+Security, Compliance & Resilience Awareness Training
---+Simulated Cyber Attack Scenario Training
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Security, Compliance & Resilience Awareness Training
Description
Mechanisms exist to provide all employees and contractors appropriate security, compliance and resilience awareness education and training that is relevant for their job function.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.
Level 2 Planned Tracked
Security Awareness & Training (SAT) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.
Level 3 Well Defined
Security Awareness & Training (SAT) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with SAT domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with SAT domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to provide all employees and contractors appropriate security, compliance and resilience awareness education and training that is relevant for their job function.
Level 4 Quantitatively Controlled
Security Awareness & Training (SAT) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
1. Panoramica
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Standard |
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Simulated Cyber Attack Scenario Training
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Description
Mechanisms exist to include simulated actual cyber-attacks through practical exercises that are aligned with current threat scenarios.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Provide basic insider threat awareness information to staff
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Insider threat awareness training module
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal insider threat awareness program
∙ Annual training for all staff
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise insider threat awareness and behavior monitoring program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise insider threat program (NITTF-aligned)
∙ Dedicated insider threat team
∙ UEBA for behavioral monitoring
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.
Level 2 Planned Tracked
Security Awareness & Training (SAT) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
Level 3 Well Defined
Security Awareness & Training (SAT) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with SAT domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with SAT domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to include simulated actual cyber-attacks through practical exercises that are aligned with current threat scenarios.
Level 4 Quantitatively Controlled
Security Awareness & Training (SAT) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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1.1 Riferimenti
1.2 Requisiti identificati
1.3 Regolamentazioni correlate
2. Requisiti identificati
Requisiti
| Fonte |
Requisito |
3. Regolamentazioni correlate
Regolamentazioni
| Fonte |
Regolamentazione |
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EULAW
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Articolo 19 Politica delle risorse umane
Articolo 19
Politica delle risorse umane
Le entità finanziarie includono nella loro politica delle risorse umane o in altre politiche pertinenti tutti gli elementi seguenti relativi alla sicurezza delle TIC:
a)
l’identificazione e l’assegnazione di eventuali responsabilità specifiche in materia di sicurezza delle TIC;
b)
l’obbligo, per il personale dell’entità finanziaria e dei fornitori terzi di servizi TIC che utilizzano o accedono alle risorse TIC dell’entità finanziaria, di:
i)
essere informati e rispettare le politiche, le procedure e i protocolli di sicurezza delle TIC dell’entità finanziaria;
ii)
essere a conoscenza dei canali di segnalazione predisposti dall’entità finanziaria per l’individuazione di comportamenti anomali, compresi, se del caso, i canali di segnalazione stabiliti in linea con la direttiva (UE) 2019/1937 del Parlamento europeo e del Consiglio (
1
);
iii)
per il personale, restituire all’entità finanziaria, alla cessazione del rapporto di lavoro, tutte le risorse TIC e i patrimoni informativi materiali in loro possesso che appartengono all’entità finanziaria.
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EULAW
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Articolo 28 Governance e organizzazione
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EULAW
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Articolo 28 Governance e organizzazione
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EULAW
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Articolo 13 Apprendimento ed evoluzione
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DELAW
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BDSG § 48 Verarbeitung besonderer Kategorien personenbezogener Daten
(1) Die Verarbeitung besonderer Kategorien personenbezogener Daten ist nur zulässig, wenn sie zur Aufgabenerfüllung unbedingt erforderlich ist. (2) Werden besondere Kategorien personenbezogener Daten verarbeitet, sind geeignete Garantien für die Rechtsgüter der betroffenen Personen vorzusehen. Geeignete Garantien können insbesondere sein - 1.
spezifische Anforderungen an die Datensicherheit oder die Datenschutzkontrolle, - 2.
die Festlegung von besonderen Aussonderungsprüffristen, - 3.
die Sensibilisierung der an Verarbeitungsvorgängen Beteiligten, - 4.
die Beschränkung des Zugangs zu den personenbezogenen Daten innerhalb der verantwortlichen Stelle, - 5.
die von anderen Daten getrennte Verarbeitung, - 6.
die Pseudonymisierung personenbezogener Daten, - 7.
die Verschlüsselung personenbezogener Daten oder - 8.
spezifische Verfahrensregelungen, die im Fall einer Übermittlung oder Verarbeitung für andere Zwecke die Rechtmäßigkeit der Verarbeitung sicherstellen.
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EULAW
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Articolo 13 6
6. Le entità finanziarie elaborano programmi di sensibilizzazione sulla sicurezza delle TIC nonché attività di formazione sulla resilienza operativa digitale, che rappresentano moduli obbligatori nei programmi di formazione del personale. Tali programmi e attività di formazione riguardano tutti i dipendenti e gli alti dirigenti, e presentano un livello di complessità commisurato all’ambito delle loro funzioni. Se del caso, le entità finanziarie includono anche i fornitori terzi di servizi TIC nei loro sistemi di formazione pertinenti, conformemente all’articolo 30, paragrafo 2, lettera i).
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Ticket collegati
- Secure Controls Framework -
"The SCF is the Common Controls Framework™ (CCF), the world's most comprehensive cybersecurity and data privacy metaframework - it is also free to use. The entire concept is building secure, compliant and resilient capabilities in the most efficient and cost-effective manner possible.
The SCF is more than just a unified control catalog, since its included content creates a playbook for Governance, Risk & Compliance (GRC) capabilities. Used globally by organizations of every size, the SCF is a robust and scalable solution for security, compliance and resilience controls. As a comprehensive security framework, the SCF maps 1,400+ controls across 200+ laws, regulations, and industry frameworks so you can implement once and comply everywhere.
Like it or not, cybersecurity is a protracted war on an asymmetric battlefield, where the threats are everywhere and as defenders we have to make the effort to work together to help improve cybersecurity and data privacy practices, since we all suffer when massive data breaches occur or when cyber attacks have physical impacts. Hackers share information on attack methods with other hackers, so why shouldn’t the good guys share information on how to best protect an organization? We decided to take action and make a difference, since we feel it is too important to wait for someone else to fix the problems that exist.
The SCF is made up of volunteers, mainly specialists within the cybersecurity profession, who focus on GRC and the cybersecurity side of data privacy. These are auditors, engineers, architects, incident responders, consultants and other specialists who live and breathe these topics on a daily basis. The end product is "expert-derived content" that makes up the SCF." https://securecontrolsframework.com/
Terms & Conditions
The SCF End User License Agreement (EULA) governs the use of the Secure Controls Framework® (SCF) under the Creative Commons Attribution-No Derivatives 4.0 International Public License.
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