+Artikolu 32 Proċeduri ta’ valutazzjoni ta’ konformità għall-prodotti b’elementi diġitali
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Artikolu 32 Proċeduri ta’ valutazzjoni ta’ konformità għall-prodotti b’elementi diġitali

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1. Ħarsa ġenerali

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Artikolu 32 1.

Il-manifattur għandu jwettaq valutazzjoni ta’ konformità tal-prodott b’elementi diġitali u l-proċessi stabbiliti mill-manifattur biex jiddetermina jekk ir-rekwiżiti essenzjali taċ-ċibersigurtà stabbiliti fl-Anness I humiex issodisfati. Il-manifattur għandu juri l-konformità mar-rekwiżiti essenzjali taċ-ċibersigurtà billi juża kwalunkwe waħda mill-proċeduri li ġejjin:

(a) 

il-proċedura ta’ kontroll intern (ibbażata fuq il-modulu A) stabbilita fl-Anness VIII;

(b) 

il-proċedura ta’ eżami tat-tip tal-UE (ibbażata fuq il-modulu B) stabbilita fl-Anness VIII segwita mill-konformità mat-tip tal-UE abbażi tal-kontroll intern tal-produzzjoni (ibbażata fuq il-modulu C) stabbilita fl-Anness VIII;

(c) 

valutazzjoni ta’ konformità bbażata fuq assigurazzjoni sħiħa tal-kwalità (ibbażata fuq il-modulu H) stabbilita fl-Anness VIII; jew

(d) 

meta tkun disponibbli u applikabbli, skema Ewropea ta’ ċertifikazzjoni taċ-ċibersigurtà skont l-Artikolu 27(9).
Artikolu 32 2.

Meta, fil-valutazzjoni ta’ konformità ta’ prodott importanti b’elementi diġitali li jaqa’ taħt il-klassi I kif stabbilit fl-Anness III u l-proċessi stabbiliti mill-manifattur tiegħu mar-rekwiżiti essenzjali taċ-ċibersigurtà stabbiliti fl-Anness I, il-manifattur ma jkunx applika jew ikun applika biss parzjalment standards armonizzati, speċifikazzjonijiet komuni jew skemi Ewropej ta’ ċertifikazzjoni taċ-ċibersigurtà f’livell ta’ assigurazzjoni li mill-anqas ikun “sostanzjali” kif imsemmi fl-Artikolu 27, jew meta dawn l-istandards armonizzati, speċifikazzjonijiet komuni jew skemi Ewropej ta’ ċertifikazzjoni taċ-ċibersigurtà ma jkunux jeżistu, il-prodott b’elementi diġitali kkonċernat u l-proċessi stabbiliti mill-manifattur għandhom jiġu sottomessi fir-rigward ta’ dawk ir-rekwiżiti essenzjali taċ-ċibersigurtà għal waħda mill-proċeduri li ġejjin:

(a) 

il-proċedura ta’ eżami tat-tip tal-UE (ibbażata fuq il-modulu B) stabbilita fl-Anness VIII segwita mill-konformità mat-tip tal-UE abbażi tal-kontroll intern tal-produzzjoni (ibbażata fuq il-modulu C) stabbilita fl-Anness VIII; jew

(b) 

valutazzjoni ta’ konformità bbażata fuq assigurazzjoni sħiħa tal-kwalità (ibbażata fuq il-modulu H) stabbilita fl-Anness VIII.
Artikolu 32 3.

Meta l-prodott ikun prodott importanti b’elementi diġitali li jaqa’ taħt il-klassi II kif stabbilit fl-Anness III, il-manifattur għandu juri l-konformità mar-rekwiżiti essenzjali taċ-ċibersigurtà stabbiliti fl-Anness I billi juża kwalunkwe waħda mill-proċeduri li ġejjin:

(a) 

il-proċedura ta’ eżami tat-tip tal-UE (ibbażata fuq il-modulu B) stabbilita fl-Anness VIII, segwita minn konformità mat-tip tal-UE abbażi tal-kontroll intern tal-produzzjoni (ibbażata fuq il-modulu C) stabbilita fl-Anness VIII;

(b) 

il-valutazzjoni ta’ konformità bbażata fuq assigurazzjoni sħiħa tal-kwalità (ibbażata fuq il-modulu H) stabbilita fl-Anness VIII; jew

(c) 

meta tkun disponibbli u applikabbli, skema Ewropea ta’ ċertifikazzjoni taċ-ċibersigurtà skont l-Artikolu 27(9) ta’ dan ir-Regolament f’livell ta’ assigurazzjoni li mill-anqas ikun “sostanzjali” skont ir-Regolament (UE) 2019/881.
Artikolu 32 4.

Il-prodotti kritiċi b’elementi diġitali elenkati fl-Anness IV għandhom juru l-konformità mar-rekwiżiti essenzjali taċ-ċibersigurtà stabbiliti fl-Anness I billi jużaw waħda mill-proċeduri li ġejjin:

(a) 

skema Ewropea ta’ ċertifikazzjoni taċ-ċibersigurtà f’konformità mal-Artikolu 8(1); jew

(b) 

meta l-kundizzjonijiet fl-Artikolu 8(1) ma jiġux issodisfati, kwalunkwe waħda mill-proċeduri msemmija fil-paragrafu 3 ta’ dan l-Artikolu.
Artikolu 32 5.
Il-manifatturi ta’ prodotti b’elementi diġitali li jikkwalifikaw bħala software liberu u b’sors miftuħ, li jaqgħu taħt il-kategoriji stabbiliti fl-Anness III, għandhom ikunu jistgħu juru l-konformità mar-rekwiżiti essenzjali taċ-ċibersigurtà stabbiliti fl-Anness I billi jużaw waħda mill-proċeduri msemmija fil-paragrafu 1 ta’ dan l-Artikolu, dment li d-dokumentazzjoni teknika msemmija fl-Artikolu 31 issir disponibbli għall-pubbliku fil-mument tal-introduzzjoni fis-suq ta’ dawk il-prodotti.
Artikolu 32 6.
L-interessi u l-ħtiġijiet speċifiċi tal-intrapriżi mikro u tal-intrapriżi żgħar u ta’ daqs medju, inklużi n-negozji ġodda, għandhom jitqiesu meta jiġu stabbiliti t-tariffi għall-proċeduri ta’ valutazzjoni ta’ konformità u dawk it-tariffi għandhom jitnaqqsu b’mod proporzjonat għall-interessi u l-ħtiġijiet speċifiċi tagħhom.

1.1 Referenzi

1.2 Rekwiżiti identifikati

1.3 Standards relatati

2. Rekwiżiti identifikati

Rekwiżiti

3. Standards relatati

Standards
SCF Ability To Demonstrate Conformity

Description

Mechanisms exist to ensure the organization is able to demonstrate security, compliance and/or resilience capability conformity with applicable cybersecurity and data protection laws, regulations and/or contractual obligations.

Possible Solutions & Considerations

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

∙ Document applicable regulatory requirements in a checklist

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

∙ Compliance checklist
∙ Annual compliance review

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

∙ Compliance management program
∙ Regulatory mapping
∙ Compliance calendar

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

∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Compliance team

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

∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Dedicated compliance team
∙ Automated compliance monitoring

SCR-CMM

Level 0 Not Performed

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

Level 1 Performed Informally

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.

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 ensure the organization is able to demonstrate security, compliance and/or resilience capability conformity with applicable cybersecurity and data protection laws, regulations and/or contractual obligations.

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.
SCF Conformity Assessment

Description

Mechanisms exist to conduct assessments to demonstrate security, compliance and/or resilience capability conformity with applicable cybersecurity and data protection laws, regulations and/or contractual obligations.

Possible Solutions & Considerations

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

∙ Document applicable regulatory requirements in a checklist

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

∙ Compliance checklist
∙ Annual compliance review

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

∙ Compliance management program
∙ Regulatory mapping
∙ Compliance calendar

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

∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Compliance team

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

∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Dedicated compliance team
∙ Automated compliance monitoring

SCR-CMM

Level 0 Not Performed

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

Level 1 Performed Informally

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 work with business stakeholders and process owners to assigned cybersecurity and/or data protection controls to comply with specific compliance requirements.

Level 3 Well Defined

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

Level 4 Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Level 5 Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
SCF Control Validation Testing (CVT)

Description

Mechanisms exist to formally assess the security, compliance and resilience controls in Technology Assets, Applications and/or Services (TAAS) through Information Assurance Program (IAP) activities to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting expected requirements.

Possible Solutions & Considerations

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

∙ Controls Validation Testing (CVT)

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

∙ Controls Validation Testing (CVT)

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

∙ Controls Validation Testing (CVT)
∙ Information Assurance (IA) program
∙ VisibleOps security management

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

∙ Controls Validation Testing (CVT)
∙ Information Assurance (IA) program
∙ VisibleOps security management

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

∙ Controls Validation Testing (CVT)
∙ Information Assurance (IA) program
∙ VisibleOps security management

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

Information Assurance (IAO) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAO domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Pre-production security testing-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain an informal process to conduct limited control testing of High Value Assets (HVAs) to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

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.
▪ IAP operations focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel coordinate IAP activities with affected stakeholders before conducting such activities in order to reduce the potential impact on operations.
▪ IAP testing results in a formal risk assessment where Business process owners (BPOs) are required to make a decision to (1) reduce, (2) avoid, (3) transfer and/or (4) accept risk(s) on behalf of the organization.

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 formally assess the security, compliance and resilience controls in Technology Assets, Applications and/or Services (TAAS) through Information Assurance Program (IAP) activities to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting expected requirements.

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.
SCF Specialized Assessments

Description

Mechanisms exist to conduct specialized assessments for:
(1) Statutory, regulatory and contractual compliance obligations;
(2) Monitoring capabilities;
(3) Mobile devices;
(4) Databases;
(5) Application security;
(6) Embedded technologies (e.g., IoT and OT);
(7) Vulnerability management;
(8) Malicious code;
(9) Insider threats;
(10) Performance/load testing;
(11) Artificial Intelligence and Autonomous Technologies (AAT); and/or
(12) Other Technology Assets, Applications and/or Services (TAAS) that require specialized expertise to determine conformity with security, compliance and/or resilience requirements.

Possible Solutions & Considerations

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

∙ Controls Validation Testing (CVT)

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

∙ Controls Validation Testing (CVT)

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

∙ Controls Validation Testing (CVT)

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

∙ Controls Validation Testing (CVT)

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

∙ Controls Validation Testing (CVT)

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

Information Assurance (IAO) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAO domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Pre-production security testing-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain an informal process to conduct limited control testing of High Value Assets (HVAs) to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

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.
▪ IAP operations focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

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 conduct specialized assessments for:
(1) Statutory, regulatory and contractual compliance obligations;
(2) Monitoring capabilities;
(3) Mobile devices;
(4) Databases;
(5) Application security;
(6) Embedded technologies (e.g., IoT and OT);
(7) Vulnerability management;
(8) Malicious code;
(9) Insider threats;
(10) Performance/load testing;
(11) Artificial Intelligence and Autonomous Technologies (AAT); and/or
(12) Other Technology Assets, Applications and/or Services (TAAS) that require specialized expertise to determine conformity with security, compliance and/or resilience requirements.

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.
SCF Control Validation Testing (CVT)

Description

Mechanisms exist to formally assess the security, compliance and resilience controls in Technology Assets, Applications and/or Services (TAAS) through Information Assurance Program (IAP) activities to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting expected requirements.

Possible Solutions & Considerations

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

∙ Controls Validation Testing (CVT)

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

∙ Controls Validation Testing (CVT)

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

∙ Controls Validation Testing (CVT)
∙ Information Assurance (IA) program
∙ VisibleOps security management

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

∙ Controls Validation Testing (CVT)
∙ Information Assurance (IA) program
∙ VisibleOps security management

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

∙ Controls Validation Testing (CVT)
∙ Information Assurance (IA) program
∙ VisibleOps security management

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

Information Assurance (IAO) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with IAO domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Pre-production security testing-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel implement and maintain an informal process to conduct limited control testing of High Value Assets (HVAs) to meet specific statutory, regulatory and/or contractual requirements for pre-production cybersecurity and data protection control testing.

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.
▪ IAP operations focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel coordinate IAP activities with affected stakeholders before conducting such activities in order to reduce the potential impact on operations.
▪ IAP testing results in a formal risk assessment where Business process owners (BPOs) are required to make a decision to (1) reduce, (2) avoid, (3) transfer and/or (4) accept risk(s) on behalf of the organization.

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 formally assess the security, compliance and resilience controls in Technology Assets, Applications and/or Services (TAAS) through Information Assurance Program (IAP) activities to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting expected requirements.

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.