+Article 5 3

Article 5 3

3.   Financial entities, other than microenterprises, shall establish a role in order to monitor the arrangements concluded with ICT third-party service providers on the use of ICT services, or shall designate a member of senior management as responsible for overseeing the related risk exposure and relevant documentation.

1. Vue d’ensemble

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1.1 Références

1.2 Exigences identifiées

1.3 Normes associées

2. Exigences identifiées

Exigences

3. Normes associées

Normes
NOREA Governance of ICT risk

The Management body shall take ultimate responsibility for effectively managing all ICT risks of the financial entity. As such, the management body periodically (e.g. annually) ensures:

  • Establish policies related to the availability, authenticity, integrity, and confidentiality of data, including the policy on arrangements with ICT third-party service providers (see control 2.1).
  • Define the roles, responsibilities and goverance arrangements for ICT related functions risk management (including those related to ICT third-party arrangements), including the continuous monitoring thereof.
  • Review the policy on arrangements with ICT third-party service providers and stay informed about third-party  arrangements, services provided, planned material changes regarding third- party service providers, and understand the impact of these changes on critical and important functions of the entity (including risk assessment results). 
NOREA Knowledge of the Management Body
The Management body shall ensure that it is kept up to date with sufficient knowledge and skills to understand and assess ICT risks and operations (e.g. through periodic trainings).
NOREA Digital Operational Resilience Strategy

The Management body shall set and approve the digital operational resilience strategy and periodically update when needed.

The digital operational resilience strategy  must:

  • Set out how the risk management framework will be implemented.
  • Elaborate on the alignment between the risk management framework and the business strategy and objectives.
  • Establish the ICT risk tolerance level (based on risk appetite) and the impact tolerance level for ICT disruptions.
  • Include clear security objectives, including Key Performance Indicators (KPIs) and risk metrics.
  • Elaborate on the ICT reference architecture and any changes needed to reach specific business objectives.
  • Outline the mechanisms in place to detect ICT-related incidents
  • Contain evidence to prove the current digital operational resilience situation (e.g. based on the number of major ICT-related incidents and the effectiveness of preventive measures.
  • Contain how the digital operational resilience testing is implemented (see controls under 19 and 20).
  • Outline the communication strategy in case of incidents (see 11.3)

The Management body shall allocate and review the budget required for resources to fulfill the digital operational resilience needs of the entity.

Ensure monitoring is arranged on the the effectiveness of the implementation of the digital operational resilience.
NOREA Business Continuity Oversight
The Management body reviews and approves periodically (e.g. annually) the ICT business continuity policy and the ICT response and recovery plans.
NOREA Audit Plan Approval and Review
The Management body reviews and approves periodically (e.g. annually) internal ICT audit plans, ICT audits, and material modifications to the audits.
SCF Publishing Security, Compliance & Resilience Documentation

Description

Mechanisms exist to establish, maintain and disseminate policies, standards and procedures necessary for secure, compliant and resilient capabilities.

Possible Solutions & Considerations

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

∙ ComplianceForge - Cybersecurity & Data Protection Program (CDPP) (https://complianceforge.com)
∙ SCFConnect (https://scfconnect.com)
∙ Shared drive or intranet for policy distribution (e.g., Google Drive, SharePoint Online)

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

∙ ComplianceForge - Cybersecurity & Data Protection Program (CDPP) (https://complianceforge.com)
∙ SCFConnect (https://scfconnect.com)
∙ Document management system (e.g., SharePoint, Confluence, Notion)

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ ComplianceForge - Cybersecurity & Data Protection Program (CDPP) (https://complianceforge.com)
∙ Document management / intranet portal (e.g., SharePoint, Confluence)
∙ Policy acknowledgement tracking (e.g., KnowBe4, Absorb LMS)

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ Policy management platform
∙ Version-controlled policy repository with access controls
∙ Automated policy attestation and acknowledgement tracking

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ Enterprise policy management platform
∙ Integrated GRC policy module with automated review workflows
∙ Enterprise-wide policy acknowledgement and training integration

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

Cybersecurity & Data Protection Governance (GOV) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with GOV domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Governance-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT/cybersecurity personnel.
▪ Cybersecurity and data protection governance is informally assigned as an additional duty to existing IT/cybersecurity personnel.
▪ Basic procedures are established for important tasks, but are ad hoc and not formally documented.
▪ No formal cybersecurity and/or data protection principles are identified for the organization.
▪ Informal recommendations are leveraged to update existing policies and standards.
▪ The responsibility for developing and operating cybersecurity and data privacy procedures are up to the business process owner(s) to determine, including the definition and enforcement of roles and responsibilities.
▪ Governance documentation is made available to internal personnel (e.g., policies, standards and procedures).
▪ People affected by documentation changes are provided notification of the policy and standard changes.

Level 2 Planned Tracked

Cybersecurity & Data Protection Governance (GOV) 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 GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV 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 GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel ensure cybersecurity policies and standards are aligned with a leading cybersecurity framework (e.g., SCF, NIST 800-53, NIST 800-171, ISO 27002 or NIST Cybersecurity Framework).
▪ The organization's cybersecurity policies and standards are made available to internal personnel.
▪ Documented procedures exist for requesting a deviation from approved standards.
▪ The responsibility for enforcing cybersecurity and data protection control implementation is assigned to business / process owners and asset custodians.

Level 3 Well Defined

Cybersecurity & Data Protection Governance (GOV) 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 GOV 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 GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain GOV 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).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to establish, maintain and disseminate policies, standards and procedures necessary for secure, compliant and resilient capabilities.

Level 4 Quantitatively Controlled

Cybersecurity & Data Protection Governance (GOV) 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 Assigned Security, Compliance & Resilience Responsibilities

Description

Mechanisms exist to assign one or more qualified individuals with the mission and resources to centrally-manage, coordinate, develop, implement and maintain an enterprise-wide Security, Compliance & Resilience Program (SCRP).

Possible Solutions & Considerations

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

∙ Third-party advisors (e.g., virtual CISO (vCISO), Managed Security Services Provider (MSSP))
∙ Designated internal security point of contact
∙ vCISO services (e.g., Truvantis, private vCISO firms)

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

∙ Third-party advisors (e.g., virtual CISO (vCISO), Managed Security Services Provider (MSSP))
∙ Part-time or shared security manager
∙ vCISO services with defined scope and deliverables

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

∙ Dedicated Information Security Manager (ISM) or fractional CISO
∙ Chief Information Security Officer (CISO) or equivalent role
∙ Defined Information Security Management System (ISMS) ownership

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

∙ Chief Information Security Officer (CISO) with defined authority and budget
∙ Security leadership team (CISO, DPO, IAM lead, etc.)
∙ Security organizational structure with clear reporting lines

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

∙ Chief Information Security Officer (CISO) with C-suite authority and board access
∙ Security leadership organization (CISO, Deputy CISO, DPO, domain leads)
∙ Security Center of Excellence (CoE)
∙ Defined succession planning for key security roles

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

Cybersecurity & Data Protection Governance (GOV) 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 GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV 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 GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ A qualified individual is assigned the role and responsibilities to centrally manage, coordinate, develop, implement and maintain a cybersecurity and data protection program (e.g., cybersecurity director or Chief Information Security Officer (CISO)).
▪ The individual assigned the role and responsibilities to centrally manage, coordinate, develop, implement and maintain a cybersecurity and data protection program develops plans to implement the organization's security, compliance and resiliency-related objectives.

Level 3 Well Defined

Cybersecurity & Data Protection Governance (GOV) 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 GOV 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 GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain GOV 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).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ A qualified individual is assigned the role and responsibilities to centrally-manage, coordinate, develop, implement and maintain an enterprise-wide Security, Compliance & Resilience Program (SCRP) (e.g., cybersecurity director or Chief Information Security Officer (CISO)).

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.