+Article 14 Securing information in transit
---+Article 14 1.
---+Article 14 2.

Article 14 Securing information in transit

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1. Overview

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Article 14 1.

As part of the safeguards to preserve the availability, authenticity, integrity and confidentiality of data, financial entities shall develop, document, and implement the policies, procedures, protocols, and tools to protect information in transit. Financial entities shall in particular ensure all of the following:

(a) 

the availability, authenticity, integrity and confidentiality of data during network transmission, and the establishment of procedures to assess compliance with those requirements;

(b) 

the prevention and detection of data leakages and the secure transfer of information between the financial entity and external parties;

(c) 

that requirements on confidentiality or non-disclosure arrangements reflecting the financial entity’s needs for the protection of information for both the staff of the financial entity and of third parties are implemented, documented, and regularly reviewed.
Article 14 2.
Financial entities shall design the policies, procedures, protocols, and tools to protect the information in transit referred to in paragraph 1 on the basis of the results of the approved data classification and of the ICT risk assessment.

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

Requirements

3. Related Standards

Standards
SCF Encrypting Data In Transit

Description

Cryptographic mechanisms exist to prevent the unauthorized disclosure of data in transit.

Possible Solutions & Considerations

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

∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)

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

∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)

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

∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)

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

∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)

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

∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)

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

Cryptographic Protections (CRY) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with CRY domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Cryptography management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel provide an encryption solution (software or hardware) for the storage of sensitive/regulated data.
▪ Sensitive/regulated data is encrypted in transit according to standardized processes.

Level 2 Planned Tracked

Cryptographic Protections (CRY) 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 CRY domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CRY 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 CRY domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Cryptographic management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Cryptographic management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Technology Assets, Applications and/or Services (TAAS) that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.
▪ External compliance requirements for cryptography are identified and documented, based on applicable laws, regulations and contractual obligations.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to implement cryptographic mechanisms that are applicability for statutory, regulatory and/or contractual compliance obligations.
▪ Sensitive/regulated data is encrypted at rest using cryptographic protections that are commensurate with the sensitivity of the data.
▪ Sensitive/regulated data is encrypted during transmission using cryptographic protections that are commensurate with the sensitivity of the data.

Level 3 Well Defined

Cryptographic Protections (CRY) 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 CRY 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 CRY domain capabilities are well-documented and kept current by process owners.
▪ A security engineering team, or similar function, is appropriately staffed and supported to implement and maintain CRY domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of cryptographic protections operations (e.g., PKI management 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 CRY 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 cryptographic capability exists to protect the confidentiality of data being transmitted.

Level 4 Quantitatively Controlled

Cryptographic Protections (CRY) 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.
SCF Encrypting Data In Transit

Description

Cryptographic mechanisms exist to prevent the unauthorized disclosure of data in transit.

Possible Solutions & Considerations

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

∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)

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

∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)

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

∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)

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

∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)

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

∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov)
∙ Transport Layer Security (TLS)
∙ IPSec encryption
∙ Encrypted Multiprotocol Label Switching (MPLS)

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

Cryptographic Protections (CRY) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with CRY domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Cryptography management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel provide an encryption solution (software or hardware) for the storage of sensitive/regulated data.
▪ Sensitive/regulated data is encrypted in transit according to standardized processes.

Level 2 Planned Tracked

Cryptographic Protections (CRY) 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 CRY domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CRY 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 CRY domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Cryptographic management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Cryptographic management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Technology Assets, Applications and/or Services (TAAS) that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.
▪ External compliance requirements for cryptography are identified and documented, based on applicable laws, regulations and contractual obligations.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to implement cryptographic mechanisms that are applicability for statutory, regulatory and/or contractual compliance obligations.
▪ Sensitive/regulated data is encrypted at rest using cryptographic protections that are commensurate with the sensitivity of the data.
▪ Sensitive/regulated data is encrypted during transmission using cryptographic protections that are commensurate with the sensitivity of the data.

Level 3 Well Defined

Cryptographic Protections (CRY) 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 CRY 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 CRY domain capabilities are well-documented and kept current by process owners.
▪ A security engineering team, or similar function, is appropriately staffed and supported to implement and maintain CRY domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of cryptographic protections operations (e.g., PKI management 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 CRY 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 cryptographic capability exists to protect the confidentiality of data being transmitted.

Level 4 Quantitatively Controlled

Cryptographic Protections (CRY) 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.
SCF Integrity of Data In Transit

Description

Cryptographic mechanisms exist to detect unauthorized changes to data in transit.

Possible Solutions & Considerations

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

∙ TLS for all data in transit (integrity via TLS)

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

∙ Secure Baseline Configurations (SBC)
∙ TLS 1.2+ with authenticated cipher suites (AEAD)

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

∙ Secure Baseline Configurations (SBC)
∙ TLS with integrity-protected cipher suites; message signing for sensitive transfers
∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov/projects/cryptographic-module-validation-program)

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

∙ Cryptographic governance program
∙ Enforced TLS/IPsec with AEAD cipher suites
∙ Digital signatures / HMAC for integrity of critical transfers

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

∙ Enterprise transport integrity standards (TLS 1.3/IPsec with AEAD, message-level signing)
∙ Certificate management platform
∙ FIPS 140-3 validated modules

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

Cryptographic Protections (CRY) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with CRY domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Cryptography management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel provide an encryption solution (software or hardware) for the storage of sensitive/regulated data.

Level 2 Planned Tracked

Cryptographic Protections (CRY) 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 CRY domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CRY 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 CRY domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Cryptographic management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Cryptographic management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Technology Assets, Applications and/or Services (TAAS) that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.
▪ External compliance requirements for cryptography are identified and documented, based on applicable laws, regulations and contractual obligations.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to implement cryptographic mechanisms that are applicability for statutory, regulatory and/or contractual compliance obligations.
▪ Sensitive/regulated data is encrypted at rest using cryptographic protections that are commensurate with the sensitivity of the data.

Level 3 Well Defined

Cryptographic Protections (CRY) 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 CRY 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 CRY domain capabilities are well-documented and kept current by process owners.
▪ A security engineering team, or similar function, is appropriately staffed and supported to implement and maintain CRY domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of cryptographic protections operations (e.g., PKI management 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 CRY 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 cryptographic capability exists to protect the integrity of data being transmitted.

Level 4 Quantitatively Controlled

Cryptographic Protections (CRY) 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.
SCF Integrity of Data In Transit

Description

Cryptographic mechanisms exist to detect unauthorized changes to data in transit.

Possible Solutions & Considerations

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

∙ TLS for all data in transit (integrity via TLS)

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

∙ Secure Baseline Configurations (SBC)
∙ TLS 1.2+ with authenticated cipher suites (AEAD)

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

∙ Secure Baseline Configurations (SBC)
∙ TLS with integrity-protected cipher suites; message signing for sensitive transfers
∙ NIST Cryptographic Module Validation Program (CMVP) (https://csrc.nist.gov/projects/cryptographic-module-validation-program)

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

∙ Cryptographic governance program
∙ Enforced TLS/IPsec with AEAD cipher suites
∙ Digital signatures / HMAC for integrity of critical transfers

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

∙ Enterprise transport integrity standards (TLS 1.3/IPsec with AEAD, message-level signing)
∙ Certificate management platform
∙ FIPS 140-3 validated modules

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

Cryptographic Protections (CRY) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with CRY domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Cryptography management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel provide an encryption solution (software or hardware) for the storage of sensitive/regulated data.

Level 2 Planned Tracked

Cryptographic Protections (CRY) 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 CRY domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CRY 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 CRY domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Cryptographic management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Cryptographic management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Technology Assets, Applications and/or Services (TAAS) that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.
▪ External compliance requirements for cryptography are identified and documented, based on applicable laws, regulations and contractual obligations.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to implement cryptographic mechanisms that are applicability for statutory, regulatory and/or contractual compliance obligations.
▪ Sensitive/regulated data is encrypted at rest using cryptographic protections that are commensurate with the sensitivity of the data.

Level 3 Well Defined

Cryptographic Protections (CRY) 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 CRY 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 CRY domain capabilities are well-documented and kept current by process owners.
▪ A security engineering team, or similar function, is appropriately staffed and supported to implement and maintain CRY domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of cryptographic protections operations (e.g., PKI management 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 CRY 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 cryptographic capability exists to protect the integrity of data being transmitted.

Level 4 Quantitatively Controlled

Cryptographic Protections (CRY) 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.
SCF Data & Asset Classification

Description

Mechanisms exist to ensure data and assets are categorized in accordance with applicable statutory, regulatory and contractual requirements.

Possible Solutions & Considerations

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

∙ Data classification program
∙ IT Asset Management (ITAM) program

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

∙ Data classification program
∙ IT Asset Management (ITAM) program

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

∙ Data classification program
∙ IT Asset Management (ITAM) program
∙ Data governance program

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

∙ Data classification program
∙ IT Asset Management (ITAM) program
∙ Data governance program

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

∙ Data classification program
∙ IT Asset Management (ITAM) program
∙ Data governance program

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

Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations.
▪ TAASD are categorized according to data classification and business criticality.
▪ Data classification and handling criteria govern requirements protect sensitive/regulated regardless of where it is stored, processed and/or transmitted.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to categorize data in accordance with organizational policies and standards.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to document where sensitive/regulated data is stored, transmitted and/or processed.

Level 3 Well Defined

Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners.
▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform).
▪ 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 DCH 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 ensure data and assets are categorized in accordance with applicable statutory, regulatory and contractual requirements.

Level 4 Quantitatively Controlled

Data Classification & Handling (DCH) 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.
SCF Sensitive / Regulated Data Sharing Decisions

Description

Mechanisms exist to utilize a process to assist users in making information sharing decisions to ensure data is appropriately protected.

Possible Solutions & Considerations

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

∙ Data classification program

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

∙ Data classification program

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

∙ Data classification program

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

∙ Data classification program
∙ Data governance program

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

∙ Data classification program
∙ Data governance program

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

Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Data classification and handling management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ A formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations.

Level 3 Well Defined

Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners.
▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform).
▪ 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 DCH 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 utilize a process to assist users in making information sharing decisions to ensure data is appropriately protected.

Level 4 Quantitatively Controlled

Data Classification & Handling (DCH) 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

Data Classification & Handling (DCH) 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.
▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.
▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
SCF Data Loss Prevention (DLP)

Description

Automated mechanisms exist to implement Data Loss Prevention (DLP) to protect sensitive information as it is stored, transmitted and processed.

Possible Solutions & Considerations

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

∙ Data Loss Prevention (DLP)

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

∙ Data Loss Prevention (DLP)

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

∙ Data Loss Prevention (DLP)

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

∙ Data Loss Prevention (DLP)

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

∙ Data Loss Prevention (DLP)

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

Network Security (NET) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with NET domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Network security-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.

Level 2 Planned Tracked

Network Security (NET) 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 NET domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with NET 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 NET domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Network security-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Network security 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 personnel define secure networking practices to protect the Confidentiality, Integrity, Availability and Safety (CIAS) of the organization's TAASD.
▪ Secure Baseline Configurations (SBC) enforce the principles of least privileges and least functionality for boundary protection technologies.
▪ Data Loss Prevention (DLP), or similar technologies, prevent unauthorized devices from connecting to endpoint devices to control the distribution of sensitive/regulated data.
▪ DLP prevents unauthorized devices from connecting to endpoint devices to control the distribution of sensitive/regulated data.

Level 3 Well Defined

Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners.
▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform).
▪ 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 DCH 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 automatically implement Data Loss Prevention (DLP) to protect sensitive information as it is stored, transmitted and processed.

Level 4 Quantitatively Controlled

Network Security (NET) 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

Network Security (NET) 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.
▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.
▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
SCF Confidentiality Agreements

Description

Mechanisms exist to require Non-Disclosure Agreements (NDAs) or similar confidentiality agreements that reflect the needs to protect data and operational details, for both employees and third-parties.

Possible Solutions & Considerations

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

∙ Access agreement
∙ Non-Disclosure Agreements (NDAs)

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

∙ Access agreement
∙ Non-Disclosure Agreements (NDAs)

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

∙ Access agreement
∙ Non-Disclosure Agreements (NDAs)

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

∙ Access agreement
∙ Non-Disclosure Agreements (NDAs)

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

∙ Access agreement
∙ Non-Disclosure Agreements (NDAs)

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.
▪ HR requires personnel with access to sensitive/regulated data to sign a Non-Disclosure Agreement (NDA).

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 require Non-Disclosure Agreements (NDAs) or similar confidentiality agreements that reflect the needs to protect data and operational details, or both employees and third-parties.

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.
SCF Safeguarding Data Over Open Networks

Description

Cryptographic mechanisms exist to implement strong cryptography and security protocols to safeguard sensitive and/or regulated data during transmission over open, public networks.

Possible Solutions & Considerations

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

∙ Use HTTPS/TLS for all internet-facing communications

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

∙ TLS for all internet traffic
∙ No unencrypted protocols over public networks

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

∙ Encryption-in-transit standards
∙ TLS 1.2+ enforcement
∙ Certificate management

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

∙ Enterprise encryption-in-transit program
∙ TLS 1.3 enforcement
∙ Certificate lifecycle management

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

∙ Enterprise encryption governance program
∙ TLS 1.3+
∙ Certificate management platform (e.g., Venafi)
∙ Automated certificate monitoring

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

Network Security (NET) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with NET domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Network security-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Network communications containing sensitive/regulated data are protected using a cryptographic mechanism to prevent unauthorized disclosure of information while in transit (e.g., SSH, TLS and VPN).
▪ Wireless access is protected via secure authentication and encryption.

Level 2 Planned Tracked

Network Security (NET) 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 NET domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with NET 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 NET domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Network security-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Network security 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 personnel define secure networking practices to protect the Confidentiality, Integrity, Availability and Safety (CIAS) of the organization's TAASD.
▪ Secure Baseline Configurations (SBC) enforce the principles of least privileges and least functionality for boundary protection technologies.
▪ Network communications containing sensitive/regulated data use a cryptographic mechanism to prevent the unauthorized disclosure of information while in transit (e.g., SSH, TLS and VPN).

Level 3 Well Defined

Network Security (NET) 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 NET 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 NET domain capabilities are well-documented and kept current by process owners.
▪ A network security management team, or similar function, is appropriately staffed and supported to implement and maintain NET domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of network security operations (e.g., network management solution and log aggregator).
▪ 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 NET 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 principles of least privileges and least functionality for boundary protection technologies.
▪ An implemented and operational cryptographic capability exists to implement strong cryptography and security protocols to safeguard sensitive/regulated data during transmission over open, public networks.

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.
SCF Risk Assessment

Description

Mechanisms exist to conduct recurring assessments of risk that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's Technology Assets, Applications, Services and/or Data (TAASD).

Possible Solutions & Considerations

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

∙ Risk Management Program (RMP)
∙ Risk assessment
∙ Business Impact Analysis (BIA)
∙ Data Protection Impact Assessment (DPIA)

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

∙ Risk Management Program (RMP)
∙ Risk assessment
∙ Business Impact Analysis (BIA)
∙ Data Protection Impact Assessment (DPIA)

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

∙ Risk Management Program (RMP)
∙ Risk assessment
∙ Business Impact Analysis (BIA)
∙ Data Protection Impact Assessment (DPIA)

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

∙ Risk Management Program (RMP)
∙ Risk assessment
∙ Business Impact Analysis (BIA)
∙ Data Protection Impact Assessment (DPIA)

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

∙ Risk Management Program (RMP)
∙ Risk assessment
∙ Business Impact Analysis (BIA)
∙ Data Protection Impact Assessment (DPIA)

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

Risk Management (RSK) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with RSK domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Risk management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel use an informal process to identify, assess, remediate and report on risk.
▪ Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ Data/process owners are expected to self-manage risks associated with their Technology Assets, Applications, Services and/or Data (TAASD), based on the organization's published policies and standards, including the identification, remediation and reporting of risks.

Level 2 Planned Tracked

Risk Management (RSK) 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 RSK domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with RSK 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 RSK domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported.
▪ Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
▪ Business process owners (BPOs) are made aware of cybersecurity and data protection risk(s).

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 conduct recurring assessments of risk that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's TAASD.

Level 4 Quantitatively Controlled

Risk Management (RSK) 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.