+Artigo 19.o Política de recursos humanos

Artigo 19.o Política de recursos humanos

Artigo 19.o

Política de recursos humanos

As entidades financeiras devem incluir na sua política de recursos humanos ou noutras políticas relevantes todos os elementos seguintes relacionados com a segurança das TIC:

a) 

A identificação e atribuição de quaisquer responsabilidades específicas em matéria de segurança das TIC;

b) 

Os requisitos aplicáveis aos membros do pessoal da entidade financeira e dos terceiros prestadores de serviços de TIC que utilizam ou acedem a ativos de TIC da entidade financeira para:

i) 

estarem informados e aderirem às políticas, procedimentos e protocolos de segurança das TIC da entidade financeira,

ii) 

terem conhecimento dos canais de comunicação criados pela entidade financeira para a deteção de comportamentos anómalos, incluindo, se for caso disso, os canais de comunicação estabelecidos em conformidade com a Diretiva (UE) 2019/1937 do Parlamento Europeu e do Conselho ( 1 ),

iii) 

no que toca aos membros do pessoal, devolverem à entidade financeira, após a cessação do contrato de trabalho, todos os ativos de TIC e ativos de informação tangíveis na sua posse que pertençam à entidade financeira.

1. Visão geral

,

1.1 Referências

1.2 Requisitos identificados

1.3 Normas relacionadas

2. Requisitos identificados

Requisitos

3. Normas relacionadas

Normas
SCF Assigned Security, Compliance & Resilience Responsibilities

Description

Mechanisms exist to assign one or more qualified individuals with the mission and resources to centrally-manage, coordinate, develop, implement and maintain an enterprise-wide Security, Compliance & Resilience Program (SCRP).

Possible Solutions & Considerations

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

∙ Third-party advisors (e.g., virtual CISO (vCISO), Managed Security Services Provider (MSSP))
∙ Designated internal security point of contact
∙ vCISO services (e.g., Truvantis, private vCISO firms)

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

∙ Third-party advisors (e.g., virtual CISO (vCISO), Managed Security Services Provider (MSSP))
∙ Part-time or shared security manager
∙ vCISO services with defined scope and deliverables

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

∙ Dedicated Information Security Manager (ISM) or fractional CISO
∙ Chief Information Security Officer (CISO) or equivalent role
∙ Defined Information Security Management System (ISMS) ownership

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

∙ Chief Information Security Officer (CISO) with defined authority and budget
∙ Security leadership team (CISO, DPO, IAM lead, etc.)
∙ Security organizational structure with clear reporting lines

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

∙ Chief Information Security Officer (CISO) with C-suite authority and board access
∙ Security leadership organization (CISO, Deputy CISO, DPO, domain leads)
∙ Security Center of Excellence (CoE)
∙ Defined succession planning for key security roles

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.
▪ A qualified individual is assigned the role and responsibilities to centrally manage, coordinate, develop, implement and maintain a cybersecurity and data protection program (e.g., cybersecurity director or Chief Information Security Officer (CISO)).
▪ The individual assigned the role and responsibilities to centrally manage, coordinate, develop, implement and maintain a cybersecurity and data protection program develops plans to implement the organization's security, compliance and resiliency-related objectives.

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).
▪ A qualified individual is assigned the role and responsibilities to centrally-manage, coordinate, develop, implement and maintain an enterprise-wide Security, Compliance & Resilience Program (SCRP) (e.g., cybersecurity director or Chief Information Security Officer (CISO)).

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 Human Resources Security Policy

Description

Mechanisms exist to establish a formal, documented human resources security policy that:
(1) Conveys executive management's intent;
(2) Provides organizational direction and expected behaviors;
(3) Is reviewed at least annually; and
(4) Is updated, as necessary, to adapt to evolving risks, threats and other changes that affect the organization.

Possible Solutions & Considerations

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ Executive-approved written policy with documented annual review

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ Executive-approved written policy with documented annual review
∙ Policy acknowledgement tracking (e.g., HR onboarding records)

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.) for policy lifecycle management
∙ Documented annual policy review with version control

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

∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.) for policy lifecycle management
∙ Policy governance committee with formal annual review and approval workflow
∙ Automated policy attestation and acknowledgement tracking

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

∙ Steering committee
∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ Enterprise GRC platform (e.g., Cyturus, Archer, MetricStream, ServiceNow IRM) for policy lifecycle management
∙ Automated policy attestation, exception tracking and change history
∙ Annual executive approval and board-level reporting

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

Human Resources Security (HRS) 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 HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS 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 HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.

Level 3 Well Defined

Human Resources Security (HRS) 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 HRS 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 HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software 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 HRS 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).

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 Human Resources Security Management

Description

Mechanisms exist to facilitate the implementation of personnel security controls.

Possible Solutions & Considerations

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

∙ Employee security policy acknowledgment
∙ Background check for sensitive roles

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

∙ Security awareness policy
∙ Background checks
∙ Security onboarding checklist

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

∙ HR security program
∙ Background checks for all staff
∙ Security onboarding training

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

∙ Enterprise HR security program
∙ Background screening service
∙ Automated offboarding workflows

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

∙ Enterprise HR security framework
∙ Background screening platform
∙ Integrated HR/IAM offboarding
∙ Continuous 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

Human Resources Security (HRS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with HRS domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Personnel management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ The Human Resources (HR) department provides guidance on secure HR practices for hiring, retaining and terminating employees, contractors and other personnel that work on behalf of the organization.
▪ HR maintains a current list of authorized personnel and facilitates the implementation of physical access management controls.

Level 2 Planned Tracked

Human Resources Security (HRS) 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 HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS 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 HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.
▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization.
▪ The HR department works with cybersecurity personnel to facilitate workforce development and awareness to help ensure secure practices are implemented.

Level 3 Well Defined

Human Resources Security (HRS) 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 HRS 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 HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software 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 HRS 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 facilitate the implementation of personnel security controls.

Level 4 Quantitatively Controlled

Human Resources Security (HRS) 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 Defined Roles & Responsibilities

Description

Mechanisms exist to define cybersecurity roles & responsibilities for all personnel.

Possible Solutions & Considerations

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ NIST NICE cybersecurity workforce framework alignment
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

Human Resources Security (HRS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with HRS domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Personnel management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ The Human Resources (HR) department provides guidance on secure HR practices for hiring, retaining and terminating employees, contractors and other personnel that work on behalf of the organization.
▪ Formal roles and responsibilities for cybersecurity and/or data protection are not consistent and/or standardized.

Level 2 Planned Tracked

Human Resources Security (HRS) 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 HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS 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 HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.
▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization.

Level 3 Well Defined

Human Resources Security (HRS) 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 HRS 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 HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software 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 HRS 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 define cybersecurity roles & responsibilities for all personnel.

Level 4 Quantitatively Controlled

Human Resources Security (HRS) 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 Terms of Employment

Description

Mechanisms exist to require all employees and contractors to apply cybersecurity and data protection principles in their daily work to enable secure, compliant and resilient capabilities.

Possible Solutions & Considerations

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

∙ Formal onboarding training
∙ Acceptable Use / Rules of Behavior (RoB)

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

∙ Formal onboarding training
∙ Acceptable Use / Rules of Behavior (RoB)

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

∙ Formal onboarding training
∙ Acceptable Use / Rules of Behavior (RoB)

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

∙ Formal onboarding training
∙ Acceptable Use / Rules of Behavior (RoB)

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

∙ Formal onboarding training
∙ Acceptable Use / Rules of Behavior (RoB)

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

Human Resources Security (HRS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with HRS domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Personnel management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ The Human Resources (HR) department provides guidance on secure HR practices for hiring, retaining and terminating employees, contractors and other personnel that work on behalf of the organization.

Level 2 Planned Tracked

Human Resources Security (HRS) 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 HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS 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 HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.
▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization.
▪ HR defines terms of employment, including acceptable and unacceptable rules of behavior for the use of technologies, including consequences for unacceptable behavior.
▪ HR maintains formal Terms of Employment (ToE) and/or Rules of Behavior (RoB) that stipulates acceptable and unacceptable employee activities.

Level 3 Well Defined

Human Resources Security (HRS) 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 HRS 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 HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software 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 HRS 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 require all employees and contractors to apply cybersecurity and data protection principles in their daily work to enable secure, compliant and resilient capabilities.

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 Policy Familiarization & Acknowledgement

Description

Mechanisms exist to ensure personnel receive recurring familiarization with the organization's security, compliance and resilience policies and provide acknowledgement.

Possible Solutions & Considerations

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

∙ Formal onboarding training
∙ Written policy acknowledgement

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

∙ Formal onboarding training
∙ Written policy acknowledgement

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

∙ Formal onboarding training
∙ Written policy acknowledgement

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

∙ Formal onboarding training
∙ Written policy acknowledgement

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

∙ Formal onboarding training
∙ Written policy acknowledgement

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

Human Resources Security (HRS) 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 HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS 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 HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.
▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization.

Level 3 Well Defined

Human Resources Security (HRS) 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 HRS 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 HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software 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 HRS 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 personnel receive recurring familiarization with the organization's security, compliance and resilience policies and provide acknowledgement.

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 Asset Collection

Description

Mechanisms exist to retrieve organization-owned assets upon termination of an individual's employment.

Possible Solutions & Considerations

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

∙ Employee security policy acknowledgment
∙ Background check for sensitive roles

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

∙ Security awareness policy
∙ Background checks
∙ Security onboarding checklist

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

∙ HR security program
∙ Background checks for all staff
∙ Security onboarding training

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

∙ Enterprise HR security program
∙ Background screening service
∙ Automated offboarding workflows

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

∙ Enterprise HR security framework
∙ Background screening platform
∙ Integrated HR/IAM offboarding
∙ Continuous 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

Human Resources Security (HRS) 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 HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS 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 HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.
▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization.

Level 3 Well Defined

Human Resources Security (HRS) 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 HRS 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 HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software 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 HRS 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 retrieve organization-owned assets upon termination of an individual's employment.

Level 4 Quantitatively Controlled

Human Resources Security (HRS) 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 Third-Party Personnel

Description

Mechanisms exist to govern third-party personnel by reviewing and monitoring third-party security, compliance and/or resilience roles and responsibilities.

Possible Solutions & Considerations

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

∙ Contract Statement of Work (SOW) review.
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ Contract Statement of Work (SOW) review.
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ Contract Statement of Work (SOW) review.
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ Contract Statement of Work (SOW) review.
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

∙ Contract Statement of Work (SOW) review.
∙ Responsible, Accountable, Supporting, Consulted and Informed (RASCI) matrix

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

Human Resources Security (HRS) 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 HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS 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 HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.
▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization.

Level 3 Well Defined

Human Resources Security (HRS) 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 HRS 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 HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software 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 HRS 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 third-party personnel by reviewing and monitoring third-party security, compliance and/or resilience roles and responsibilities.

Level 4 Quantitatively Controlled

Human Resources Security (HRS) 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 Reporting Suspicious Activities

Description

Mechanisms exist to enable personnel to report suspicious activities and/or behavior without fear of reprisal or other negative consequences (e.g., whistleblower protections).

Possible Solutions & Considerations

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

∙ Employee security policy acknowledgment
∙ Background check for sensitive roles

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

∙ Security awareness policy
∙ Background checks
∙ Security onboarding checklist

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

∙ HR security program
∙ Background checks for all staff
∙ Security onboarding training

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

∙ Enterprise HR security program
∙ Background screening service
∙ Automated offboarding workflows

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

∙ Enterprise HR security framework
∙ Background screening platform
∙ Integrated HR/IAM offboarding
∙ Continuous 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

Human Resources Security (HRS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with HRS domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Personnel management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ The Human Resources (HR) department provides guidance on secure HR practices for hiring, retaining and terminating employees, contractors and other personnel that work on behalf of the organization.

Level 2 Planned Tracked

Human Resources Security (HRS) 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 HRS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with HRS 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 HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization.
▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization.

Level 3 Well Defined

Human Resources Security (HRS) 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 HRS 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 HRS domain capabilities are well-documented and kept current by process owners.
▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software 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 HRS 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 enable personnel to report suspicious activities and/or behavior without fear of reprisal or other negative consequences (e.g., whistleblower protections).

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 Security, Compliance & Resilience Awareness Training

Description

Mechanisms exist to provide all employees and contractors appropriate security, compliance and resilience awareness education and training that is relevant for their job function.

Possible Solutions & Considerations

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

∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)

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

∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)

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

∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)

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

∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)

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

∙ Initial & annual security, compliance and resilience awareness training
∙ KnowB4 (https://knowbe4.com)

SCR-CMM

Level 0 Not Performed

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

Level 1 Performed Informally

Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.

Level 2 Planned Tracked

Security Awareness & Training (SAT) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.

Level 3 Well Defined

Security Awareness & Training (SAT) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with SAT domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with SAT domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to provide all employees and contractors appropriate security, compliance and resilience awareness education and training that is relevant for their job function.

Level 4 Quantitatively Controlled

Security Awareness & Training (SAT) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

Level 5 Continuously Improving

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