+Regulatory & Law Enforcement Contacts

Regulatory & Law Enforcement Contacts

Description

Mechanisms exist to maintain incident response contacts with applicable regulatory and law enforcement agencies.

Possible Solutions & Considerations

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

∙ Basic incident response plan
∙ Designate incident response contact

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

∙ Documented incident response plan
∙ Incident log
∙ Designated IR team

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

∙ Formal incident response program
∙ IR playbooks
∙ Tabletop exercises

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

∙ Enterprise incident response program
∙ 24/7 SOC monitoring
∙ SOAR platform

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

∙ Enterprise SOC with SIEM/SOAR (e.g., Splunk SOAR, Palo Alto XSOAR)
∙ IR retainer
∙ Threat hunting

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

Incident Response (IRO) 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 IRO 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 IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to maintain incident response contacts with applicable regulatory and law enforcement agencies.

Level 4 Quantitatively Controlled

Incident Response (IRO) 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

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
EULAW Article 22 ICT-related incident management policy

Article 22

ICT-related incident management policy

As part of the mechanisms to detect anomalous activities, including ICT network performance issues and ICT-related incidents, financial entities shall develop, document, and implement an ICT-related incident policy through which they shall:

(a) 

document the ICT-related incident management process referred to in Article 17 of Regulation (EU) 2022/2554;

(b) 

establish a list of relevant contacts with internal functions and external stakeholders that are directly involved in ICT operations security, including on:

(i) 

the detection and monitoring of cyber threats;

(ii) 

the detection of anomalous activities;

(iii) 

vulnerability management;

(c) 

establish, implement, and operate technical, organisational, and operational mechanisms to support the ICT-related incident management process, including mechanisms to enable a prompt detection of anomalous activities and behaviours in accordance with Article 23 of this Regulation;

▼C1

(d) 

retain all evidence relating to ICT-related incidents for a period that shall be no longer than necessary for the purposes for which the data are collected, commensurate with the criticality of the affected business functions, supporting processes, and ICT and information assets, in accordance with Article 8(2) of Commission Delegated Regulation (EU) 2024/1772 ( 2 ) and with any applicable retention requirement pursuant to Union law;

▼B

(e) 

establish and implement mechanisms to analyse significant or recurring ICT-related incidents and patterns in the number and the occurrence of ICT-related incidents.

For the purposes of point (d), financial entities shall retain the evidence referred to in that point in a secure manner.

Linked Issues

Issuelinks
Linktype Issue
is related to Annual
is related to relative Control Weighting = 05
is related to Technology
is related to Respond
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 Unauthorized Retention / Inability to Dispose of Data
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 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
blocks Office Application Startup
blocks Office Template Macros
blocks Office Test
blocks Outlook Forms
blocks Outlook Home Page
blocks Outlook Rules
blocks Add-ins
blocks Exploitation for Client Execution
blocks User Execution
blocks Malicious Link
blocks Malicious File
blocks Malicious Image
blocks Template Injection
blocks Resource Forking
blocks Phishing
blocks Spearphishing Attachment
blocks Spearphishing Link
blocks Spearphishing via Service
blocks Phishing for Information
blocks Spearphishing Service
blocks Spearphishing Attachment
blocks Spearphishing Link
is related to relative Control Weighting = 09
is related to Process
is related to Identify
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Loss of Critical Knowledge / Capability
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 Technical / Mechanical Failure
blocks Statutory / Regulatory / Contractual Change
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
blocks SIM-01.03B
blocks BCM-04.04AC
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Loss of Critical Knowledge / Capability
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 Technical / Mechanical Failure
blocks Statutory / Regulatory / Contractual Change
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
blocks SIM-01.03B
blocks BCM-04.04AC
is blocked by IRO-15 Regulatory & Law Enforcement Contacts – Assessment Procedure
blocks IR-06 Incident Reporting
blocks IR-06 [L] Incident Reporting
blocks IR-06 [M] Incident Reporting
blocks IR-06 [H] Incident Reporting
blocks IR-06 [P] Incident Reporting
blocks 03.06.02 Incident Monitoring, Reporting, and Response Assistance
  • Secure Controls Framework -

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