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+Data Action Mapping |
Data Action MappingDescriptionMechanisms exist to create and maintain a map of Technology Assets, Applications and/or Services (TAAS) where sensitive and/or regulated data is stored, transmitted or processed.Possible Solutions & ConsiderationsMicro-Small Business (<10 staff) / BLS Firm Size Classes 1-2∙ Microsoft Visio or draw.io (free, https://draw.io) for data flow diagrams∙ LucidChart (https://lucidchart.com) Small Business (10-49 staff) / BLS Firm Size Classes 3-4∙ Microsoft Visio or draw.io (free, https://draw.io)∙ LucidChart (https://lucidchart.com) ∙ Documented data flow diagrams with sensitivity labels Medium Business (50-249 staff) / BLS Firm Size Classes 5-6∙ Microsoft Visio∙ LucidChart (https://lucidchart.com) ∙ draw.io (https://draw.io) ∙ Data flow diagrams integrated with privacy impact assessments Large Business (250-999 staff) / BLS Firm Size Classes 7-8∙ Microsoft Visio∙ LucidChart (https://lucidchart.com) ∙ Data flow diagrams maintained in CMDB or GRC platform ∙ Automated data mapping tools (e.g., BigID, OneTrust Data Mapping) Enterprise (> 1,000 staff) / BLS Firm Size Class 9∙ Enterprise data flow/action mapping platform (e.g., BigID, OneTrust, Securiti.ai)∙ Microsoft Visio / LucidChart for technical documentation ∙ Automated data lineage tools (e.g., Collibra, Alation) ∙ Data maps maintained current for regulatory compliance (GDPR Article 30) SCR-CMMLevel 0 Not PerformedPractices 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 InformallySCR-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 TrackedAsset Management (AST) 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 AST domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with AST 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 AST domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Asset management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ The IT department establishes, maintains and updates an inventory that contains a listing of all organizational-owned TAASD, at a minimum covering common devices (e.g., laptops, workstations and servers). ▪ IT and/or cybersecurity personnel work with process owners to generate and maintain Data Flow Diagrams (DFDs) and network diagrams to document the flow of data to create and maintain a map of systems where sensitive/regulated data is stored, transmitted or processed. Level 3 Well DefinedAsset Management (AST) 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 AST 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 AST domain capabilities are well-documented and kept current by process owners. ▪ An IT Asset Management (ITAM) team, or similar function, is appropriately staffed and supported to implement and maintain AST domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of ITAM operations (e.g., ITAM platform, (e.g., Configuration Management Database (CMBD) Asset Management solution). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with AST 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 create and maintain a map of Technology Assets, Applications and/or Services (TAAS) where sensitive/regulated data is stored, transmitted or processed. Level 4 Quantitatively ControlledAsset Management (AST) 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 ImprovingUtilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define. 1. Visão geral
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