Status Reporting To Governing Body

Description

Mechanisms exist to provide governance oversight reporting and recommendations to those entrusted to make executive decisions about matters considered material to the organization's Security, Compliance & Resilience Program (SCRP).

Possible Solutions & Considerations

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

∙ Quarterly Business Review (QBR)
∙ Simple security status dashboard (spreadsheet or slide deck)
∙ Email status updates to owner/manager

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

∙ Quarterly Business Review (QBR)
∙ Structured security metrics report (incidents, patching status, training completion)
∙ Documented reporting cadence

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

∙ Quarterly Business Review (QBR)
∙ Formal security status reports to leadership
∙ KPI/KRI dashboard (e.g., Power BI, Tableau, or GRC tool reporting)

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

∙ Quarterly Business Review (QBR)
∙ Executive security dashboard with KPIs/KRIs
∙ Board-level reporting on material risk indicators
∙ Automated reporting via GRC platform

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

∙ Quarterly Business Review (QBR)
∙ Board and audit committee cybersecurity briefings
∙ Integrated GRC dashboard with real-time metrics
∙ SEC cybersecurity disclosure-ready reporting processes (if applicable)

SCR-CMM

Level 0 Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 Performed Informally

SCR-CMM Level 1 criteria definitions are not available for this control:
▪ A reasonable person would conclude this control requires a structured process.
▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

Level 2 Planned Tracked

Cybersecurity & Data Protection Governance (GOV) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ Organizational leadership maintains an informal process to review and respond to trends.

Level 3 Well Defined

Cybersecurity & Data Protection Governance (GOV) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's GRC team, or similar function, is appropriately staffed and supported to implement and maintain GOV domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to provide governance oversight reporting and recommendations to those entrusted to make executive decisions about matters considered material to the organization's Security, Compliance & Resilience Program (SCRP).

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. Overview

Summary	Standard

1.1 References

1.2 Identified Requirements

1.3 Related Regulations

2. Identified Requirements

Requirements
Source	Requirement

3. Related Regulations

Regulations
Source	Regulation
DORA	DORA Ch. II Sec. I Art. 5 2. 2. The management body of the financial entity shall define, approve, oversee and be responsible for the implementation of all arrangements related to the ICT risk management framework referred to in Article 6(1). For the purposes of the first subparagraph, the management body shall: (a) bear the ultimate responsibility for managing the financial entity’s ICT risk; (b) put in place policies that aim to ensure the maintenance of high standards of availability, authenticity, integrity and confidentiality, of data; (c) set clear roles and responsibilities for all ICT-related functions and establish appropriate governance arrangements to ensure effective and timely communication, cooperation and coordination among those functions; (d) bear the overall responsibility for setting and approving the digital operational resilience strategy as referred to in Article 6(8), including the determination of the appropriate risk tolerance level of ICT risk of the financial entity, as referred to in Article 6(8), point (b); (e) approve, oversee and periodically review the implementation of the financial entity’s ICT business continuity policy and ICT response and recovery plans, referred to, respectively, in Article 11(1) and (3), which may be adopted as a dedicated specific policy forming an integral part of the financial entity’s overall business continuity policy and response and recovery plan; (f) approve and periodically review the financial entity’s ICT internal audit plans, ICT audits and material modifications to them; (g) allocate and periodically review the appropriate budget to fulfil the financial entity’s digital operational resilience needs in respect of all types of resources, including relevant ICT security awareness programmes and digital operational resilience training referred to in Article 13(6), and ICT skills for all staff; (h) approve and periodically review the financial entity’s policy on arrangements regarding the use of ICT services provided by ICT third-party service providers; (i) put in place, at corporate level, reporting channels enabling it to be duly informed of the following: (i) arrangements concluded with ICT third-party service providers on the use of ICT services, (ii) any relevant planned material changes regarding the ICT third-party service providers, (iii) the potential impact of such changes on the critical or important functions subject to those arrangements, including a risk analysis summary to assess the impact of those changes, and at least major ICT-related incidents and their impact, as well as response, recovery and corrective measures.
DORA	DORA Ch. II Sec. II Art. 13 5. 5. Senior ICT staff shall report at least yearly to the management body on the findings referred to in paragraph 3 and put forward recommendations.

Linked Issues

Issuelinks
Linktype	Issue
is related to	Annual
is related to	relative Control Weighting = 05
is related to	Process
is related to	Govern
is related to	SCRM Focus Tier 1 STRATEGIC
is related to	SCRM Focus Tier 2 OPERATIONAL
blocks	Inability to maintain individual accountability
blocks	Diminished competitive advantage
blocks	Diminished reputation
blocks	Inability to support business processes
blocks	Inadequate internal practices
blocks	Inadequate third-party practices
blocks	Lack of oversight of internal controls
blocks	Lack of oversight of third-party controls
blocks	Third-party cybersecurity exposure
blocks	Third-party physical security exposure
blocks	Third-party supply chain relationships, visibility and controls
blocks	Third-party compliance / legal exposure
blocks	Use of product / service
blocks	Reliance on the third-party

Secure Controls Framework -
The Secure Controls Framework® (SCF)

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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.

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