+20 artikla Henkilöllisyyden hallinta
---+20 artikla 1.
---+20 artikla 2.

20 artikla Henkilöllisyyden hallinta

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1. Yleiskatsaus

,
Otsikko Sääntely
20 artikla 1.
Käyttöoikeuksien myöntämiseksi 21 artiklan mukaisesti finanssiyhteisöjen on osana pääsynhallintaoikeuksien valvontaa laadittava, dokumentoitava ja otettava käyttöön henkilöllisyyden hallintaa koskevat toimintaperiaatteet ja menettelyt, joilla varmistetaan sellaisten luonnollisten henkilöiden ja järjestelmien yksilöllinen tunnistaminen ja todentaminen, joilla on pääsy finanssiyhteisöjen tietoihin.
20 artikla 2.

Edellä 1 kohdassa tarkoitettujen henkilöllisyyden hallintaa koskevien toimintaperiaatteiden ja menettelyjen on sisällettävä kaikki seuraavat:

a) 

kaikille finanssiyhteisön henkilöstön jäsenille taikka TVT-palveluntarjoajana olevien kolmansien osapuolten henkilöstölle, jo(i)lla on pääsy finanssiyhteisön tieto-omaisuuteen ja TVT-omaisuuteen, on annettava yksilöllistä käyttäjätiliä vastaava yksilöllinen henkilöllisyys, sanotun kuitenkaan rajoittamatta 21 artiklan ensimmäisen kohdan c alakohdan soveltamista;

b) 

elinkaarenhallintamenettely henkilöllisyyksille ja tileille, joilla hallinnoidaan kaikkien tilien luomista, muuttamista, tarkistamista ja päivittämistä, väliaikaista käytöstäpoistamista ja sulkemista.

Sovellettaessa a alakohtaa finanssiyhteisöjen on pidettävä kirjaa kaikista luoduista henkilöllisyyksistä. Nämä tiedot on säilytettävä finanssiyhteisön uudelleenjärjestelyn tai sopimussuhteen päättymisen jälkeen, sanotun kuitenkaan rajoittamatta sovellettavassa unionin ja kansallisessa lainsäädännössä säädettyjen säilyttämisvaatimusten soveltamista.

Sovellettaessa b alakohtaa finanssiyhteisöjen on mahdollisuuksien mukaan ja tarvittaessa otettava käyttöön automatisoituja ratkaisuja henkilöllisyyksien elinkaarenhallintamenettelyä varten.

1.1 Viittaukset

1.2 Tunnistetut vaatimukset

1.3 Liittyvät standardit

2. Tunnistetut vaatimukset

Vaatimukset
Lähde Vaatimus

3. Liittyvät standardit

Standardit
Lähde Vaatimus
SCF Identity & Access Management (IAM)

Description

Mechanisms exist to facilitate the implementation of Identification and Access Management (IAM) controls.

Possible Solutions & Considerations

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

∙ Strong password policy
∙ MFA for key accounts

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

∙ Password manager
∙ MFA on all accounts
∙ Identity policy

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

∙ Identity & Access Management (IAM) program

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

∙ Identity & Access Management (IAM) program

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

∙ Identity & Access Management (IAM) 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

Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions.
▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.
▪ Active Directory (AD), or a similar technologies, are used to centrally manage identities and permissions, but asset/process owners are authorized to operate a decentralized access control program for their specific Technology Assets, Applications, Services and/or Data (TAASD).

Level 2 Planned Tracked

Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
▪ IAM restricts the assignment of privileged accounts to entity-defined personnel and/or roles (privilege assignment requires management approval).

Level 3 Well Defined

Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 identification and access management controls.

Level 4 Quantitatively Controlled

Identification & Authentication (IAC) 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 Identity & Access Management (IAM)

Description

Mechanisms exist to facilitate the implementation of Identification and Access Management (IAM) controls.

Possible Solutions & Considerations

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

∙ Strong password policy
∙ MFA for key accounts

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

∙ Password manager
∙ MFA on all accounts
∙ Identity policy

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

∙ Identity & Access Management (IAM) program

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

∙ Identity & Access Management (IAM) program

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

∙ Identity & Access Management (IAM) 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

Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions.
▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.
▪ Active Directory (AD), or a similar technologies, are used to centrally manage identities and permissions, but asset/process owners are authorized to operate a decentralized access control program for their specific Technology Assets, Applications, Services and/or Data (TAASD).

Level 2 Planned Tracked

Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
▪ IAM restricts the assignment of privileged accounts to entity-defined personnel and/or roles (privilege assignment requires management approval).

Level 3 Well Defined

Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 identification and access management controls.

Level 4 Quantitatively Controlled

Identification & Authentication (IAC) 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 Retain Access Records

Description

Mechanisms exist to retain a record of personnel accountability to ensure there is a record of all access granted to an individual (system and application-wise), who provided the authorization, when the authorization was granted and when the access was last reviewed.

Possible Solutions & Considerations

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

∙ Retain access logs per backup/log retention policy

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

∙ Access log retention policy
∙ Store logs for minimum retention period

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

∙ Formal access records retention policy
∙ Centralized log storage

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

∙ Enterprise log management system
∙ Defined retention periods per compliance requirement

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

∙ Enterprise SIEM/log management platform (e.g., Splunk, IBM QRadar)
∙ Immutable log storage
∙ Compliance-driven retention schedules

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

Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.

Level 3 Well Defined

Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 retain a record of personnel accountability to ensure there is a record of all access granted to an individual (system and application-wise), who provided the authorization, when the authorization was granted and when the access was last reviewed.

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 User Provisioning & De-Provisioning

Description

Mechanisms exist to utilize a formal user registration and de-registration process that governs the assignment of access rights.

Possible Solutions & Considerations

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

∙ Documented process for adding/removing user access

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

∙ User provisioning and de-provisioning procedure
∙ Timely removal of access on departure

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

∙ Formal user lifecycle management process
∙ Provisioning workflows
∙ Timely de-provisioning

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

∙ Enterprise IAM with automated provisioning/de-provisioning (e.g., SailPoint, Saviynt)

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

∙ Enterprise IGA platform (e.g., SailPoint, Saviynt, Microsoft Entra ID Governance)
∙ Automated lifecycle management
∙ Role-based access provisioning

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

Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions.
▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.

Level 2 Planned Tracked

Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
▪ IAM restricts the assignment of privileged accounts to entity-defined personnel and/or roles (privilege assignment requires management approval).

Level 3 Well Defined

Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 formal user registration and de-registration process that governs the assignment of access rights.

Level 4 Quantitatively Controlled

Identification & Authentication (IAC) 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 Account Management

Description

Mechanisms exist to:
(1) Define authorized system account types;
(2) Define prohibited system account types; and
(3) Proactively govern individual, group, system, service, application, guest and temporary accounts.

Possible Solutions & Considerations

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

∙ Microsoft Active Directory
∙ Microsoft Entra
∙ AWS IAM

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

∙ Microsoft Active Directory
∙ Microsoft Entra
∙ AWS IAM

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

∙ Microsoft Active Directory
∙ Microsoft Entra
∙ AWS IAM

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

∙ Microsoft Active Directory
∙ Microsoft Entra
∙ AWS IAM

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

∙ Microsoft Active Directory
∙ Microsoft Entra
∙ AWS IAM

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

Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.

Level 3 Well Defined

Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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:
(1) Define authorized system account types;
(2) Define prohibited system account types; and
(3) Proactively govern individual, group, system, service, application, guest and temporary accounts.

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 Automated System Account Management (Directory Services)

Description

Automated mechanisms exist to support the management of system accounts (e.g., directory services).

Possible Solutions & Considerations

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.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

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

Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.

Level 3 Well Defined

Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 support the management of system accounts (e.g., directory services).

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 Standardized Identifier Management (User Names)

Description

Mechanisms exist to govern naming standards for usernames and Technology Assets, Applications and/or Services (TAAS).

Possible Solutions & Considerations

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.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

Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions.
▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.

Level 2 Planned Tracked

Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.

Level 3 Well Defined

Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 govern naming standards for usernames and Technology Assets, Applications and/or Services (TAAS).

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 Standardized Identifier Management (User Names)

Description

Mechanisms exist to govern naming standards for usernames and Technology Assets, Applications and/or Services (TAAS).

Possible Solutions & Considerations

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.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

Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions.
▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.

Level 2 Planned Tracked

Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.

Level 3 Well Defined

Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 govern naming standards for usernames and Technology Assets, Applications and/or Services (TAAS).

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 Identification & Authentication for Organizational Users

Description

Mechanisms exist to uniquely identify and centrally Authenticate, Authorize and Audit (AAA) organizational users and processes acting on behalf of organizational users.

Possible Solutions & Considerations

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.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

Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions.
▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.
▪ Active Directory (AD), or a similar technologies, are used to centrally manage identities and permissions, but asset/process owners are authorized to operate a decentralized access control program for their specific Technology Assets, Applications, Services and/or Data (TAASD).

Level 2 Planned Tracked

Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.

Level 3 Well Defined

Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 uniquely identify and centrally Authenticate, Authorize and Audit (AAA) organizational users and processes acting on behalf of organizational users.

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 Identification & Authentication for Organizational Users

Description

Mechanisms exist to uniquely identify and centrally Authenticate, Authorize and Audit (AAA) organizational users and processes acting on behalf of organizational users.

Possible Solutions & Considerations

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.com)

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

∙ Microsoft Active Directory (https://microsoft.com)
∙ Microsoft Entra (https://microsoft.com)
∙ AWS IAM (https://aws.amazon.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

Identification & Authentication (IAC) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAC domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Identity & Access Management (IAM)-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IAM controls are primarily administrative in nature (e.g., policies & standards) to manage accounts and permissions.
▪ IT and/or cybersecurity personnel identify and implement IAM cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements.
▪ Active Directory (AD), or a similar technologies, are used to centrally manage identities and permissions, but asset/process owners are authorized to operate a decentralized access control program for their specific Technology Assets, Applications, Services and/or Data (TAASD).

Level 2 Planned Tracked

Identification & Authentication (IAC) 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 IAC domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with IAC 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 IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC).
▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts.
▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services.
▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.

Level 3 Well Defined

Identification & Authentication (IAC) 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 IAC 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 IAC domain capabilities are well-documented and kept current by process owners.
▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) 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 IAC 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 uniquely identify and centrally Authenticate, Authorize and Audit (AAA) organizational users and processes acting on behalf of organizational users.

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.