+Periodic Review & Update of Security, Compliance & Resilience Program

Periodic Review & Update of Security, Compliance & Resilience Program

Description

Mechanisms exist to review the Security, Compliance & Resilience Program (SCRP), including policies, standards and procedures, at planned intervals or if significant changes occur to ensure their continuing suitability, adequacy and effectiveness.

Possible Solutions & Considerations

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

∙ Annual human reviews of policies and procedures
∙ Documentation change control (version history in document)
∙ Calendar reminders for review cycles

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

∙ Annual human reviews with documented review log
∙ Documentation change control with version history
∙ Defined policy review and approval process

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

∙ Documented review cycle (minimum annual) with ownership assignment
∙ Change control process with approval workflows
∙ Document management system with review reminders (e.g., SharePoint, PolicyTech)

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

∙ Formalized policy lifecycle management (create, review, retire)
∙ Automated review reminders via policy management platform
∙ GRC-integrated documentation change control
∙ Triggered reviews for significant regulatory or organizational changes

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

∙ Enterprise policy lifecycle management integrated with GRC platform
∙ Automated review workflows with escalation paths
∙ Regulatory change monitoring integrated with policy review triggers
∙ Audit-ready documentation of all policy changes and approvals

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 and procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel perform an annual documentation review process that includes the scope of applicable statutory, regulatory and/or contractual obligations.
▪ Recommendations for documentation edits are submitted for review and are handled in accordance with documentation change control processes.
▪ Updated documentation versions are published, based on no less than an annual review cycle.

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 Governance, Risk & Compliance (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 review the Security, Compliance & Resilience Program (SCRP), including policies, standards and procedures, at planned intervals or if significant changes occur to ensure their continuing suitability, adequacy and effectiveness.

Level 4 Quantitatively Controlled

Cybersecurity & Data Protection Governance (GOV) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

Level 5 Continuously Improving

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

1. Overview

1.1 References

1.2 Identified Requirements

1.3 Related Regulations

2. Identified Requirements

Requirements

3. Related Regulations

Regulations
EULAW Article 2 General elements of ICT security policies, procedures, protocols, and tools
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EULAW Article 2 General elements of ICT security policies, procedures, protocols, and tools
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EULAW Article 3 ICT risk management

Article 3

ICT risk management

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

(a) 

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

(b) 

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

(i) 

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

(ii) 

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

(c) 

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

(d) 

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

(i) 

provisions on the identification of those residual ICT risks;

(ii) 

the assignment of roles and responsibilities regarding:

(1) 

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

(2) 

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

(iii) 

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

(iv) 

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

(1) 

the identification of any changes to the residual ICT risks;

(2) 

the assessment of available mitigation measures;

(3) 

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

(e) 

provisions on the monitoring of:

(i) 

any changes to the ICT risk and cyber threat landscape;

(ii) 

internal and external vulnerabilities and threats:

(iii) 

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

(f) 

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

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

(a) 

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

(b) 

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

(c) 

the assessment of whether the financial entity has taken actions to correct or improve those measures where necessary.

Linked Issues

Issuelinks
is related to Annual
is related to relative Control Weighting = 08
is related to Process
is related to Govern
is related to SCRM Focus Tier 1 STRATEGIC
is related to SCRM Focus Tier 2 OPERATIONAL
is related to SCRM Focus Tier 3 TACTICAL
blocks Loss of Accountability / Attribution
blocks Excessive or Unauthorized Privilege
blocks Unauthorized Privilege Elevation
blocks Unauthorized Access
blocks Loss, Theft or Damage of Assets
blocks Unauthorized Modification / Loss of System Integrity
blocks Business / Service Interruption
blocks Data Loss / Integrity Compromise
blocks Reduced Operational Productivity
blocks System / Data Compromise (Technical Vector)
blocks System / Data Compromise (Non-Technical Vector)
blocks Revenue Loss
blocks Contractual Default / Termination
blocks Loss of Competitive Advantage
blocks Reputational Harm / Loss of Stakeholder Trust
blocks Regulatory / Legal / Contractual Financial Liability
blocks Exposure from Unaddressed Vulnerabilities
blocks System / Service Compromise
blocks Failure to Support Business / Mission Objectives
blocks Unaddressed Security / Compliance Exposure
blocks Unperformed / Unowned Control Responsibilities
blocks Uncontrolled Internal Security / Privacy Exposure
blocks Uncontrolled Third-Party Security / Privacy Exposure
blocks Lack of oversight of internal controls
blocks Lack of oversight of third-party controls
blocks Harm from Illegal, Abusive or Unsafe Content / Conduct
blocks Loss of Investigative / Evidentiary Capability
blocks Delayed Containment / Increased Incident Impact
blocks Incident Persistence / Recurrence
blocks Incident Response / Recovery Cost
blocks Undetected / Delayed Detection of Adverse Activity
blocks Lack of a security-minded workforce
blocks Third-Party Cybersecurity Compromise / Exposure
blocks Third-Party Physical Security Disruption / Exposure
blocks Sub-Tier / Fourth-Party Supply Chain Exposure
blocks Third-Party Legal / Compliance Exposure
blocks Harm from Unauthorized / Unintended Product or Service Use
blocks Third-Party Dependency Failure
is related to relative Control Weighting = 07
blocks Failure to Achieve Strategic / Mission Objectives
blocks Loss of Authorization / Certification / License
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Unreliable Assurance / Decision Information
blocks Drought & Water Shortage
blocks Earthquakes
blocks Fire & Wildfires
blocks Floods
blocks Hurricanes & Tropical Storms
blocks Landslides & Debris Flow
blocks Pandemic (Disease) Outbreaks
blocks Severe Weather
blocks Space Weather
blocks Thunderstorms & Lightning
blocks Tornadoes
blocks Tsunamis
blocks Volcanoes
blocks Winter Storms & Extreme Cold
blocks Malicious Cyber Activity
blocks Dysfunctional Management Practices
blocks Human Error
blocks Technical / Mechanical Failure
blocks Statutory / Regulatory / Contractual Change
blocks Data Quality Degradation / Data Poisoning
blocks Fraud, Corruption and/or Intentional Criminal Conduct
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Economic Shock / Market Disruption
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
blocks OIS-01.02B
blocks SP-02.01B
blocks SP-02.02B
blocks CRY-01.02B
is blocked by GOV-04.1 Periodic Review & Update of Security, Compliance & Resilience Program – Assessment Procedure
blocks AC-01 Policy and Procedures
blocks AT-01 Policy and Procedures
blocks AU-01 Policy and Procedures
blocks CA-01 Policy and Procedures
blocks CM-01 Policy and Procedures
blocks CP-01 Policy and Procedures
blocks IA-01 Policy and Procedures
blocks IR-01 Policy and Procedures
blocks MA-01 Policy and Procedures
blocks MP-01 Policy and Procedures
blocks PE-01 Policy and Procedures
blocks PL-01 Policy and Procedures
blocks PM-01 Information Security Program Plan
blocks PS-01 Policy and Procedures
blocks PT-01 Policy and Procedures
blocks RA-01 Policy and Procedures
blocks SA-01 Policy and Procedures
blocks SC-01 Policy and Procedures
blocks SI-01 Policy and Procedures
blocks SR-01 Policy and Procedures
blocks AC-01 [L] Policy and Procedures
blocks AT-01 [L] Policy and Procedures
blocks AU-01 [L] Policy and Procedures
blocks CA-01 [L] Policy and Procedures
blocks CM-01 [L] Policy and Procedures
blocks CP-01 [L] Policy and Procedures
blocks IA-01 [L] Policy and Procedures
blocks IR-01 [L] Policy and Procedures
blocks MA-01 [L] Policy and Procedures
blocks MP-01 [L] Policy and Procedures
blocks PE-01 [L] Policy and Procedures
blocks PL-01 [L] Policy and Procedures
blocks PS-01 [L] Policy and Procedures
blocks RA-01 [L] Policy and Procedures
blocks SA-01 [L] Policy and Procedures
blocks SC-01 [L] Policy and Procedures
blocks SI-01 [L] Policy and Procedures
blocks SR-01 [L] Policy and Procedures
blocks AC-01 [M] Policy and Procedures
blocks AT-01 [M] Policy and Procedures
blocks AU-01 [M] Policy and Procedures
blocks CA-01 [M] Policy and Procedures
blocks CM-01 [M] Policy and Procedures
blocks CP-01 [M] Policy and Procedures
blocks IA-01 [M] Policy and Procedures
blocks IR-01 [M] Policy and Procedures
blocks MA-01 [M] Policy and Procedures
blocks MP-01 [M] Policy and Procedures
blocks PE-01 [M] Policy and Procedures
blocks PL-01 [M] Policy and Procedures
blocks PS-01 [M] Policy and Procedures
blocks RA-01 [M] Policy and Procedures
blocks SA-01 [M] Policy and Procedures
blocks SC-01 [M] Policy and Procedures
blocks SI-01 [M] Policy and Procedures
blocks SR-01 [M] Policy and Procedures
blocks AC-01 [H] Policy and Procedures
blocks AT-01 [H] Policy and Procedures
blocks AU-01 [H] Policy and Procedures
blocks CA-01 [H] Policy and Procedures
blocks CM-01 [H] Policy and Procedures
blocks CP-01 [H] Policy and Procedures
blocks IA-01 [H] Policy and Procedures
blocks IR-01 [H] Policy and Procedures
blocks MA-01 [H] Policy and Procedures
blocks MP-01 [H] Policy and Procedures
blocks PL-01 [H] Policy and Procedures
blocks PS-01 [H] Policy and Procedures
blocks RA-01 [H] Policy and Procedures
blocks SA-01 [H] Policy and Procedures
blocks SC-01 [H] Policy and Procedures
blocks SI-01 [H] Policy and Procedures
blocks SR-01 [H] Policy and Procedures
blocks AC-01 [P] Policy and Procedures
blocks AT-01 [P] Policy and Procedures
blocks AU-01 [P] Policy and Procedures
blocks CA-01 [P] Policy and Procedures
blocks CM-01 [P] Policy and Procedures
blocks IR-01 [P] Policy and Procedures
blocks MP-01 [P] Policy and Procedures
blocks PL-01 [P] Policy and Procedures
blocks PT-01 [P] Policy and Procedures
blocks RA-01 [P] Policy and Procedures
blocks SA-01 [P] Policy and Procedures
blocks SI-01 [P] Policy and Procedures
blocks 03.15.01 Policy and Procedures
blocks 03.15.03 Rules of Behavior
blocks GV.PO-02 Policy for managing cybersecurity risks is reviewed, updated, communicated, and enforced to reflect changes in requirements, threats, technology, and …
blocks GV.OV Oversight
blocks GV.OV-01 Cybersecurity risk management strategy outcomes are reviewed to inform and adjust strategy and direction
blocks GV.OV-02 The cybersecurity risk management strategy is reviewed and adjusted to ensure coverage of organizational requirements and risks
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