+Articolul 6 Cadrul de gestionare a riscurilor TIC
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Articolul 6 Cadrul de gestionare a riscurilor TIC
1. Prezentare generală
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Reglementare |
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Articolul 6 (1)
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Entitățile financiare dispun de un cadru solid, cuprinzător și bine documentat de gestionare a riscurilor TIC, ca parte a sistemului lor general de gestionare a riscurilor, care le permite să abordeze riscurile TIC în mod rapid, eficient și cuprinzător și să asigure un nivel ridicat de reziliență operațională digitală.
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Articolul 6 (2)
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Cadrul de gestionare a riscurilor TIC include cel puțin strategii, politici, proceduri, precum și protocoale și instrumente TIC care sunt necesare pentru a proteja în mod corespunzător și adecvat toate activele informaționale și toate activele TIC, inclusiv software pentru calculatoare, hardware și servere, precum și pentru a proteja toate componentele și infrastructurile fizice relevante, precum sediile, centrele de date și zonele desemnate sensibile, pentru a asigura că toate activele informaționale și toate activele TIC sunt protejate în mod adecvat împotriva riscurilor, inclusiv împotriva pagubelor și a accesului sau utilizării neautorizate.
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Articolul 6 (3)
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În conformitate cu cadrul lor de gestionare a riscurilor TIC, entitățile financiare reduc la minimum impactul riscurilor TIC prin utilizarea unor strategii, politici, proceduri, protocoale și instrumente TIC adecvate. Acestea furnizează autorităților competente, la cererea acestora, informații complete și actualizate cu privire la riscurile TIC și la cadrul lor de gestionare a riscurilor TIC.
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Articolul 6 (4)
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Entitățile financiare, altele decât microîntreprinderile, atribuie responsabilitatea pentru gestionarea și supravegherea riscurilor TIC unei funcții de control și asigură independența acestei funcții de control la un nivel adecvat, pentru a evita conflictele de interese. Entitățile financiare asigură în mod adecvat separarea și independența a funcțiilor de gestionare a riscurilor TIC, a funcțiilor de control și a funcțiilor de audit intern, în conformitate cu cele trei linii ale modelului de apărare sau cu un model intern de gestionare și control al riscurilor.
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Articolul 6 (5)
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Cadrul de gestionare a riscurilor TIC se documentează și se revizuiește cel puțin o dată pe an, sau periodic în cazul microîntreprinderilor, precum și în cazul unor incidente majore legate de TIC și în urma instrucțiunilor sau concluziilor în materie de supraveghere care decurg din testarea relevantă a rezilienței operaționale digitale sau din procesele de audit relevante. Acesta este îmbunătățit în permanență, pe baza învățămintelor desprinse în urma punerii în aplicare și a monitorizării. Autorității competente i se prezintă, la cererea sa, un raport privind revizuirea cadrului de gestionare a riscurilor TIC.
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Articolul 6 (6)
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Cadrul de gestionare a riscurilor TIC al entităților financiare, altele decât microîntreprinderile, este supus auditului intern de către auditori în mod regulat, în conformitate cu planul de audit al entităților financiare. Auditorii respectivi dețin suficiente cunoștințe, competențe și expertiză în ceea ce privește riscurile TIC, precum și o independență adecvată. Frecvența și obiectivul auditurilor TIC sunt proporționale cu riscurile TIC ale entităților financiare.
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Articolul 6 (7)
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Pe baza concluziilor evaluării de audit intern, entitățile financiare stabilesc un proces formal de urmărire, care include reguli pentru verificarea și remedierea în timp util a elementelor critice constatate în cadrul auditurilor TIC.
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Articolul 6 (8)
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Cadrul de gestionare a riscurilor TIC include o strategie privind reziliența operațională digitală, care stabilește modul de punere în aplicare a cadrului. În acest scop, strategia privind reziliența operațională digitală include metode de abordare a riscurilor TIC și de realizare a obiectivelor TIC specifice, prin:
(a)
explicarea modului în care cadrul de gestionare a riscurilor TIC sprijină strategia de afaceri și obiectivele entității financiare;
(b)
stabilirea nivelului de toleranță la risc pentru riscurile TIC, în conformitate cu apetitul pentru risc al entității financiare, și analizarea toleranței la impact pentru perturbările TIC;
(c)
stabilirea unor obiective clare privind securitatea informațiilor, inclusiv indicatori-cheie de performanță și indicatori-cheie de risc;
(d)
explicarea arhitecturii TIC de referință și a oricăror modificări necesare pentru atingerea obiectivelor specifice de activitate;
(e)
prezentarea diferitelor mecanisme instituite pentru a detecta incidentele legate de TIC, a preveni impactul acestora și a asigura protecție împotriva acestora;
(f)
evidențierea situației actuale a rezilienței operaționale digitale pe baza numărului de incidente majore legate de TIC raportate și a eficacității măsurilor preventive;
(g)
implementarea testării rezilienței operaționale digitale, în conformitate cu capitolul IV din prezentul regulament;
(h)
conturarea unei strategii de comunicare în cazul producerii unor incidente legate de TIC cu privire la care este necesară informarea în conformitate cu articolul 14.
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Articolul 6 (9)
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Entitățile financiare pot defini, în contextul strategiei privind reziliența operațională digitală menționate la alineatul (8), o strategie TIC cuprinzătoare privind existența mai multor furnizori, la nivel de grup sau de entitate, care să prezinte principalele dependențe față de furnizorii terți de servicii TIC și să explice raționamentul care stă la baza mixului de achiziții de la furnizori terți de servicii TIC.
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Articolul 6 (10)
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Entitățile financiare pot externaliza, în conformitate cu legislația sectorială a Uniunii și cea națională, sarcinile de verificare a conformității cu cerințele de gestionare a riscurilor TIC către entități intragrup sau externe. În cazul unei astfel de externalizări, entitatea financiară rămâne pe deplin responsabilă de verificarea conformității cu cerințele de gestionare a riscurilor TIC.
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1.1 Referințe
1.2 Cerințe identificate
1.3 Standarde asociate
2. Cerințe identificate
3. Standarde asociate
Standarde
| Sursă |
Cerință |
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SCF
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Publishing Security, Compliance & Resilience Documentation
Description
Mechanisms exist to establish, maintain and disseminate policies, standards and procedures necessary for secure, compliant and resilient capabilities.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ ComplianceForge - Cybersecurity & Data Protection Program (CDPP) (https://complianceforge.com)
∙ SCFConnect (https://scfconnect.com)
∙ Shared drive or intranet for policy distribution (e.g., Google Drive, SharePoint Online)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ ComplianceForge - Cybersecurity & Data Protection Program (CDPP) (https://complianceforge.com)
∙ SCFConnect (https://scfconnect.com)
∙ Document management system (e.g., SharePoint, Confluence, Notion)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ ComplianceForge - Cybersecurity & Data Protection Program (CDPP) (https://complianceforge.com)
∙ Document management / intranet portal (e.g., SharePoint, Confluence)
∙ Policy acknowledgement tracking (e.g., KnowBe4, Absorb LMS)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ Policy management platform
∙ Version-controlled policy repository with access controls
∙ Automated policy attestation and acknowledgement tracking
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
∙ Enterprise policy management platform
∙ Integrated GRC policy module with automated review workflows
∙ Enterprise-wide policy acknowledgement and training integration
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
Cybersecurity & Data Protection Governance (GOV) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with GOV domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Governance-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT/cybersecurity personnel.
▪ Cybersecurity and data protection governance is informally assigned as an additional duty to existing IT/cybersecurity personnel.
▪ Basic procedures are established for important tasks, but are ad hoc and not formally documented.
▪ No formal cybersecurity and/or data protection principles are identified for the organization.
▪ Informal recommendations are leveraged to update existing policies and standards.
▪ The responsibility for developing and operating cybersecurity and data privacy procedures are up to the business process owner(s) to determine, including the definition and enforcement of roles and responsibilities.
▪ Governance documentation is made available to internal personnel (e.g., policies, standards and procedures).
▪ People affected by documentation changes are provided notification of the policy and standard changes.
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.
▪ IT and/or cybersecurity personnel ensure cybersecurity policies and standards are aligned with a leading cybersecurity framework (e.g., SCF, NIST 800-53, NIST 800-171, ISO 27002 or NIST Cybersecurity Framework).
▪ The organization's cybersecurity policies and standards are made available to internal personnel.
▪ Documented procedures exist for requesting a deviation from approved standards.
▪ The responsibility for enforcing cybersecurity and data protection control implementation is assigned to business / process owners and asset custodians.
Level 3 Well Defined
Cybersecurity & Data Protection Governance (GOV) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain GOV domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to establish, maintain and disseminate policies, standards and procedures necessary for secure, compliant and resilient capabilities.
Level 4 Quantitatively Controlled
Cybersecurity & Data Protection Governance (GOV) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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SCF
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Key Performance Indicators (KPIs)
Description
Mechanisms exist to develop, report and monitor Key Performance Indicators (KPIs) to assist organizational management in performance monitoring, trend analysis, and possible control redesign or replacement for the Security, Compliance & Resilience Program (SCRP).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Manually-generated metrics (spreadsheet)
∙ Key security KPIs: patch compliance %, training completion %, incident count, open vulnerability age
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Manually-generated metrics with defined KPI thresholds
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Monthly/quarterly KPI reporting to leadership
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Defined security KPI library (CIS, CISA, or custom)
∙ Automated KPI collection via GRC or SIEM integration
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Formal KPI program with defined targets, thresholds, and owners
∙ GRC platform with automated KPI dashboards (e.g., SCFConnect, Cyturus, etc.)
∙ Board-level security KPI reporting cadence
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise KPI program aligned to NIST, CIS, or custom security frameworks
∙ Automated KPI collection and reporting via GRC/SIEM integration
∙ Board and audit committee KPI reporting with trend analysis
∙ KPIs mapped to business risk appetite and strategic objectives
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
SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Cybersecurity & Data Protection Governance (GOV) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain GOV domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to develop, report and monitor Key Performance Indicators (KPIs) to assist organizational management in performance monitoring and trend analysis of the Security, Compliance & Resilience Program (SCRP).
Level 4 Quantitatively Controlled
Cybersecurity & Data Protection Governance (GOV) 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
Cybersecurity & Data Protection Governance (GOV) 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.
▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.
▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
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SCF
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Key Risk Indicators (KRIs)
Description
Mechanisms exist to develop, report and monitor Key Risk Indicators (KRIs) to assist senior management in performance monitoring, trend analysis, and possible control redesign or replacement for the Security, Compliance & Resilience Program (SCRP).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Manually-generated metrics (spreadsheet)
∙ Basic risk indicators: critical unpatched vulnerabilities, failed logins, open security incidents
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Manually-generated KRI tracking with alert thresholds
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
∙ Documented risk tolerance thresholds
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Defined KRI library tied to organizational risk register
∙ Automated KRI monitoring via GRC platform or SIEM (e.g., Splunk, Microsoft Sentinel)
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Formal KRI program with defined risk appetite thresholds
∙ Automated KRI monitoring with escalation triggers
∙ GRC platform with KRI dashboards linked to risk register
∙ Regular KRI reporting to risk committee
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise KRI program integrated with risk management framework
∙ Automated real-time KRI monitoring with AI-assisted anomaly detection
∙ Board-level risk indicator reporting with trend analysis
∙ KRIs linked to enterprise risk appetite and materiality thresholds
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
Cybersecurity & Data Protection Governance (GOV) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with GOV domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Governance-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT/cybersecurity personnel.
▪ Cybersecurity and data protection governance is informally assigned as an additional duty to existing IT/cybersecurity personnel.
▪ Organizational leadership maintains an informal process to review and respond to observed trends.
Level 2 Planned Tracked
SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Cybersecurity & Data Protection Governance (GOV) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain GOV domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to develop, report and monitor Key Risk Indicators (KRIs) to assist senior management in performance monitoring and trend analysis of the Security, Compliance & Resilience Program (SCRP).
Level 4 Quantitatively Controlled
Cybersecurity & Data Protection Governance (GOV) 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
Cybersecurity & Data Protection Governance (GOV) 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.
▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.
▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
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SCF
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Strategic Plan & Objectives
Description
Mechanisms exist to establish a:
(1) Strategic security, compliance and resilience-specific business plan; and
(2) Set of objectives to achieve that plan.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Include security tasks in project plans
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Security requirements in project planning
∙ Project security checklist
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Documented cybersecurity and data protection-specific business plan
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Documented cybersecurity and data protection-specific business plan
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Documented cybersecurity and data protection-specific business plan
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
Project & Resource Management (PRM) 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 PRM domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with PRM 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 PRM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Project & Resource Management -related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Project & Resource 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 Chief Information Officer (CIO), or similar function, analyzes the organization's business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements.
▪ A Project Management Office (PMO), or project management function, enables the implementation of cybersecurity and data protection-related resource planning controls across the System Development Lifecycle (SDLC) for all high-value projects.
▪ Quarterly Business Review (QBR), or similar status reporting, exists to provide recurring reports on the state of the cybersecurity and data protection program.
Level 3 Well Defined
Project & Resource Management (PRM) 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 PRM 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 PRM domain capabilities are well-documented and kept current by process owners.
▪ A Project Management Office (PMO), or similar function, is appropriately staffed and supported to implement and maintain PRM domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of project and resource management operations (e.g., project 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 PRM 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).
▪ The Chief Information Officer (CIO), or similar function, analyzes the organization's business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements.
▪ An implemented and operational capability exists to establish a:
(1) Strategic security, compliance and resilience-specific business plan; and
(2) Set of objectives to achieve that plan.
Level 4 Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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SCF
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Risk Management Program
Description
Mechanisms exist to facilitate the implementation of strategic, operational and tactical risk management controls that are aligned with:
(1) The organization's Enterprise Risk Management (ERM); and
(2) Industry-recognized cybersecurity risk management practices.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Risk Management Program (RMP)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Risk Management Program (RMP)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Risk Management Program (RMP)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Risk Management Program (RMP)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Risk Management Program (RMP)
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
Risk Management (RSK) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with RSK domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Risk management-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 use an informal process to identify, assess, remediate and report on risk.
▪ Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ Data/process owners are expected to self-manage risks associated with their Technology Assets, Applications, Services and/or Data (TAASD), based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
Level 2 Planned Tracked
Risk Management (RSK) 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 RSK domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with RSK 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 RSK domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported.
▪ Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
▪ Business process owners (BPOs) are made aware of cybersecurity and data protection risk(s).
Level 3 Well Defined
Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 strategic, operational and tactical risk management controls.
Level 4 Quantitatively Controlled
Risk Management (RSK) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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SCF
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Standardized Operating Procedures (SOP)
Description
Mechanisms exist to identify and document Standardized Operating Procedures (SOP), or similar documentation, to enable the proper execution of day-to-day / assigned tasks.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Documented Standardized Operating Procedures (SOP)
∙ ComplianceForge - Cybersecurity Standardized Operating Procedures (CSOP)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Documented Standardized Operating Procedures (SOP)
∙ ComplianceForge - Cybersecurity Standardized Operating Procedures (CSOP)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Documented Standardized Operating Procedures (SOP)
∙ ComplianceForge - Cybersecurity Standardized Operating Procedures (CSOP)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Documented Standardized Operating Procedures (SOP)
∙ ComplianceForge - Cybersecurity Standardized Operating Procedures (CSOP)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Documented Standardized Operating Procedures (SOP)
∙ ComplianceForge - Cybersecurity Standardized Operating Procedures (CSOP)
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
Security Operations (OPS) 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 OPS domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with OPS 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 OPS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security operations management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Security operations management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel create “run books,” or SOPs, to capture operational knowledge in documentation form for critical business functions and/or for sensitive/regulated obligations to protect the Confidentiality, Integrity, Availability and Safety (CIAS) of the organization's TAASD.
Level 3 Well Defined
Security Operations (OPS) 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 OPS 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 OPS domain capabilities are well-documented and kept current by process owners.
▪ A Security Operations Center (SOC), or similar function, is appropriately staffed and supported to implement and maintain OPS domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security operations management (e.g., SIEM solution and EDR/XDR tools).
▪ 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 OPS 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).
▪ Cybersecurity personnel create “run books,” or SOPs, to capture operational knowledge in documentation form for critical business functions and/or for sensitive/regulated obligations.
▪ An implemented and operational capability exists to identify and document Standardized Operating Procedures (SOP), or similar documentation, to enable the proper execution of day-to-day / assigned tasks.
Level 4 Quantitatively Controlled
Security Operations (OPS) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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SCF
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Risk Management Program
Description
Mechanisms exist to facilitate the implementation of strategic, operational and tactical risk management controls that are aligned with:
(1) The organization's Enterprise Risk Management (ERM); and
(2) Industry-recognized cybersecurity risk management practices.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Risk Management Program (RMP)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Risk Management Program (RMP)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Risk Management Program (RMP)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Risk Management Program (RMP)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Risk Management Program (RMP)
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
Risk Management (RSK) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with RSK domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Risk management-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 use an informal process to identify, assess, remediate and report on risk.
▪ Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ Data/process owners are expected to self-manage risks associated with their Technology Assets, Applications, Services and/or Data (TAASD), based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
Level 2 Planned Tracked
Risk Management (RSK) 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 RSK domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with RSK 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 RSK domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Risk management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Risk management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ IT and/or cybersecurity personnel implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported.
▪ Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization's published policies and standards, including the identification, remediation and reporting of risks.
▪ Business process owners (BPOs) are made aware of cybersecurity and data protection risk(s).
Level 3 Well Defined
Risk Management (RSK) 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 RSK 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 RSK domain capabilities are well-documented and kept current by process owners.
▪ A risk management team, or similar function, is appropriately staffed and supported to implement and maintain RSK domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of risk management operations (e.g., risk management solution, GRC platform and TPRM tool).
▪ 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 RSK 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 strategic, operational and tactical risk management controls.
Level 4 Quantitatively Controlled
Risk Management (RSK) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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