+Adequate Security for Sensitive / Regulated Data In Support of Contracts

Adequate Security for Sensitive / Regulated Data In Support of Contracts

Description

Mechanisms exist to protect sensitive/regulated data that is collected, developed, received, transmitted, used or stored in support of the performance of a contract.

Possible Solutions & Considerations

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

∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
∙ Contract flow-down requirements

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

∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
∙ Contract flow-down requirements

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

∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
∙ Contract flow-down requirements

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

∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
∙ Contract flow-down requirements

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

∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
∙ Contract flow-down requirements

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

Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

Level 3 Well Defined

Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners.
▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software, risk assessment software, etc.).
▪ 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 IAO 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 sensitive/regulated data that is collected, developed, received, transmitted, used or stored in support of the performance of a contract.

Level 4 Quantitatively Controlled

Information Assurance (IAO) 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

Linked Issues

Issuelinks
is related to Annual
is related to relative Control Weighting = 07
is related to Process
is related to Protect
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 Inability to maintain individual accountability
blocks Improper assignment of privileged functions
blocks Privilege escalation
blocks Unauthorized access
blocks Lost, damaged or stolen asset(s)
blocks Loss of integrity through unauthorized changes
blocks Business interruption
blocks Data loss / corruption
blocks Reduction in productivity
blocks Information loss / corruption or system compromise due to technical attack
blocks Information loss / corruption or system compromise due to non‐technical attack
blocks Loss of revenue
blocks Cancelled contract
blocks Diminished competitive advantage
blocks Diminished reputation
blocks Fines and judgements
blocks Unmitigated vulnerabilities
blocks System compromise
blocks Inability to support business processes
blocks Incorrect controls scoping
blocks Lack of roles & responsibilities
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 Inability to investigate / prosecute incidents
blocks Improper response to incidents
blocks Ineffective remediation actions
blocks Expense associated with managing a loss event
blocks Inability to maintain situational awareness
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)

    "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/ 

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