+Articolul 28 Principii generale
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Articolul 28 Principii generale
1. Prezentare generală
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Reglementare |
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Articolul 28 (1)
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Entitățile financiare gestionează riscurile TIC generate de părți terțe ca parte integrantă a riscurilor TIC în cadrul lor de gestionare a riscurilor TIC astfel cum este menționat la articolul 6 alineatul (1) și în conformitate cu următoarele principii:
(a)
entitățile financiare care au instituit acorduri contractuale pentru utilizarea serviciilor TIC în scopul desfășurării operațiunilor lor rămân în orice moment pe deplin responsabile de respectarea și de îndeplinirea tuturor obligațiilor care decurg din prezentul regulament și din dreptul aplicabil în domeniul serviciilor financiare;
(b)
gestionarea de către entitățile financiare a riscurilor TIC generate de părți terțe este pusă în aplicare din perspectiva principiului proporționalității, luând în considerare:
(i)
natura, amploarea, complexitatea și importanța dependențelor legate de TIC;
(ii)
riscurile care decurg din acordurile contractuale privind utilizarea serviciilor TIC încheiate cu furnizori terți de servicii TIC, ținând seama de caracterul critic sau importanța serviciului, procesului sau funcției respective, precum și de impactul potențial asupra continuității și disponibilității serviciilor și activităților financiare, la nivel individual și la nivel de grup.
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Articolul 28 (2)
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Ca parte a cadrului lor de gestionare a riscurilor TIC, entitățile financiare, altele decât entitățile menționate la articolul 16 alineatul (1) primul paragraf și altele decât microîntreprinderile, adoptă și revizuiesc periodic o strategie privind riscurile TIC generate de părți terțe, ținând seama de strategia privind existența mai multor furnizori menționată la articolul 6 alineatul (9), după caz. Această strategie privind riscurile TIC generate de părți terțe include o politică privind utilizarea serviciilor TIC care sprijină funcții critice sau importante oferite de furnizori terți de servicii TIC și se aplică pe o bază individuală și, după caz, pe o bază subconsolidată și consolidată. Pe baza unei evaluări a profilului general de risc al entității financiare și a amplorii și complexității serviciilor comerciale, organul de conducere examinează periodic riscurile identificate în ceea ce privește acordurile contractuale privind utilizarea serviciilor TIC care sprijină funcții critice sau importante.
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Articolul 28 (3)
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Ca parte a cadrului lor de gestionare a riscurilor TIC, entitățile financiare mențin și actualizează la nivel de entitate și la nivel subconsolidat și consolidat un registru de informații în legătură cu toate acordurile contractuale privind utilizarea serviciilor TIC oferite de furnizori terți de servicii TIC. Acordurile contractuale menționate la primul paragraf sunt documentate în mod corespunzător, făcându-se distincția între cele care acoperă servicii TIC de sprijinire a funcțiilor critice sau importante și cele care nu le acoperă. Entitățile financiare raportează cel puțin o dată pe an autorităților competente cu privire la numărul de noi acorduri privind utilizarea serviciilor TIC, categoriile de furnizori terți de servicii TIC, tipurile de acorduri contractuale și serviciile și funcțiile TIC care sunt oferite. Entitățile financiare pun la dispoziția autorității competente, la cererea acesteia, registrul complet de informații sau, după caz, secțiuni specifice din acesta, împreună cu orice informații considerate necesare pentru a permite supravegherea eficace a entității financiare. Entitățile financiare informează autoritatea competentă în timp util cu privire la orice acord contractual planificat privind utilizarea unor servicii TIC care sprijină funcții critice sau importante, precum și atunci când o funcție a devenit critică sau importantă.
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Articolul 28 (4)
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Înainte de a încheia un acord contractual privind utilizarea serviciilor TIC, entitățile financiare:
(a)
evaluează dacă acordul contractual vizează utilizarea unor servicii TIC care sprijină o funcție critică sau importantă;
(b)
evaluează dacă sunt îndeplinite condițiile pentru contractare din perspectiva supravegherii;
(c)
identifică și evaluează toate riscurile relevante legate de acordul contractual, inclusiv posibilitatea ca un astfel de acord contractual să contribuie la consolidarea riscului de concentrare a serviciilor TIC, astfel cum este menționat la articolul 29;
(d)
efectuează toate diligențele necesare cu privire la potențialii furnizori terți de servicii TIC și se asigură, pe parcursul proceselor de selecție și evaluare, că furnizorul terț de servicii TIC este adecvat;
(e)
identifică și evaluează conflictele de interese pe care acordul contractual le poate cauza.
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Articolul 28 (5)
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Entitățile financiare pot încheia acorduri contractuale numai cu furnizori terți de servicii TIC care respectă standarde adecvate de securitate a informațiilor. În cazul în care acordurile contractuale respective se referă la funcții critice sau importante, entitățile financiare, înainte de încheierea acordurilor, țin seama în mod corespunzător de utilizarea de către furnizorii terți de servicii TIC a celor mai recente și de cea mai înaltă calitate standarde de securitate a informațiilor.
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Articolul 28 (6)
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În exercitarea drepturilor de acces, de inspecție și de audit cu privire la furnizorul terț de servicii TIC, entitățile financiare stabilesc în prealabil, utilizând o abordare bazată pe riscuri, frecvența auditurilor și a inspecțiilor, precum și domeniile care urmează să fie auditate prin aderarea la standardele de audit acceptate de comun acord, în concordanță cu instrucțiunile de supraveghere privind utilizarea și integrarea unor astfel de standarde de audit. În cazul în care acordurile contractuale încheiate cu furnizori terți de servicii TIC privind utilizarea unor servicii TIC prezintă o complexitate tehnică ridicată, entitatea financiară verifică dacă auditorii, atât cei interni, cât și cei externi, sau un grup de auditori, dețin competențele și cunoștințele corespunzătoare pentru a efectua în mod eficace auditurile și evaluările relevante.
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Articolul 28 (7)
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Entitățile financiare se asigură că acordurile contractuale privind utilizarea serviciilor TIC pot fi reziliate în oricare dintre următoarele circumstanțe:
(a)
încălcarea semnificativă de către furnizorul terț de servicii TIC a actelor cu putere de lege, a reglementărilor sau a clauzelor contractuale aplicabile;
(b)
circumstanțe identificate pe parcursul monitorizării riscurilor TIC generate de părți terțe care sunt considerate capabile să modifice îndeplinirea funcțiilor oferite prin acordul contractual, inclusiv modificările semnificative care afectează acordul sau situația furnizorului terț de servicii TIC;
(c)
deficiențe demonstrate ale furnizorului terț de servicii TIC legate de gestionarea sa generală a riscurilor TIC și, în special, legate de modul în care asigură disponibilitatea, autenticitatea, integritatea și confidențialitatea datelor, fie date cu caracter personal sau date sensibile din alt punct de vedere, ori a datelor fără caracter personal;
(d)
în cazul în care autoritatea competentă nu mai poate supraveghea în mod eficace entitatea financiară ca urmare a condițiilor acordului contractual respectiv sau a unor circumstanțe legate de acesta.
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Articolul 28 (8)
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Pentru serviciile TIC care sprijină funcții critice sau importante, entitățile financiare instituie strategii de ieșire. Strategiile de ieșire țin seama de riscurile care pot apărea la nivelul furnizorilor terți de servicii TIC, în special o posibilă deficiență din partea acestora, o deteriorare a calității serviciilor TIC oferite, orice perturbare a activității cauzată de furnizarea necorespunzătoare sau defectuoasă a serviciilor TIC sau orice riscuri semnificative care decurg din utilizarea adecvată și continuă a serviciului TIC respectiv ori încetarea acordurilor contractuale cu furnizorii terți de servicii TIC în oricare dintre situațiile enumerate la alineatul (7). Entitățile financiare se asigură că pot să se retragă din acordurile contractuale fără:
(a)
perturbarea activităților lor comerciale;
(b)
limitarea respectării cerințelor în materie de reglementare;
(c)
afectarea continuității și calității serviciilor furnizate către clienți.
Planurile de ieșire trebuie să fie cuprinzătoare, documentate și, în conformitate cu criteriile stabilite la articolul 4 alineatul (2), trebuie să fie testate în mod suficient și revizuite periodic. Entitățile financiare identifică soluții alternative și dezvoltă planuri de tranziție care să le permită să elimine serviciile TIC contractate și datele relevante de la furnizorul terț de servicii TIC și să le transfere în condiții de siguranță și în integralitatea lor către furnizori alternativi sau să le reintegreze în sistemul propriu. Entitățile financiare instituie măsuri adecvate pentru situații neprevăzute astfel încât să păstreze continuitatea activității în cazul apariției situațiilor menționate la primul paragraf.
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Articolul 28 (9)
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AES elaborează, prin intermediul Comitetului comun, proiecte de standarde tehnice de punere în aplicare pentru a stabili modelele standard pentru registrul de informații menționat la alineatul (3), inclusiv informații care sunt comune tuturor acordurilor contractuale privind utilizarea serviciilor TIC. AES transmit Comisiei aceste proiecte de standarde tehnice de punere în aplicare până la 17 ianuarie 2024. Se conferă Comisiei competența de a adopta standardele tehnice de punere în aplicare menționate la primul paragraf în conformitate cu articolul 15 din Regulamentele (UE) nr. 1093/2010, (UE) nr. 1094/2010 și (UE) nr. 1095/2010.
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Articolul 28 (10)
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AES elaborează, prin intermediul Comitetului comun, proiecte de standarde tehnice de reglementare pentru a aduce precizări suplimentare privind conținutul detaliat al politicii menționate la alineatul (2) în legătură cu acordurile contractuale privind utilizarea serviciilor TIC care sprijină funcții critice sau importante oferite de furnizori terți de servicii TIC. Atunci când elaborează proiectele respective de standarde tehnice de reglementare, AES iau în considerare dimensiunea și profilul general de risc al entității financiare, precum și natura, amploarea și complexitatea serviciilor, activităților și operațiunilor sale. AES transmit Comisiei aceste proiecte de standarde tehnice de reglementare până la 17 ianuarie 2024. Se deleagă Comisiei competența de a completa prezentul regulament prin adoptarea standardelor tehnice de reglementare menționate la primul paragraf, în conformitate cu articolele 10-14 din Regulamentele (UE) nr. 1093/2010, (UE) nr. 1094/2010 și (UE) nr. 1095/2010.
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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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Alternate Sources for Continued Support
Description
Mechanisms exist to provide in-house support or contract external providers for support with unsupported Technology Assets, Applications and/or Services (TAAS).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Product / project management
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
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
Technology Development & Acquisition (TDA) 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 TDA domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TDA 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 TDA domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Technology development and acquisition-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Technology development and acquisition management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Secure development practices mostly conform to industry-recognized standards for secure engineering of Technology Assets, Applications and/or Services (TAAS) (e.g., OWASP, NIST SP 800-218 and NIST SP 800-160). ▪ An application development team, or similar function, uses a structured process to design, build and maintain secure configurations for test, development, staging and production environments.
Level 3 Well Defined
Asset Management (AST) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with AST domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with AST domain capabilities are well-documented and kept current by process owners. ▪ An IT Asset Management (ITAM) team, or similar function, is appropriately staffed and supported to implement and maintain AST domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of ITAM operations (e.g., ITAM platform, (e.g., Configuration Management Database (CMBD) Asset Management solution). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with AST domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to provide in-house support or contract external providers for support with unsupported Technology Assets, Applications and/or Services (TAAS).
Level 4 Quantitatively Controlled
Technology Development & Acquisition (TDA) 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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Supply Chain Risk Management (SCRM) Plan
Description
Mechanisms exist to develop a plan for Supply Chain Risk Management (SCRM) associated with the development, acquisition, maintenance and disposal of Technology Assets, Applications and/or Services (TAAS), including documenting selected mitigating actions and monitoring performance against those plans.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Risk Management Program (RMP) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Supply Chain Risk Management (SCRM) Plan
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Risk Management Program (RMP) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Supply Chain Risk Management (SCRM) Plan
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Risk Management Program (RMP) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Supply Chain Risk Management (SCRM) Plan
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Risk Management Program (RMP) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Supply Chain Risk Management (SCRM) Plan
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Risk Management Program (RMP) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Supply Chain Risk Management (SCRM) 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
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 develop a plan for Supply Chain Risk Management (SCRM) associated with the development, acquisition, maintenance and disposal of Technology Assets, Applications and/or Services (TAAS), including documenting selected mitigating actions and monitoring performance against those plans.
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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Supply Chain Risk Assessment (SCRA)
Description
Mechanisms exist to periodically assess supply chain risks associated with Technology Assets, Applications and/or Services (TAAS).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Risk Management Program (RMP) ∙ Data Protection Impact Assessment (DPIA) ∙ Business Impact Analysis (BIA)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Risk Management Program (RMP) ∙ Data Protection Impact Assessment (DPIA) ∙ Business Impact Analysis (BIA)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Risk Management Program (RMP) ∙ Data Protection Impact Assessment (DPIA) ∙ Business Impact Analysis (BIA)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Risk Management Program (RMP) ∙ Data Protection Impact Assessment (DPIA) ∙ Business Impact Analysis (BIA)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Risk Management Program (RMP) ∙ Data Protection Impact Assessment (DPIA) ∙ Business Impact Analysis (BIA)
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
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 periodically assess supply chain risks associated with Technology Assets, Applications and/or Services (TAAS).
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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Supply Chain Risk Management (SCRM) Plan
Description
Mechanisms exist to develop a plan for Supply Chain Risk Management (SCRM) associated with the development, acquisition, maintenance and disposal of Technology Assets, Applications and/or Services (TAAS), including documenting selected mitigating actions and monitoring performance against those plans.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Risk Management Program (RMP) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Supply Chain Risk Management (SCRM) Plan
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Risk Management Program (RMP) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Supply Chain Risk Management (SCRM) Plan
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Risk Management Program (RMP) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Supply Chain Risk Management (SCRM) Plan
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Risk Management Program (RMP) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Supply Chain Risk Management (SCRM) Plan
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Risk Management Program (RMP) ∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Supply Chain Risk Management (SCRM) 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
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 develop a plan for Supply Chain Risk Management (SCRM) associated with the development, acquisition, maintenance and disposal of Technology Assets, Applications and/or Services (TAAS), including documenting selected mitigating actions and monitoring performance against those plans.
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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Supply Chain Risk Assessment (SCRA)
Description
Mechanisms exist to periodically assess supply chain risks associated with Technology Assets, Applications and/or Services (TAAS).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Risk Management Program (RMP) ∙ Data Protection Impact Assessment (DPIA) ∙ Business Impact Analysis (BIA)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Risk Management Program (RMP) ∙ Data Protection Impact Assessment (DPIA) ∙ Business Impact Analysis (BIA)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Risk Management Program (RMP) ∙ Data Protection Impact Assessment (DPIA) ∙ Business Impact Analysis (BIA)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Risk Management Program (RMP) ∙ Data Protection Impact Assessment (DPIA) ∙ Business Impact Analysis (BIA)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Risk Management Program (RMP) ∙ Data Protection Impact Assessment (DPIA) ∙ Business Impact Analysis (BIA)
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
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 periodically assess supply chain risks associated with Technology Assets, Applications and/or Services (TAAS).
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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Third-Party Inventories
Description
Mechanisms exist to maintain a current, accurate and complete list of External Service Providers (ESPs) that can potentially impact the Confidentiality, Integrity, Availability and/or Safety (CIAS) of the organization's Technology Assets, Applications, Services and/or Data (TAASD).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A procurement function maintains a list of all active External Service Providers (ESPs), including pertinent contract information that will assist in a risk assessment.
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM 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 maintain a current, accurate and complete list of External Service Providers (ESPs) that can potentially impact the Confidentiality, Integrity, Availability and/or Safety (CIAS) of the organization's TAASD.
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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Third-Party Risk Assessments & Approvals
Description
Mechanisms exist to conduct a risk assessment prior to the acquisition or outsourcing of technology-related Technology Assets, Applications and/or Services (TAAS).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to conduct a risk assessment prior to the acquisition or outsourcing of technology-related Technology Assets, Applications and/or Services (TAAS).
Level 4 Quantitatively Controlled
Third-Party Management (TPM) 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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Third-Party Contract Requirements
Description
Mechanisms exist to require contractual requirements for applicable security, compliance and resilience requirements with third-parties, reflecting the organization's needs to protect its Technology Assets, Applications, Services and/or Data (TAASD).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Procurement practices contractually require ESP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. ▪ A formal agreement exists between the organization and applicable third-parties that includes a Non-Disclosure Agreement (NDA) addressing shared sensitive data.
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM 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 contractual requirements for applicable security, compliance and resilience requirements with third-parties, reflecting the organization's needs to protect its TAASD.
Level 4 Quantitatively Controlled
Third-Party Management (TPM) 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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Review of Third-Party Services
Description
Mechanisms exist to monitor, regularly review and assess External Service Providers (ESPs) for compliance with established contractual requirements for security, compliance and resilience controls.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM 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 monitor, regularly review and assess External Service Providers (ESPs) for compliance with established contractual requirements for security, compliance and resilience controls.
Level 4 Quantitatively Controlled
Third-Party Management (TPM) 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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Break Clauses
Description
Mechanisms exist to include "break clauses" within contracts for failure to meet contract criteria for security, compliance and/or resilience controls.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Contracts with ESP contain break clauses to enable penalty-free, early termination of a contract for cause, based on ESP cybersecurity and/or data protection practices deficiency(ies).
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM 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 include "break clauses" within contracts for failure to meet contract criteria for security, compliance and/or resilience 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.
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SCF
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Third-Party Inventories
Description
Mechanisms exist to maintain a current, accurate and complete list of External Service Providers (ESPs) that can potentially impact the Confidentiality, Integrity, Availability and/or Safety (CIAS) of the organization's Technology Assets, Applications, Services and/or Data (TAASD).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A procurement function maintains a list of all active External Service Providers (ESPs), including pertinent contract information that will assist in a risk assessment.
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM 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 maintain a current, accurate and complete list of External Service Providers (ESPs) that can potentially impact the Confidentiality, Integrity, Availability and/or Safety (CIAS) of the organization's TAASD.
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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Third-Party Risk Assessments & Approvals
Description
Mechanisms exist to conduct a risk assessment prior to the acquisition or outsourcing of technology-related Technology Assets, Applications and/or Services (TAAS).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to conduct a risk assessment prior to the acquisition or outsourcing of technology-related Technology Assets, Applications and/or Services (TAAS).
Level 4 Quantitatively Controlled
Third-Party Management (TPM) 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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Third-Party Contract Requirements
Description
Mechanisms exist to require contractual requirements for applicable security, compliance and resilience requirements with third-parties, reflecting the organization's needs to protect its Technology Assets, Applications, Services and/or Data (TAASD).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Procurement practices contractually require ESP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. ▪ A formal agreement exists between the organization and applicable third-parties that includes a Non-Disclosure Agreement (NDA) addressing shared sensitive data.
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM 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 contractual requirements for applicable security, compliance and resilience requirements with third-parties, reflecting the organization's needs to protect its TAASD.
Level 4 Quantitatively Controlled
Third-Party Management (TPM) 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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Third-Party Inventories
Description
Mechanisms exist to maintain a current, accurate and complete list of External Service Providers (ESPs) that can potentially impact the Confidentiality, Integrity, Availability and/or Safety (CIAS) of the organization's Technology Assets, Applications, Services and/or Data (TAASD).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ A procurement function maintains a list of all active External Service Providers (ESPs), including pertinent contract information that will assist in a risk assessment.
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM 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 maintain a current, accurate and complete list of External Service Providers (ESPs) that can potentially impact the Confidentiality, Integrity, Availability and/or Safety (CIAS) of the organization's TAASD.
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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Third-Party Risk Assessments & Approvals
Description
Mechanisms exist to conduct a risk assessment prior to the acquisition or outsourcing of technology-related Technology Assets, Applications and/or Services (TAAS).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA)
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to conduct a risk assessment prior to the acquisition or outsourcing of technology-related Technology Assets, Applications and/or Services (TAAS).
Level 4 Quantitatively Controlled
Third-Party Management (TPM) 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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Third-Party Contract Requirements
Description
Mechanisms exist to require contractual requirements for applicable security, compliance and resilience requirements with third-parties, reflecting the organization's needs to protect its Technology Assets, Applications, Services and/or Data (TAASD).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Cybersecurity Supply Chain Risk Management (C-SCRM) program ∙ Data Protection Impact Assessment (DPIA) ∙ Third-party contract requirements for cybersecurity controls ∙ Non-Disclosure Agreements (NDAs)
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
Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Procurement practices contractually require ESP to follow secure engineering practices as part of a broader Cybersecurity Supply Chain Risk Management (C-SCRM) initiative. ▪ A formal agreement exists between the organization and applicable third-parties that includes a Non-Disclosure Agreement (NDA) addressing shared sensitive data.
Level 3 Well Defined
Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM 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 contractual requirements for applicable security, compliance and resilience requirements with third-parties, reflecting the organization's needs to protect its TAASD.
Level 4 Quantitatively Controlled
Third-Party Management (TPM) 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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