+Artículo 13 6

Artículo 13 6

6.   Las entidades financieras desarrollarán programas de sensibilización en materia de seguridad de las TIC y formación sobre resiliencia operativa digital, que constituirán módulos obligatorios en sus programas de formación del personal. Esos programas y acciones formativas serán aplicables a todos los empleados y al personal de alta dirección y tendrán un nivel de complejidad acorde con las atribuciones de sus funciones. Cuando proceda, las entidades financieras también incluirán a proveedores terceros de servicios de TIC en sus planes de formación pertinentes de conformidad con el artículo 30, apartado 2, letra i).

1. Resumen

,

1.1 Referencias

1.2 Requisitos identificados

1.3 Estándares relacionados

2. Requisitos identificados

Requisitos

3. Estándares relacionados

Estándares
NOREA Resilience Training Programs
Implement security awareness and digital operational resilience training as integral components of staff training schemes and ensure training extends to all staff members, including senior management. Customize training intensity based on employee roles and functions. For the training content, cover topics such as network security, insights from prior incidents, threat intelligence, defenses against intrusions, data protection measures (e.g., encryption, cryptography). Conduct the resilience training program on an annual basis. Staff shall be informed on the ICT security policies, procedures and protocols and be made aware of the reporting channels put in place for detecting anomalous activities. Upon termination of employment, all staff are required to return all ICT assets and information assets.
NOREA Inclusion of Third-Party Providers

Incorporate ICT third-party service providers as participants in relevant training programs, where appropriate. Third-parties shall be informed on the ICT security policies, procedures and protocols and be made aware of the reporting channels put in place for detecting anomalous activities. Upon termination of employment or contract termination, the third-parties are required to return all ICT assets and information assets that belong to the financial entity. 
SCF Security Awareness & Training Policy

Description

Mechanisms exist to establish a formal, documented security awareness and training policy that:
(1) Conveys executive management's intent;
(2) Provides organizational direction and expected behaviors;
(3) Is reviewed at least annually; and
(4) Is updated, as necessary, to adapt to evolving risks, threats and other changes that affect the organization.

Possible Solutions & Considerations

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ Executive-approved written policy with documented annual review

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ Executive-approved written policy with documented annual review
∙ Policy acknowledgement tracking (e.g., HR onboarding records)

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.) for policy lifecycle management
∙ Documented annual policy review with version control

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.) for policy lifecycle management
∙ Policy governance committee with formal annual review and approval workflow
∙ Automated policy attestation and acknowledgement tracking

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

∙ Steering committee
∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ Enterprise GRC platform (e.g., Cyturus, Archer, MetricStream, ServiceNow IRM) for policy lifecycle management
∙ Automated policy attestation, exception tracking and change history
∙ Annual executive approval and board-level reporting

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

Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.

Level 3 Well Defined

Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions).
▪ 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 SAT 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).

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 Security, Compliance & Resilience-Minded Workforce

Description

Mechanisms exist to facilitate the implementation of security workforce development and awareness controls.

Possible Solutions & Considerations

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

∙ Third-party advisors (e.g., virtual CISO, Managed Security Services Provider (MSSP), etc.)

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

∙ Third-party advisors (e.g., virtual CISO, Managed Security Services Provider (MSSP), etc.)

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

∙ Chief Information Security Officer (CISO)

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

∙ Chief Information Security Officer (CISO)

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

∙ Chief Information Security Officer (CISO)

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

Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.

Level 2 Planned Tracked

Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.
▪ Privileged users receive formal security and/or data privacy awareness training to ensure they understand their unique roles and responsibilities.
▪ The responsibility for training users and enforcing policies may be assigned to user's immediate supervisor(s)/manager(s), including the definition and enforcement of the user's specific role(s) and responsibilities.

Level 3 Well Defined

Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions).
▪ 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 SAT 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 facilitate the implementation of security workforce development and awareness controls.

Level 4 Quantitatively Controlled

Security Awareness & Training (SAT) 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 Maintaining Workforce Development Relevancy

Description

Mechanisms exist to periodically review security workforce development and awareness training to account for changes to:
(1) Organizational policies, standards and procedures;
(2) Assigned roles and responsibilities;
(3) Relevant threats and risks; and
(4) Technological developments.

Possible Solutions & Considerations

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

∙ Provide role-specific security guidance for IT/admin roles

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

∙ Role-based security training for IT personnel

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

∙ Formal role-based security training program
∙ IT/admin-specific cybersecurity curriculum

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

∙ Enterprise role-based security training platform
∙ Technical security training for IT/admin roles

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

∙ Enterprise role-based security training program (e.g., KnowBe4, SANS)
∙ Technical training paths by role
∙ Certification support

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

Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.

Level 2 Planned Tracked

Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Business process owners are required to incorporate vendor-specific security training in support of new technology initiatives.

Level 3 Well Defined

Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions).
▪ 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 SAT 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 periodically review security workforce development and awareness training to account for changes to:
(1) Organizational policies, standards and procedures;
(2) Assigned roles and responsibilities;
(3) Relevant threats and risks; and
(4) Technological developments.

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 Security, Compliance & Resilience Awareness Training

Description

Mechanisms exist to provide all employees and contractors appropriate security, compliance and resilience awareness education and training that is relevant for their job function.

Possible Solutions & Considerations

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

∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)

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

∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)

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

∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)

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

∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)

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

∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)

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

Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.

Level 2 Planned Tracked

Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.

Level 3 Well Defined

Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions).
▪ 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 SAT 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 provide all employees and contractors appropriate security, compliance and resilience awareness education and training that is relevant for their job function.

Level 4 Quantitatively Controlled

Security Awareness & Training (SAT) 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 Role-Based Security, Compliance & Resilience Training

Description

Mechanisms exist to provide role-based security, compliance and resilience-related training:
(1) Before authorizing access to the system or performing assigned duties;
(2) When required by system changes; and
(3) Annually thereafter.

Possible Solutions & Considerations

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

∙ KnowB4 (https://knowbe4.com)

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

∙ KnowB4 (https://knowbe4.com)

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

∙ KnowB4 (https://knowbe4.com)

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

∙ KnowB4 (https://knowbe4.com)

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

∙ KnowB4 (https://knowbe4.com)

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

Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.
▪ IT/cybersecurity personnel self-manage their professional certification requirements to support their assigned duties.

Level 2 Planned Tracked

Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.
▪ Privileged users receive formal security and/or data privacy awareness training to ensure they understand their unique roles and responsibilities.
▪ The responsibility for training users and enforcing policies may be assigned to user's immediate supervisor(s)/manager(s), including the definition and enforcement of the user's specific role(s) and responsibilities.
▪ Security awareness and training methods are role-based (e.g., handling sensitive/regulated data).

Level 3 Well Defined

Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions).
▪ 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 SAT 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 provide role-based security, compliance and resilience-related training:
(1) Before authorizing access to the system or performing assigned duties;
(2) When required by system changes; and
(3) Annually thereafter.

Level 4 Quantitatively Controlled

Security Awareness & Training (SAT) 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 Cyber Threat Environment Situational Awareness

Description

Mechanisms exist to provide role-based security, compliance and resilience awareness training that is current and relevant to the cyber threats that users might encounter in day-to-day business operations.

Possible Solutions & Considerations

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

∙ US-CERT mailing lists & feeds
∙ Internal newsletters

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

∙ US-CERT mailing lists & feeds
∙ Internal newsletters

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

∙ US-CERT mailing lists & feeds
∙ Internal newsletters
∙ InfraGard (https://infragard.org)

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

∙ US-CERT mailing lists & feeds
∙ Internal newsletters
∙ InfraGard (https://infragard.org)

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

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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

Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.
▪ Privileged users receive formal security and/or data privacy awareness training to ensure they understand their unique roles and responsibilities.
▪ The responsibility for training users and enforcing policies may be assigned to user's immediate supervisor(s)/manager(s), including the definition and enforcement of the user's specific role(s) and responsibilities.
▪ Security awareness and training methods are role-based (e.g., handling sensitive/regulated data).
▪ Business process owners are required to incorporate vendor-specific security training in support of new technology initiatives.
▪ Security awareness training covers recommended practices for securing laptops and mobile devices while traveling.
▪ Security awareness training covers reporting of unauthorized alterations and evidence of tampering of equipment

Level 3 Well Defined

Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions).
▪ 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 SAT 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 provide role-based security, compliance and resilience awareness training that is current and relevant to the cyber threats that users might encounter in day-to-day business operations.

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.