+Articolo 41 Formato e contenuto della relazione sul riesame del quadro semplificato per la gestione dei rischi informatici
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Articolo 41 Formato e contenuto della relazione sul riesame del quadro semplificato per la gestione dei rischi informatici
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1. Panoramica
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Regolamentazione |
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Articolo 41 1.
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Le entità finanziarie di cui all’articolo 16, paragrafo 1, del regolamento (UE) 2022/2554 presentano la relazione sul riesame del quadro per la gestione dei rischi informatici di cui al paragrafo 2 di tale articolo in un formato elettronico che permetta la ricerca al suo interno.
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Articolo 41 2.
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La relazione di cui al paragrafo 1 contiene tutte le informazioni seguenti:
a)
una sezione introduttiva che fornisce:
i)
una descrizione del contesto della relazione in termini di natura, portata e complessità dei servizi, delle attività e delle operazioni dell’entità finanziaria, della sua organizzazione, delle funzioni essenziali identificate, della strategia, dei principali progetti o attività in corso, dei rapporti e della dipendenza dell’entità finanziaria da servizi e sistemi di TIC interni e appaltati o delle implicazioni che una perdita totale o un grave degrado di tali sistemi avrebbe sulle funzioni essenziali o importanti e sull’efficienza del mercato;
ii)
una sintesi di livello esecutivo dei rischi informatici corrente e a breve termine, del panorama delle minacce, della valutazione dell’efficacia dei controlli e della posizione in materia di sicurezza dell’entità finanziaria;
iii)
informazioni sull’area oggetto della relazione;
iv)
una sintesi delle modifiche di rilievo apportate al quadro per la gestione dei rischi informatici rispetto alla precedente relazione;
v)
una sintesi e una descrizione dell’impatto delle modifiche e dei miglioramenti di rilievo apportati al quadro semplificato per la gestione dei rischi informatici rispetto alla relazione precedente;
b)
se del caso, la data di approvazione della relazione da parte dell’organo di gestione dell’entità finanziaria;
c)
una descrizione delle ragioni del riesame, comprensiva di:
i)
nel caso in cui il riesame sia stato avviato a seguito di istruzioni delle autorità di vigilanza, la prova di tali istruzioni;
ii)
nel caso in cui il riesame sia stato avviato a seguito del verificarsi di incidenti connessi alle TIC, l’elenco di tutti gli incidenti connessi alle TIC con la relativa analisi delle cause di fondo;
d)
la data di inizio e di fine del periodo del riesame;
e)
la persona responsabile del riesame;
f)
una sintesi delle risultanze e un’autovalutazione della gravità delle debolezze, delle carenze e delle lacune identificate nel quadro per la gestione dei rischi informatici per il periodo del riesame, compresa un’analisi dettagliata delle stesse;
g)
misure di riparazione individuate per affrontare le debolezze, le carenze e le lacune del quadro semplificato per la gestione dei rischi informatici e la data prevista per l’attuazione di tali misure, compreso il seguito dato alle debolezze, alle carenze e alle lacune identificate nelle relazioni precedenti, qualora tali debolezze, carenze e lacune non siano ancora state risolte;
h)
conclusioni generali sul riesame del quadro semplificato per la gestione dei rischi informatici, compresi eventuali ulteriori sviluppi previsti.
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1.1 Riferimenti
1.2 Requisiti identificati
1.3 Standard correlati
2. Requisiti identificati
Requisiti
| Fonte |
Requisito |
3. Standard correlati
Standard
| Fonte |
Requisito |
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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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.
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SCF
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Functional Review Of Security, Compliance & Resilience Controls
Description
Mechanisms exist to regularly review Technology Assets, Applications and/or Services (TAAS) for adherence to the organization's security, compliance and/or resilience policies and standards.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE) ∙ Regular/yearly policy and standards review process
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE) ∙ Regular/yearly policy and standards review process
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE) ∙ Regular/yearly policy and standards review process
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE) ∙ Regular/yearly policy and standards review process
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE) ∙ Regular/yearly policy and standards review process
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
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 personnel use an entity-defined set of controls to conduct cybersecurity and data protection control assessments.
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 regularly review Technology Assets, Applications and/or Services (TAAS) for adherence to the organization's security, compliance and/or resilience policies and standards.
Level 4 Quantitatively Controlled
Compliance (CPL) 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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SCF
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Non-Conformity Corrective Action
Description
Mechanisms exist to implement corrective action to remediate instances of non-conformity with applicable statutory, regulatory, and/or contractual compliance obligations.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Corrective action log (spreadsheet) ∙ Documented remediation plans for audit findings
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Corrective action register with remediation tracking ∙ Management review of open findings
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal corrective action plan process ∙ GRC platform for finding tracking and remediation ∙ Management review of open findings
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise corrective action management program ∙ GRC platform with workflow-driven remediation tracking ∙ Executive reporting on open findings
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise GRC platform for corrective action management ∙ Automated finding tracking and escalation workflows ∙ Board-level reporting on material findings
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.
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 take corrective action to remediate instances of non-conformity with applicable statutory, regulatory, and/or contractual compliance 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.
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SCF
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Root Cause Analysis (RCA) & Lessons Learned
Description
Mechanisms exist to incorporate lessons learned from analyzing and resolving cybersecurity and data protection incidents to reduce the likelihood or impact of future incidents.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Root Cause Analysis (RCA)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Root Cause Analysis (RCA)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Root Cause Analysis (RCA)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Root Cause Analysis (RCA)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Root Cause Analysis (RCA)
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 provide After Action Review (AAR) feedback on what worked, what did not work and ways to improve future responses to similar incidents. ▪ A formal Root Cause Analysis (RCA) is performed that documents the findings in a report for both technical and business leadership management.
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 incorporate lessons learned from analyzing and resolving cybersecurity and data protection incidents to reduce the likelihood or impact of future incidents.
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.
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SCF
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Capabilities Deficiency Tracking
Description
Mechanisms exist to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum: (1) Deficiency tracking number; (2) Applicable security, compliance and/or resilience control; (3) Description of the deficiency(ies); (4) Risk associated with the deficiency(ies); (5) Source deficiency identification/detection; (6) Temporary compensating controls, if applicable; (7) Point of Contact (POC) (e.g., asset/process owner); (8) Resources required to conduct remediation actions; (9) Planned remedial actions to the deficiency(ies); (10) Proposed remediation timeline; and (11) Disposition statement (e.g., closeout summary).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Plan of Action and Milestones (POA&M) ∙ Risk register
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Plan of Action and Milestones (POA&M) ∙ Risk register
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Plan of Action and Milestones (POA&M) ∙ Risk register
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Plan of Action and Milestones (POA&M) ∙ Risk register
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Plan of Action and Milestones (POA&M) ∙ Risk register
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
Information Assurance (IAO) 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 IAO domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with IAO 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 IAO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Information Assurance (IA)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ IA management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Pre-production security testing is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ IT and/or cybersecurity personnel implement and maintain a limited Information Assurance Program (IAP) capability to conduct limited control testing to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.
Level 3 Well Defined
Information Assurance (IAO) 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 IAO 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 IAO domain capabilities are well-documented and kept current by process owners. ▪ An information assurance team, or similar function, is appropriately staffed and supported to implement and maintain IAO domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of information assurance operations (e.g., assessment scheduling software and risk assessment 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 IAO domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to govern identified deficiencies (e.g., Plan of Action and Milestones (POA&M) or similar methodology) that formally documents, at a minimum: (1) Deficiency tracking number; (2) Applicable security, compliance and/or resilience control; (3) Description of the deficiency(ies); (4) Risk associated with the deficiency(ies); (5) Source deficiency identification/detection; (6) Temporary compensating controls, if applicable; (7) Point of Contact (POC) (e.g., asset/process owner); (8) Resources required to conduct remediation actions; (9) Planned remedial actions to the deficiency(ies); (10) Proposed remediation timeline; and (11) Disposition statement (e.g., closeout summary).
Level 4 Quantitatively Controlled
Information Assurance (IAO) 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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