+Airteagal 5 Rialachas agus eagraíocht
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---+Airteagal 5 2
---+Airteagal 5 3
---+Airteagal 5 4

Airteagal 5 Rialachas agus eagraíocht

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1. Forbhreathnú

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Airteagal 5 1

1.   Beidh creat rialachais agus rialaithe inmheánaigh i bhfeidhm ag eintitis airgeadais lena n-áirithítear bainistíocht éifeachtach stuama i gcás gach riosca TFC, i gcomhréir le hAirteagal 6(4), chun ardchaighdeán athléimneachta digití oibríochtúla a bhaint amach.
Airteagal 5 2

2.   Déanfaidh comhlacht bainistíochta an eintitis airgeadais cur chun feidhme na socruithe uile a bhaineann le creat bainistíochta riosca TFC dá dtagraítear in Airteagal 6(1) a shainiú, a fhormheas, agus a fhormhaoirsiú, agus is é a bheidh freagrach as na socruithe sin a chur chun feidhme.

Chun críocha na chéad fhomhíre, maidir leis an gcomhlacht bainistíochta:

(a)

is air a bheidh an fhreagracht deiridh as rioscaí TFC an eintitis airgeadais a bhainistiú;

(b)

cuirfidh sé beartais i bhfeidhm lena ndírítear ar a áirithiú go gcoimeádfar ardchaighdeáin infhaighteachta, barántúlachta, sláine agus rúndachta sonraí;

(c)

leagfaidh sé síos róil agus freagrachtaí soiléire le haghaidh gach feidhme a bhaineann le TFC agus bunóidh sé socruithe iomchuí rialachais chun cumarsáid, comhar agus comhordú atá éifeachtach agus tráthúil i measc na bhfeidhmeanna sin a áirithiú;

(d)

is air a bheidh an fhreagracht fhoriomlán as an straitéis athléimneachta digití oibríochtúla dá dtagraítear in Airteagal 6(8) a leagan amach agus a fhormheas, lena n-áirítear an leibhéal lamháltais riosca iomchuí maidir le riosca TFC an eintitis airgeadais, dá dtagraítear in Airteagal 6(8), pointe (b), a chinneadh;

(e)

is é a dhéanfaidh cur chun feidhme bheartas leanúnachais gnó TFC agus pleananna freagartha agus athshlánaithe TFC an eintitis airgeadais, dá dtagraítear, faoi seach, in Airteagal 11(1) agus (3), a fhormheas agus a mhaoirsiú, agus a athbhreithniú go tréimhsiúil, ar beartais agus pleananna iad ar féidir a ghlacadh mar bheartas tiomnaithe sonrach ar cuid lárnach de bheartas foriomlán leanúnachais gnó agus de phlean freagartha agus athshlánaithe an eintitis airgeadais é;

(f)

is é a dhéanfaidh pleananna iniúchta inmheánaigh TFC an eintitis airgeadais, iniúchtaí TFC, agus modhnuithe ábharacha orthu sin, a fhormheas agus a athbhreithniú go tréimhsiúil;

(g)

is é a dhéanfaidh an buiséad iomchuí a leithdháileadh agus a athbhreithniú go tréimhsiúil, chun riachtanais athléimneachta digití oibríochtúla an eintitis airgeadais a chomhlíonadh i ndáil le gach cineál acmhainne, lena n-áirítear cláir ábhartha feasachta slándála TFC agus an oiliúint ábhartha san athléimneacht dhigiteach oibríochtúil dá dtagraítear in Airteagal 13(6), agus scileanna TFC don fhoireann ar fad;

(h)

is é a dhéanfaidh beartas an eintitis airgeadais maidir le socruithe i ndáil le húsáid seirbhísí TFC arna soláthar ag soláthraithe seirbhísí TFC tríú páirtí a fhormheas agus a athbhreithniú go tréimhsiúil;

(i)

cuirfidh sé bealaí tuairiscithe ar bun, ar an leibhéal corparáideach, chun gur féidir eolas cuí a thabhairt dó i ndáil leis na nithe seo a leanas:

(i)

socruithe arna dtabhairt i gcrích le soláthraithe seirbhísí tríú páirtí TFC maidir leis an úsáid a bhaintear as seirbhísí TFC,

(ii)

aon athruithe ábhartha pleanáilte ábharacha maidir le soláthraithe seirbhísí TFC tríú páirtí,

(iii)

an tionchar a d’fhéadfadh a bheith ag athruithe den sórt sin ar na feidhmeanna criticiúla nó tábhachtacha atá faoi réir na socruithe sin, lena n-áirítear achoimre ar an anailís riosca chun tionchar na n-athruithe sin a mheasúnú, agus ar a laghad mórtheagmhais a bhaineann le TFC agus a dtionchar, chomh maith le bearta freagartha, athshlánaithe agus ceartaitheacha.
Airteagal 5 3

3.   Eintitis airgeadais, nach micrifhiontair iad, bunóidh siad ról chun faireachán a dhéanamh ar na socruithe a dhéantar le soláthraithe seirbhísí TFC tríú páirtí maidir le húsáid seirbhísí TFC, nó ainmneoidh siad duine den ardbhainistíocht a bheidh freagrach as maoirseacht a dhéanamh ar an neamhchosaint ghaolmhar ar riosca agus ar na doiciméid ábhartha.
Airteagal 5 4

4.   Déanfaidh comhaltaí de chomhlacht bainistíochta an eintitis airgeadais eolas agus scileanna leordhóthanacha a choinneáil cothrom le dáta go gníomhach chun riosca TFC agus a thionchar ar oibríochtaí an eintitis airgeadais a thuiscint agus a mheasúnú, lena n-áirítear trí oiliúint shonrach a leanúint ar bhonn rialta, i gcomhréir le riosca TFC atá á bhainistiú.

1.1 Tagairtí

1.2 Ceanglais aitheanta

1.3 Caighdeáin ghaolmhara

2. Ceanglais aitheanta

Ceanglais

3. Caighdeáin ghaolmhara

Caighdeáin
SCF Security, Compliance & Resilience Program (SCRP)

Description

Mechanisms exist to facilitate the design, implementation, and monitoring of security, compliance and resilience governance controls.

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)
∙ NIST Cybersecurity Framework (CSF) 2.0 (https://www.nist.gov/cyberframework)

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

∙ ComplianceForge - Cybersecurity & Data Protection Program (CDPP) (https://complianceforge.com)
∙ SCFConnect (https://scfconnect.com)
∙ NIST Cybersecurity Framework (CSF) 2.0 (https://www.nist.gov/cyberframework)

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

∙ Steering committee
∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ ComplianceForge - Cybersecurity & Data Protection Program (CDPP) (https://complianceforge.com)
∙ GRC platform (e.g., OneTrust, ServiceNow GRC, LogicGate)
∙ Secure Controls Framework (SCF), NIST SP 800-53 Rev 5 and/or ISO 27001:2022 alignment

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

∙ Steering committee
∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Secure Controls Framework (SCF), NIST SP 800-53 Rev 5 and/or ISO 27001:2022 alignment

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)
∙ Secure Controls Framework (SCF), NIST SP 800-53 Rev 5 and/or ISO 27001:2022 alignment

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.
▪ 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).
▪ IT /cyber engineering governance is decentralized, with the responsibility for implementing and testing cybersecurity and data protection controls being assigned to the business process owner(s), including the definition and enforcement of roles and responsibilities.

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).
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to implement and manage the organization's internal control system.
▪ Legal representation is consulted on an as-needed basis.

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 facilitate the implementation of security, compliance and resilience governance controls.

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.
SCF Steering Committee & Program Oversight

Description

Mechanisms exist to align security, compliance and resilience capabilities with business requirements through a steering committee or advisory board, comprised of key cybersecurity, data protection and business executives, which meets formally and on a regular basis.

Possible Solutions & Considerations

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

∙ Third-party advisors (subject matter experts)
∙ Virtual CISO (vCISO) service
∙ Fractional security advisor

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

∙ Third-party advisors (subject matter experts)
∙ Virtual CISO (vCISO) service
∙ Informal security advisory committee

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

∙ Steering committee / advisory board
∙ Quarterly security committee meetings with documented minutes
∙ Cross-functional representation (IT, Legal, HR, Operations)

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

∙ Formal steering committee / advisory board
∙ Documented charter with defined roles and meeting cadence
∙ Board-level cybersecurity reporting

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

∙ Formal steering committee / advisory board
∙ Board-level Cybersecurity Committee or subcommittee
∙ Chief Information Security Officer (CISO) with board-level access
∙ Independent security advisor / external audit committee

SCR-CMM

Level 0 Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 Performed Informally

SCR-CMM Level 1 criteria definitions are not available for this control:
▪ A reasonable person would conclude this control requires a structured process.
▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

Level 2 Planned Tracked

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.
▪ Organizational leadership maintains an informal process to review and respond to trends.

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 align security, compliance and resilience capabilities with business requirements through a steering committee or advisory board, comprised of key cybersecurity, data protection and business executives, which meets formally and on a regular basis.

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 Status Reporting To Governing Body

Description

Mechanisms exist to provide governance oversight reporting and recommendations enabling executives to make decisions about matters considered material to the organization's Security, Compliance & Resilience Program (SCRP).

Possible Solutions & Considerations

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

∙ Quarterly Business Review (QBR)
∙ Simple security status dashboard (spreadsheet or slide deck)
∙ Email status updates to owner/manager

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

∙ Quarterly Business Review (QBR)
∙ Structured security metrics report (incidents, patching status, training completion)
∙ Documented reporting cadence

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

∙ Quarterly Business Review (QBR)
∙ Formal security status reports to leadership
∙ KPI/KRI dashboard (e.g., Power BI, Tableau, or GRC tool reporting)

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

∙ Quarterly Business Review (QBR)
∙ Executive security dashboard with KPIs/KRIs
∙ Board-level reporting on material risk indicators
∙ Automated reporting via GRC platform

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

∙ Quarterly Business Review (QBR)
∙ Board and audit committee cybersecurity briefings
∙ Integrated GRC dashboard with real-time metrics
∙ SEC cybersecurity disclosure-ready reporting processes (if applicable)

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.
▪ Organizational leadership maintains an informal process to review and respond to trends.

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 provide governance oversight reporting and recommendations to those entrusted to make executive decisions about matters considered material to the organization's Security, Compliance & Resilience Program (SCRP).

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 Business Continuity & Disaster Recovery Policy

Description

Mechanisms exist to establish a formal, documented Business Continuity and Disaster Recovery (BC/DR) 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

Business Continuity & Disaster Recovery (BCD) 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 BCD domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with BCD 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 BCD domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Business Continuity / Disaster Recovery (BC/DR)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ BC/DR 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

Business Continuity & Disaster Recovery (BCD) 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 BCD 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 BCD domain capabilities are well-documented and kept current by process owners.
▪ A Business Continuity & Disaster Recovery (BC/DR) team, or similar function, is appropriately staffed and supported to implement and maintain BCD domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of BC/DR operations (e.g., BC/DR planning software, Disaster Recovery as a Service (DRaaS), Orchestration and Automation Tools).
▪ 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 BCD 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 Statutory, Regulatory & Contractual Compliance

Description

Mechanisms exist to facilitate the identification and implementation of relevant statutory, regulatory and contractual controls.

Possible Solutions & Considerations

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

∙ SCF Security, Compliance & Resilience Management System (SCRMS)
∙ Governance, Risk and Compliance (GRC) solution (e.g., SCFConnect, SureCloud, Ostendio, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)

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

∙ SCF Security, Compliance & Resilience Management System (SCRMS)
∙ Governance, Risk and Compliance (GRC) solution (e.g., SCFConnect, SureCloud, Ostendio, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)

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

∙ SCF Security, Compliance & Resilience Management System (SCRMS)
∙ Governance, Risk and Compliance (GRC) solution (e.g., SCFConnect, SureCloud, Ostendio, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Steering committee

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

∙ SCF Security, Compliance & Resilience Management System (SCRMS)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Steering committee

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

∙ SCF Security, Compliance & Resilience Management System (SCRMS)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Steering committee

SCR-CMM

Level 0 Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 Performed Informally

Compliance (CPL) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with CPL domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Compliance management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Compliance efforts are narrowly-limited to certain compliance requirements.
▪ IT and/or cybersecurity personnel use an informal process to govern statutory, regulatory and contractual compliance obligations.

Level 2 Planned Tracked

Compliance (CPL) 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 CPL domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CPL 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 CPL domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Compliance management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Compliance management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ External compliance requirements for cybersecurity and data privacy are identified and documented, based on applicable laws, regulations and contractual obligations.
▪ IT and/or cybersecurity perform an informal annual review of existing compliance requirements and research evolving or new requirements.

Level 3 Well Defined

Compliance (CPL) 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 CPL 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 CPL domain capabilities are well-documented and kept current by process owners.
▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with CPL 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 identification and implementation of relevant statutory, regulatory and contractual 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 Defined Roles & Responsibilities

Description

Mechanisms exist to define cybersecurity roles & responsibilities for all personnel.

Possible Solutions & Considerations

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

SCR-CMM

Level 0 Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 Performed Informally

Human Resources Security (HRS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with HRS domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Personnel management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ The Human Resources (HR) department provides guidance on secure HR practices for hiring, retaining and terminating employees, contractors and other personnel that work on behalf of the organization.
▪ Formal roles and responsibilities for cybersecurity and/or data protection are not consistent and/or standardized.

Level 2 Planned Tracked

Human Resources Security (HRS) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.
▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization.

Level 3 Well Defined

Human Resources Security (HRS) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with HRS domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software solution).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with HRS domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to define cybersecurity roles & responsibilities for all personnel.

Level 4 Quantitatively Controlled

Human Resources Security (HRS) 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.