+Defined Roles & Responsibilities
---+Assigned Roles & Responsibilities Awareness

Defined Roles & Responsibilities

Description

Mechanisms exist to define cybersecurity roles & responsibilities for all personnel.

Possible Solutions & Considerations

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

Human Resources Security (HRS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with HRS domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Personnel management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ The Human Resources (HR) department provides guidance on secure HR practices for hiring, retaining and terminating employees, contractors and other personnel that work on behalf of the organization.
▪ Formal roles and responsibilities for cybersecurity and/or data protection are not consistent and/or standardized.

Level 2 Planned Tracked

Human Resources Security (HRS) 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 HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS 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 HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.
▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization.

Level 3 Well Defined

Human Resources Security (HRS) 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 HRS 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 HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software solution).
▪ 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 HRS 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 define cybersecurity roles & responsibilities for all personnel.

Level 4 Quantitatively Controlled

Human Resources Security (HRS) 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

Assigned Roles & Responsibilities Awareness

Description

Mechanisms exist to communicate with users about their roles and responsibilities to maintain a safe and secure working environment.

Possible Solutions & Considerations

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

∙ Formal onboarding training
∙ Acceptable Use / Rules of Behavior (RoB)

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

∙ Formal onboarding training
∙ Acceptable Use / Rules of Behavior (RoB)

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

∙ Formal onboarding training
∙ Acceptable Use / Rules of Behavior (RoB)

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

∙ Formal onboarding training
∙ Acceptable Use / Rules of Behavior (RoB)

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

∙ Formal onboarding training
∙ Acceptable Use / Rules of Behavior (RoB)

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

Human Resources Security (HRS) 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 HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS 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 HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.
▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization.

Level 3 Well Defined

Human Resources Security (HRS) 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 HRS 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 HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software solution).
▪ 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 HRS 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 communicate with users about their roles and responsibilities to maintain a safe and secure working environment.

Level 4 Quantitatively Controlled

Human Resources Security (HRS) 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.

1.1 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
-
EULAW Article 15 ICT project management
-
EULAW Article 17 ICT change management
-
EULAW Article 19 Human resources policy

Article 19

Human resources policy

Financial entities shall include in their human resource policy or other relevant policies all of the following ICT security related elements:

(a) 

the identification and assignment of any specific ICT security responsibilities;

(b) 

requirements for staff of the financial entity and of the ICT third-party service providers using or accessing ICT assets of the financial entity to:

(i) 

be informed about, and adhere to, the financial entity’s ICT security policies, procedures, and protocols;

(ii) 

be aware of the reporting channels put in place by the financial entity for the detection of anomalous behaviour, including, where applicable, the reporting channels established in line with Directive (EU) 2019/1937 of the European Parliament and of the Council ( 1 );

(iii) 

for the staff, to return to the financial entity, upon termination of employment, all ICT assets and tangible information assets in their possession that belong to the financial entity.
EULAW Article 21 Access control

Article 21

Access control

As part of their control of access management rights, financial entities shall develop, document, and implement a policy that contains all of the following:

(a) 

the assignment of access rights to ICT assets based on need-to-know, need-to-use and least privilege principles, including for remote and emergency access;

(b) 

the segregation of duties designed to prevent unjustified access to critical data or to prevent the allocation of combinations of access rights that may be used to circumvent controls;

(c) 

a provision on user accountability, by limiting to the extent possible the use of generic and shared user accounts and ensuring that users are identifiable for the actions performed in the ICT systems at all times;

(d) 

a provision on restrictions of access to ICT assets, setting out controls and tools to prevent unauthorised access;

(e) 

account management procedures to grant, change or revoke access rights for user and generic accounts, including generic administrator accounts, including provision on all of the following:

(i) 

assignment of roles and responsibilities for granting, reviewing, and revoking access rights;

(ii) 

assignment of privileged, emergency, and administrator access on a need-to-use or an ad-hoc basis for all ICT systems;

(iii) 

withdrawal of access rights without undue delay upon termination of the employment or when the access is no longer necessary;

(iv) 

update of access rights where changes are necessary and at least once a year for all ICT systems, other than ICT systems supporting critical or important functions and at least every 6 months for ICT systems supporting critical or important functions;

(f) 

authentication methods, including all of the following:

(i) 

the use of authentication methods commensurate to the classification established in accordance with Article 8(1) of Regulation (EU) 2022/2554 and to the overall risk profile of ICT assets and considering leading practices;

(ii) 

the use of strong authentication methods in accordance with leading practices and techniques for remote access to the financial entity’s network, for privileged access, for access to ICT assets supporting critical or important functions or ICT assets that are publicly accessible;

(g) 

physical access controls measures including:

(i) 

the identification and logging of natural persons that are authorised to access premises, data centres, and sensitive designated areas identified by the financial entity where ICT and information assets reside;

(ii) 

the granting of physical access rights to critical ICT assets to authorised persons only, in accordance with the need-to-know and least privilege principles, and on an ad-hoc basis;

(iii) 

the monitoring of physical access to premises, data centres, and sensitive designated areas identified by the financial entity where ICT and information assets or both reside;

(iv) 

the review of physical access rights to ensure that unnecessary access rights are promptly revoked.

For the purposes of point (e)(i), financial entities shall establish the retention period taking into account the business and information security objectives, the reasons for recording the event in the logs, and the results of the ICT risk assessment.

For the purposes of point (e)(ii), financial entities shall, where possible, use dedicated accounts for the performance of administrative tasks on ICT systems. Where feasible and appropriate, financial entities shall deploy automated solutions for the privilege access management.

For the purposes of point (g)(i), the identification and logging shall be commensurate with the importance of the premises, data centres, sensitive designated areas, and the criticality of the operations or ICT systems located therein.

For the purposes of point (g)(iii), the monitoring shall be commensurate to the classification established in accordance with Article 8(1) of Regulation (EU) 2022/2554 and the criticality of the area accessed.
EULAW Article 23 Anomalous activities detection and criteria for ICT-related incidents detection and response
-
EULAW Article 28 Governance and organisation
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EULAW Article 5 Governance and organisation
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EULAW Article 32 Security of processing
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EULAW Article 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.

Linked Issues

Issuelinks
is related to Annual
is related to relative Control Weighting = 10
is related to People
is related to Identify
is related to SCRM Focus Tier 2 OPERATIONAL
is related to SCRM Focus Tier 3 TACTICAL
blocks Excessive or Unauthorized Privilege
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 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 SCRM Focus Tier 1 STRATEGIC
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Drought & Water Shortage
blocks Earthquakes
blocks Fire & Wildfires
blocks Floods
blocks Hurricanes & Tropical Storms
blocks Landslides & Debris Flow
blocks Pandemic (Disease) Outbreaks
blocks Severe Weather
blocks Space Weather
blocks Thunderstorms & Lightning
blocks Tornadoes
blocks Tsunamis
blocks Volcanoes
blocks Winter Storms & Extreme Cold
blocks Dysfunctional Management Practices
blocks Human Error
blocks Fraud, Corruption and/or Intentional Criminal Conduct
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
blocks SP-01.01B
blocks OPS-10.01B
blocks OPS-32.03B
is blocked by HRS-04 Defined Roles & Responsibilities – Assessment Procedure
blocks PM-13 Security and Privacy Workforce
blocks PS-09 Position Descriptions
blocks PS-09 [L] Position Descriptions
blocks PS-09 [M] Position Descriptions
blocks PS-09 [H] Position Descriptions
blocks PM-13 [P] Security and Privacy Workforce
blocks 03.01.22 Publicly Accessible Content
blocks 03.02.02 Role-Based Training
blocks 03.06.04 Incident Response Training
blocks 03.06.05 Incident Response Plan
blocks 03.07.06 Maintenance Personnel
blocks 03.08.02 Media Access
blocks 03.15.03 Rules of Behavior
blocks 03.16.03 External System Services
blocks GV.RM-05 Lines of communication across the organization are established for cybersecurity risks, including risks from suppliers and other third parties
blocks GV.RR Roles, Responsibilities, and Authorities
blocks GV.RR-02 Roles, responsibilities, and authorities related to cybersecurity risk management are established, communicated, understood, and enforced
blocks ID.AM Asset Management
blocks PO.2 Implement Roles and Responsibilities
blocks PO.2.1 Create new roles and alter responsibilities for existing roles as needed to encompass all parts of the SDLC. Periodically review and maintain the …
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