+Članak 33. Izvješćivanje nadzornog tijela o povredi osobnih podataka
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Članak 33. Izvješćivanje nadzornog tijela o povredi osobnih podataka

1. Pregled

,
Naslov Regulativa
Članak 33. 1.
U slučaju povrede osobnih podataka voditelj obrade bez nepotrebnog odgađanja i, ako je izvedivo, najkasnije 72 sata nakon saznanja o toj povredi, izvješćuje nadzorno tijelo nadležno u skladu s člankom 55. o povredi osobnih podataka, osim ako nije vjerojatno da će povreda osobnih podataka prouzročiti rizik za prava i slobode pojedinaca. Ako izvješćivanje nije učinjeno unutar 72 sata, mora biti popraćeno razlozima za kašnjenje.
Članak 33. 2.
Izvršitelj obrade bez nepotrebnog odgađanja izvješćuje voditelja obrade nakon što sazna za povredu osobnih podataka.
Članak 33. 3.

U izvješćivanju iz stavka 1. mora se barem:

(a) 

opisati priroda povrede osobnih podataka, uključujući, ako je moguće, kategorije i približan broj dotičnih ispitanika te kategorije i približan broj dotičnih evidencija osobnih podataka;

(b) 

navesti ime i kontaktne podatke službenika za zaštitu podataka ili druge kontaktne točke od koje se može dobiti još informacija;

(c) 

opisati vjerojatne posljedice povrede osobnih podataka;

(d) 

opisati mjere koje je voditelj obrade poduzeo ili predložio poduzeti za rješavanje problema povrede osobnih podataka, uključujući prema potrebi mjere umanjivanja njezinih mogućih štetnih posljedica.

Članak 33. 4.
Ako i u onoj mjeri u kojoj nije moguće istodobno pružiti informacije, informacije je moguće postupno pružati bez nepotrebnog daljnjeg odgađanja.
Članak 33. 5.
►C2  Voditelj obrade dokumentira sve povrede osobnih podataka, uključujući činjenice vezane za povredu osobnih podataka, njezine posljedice i mjere poduzete za popravljanje štete. ◄ Ta dokumentacija nadzornom tijelu omogućuje provjeru poštovanja ovog članka.

1.1 Reference

1.2 Utvrđeni zahtjevi

1.3 Povezani standardi

2. Utvrđeni zahtjevi

Zahtjevi
Izvor Zahtjev

3. Povezani standardi

Standardi
Izvor Zahtjev
SCF Incident Response Capabilities Testing

Description

Mechanisms exist to formally test incident response capabilities through realistic exercises to determine the operational effectiveness of those capabilities.

Possible Solutions & Considerations

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

∙ "Table Top" incident response exercises (rock drills)

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

∙ "Table Top" incident response exercises (rock drills)

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

∙ "Table Top" incident response exercises (rock drills)
∙ "Red team vs blue team" exercises
∙ EICAR test file antimalware detection and response exercises

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

∙ "Table Top" incident response exercises (rock drills)
∙ "Red team vs blue team" exercises
∙ EICAR test file antimalware detection and response exercises

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

∙ "Table Top" incident response exercises (rock drills)
∙ "Red team vs blue team" exercises
∙ EICAR test file antimalware detection and response exercises

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

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ Incident responders are proficient on their specific IRP role(s) and responsibilities through recurring training events (e.g., annual rock drill).
▪ On at least an annual basis, IT and/or cybersecurity personnel conduct tabletop exercises to validate disaster recovery and contingency plans, in conjunction with stakeholders and any required vendors.

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 formally test incident response capabilities through realistic exercises to determine the operational effectiveness of those capabilities.

Level 4 Quantitatively Controlled

Incident Response (IRO) 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 Automated Incident Response Training Environments

Description

Automated mechanisms exist to provide a more thorough and realistic incident response training environment.

Possible Solutions & Considerations

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

∙ Basic incident response plan
∙ Designate incident response contact

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

∙ Documented incident response plan
∙ Incident log
∙ Designated IR team

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

∙ Formal incident response program
∙ IR playbooks
∙ Tabletop exercises

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

∙ Enterprise incident response program
∙ 24/7 SOC monitoring
∙ SOAR platform

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

∙ Enterprise SOC with SIEM/SOAR (e.g., Splunk SOAR, Palo Alto XSOAR)
∙ IR retainer
∙ Threat hunting

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

Incident Response (IRO) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IRO domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Incident response-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel use an informal process to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.

Level 2 Planned Tracked

SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 provide a more thorough and realistic incident response training environment.

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 Situational Awareness For Incidents

Description

Mechanisms exist to document, monitor and report the status of cybersecurity and data protection incidents to internal stakeholders all the way through the resolution of the incident.

Possible Solutions & Considerations

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

∙ Basic incident response plan
∙ Designate incident response contact

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

∙ Documented incident response plan
∙ Incident log
∙ Designated IR team

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

∙ Formal incident response program
∙ IR playbooks
∙ Tabletop exercises

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

∙ Enterprise incident response program
∙ 24/7 SOC monitoring
∙ SOAR platform

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

∙ Enterprise SOC with SIEM/SOAR (e.g., Splunk SOAR, Palo Alto XSOAR)
∙ IR retainer
∙ Threat hunting

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

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ IT and/or cybersecurity personnel facilitate prompt response to suspected or confirmed security incidents, including timely notification to affected stakeholders.

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 document, monitor and report the status of cybersecurity and data protection incidents to internal stakeholders all the way through the resolution of the incident.

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 Cyber Incident Reporting for Sensitive / Regulated Data

Description

Mechanisms exist to report sensitive and/or regulated data incidents in a timely manner.

Possible Solutions & Considerations

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

∙ Incident Response Plan (IRP)

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

∙ Incident Response Plan (IRP)

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

∙ Integrated Incident Response Program (IIRP)
∙ Integrated Security Incident Response Team (ISIRT)

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

∙ Integrated Incident Response Program (IIRP)
∙ Integrated Security Incident Response Team (ISIRT)

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

∙ Integrated Incident Response Program (IIRP)
∙ Integrated Security Incident Response Team (ISIRT)

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

Incident Response (IRO) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IRO domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Incident response-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel use an informal process to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.

Level 2 Planned Tracked

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 report sensitive/regulated data incidents in a timely manner.

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 Data Breach

Description

Mechanisms exist to address data breaches, or other incidents involving the unauthorized disclosure of sensitive or regulated data, according to applicable laws, regulations and contractual obligations.

Possible Solutions & Considerations

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

∙ Incident Response Plan (IRP)

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

∙ Incident Response Plan (IRP)

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

∙ Integrated Incident Response Program (IIRP)

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

∙ Integrated Incident Response Program (IIRP)

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

∙ Integrated Incident Response Program (IIRP)

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

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 address data breaches, or other incidents involving the unauthorized disclosure of sensitive or regulated data, according to applicable laws, regulations and contractual obligations.

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 Situational Awareness For Incidents

Description

Mechanisms exist to document, monitor and report the status of cybersecurity and data protection incidents to internal stakeholders all the way through the resolution of the incident.

Possible Solutions & Considerations

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

∙ Basic incident response plan
∙ Designate incident response contact

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

∙ Documented incident response plan
∙ Incident log
∙ Designated IR team

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

∙ Formal incident response program
∙ IR playbooks
∙ Tabletop exercises

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

∙ Enterprise incident response program
∙ 24/7 SOC monitoring
∙ SOAR platform

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

∙ Enterprise SOC with SIEM/SOAR (e.g., Splunk SOAR, Palo Alto XSOAR)
∙ IR retainer
∙ Threat hunting

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

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ IT and/or cybersecurity personnel facilitate prompt response to suspected or confirmed security incidents, including timely notification to affected stakeholders.

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 document, monitor and report the status of cybersecurity and data protection incidents to internal stakeholders all the way through the resolution of the incident.

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 Cyber Incident Reporting for Sensitive / Regulated Data

Description

Mechanisms exist to report sensitive and/or regulated data incidents in a timely manner.

Possible Solutions & Considerations

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

∙ Incident Response Plan (IRP)

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

∙ Incident Response Plan (IRP)

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

∙ Integrated Incident Response Program (IIRP)
∙ Integrated Security Incident Response Team (ISIRT)

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

∙ Integrated Incident Response Program (IIRP)
∙ Integrated Security Incident Response Team (ISIRT)

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

∙ Integrated Incident Response Program (IIRP)
∙ Integrated Security Incident Response Team (ISIRT)

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

Incident Response (IRO) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IRO domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Incident response-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel use an informal process to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.

Level 2 Planned Tracked

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 report sensitive/regulated data incidents in a timely manner.

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 Data Breach

Description

Mechanisms exist to address data breaches, or other incidents involving the unauthorized disclosure of sensitive or regulated data, according to applicable laws, regulations and contractual obligations.

Possible Solutions & Considerations

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

∙ Incident Response Plan (IRP)

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

∙ Incident Response Plan (IRP)

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

∙ Integrated Incident Response Program (IIRP)

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

∙ Integrated Incident Response Program (IIRP)

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

∙ Integrated Incident Response Program (IIRP)

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

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.

Level 3 Well Defined

Incident Response (IRO) 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 IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software).
▪ 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 IRO 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 address data breaches, or other incidents involving the unauthorized disclosure of sensitive or regulated data, according to applicable laws, regulations and contractual obligations.

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.