior for media handling. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 protect and control digital and non-digital media during transport outside of controlled areas using appropriate security measures. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Physical Media Disposal	Description Mechanisms exist to securely dispose of media when it is no longer required, using formal procedures. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers 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 Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ The data retention process is manual and IT and/or cybersecurity personnel work with business stakeholders and process owners to manage the process. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to dispose of, destroy, erase, and/or anonymize sensitive/regulated data. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 securely dispose of media when it is no longer required, using formal procedures. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
System Media Sanitization	Description Mechanisms exist to sanitize system media with the strength and integrity commensurate with the classification or sensitivity of the information prior to disposal, release out of organizational control or release for reuse. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers 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 Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ The data retention process is manual and IT and/or cybersecurity personnel work with business stakeholders and process owners to manage the process. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to dispose of, destroy, erase, and/or anonymize sensitive/regulated data. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 sanitize system media with the strength and integrity commensurate with the classification or sensitivity of the information prior to disposal, release out of organizational control or release for reuse. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Media Use	Description Mechanisms exist to restrict the use of types of digital media on systems or system components. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Secure Baseline Configurations (SBC) Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Secure Baseline Configurations (SBC) Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Secure Baseline Configurations (SBC) Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Secure Baseline Configurations (SBC) Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Secure Baseline Configurations (SBC) 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 Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 restrict the use of types of digital media on systems or system components. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Data Reclassification	Description Mechanisms exist to reclassify data, including associated Technology Assets, Applications and/or Services (TAAS), commensurate with the security category and/or classification level of the information. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data classification program Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data classification program Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data classification program Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Data classification program ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Data classification program ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 reclassify data, including associated Technology Assets, Applications and/or Services (TAAS), commensurate with the security category and/or classification level of the information. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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 Data Classification & Handling (DCH) 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.
Removable Media Security	Description Mechanisms exist to restrict removable media in accordance with data handling and acceptable usage parameters. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Secure Baseline Configurations (SBC) ∙ Data classification program ∙ IT Asset Management (ITAM) program Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Secure Baseline Configurations (SBC) ∙ Data classification program ∙ IT Asset Management (ITAM) program Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Secure Baseline Configurations (SBC) ∙ Data classification program ∙ IT Asset Management (ITAM) program Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Secure Baseline Configurations (SBC) ∙ Data classification program ∙ IT Asset Management (ITAM) program ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Secure Baseline Configurations (SBC) ∙ Data classification program ∙ IT Asset Management (ITAM) program ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 restrict removable media in accordance with data handling and acceptable usage parameters. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Use of External Technology Assets, Applications and/or Services (TAAS)	Description Mechanisms exist to govern how external parties, including Technology Assets, Applications and/or Services (TAAS), are used to securely store, process and transmit data. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Secure Baseline Configurations (SBC) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Secure Baseline Configurations (SBC) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Secure Baseline Configurations (SBC) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Secure Baseline Configurations (SBC) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Secure Baseline Configurations (SBC) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to document where sensitive/regulated data is stored, transmitted and/or processed. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 how external parties, including Technology Assets, Applications and/or Services (TAAS), are used to securely store, process and transmit data. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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 Data Classification & Handling (DCH) 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.
Information Sharing	Description Mechanisms exist to utilize a process to assist users in making information sharing decisions to ensure data is appropriately protected. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data classification program Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data classification program Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data classification program Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Data classification program ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Data classification program ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 utilize a process to assist users in making information sharing decisions to ensure data is appropriately protected. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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 Data Classification & Handling (DCH) 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.
Publicly Accessible Content	Description Mechanisms exist to control publicly-accessible content. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data classification policy (public/internal/confidential) Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data classification policy ∙ Data handling procedures Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data classification program ∙ DLP tools ∙ Data handling standards Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Enterprise DLP solution (e.g., Microsoft Purview, Symantec DLP) ∙ Data classification tool Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Enterprise data governance platform (e.g., Collibra) ∙ DLP with automated classification ∙ Data lifecycle 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 Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Data protection controls are primarily administrative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 control publicly-accessible content. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Data Mining Protection	Description Mechanisms exist to protect data storage objects against unauthorized data mining and data harvesting techniques. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Secure Baseline Configurations (SBC) ∙ Defense-in-depth (DiD) architecture Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Secure Baseline Configurations (SBC) ∙ Defense-in-depth (DiD) architecture Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Secure Baseline Configurations (SBC) ∙ Defense-in-depth (DiD) architecture Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Secure Baseline Configurations (SBC) ∙ Defense-in-depth (DiD) architecture Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Secure Baseline Configurations (SBC) ∙ Defense-in-depth (DiD) architecture 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 Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Data protection controls are primarily administrative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. ▪ Media is securely stored until it is destroyed or sanitized using approved equipment, techniques and procedures. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 protect data storage objects against unauthorized data mining and data harvesting techniques. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Ad-Hoc Transfers	Description Mechanisms exist to secure ad-hoc exchanges of large digital files with internal or external parties. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data classification program ∙ Secure Baseline Configurations (SBC) ∙ Content / DNS filtering Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data classification program ∙ Secure Baseline Configurations (SBC) ∙ Content / DNS filtering Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data classification program ∙ Secure Baseline Configurations (SBC) ∙ Content / DNS filtering Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Data classification program ∙ Secure Baseline Configurations (SBC) ∙ Content / DNS filtering∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Data classification program ∙ Secure Baseline Configurations (SBC) ∙ Content / DNS filtering∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Restrictions for ad-hoc data transfers are primarily administrative in nature (e.g., policies & standards). Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to document where sensitive/regulated data is stored, transmitted and/or processed. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 secure ad-hoc exchanges of large digital files with internal or external parties. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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 Data Classification & Handling (DCH) 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.
Media & Data Retention	Description Mechanisms exist to retain media and data in accordance with applicable statutory, regulatory and contractual obligations. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data retention program ∙ Data classification program Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data retention program ∙ Data classification program Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data retention program ∙ Data classification program Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Data retention program ∙ Data classification program ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Data retention program ∙ Data classification program ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Data protection controls are primarily administrative in nature (e.g., policies & standards) to classify, protect and dispose of systems and data, including storage media. ▪ A manual data retention process exists. ▪ Media is securely stored until it is destroyed or sanitized using approved equipment, techniques and procedures. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ The data retention process is manual and IT and/or cybersecurity personnel work with business stakeholders and process owners to manage the process. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to dispose of, destroy, erase, and/or anonymize sensitive/regulated data. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 retain media and data in accordance with applicable statutory, regulatory and contractual obligations. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Geographic Location of Data	Description Mechanisms exist to inventory, document and maintain data flows for data that is resident (permanently or temporarily) within a service's geographically distributed applications (physical and virtual), infrastructure, systems components and/or shared with other third-parties. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to document where sensitive/regulated data is stored, transmitted and/or processed. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 inventory, document and maintain data flows for data that is resident (permanently or temporarily) within a service's geographically distributed applications (physical and virtual), infrastructure, systems components and/or shared with other third-parties. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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 Data Classification & Handling (DCH) 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.
Archived Data Sets	Description Mechanisms exist to protect archived data in accordance with applicable statutory, regulatory and contractual obligations. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Sensitive data inventories Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Sensitive data inventories Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Sensitive data inventories Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Sensitive data inventories Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Sensitive data inventories 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 Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 protect archived data in accordance with applicable statutory, regulatory and contractual obligations. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Information Disposal	Description Mechanisms exist to securely dispose of, destroy or erase information. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Shred-it (https://shredit.com) ∙ IronMountain (https://ironmountain.com) ∙ BitRaser (https://bitraser.com) ∙ DBAN (https://dban.org) ∙ DoD-strength data erasers 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 Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to dispose of, destroy, erase, and/or anonymize sensitive/regulated data. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 securely dispose of, destroy or erase information. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Data Quality Operations	Description Mechanisms exist to check for Redundant, Obsolete/Outdated, Toxic or Trivial (ROTT) data to ensure the accuracy, relevance, timeliness, impact, completeness and de-identification of information throughout the information lifecycle. 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 ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Product / project management ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts). Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 check for Redundant, Obsolete/Outdated, Toxic or Trivial (ROTT) data to ensure the accuracy, relevance, timeliness, impact, completeness and de-identification of information throughout the information lifecycle. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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 Data Classification & Handling (DCH) 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.
De-Identification (Anonymization)	Description Mechanisms exist to anonymize data by removing Personal Data (PD) from datasets. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data classification program ∙ Data privacy program ∙ Product / project management Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data classification program ∙ Data privacy program ∙ Product / project management Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data classification program ∙ Data privacy program ∙ Product / project management Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Data classification program ∙ Data privacy program ∙ Product / project management Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Data classification program ∙ Data privacy program ∙ Product / project 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 Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 anonymize data by removing Personal Data (PD) from datasets. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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.
Information Location	Description Mechanisms exist to identify and document the location of information and the specific system components on which the information resides. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ Data Flow Diagram (DFD) ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ Data Flow Diagram (DFD) ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ Data Flow Diagram (DFD) ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ Data Flow Diagram (DFD) ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ Data Flow Diagram (DFD) ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to document where sensitive/regulated data is stored, transmitted and/or processed. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 location of information and the specific system components on which the information resides. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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 Data Classification & Handling (DCH) 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.
Transfer of Sensitive and/or Regulated Data	Description Mechanisms exist to restrict and govern the transfer of sensitive and/or regulated data to third-countries or international organizations. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Model contracts ∙ Binding Corporate Rules (BCR) Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Model contracts ∙ Binding Corporate Rules (BCR) Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Model contracts ∙ Binding Corporate Rules (BCR) Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Model contracts ∙ Binding Corporate Rules (BCR) Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Model contracts ∙ Binding Corporate Rules (BCR) 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 Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines). ▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 restrict and govern the transfer of sensitive and/or regulated data to third-countries or international organizations. Level 4 Quantitatively Controlled Data Classification & Handling (DCH) 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 Data Classification & Handling (DCH) 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.
Data Localization	Description Mechanisms exist to constrain the impact of "digital sovereignty laws," that require localized data within the host country, where data and processes may be subjected to arbitrary enforcement actions that potentially violate other applicable statutory, regulatory and/or contractual obligations. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Governance, Risk & Compliance (GRC) program ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ Data Flow Diagram (DFD) ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Governance, Risk & Compliance (GRC) program ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ Data Flow Diagram (DFD) ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Governance, Risk & Compliance (GRC) program ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ Data Flow Diagram (DFD) ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Governance, Risk & Compliance (GRC) program ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ Data Flow Diagram (DFD) ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management ∙ Data governance program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Governance, Risk & Compliance (GRC) program ∙ IT Asset Management (ITAM) program ∙ Data classification program ∙ Sensitive data inventories ∙ Data Flow Diagram (DFD) ∙ System Security & Privacy Plan (SSPP) ∙ Product / project management ∙ Data governance program SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. Level 2 Planned Tracked SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts). Level 3 Well Defined Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 constrain the impact of "digital sovereignty laws," that require localized data within the host country, where data and processes may be subjected to arbitrary enforcement actions that potentially violate other applicable statutory, regulatory and/or contractual obligations. 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.
Data Rights Management (DRM)	Description Mechanisms exist to utilize Data Rights Management (DRM), or similar technologies, to protect Intellectual Property (IP) rights by preventing the unauthorized distribution and/or modification of sensitive IP. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data Rights Management (DRM) solution Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data Rights Management (DRM) solution Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data Rights Management (DRM) solution Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Data Rights Management (DRM) solution Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Data Rights Management (DRM) solution 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 Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. Level 2 Planned Tracked 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 Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with DCH 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 utilize Data Rights Management (DRM), or similar technologies, to protect Intellectual Property (IP) rights by preventing the unauthorized distribution and/or modification of sensitive IP. 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
Source	Requirement

3. Related Regulations

Regulations
Source	Regulation

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/

Terms & Conditions

The SCF End User License Agreement (EULA) governs the use of the Secure Controls Framework® (SCF) under the Creative Commons Attribution-No Derivatives 4.0 International Public License.

Data Classification & Handling

Security, Compliance & Resilience (SCR) Principles

Principle Intent

1. Overview

Description

Possible Solutions & Considerations

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

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

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

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

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

SCR-CMM

Level 0 Not Performed

Level 1 Performed Informally

Level 2 Planned Tracked

Level 3 Well Defined

Level 4 Quantitatively Controlled

Level 5 Continuously Improving

Description

Possible Solutions & Considerations

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

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

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

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

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

SCR-CMM

Level 0 Not Performed

Level 1 Performed Informally

Level 2 Planned Tracked

Level 3 Well Defined

Level 4 Quantitatively Controlled

Level 5 Continuously Improving

Description

Possible Solutions & Considerations

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

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

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

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

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

SCR-CMM

Level 0 Not Performed

Level 1 Performed Informally

Level 2 Planned Tracked

Level 3 Well Defined

Level 4 Quantitatively Controlled

Level 5 Continuously Improving

Description

Possible Solutions & Considerations

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

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

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

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

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

SCR-CMM

Level 0 Not Performed

Level 1 Performed Informally

Level 2 Planned Tracked

Level 3 Well Defined

Level 4 Quantitatively Controlled

Level 5 Continuously Improving

Description

Possible Solutions & Considerations

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

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

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

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

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

SCR-CMM

Level 0 Not Performed

Level 1 Performed Informally

Level 2 Planned Tracked

Level 3 Well Defined

Level 4 Quantitatively Controlled

Level 5 Continuously Improving

Description

Possible Solutions & Considerations

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

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

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

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