+Executive Leadership Approval For Managing Material Risk

Executive Leadership Approval For Managing Material Risk

Description

Mechanisms exist to obtain executive leadership approval for risk management decisions involving material risk.

Possible Solutions & Considerations

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

∙ Owner approves decisions on significant risks; decisions documented

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

∙ Executive sign-off for material risk decisions recorded in risk register

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

∙ Material risk decisions escalated to executive leadership with documented approval
∙ Risk register with approval fields

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

∙ Risk governance committee with executive approval authority for material risks
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)

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

∙ Enterprise risk governance with board/executive approval workflows for material risk
∙ Enterprise GRC platform (e.g., Archer, MetricStream, ServiceNow IRM)
∙ Materiality determination procedures

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

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 obtain executive leadership approval for risk management decisions involving material risk.

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

1.1 References

1.2 Identified Requirements

1.3 Related Regulations

2. Identified Requirements

Requirements

3. Related Regulations

Regulations
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 Semi-Annual
is related to relative Control Weighting = 09
is related to Process
is related to Identify
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 Annual
is related to Govern
blocks Failure to Achieve Strategic / Mission Objectives
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 Dysfunctional Management Practices
blocks Human Error
blocks Statutory / Regulatory / Contractual Change
blocks Fraud, Corruption and/or Intentional Criminal Conduct
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Foreign Ownership, Control, or Influence (FOCI)
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
blocks Failure to Achieve Strategic / Mission Objectives
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 Dysfunctional Management Practices
blocks Human Error
blocks Statutory / Regulatory / Contractual Change
blocks Fraud, Corruption and/or Intentional Criminal Conduct
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Foreign Ownership, Control, or Influence (FOCI)
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
is blocked by RSK-06.1 Executive Leadership Approval For Managing Material Risk – Assessment Procedure
  • Secure Controls Framework -

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    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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