+Alignment With Enterprise Architecture
---+Standardized Terminology
---+Outsourcing Non-Essential Functions or Services
---+Technical Debt Reviews
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Alignment With Enterprise Architecture
Description
Mechanisms exist to develop an enterprise architecture, aligned with industry-recognized leading practices, with consideration for security, compliance and resilience principles that addresses risk to organizational operations, assets, individuals and other organizations.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Follow secure coding basics
∙ Document security decisions
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Secure design checklist
∙ Basic threat modeling
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Enterprise architecture committee
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise architecture committee
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise architecture committee
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
Secure Engineering & Architecture (SEA) 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 SEA domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SEA 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 SEA domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Secure engineering and architecture-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Secure engineering and architecture 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 define entity-specific secure engineering practices to protect the Confidentiality, Integrity, Availability and Safety (CIAS) of the entity's TAASD.
▪ IT and/or cybersecurity personnel align secure engineering practices with the entity's broader IT architecture practices.
▪ IT and/or cybersecurity personnel use secure engineering practices to influence Secure Baseline Configurations (SBC).
Level 3 Well Defined
Secure Engineering & Architecture (SEA) 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 SEA 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 SEA domain capabilities are well-documented and kept current by process owners.
▪ A cybersecurity engineering / architecture 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 secure engineering management operations (e.g., project management solution, 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 SEA 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).
▪ Secure Baseline Configurations (SBC) enforce the secure engineering principles on all applicable Technology Assets, Applications and/or Services (TAAS).
▪ An implemented and operational capability exists to develop an enterprise architecture, aligned with industry-recognized leading practices, with consideration for security, compliance and resilience principles that addresses risk to organizational operations, assets, individuals and other organizations.
Level 4 Quantitatively Controlled
Secure Engineering & Architecture (SEA) 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 |
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Standardized Terminology
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Description
Mechanisms exist to standardize technology and process terminology to reduce confusion amongst groups and departments.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Follow secure coding basics when developing software
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Secure coding guidelines for developers
∙ Basic security review before release
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal security engineering principles
∙ Secure design patterns
∙ Threat modeling
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise security engineering program
∙ Formal threat modeling
∙ Security architecture standards
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise security architecture framework (SABSA)
∙ Formal threat modeling program
∙ Security design patterns library
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
Secure Engineering & Architecture (SEA) 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 SEA domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SEA 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 SEA domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Secure engineering and architecture-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Secure engineering and architecture 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 define entity-specific secure engineering practices to protect the Confidentiality, Integrity, Availability and Safety (CIAS) of the entity's TAASD.
▪ IT and/or cybersecurity personnel align secure engineering practices with the entity's broader IT architecture practices.
▪ IT and/or cybersecurity personnel use secure engineering practices to influence Secure Baseline Configurations (SBC).
Level 3 Well Defined
Secure Engineering & Architecture (SEA) 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 SEA 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 SEA domain capabilities are well-documented and kept current by process owners.
▪ A cybersecurity engineering / architecture 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 secure engineering management operations (e.g., project management solution, 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 SEA 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).
▪ Secure Baseline Configurations (SBC) enforce the secure engineering principles on all applicable Technology Assets, Applications and/or Services (TAAS).
▪ An implemented and operational capability exists to standardize technology and process terminology to reduce confusion amongst groups and departments.
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.
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Outsourcing Non-Essential Functions or Services
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Description
Mechanisms exist to identify non-essential functions or services that are capable of being outsourced to external service providers and align with the organization's enterprise architecture and security standards.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Apply security-by-design when building/procuring systems
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Security-by-design policy for new developments and acquisitions
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal security-by-design principles integrated into development lifecycle
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise security-by-design program
∙ Security architecture reviews at design phase
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise security-by-design framework
∙ Architecture review board
∙ Automated security architecture analysis
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
Secure Engineering & Architecture (SEA) 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 SEA domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SEA 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 SEA domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Secure engineering and architecture-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Secure engineering and architecture 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 define entity-specific secure engineering practices to protect the Confidentiality, Integrity, Availability and Safety (CIAS) of the entity's TAASD.
▪ IT and/or cybersecurity personnel align secure engineering practices with the entity's broader IT architecture practices.
▪ IT and/or cybersecurity personnel use secure engineering practices to influence Secure Baseline Configurations (SBC).
Level 3 Well Defined
Secure Engineering & Architecture (SEA) 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 SEA 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 SEA domain capabilities are well-documented and kept current by process owners.
▪ A cybersecurity engineering / architecture 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 secure engineering management operations (e.g., project management solution, 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 SEA 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).
▪ Secure Baseline Configurations (SBC) enforce the secure engineering principles on all applicable Technology Assets, Applications and/or Services (TAAS).
▪ An implemented and operational capability exists to identify non-essential functions or services that are capable of being outsourced to external service providers and align with the organization's enterprise architecture and security standards.
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.
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Technical Debt Reviews
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Description
Mechanisms exist to conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/or unsupported technologies.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Computer Lifecycle Program (CLP)
∙ IT Asset Management (ITAM) program
∙ Risk Management Program (RMP)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Computer Lifecycle Program (CLP)
∙ IT Asset Management (ITAM) program
∙ Risk Management Program (RMP)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Computer Lifecycle Program (CLP)
∙ IT Asset Management (ITAM) program
∙ Risk Management Program (RMP)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Computer Lifecycle Program (CLP)
∙ IT Asset Management (ITAM) program
∙ Risk Management Program (RMP)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Computer Lifecycle Program (CLP)
∙ IT Asset Management (ITAM) program
∙ Risk Management Program (RMP)
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
Secure Engineering & Architecture (SEA) 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 SEA 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 SEA domain capabilities are well-documented and kept current by process owners.
▪ A cybersecurity engineering / architecture 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 secure engineering management operations (e.g., project management solution, 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 SEA 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).
▪ Secure Baseline Configurations (SBC) enforce the secure engineering principles on all applicable Technology Assets, Applications and/or Services (TAAS).
▪ An implemented and operational capability exists to conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/or unsupported technologies.
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.
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1.1 References
1.2 Identified Requirements
1.3 Related Regulations
2. Identified Requirements
Requirements
| Source |
Requirement |
3. Related Regulations
Regulations
| Source |
Regulation |
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DORA
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DORA Ch. II Sec. II Art. 9 3.
3. In order to achieve the objectives referred to in paragraph 2, financial entities shall use ICT solutions and processes that are appropriate in accordance with Article 4. Those ICT solutions and processes shall:
- (a) ensure the security of the means of transfer of data;
- (b) minimise the risk of corruption or loss of data, unauthorised access and technical flaws that may hinder business activity;
- (c) prevent the lack of availability, the impairment of the authenticity and integrity, the breaches of confidentiality and the loss of data;
- (d) ensure that data is protected from risks arising from data management, including poor administration, processing-related risks and human error.
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DELAW
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BDSG § 9 Zuständigkeit
(1) Die oder der Bundesbeauftragte ist zuständig für die Aufsicht über die öffentlichen Stellen des Bundes, auch soweit sie als öffentlich-rechtliche Unternehmen am Wettbewerb teilnehmen, sowie über Unternehmen, soweit diese für die geschäftsmäßige Erbringung von Telekommunikationsdienstleistungen Daten von natürlichen oder juristischen Personen verarbeiten und sich die Zuständigkeit nicht bereits aus § 29 des Telekommunikation-Digitale-Dienste-Datenschutz-Gesetzes ergibt. Die Vorschriften dieses Kapitels gelten auch für Auftragsverarbeiter, soweit sie nichtöffentliche Stellen sind, bei denen dem Bund die Mehrheit der Anteile gehört oder die Mehrheit der Stimmen zusteht und der Auftraggeber eine öffentliche Stelle des Bundes ist. (2) Die oder der Bundesbeauftragte ist nicht zuständig für die Aufsicht über die von den Bundesgerichten im Rahmen ihrer justiziellen Tätigkeit vorgenommenen Verarbeitungen.
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Linked Issues
- Secure Controls Framework -
"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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