+Steering Committee & Program Oversight
---+Status Reporting To Governing Body

Steering Committee & Program Oversight

Description

Mechanisms exist to align security, compliance and resilience capabilities with business requirements through a steering committee or advisory board, comprised of key cybersecurity, data protection and business executives, which meets formally and on a regular basis.

Possible Solutions & Considerations

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

∙ Third-party advisors (subject matter experts)
∙ Virtual CISO (vCISO) service
∙ Fractional security advisor

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

∙ Third-party advisors (subject matter experts)
∙ Virtual CISO (vCISO) service
∙ Informal security advisory committee

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

∙ Steering committee / advisory board
∙ Quarterly security committee meetings with documented minutes
∙ Cross-functional representation (IT, Legal, HR, Operations)

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

∙ Formal steering committee / advisory board
∙ Documented charter with defined roles and meeting cadence
∙ Board-level cybersecurity reporting

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

∙ Formal steering committee / advisory board
∙ Board-level Cybersecurity Committee or subcommittee
∙ Chief Information Security Officer (CISO) with board-level access
∙ Independent security advisor / external audit committee

SCR-CMM

Level 0 Not Performed

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

Level 1 Performed Informally

SCR-CMM Level 1 criteria definitions are not available for this control:
▪ A reasonable person would conclude this control requires a structured process.
▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

Level 2 Planned Tracked

Cybersecurity & Data Protection Governance (GOV) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ Organizational leadership maintains an informal process to review and respond to trends.

Level 3 Well Defined

Cybersecurity & Data Protection Governance (GOV) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain GOV domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to align security, compliance and resilience capabilities with business requirements through a steering committee or advisory board, comprised of key cybersecurity, data protection and business executives, which meets formally and on a regular basis.

Level 4 Quantitatively Controlled

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

Level 5 Continuously Improving

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

1. Pregled

Status Reporting To Governing Body

Description

Mechanisms exist to provide governance oversight reporting and recommendations enabling executives to make decisions about matters considered material to the organization's Security, Compliance & Resilience Program (SCRP).

Possible Solutions & Considerations

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

∙ Quarterly Business Review (QBR)
∙ Simple security status dashboard (spreadsheet or slide deck)
∙ Email status updates to owner/manager

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

∙ Quarterly Business Review (QBR)
∙ Structured security metrics report (incidents, patching status, training completion)
∙ Documented reporting cadence

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

∙ Quarterly Business Review (QBR)
∙ Formal security status reports to leadership
∙ KPI/KRI dashboard (e.g., Power BI, Tableau, or GRC tool reporting)

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

∙ Quarterly Business Review (QBR)
∙ Executive security dashboard with KPIs/KRIs
∙ Board-level reporting on material risk indicators
∙ Automated reporting via GRC platform

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

∙ Quarterly Business Review (QBR)
∙ Board and audit committee cybersecurity briefings
∙ Integrated GRC dashboard with real-time metrics
∙ SEC cybersecurity disclosure-ready reporting processes (if applicable)

SCR-CMM

Level 0 Not Performed

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

Level 1 Performed Informally

SCR-CMM Level 1 criteria definitions are not available for this control:
▪ A reasonable person would conclude this control requires a structured process.
▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

Level 2 Planned Tracked

Cybersecurity & Data Protection Governance (GOV) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ Organizational leadership maintains an informal process to review and respond to trends.

Level 3 Well Defined

Cybersecurity & Data Protection Governance (GOV) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain GOV domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to provide governance oversight reporting and recommendations to those entrusted to make executive decisions about matters considered material to the organization's Security, Compliance & Resilience Program (SCRP).

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.

1.1 Sklici

1.2 Ugotovljene zahteve

1.3 Povezani predpisi

2. Ugotovljene zahteve

Zahteve

3. Povezani predpisi

Predpisi
EULAW Člen 28 Upravljanje in organizacija
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EULAW Člen 28 Upravljanje in organizacija
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EULAW Člen 39 Komponente načrta neprekinjenega poslovanja na področju IKT
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EULAW Člen 5 Upravljanje in organizacija
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EULAW Člen 21 Ukrepi za obvladovanje tveganj za kibernetsko varnost
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EULAW Article 5 2

2.   The management body of the financial entity shall define, approve, oversee and be responsible for the implementation of all arrangements related to the ICT risk management framework referred to in Article 6(1).

For the purposes of the first subparagraph, the management body shall:

(a)

bear the ultimate responsibility for managing the financial entity’s ICT risk;

(b)

put in place policies that aim to ensure the maintenance of high standards of availability, authenticity, integrity and confidentiality, of data;

(c)

set clear roles and responsibilities for all ICT-related functions and establish appropriate governance arrangements to ensure effective and timely communication, cooperation and coordination among those functions;

(d)

bear the overall responsibility for setting and approving the digital operational resilience strategy as referred to in Article 6(8), including the determination of the appropriate risk tolerance level of ICT risk of the financial entity, as referred to in Article 6(8), point (b);

(e)

approve, oversee and periodically review the implementation of the financial entity’s ICT business continuity policy and ICT response and recovery plans, referred to, respectively, in Article 11(1) and (3), which may be adopted as a dedicated specific policy forming an integral part of the financial entity’s overall business continuity policy and response and recovery plan;

(f)

approve and periodically review the financial entity’s ICT internal audit plans, ICT audits and material modifications to them;

(g)

allocate and periodically review the appropriate budget to fulfil the financial entity’s digital operational resilience needs in respect of all types of resources, including relevant ICT security awareness programmes and digital operational resilience training referred to in Article 13(6), and ICT skills for all staff;

(h)

approve and periodically review the financial entity’s policy on arrangements regarding the use of ICT services provided by ICT third-party service providers;

(i)

put in place, at corporate level, reporting channels enabling it to be duly informed of the following:

(i)

arrangements concluded with ICT third-party service providers on the use of ICT services,

(ii)

any relevant planned material changes regarding the ICT third-party service providers,

(iii)

the potential impact of such changes on the critical or important functions subject to those arrangements, including a risk analysis summary to assess the impact of those changes, and at least major ICT-related incidents and their impact, as well as response, recovery and corrective measures.

Povezane zadeve

Povezave
is related to Annual
is related to relative Control Weighting = 05
is related to Process
is related to Govern
is related to SCRM Focus Tier 1 STRATEGIC
is related to SCRM Focus Tier 2 OPERATIONAL
blocks Loss of Accountability / Attribution
blocks Excessive or Unauthorized Privilege
blocks Unauthorized Privilege Elevation
blocks Unauthorized Access
blocks Loss, Theft or Damage of Assets
blocks Unauthorized Modification / Loss of System Integrity
blocks Business / Service Interruption
blocks Data Loss / Integrity Compromise
blocks Reduced Operational Productivity
blocks System / Data Compromise (Technical Vector)
blocks System / Data Compromise (Non-Technical Vector)
blocks Revenue Loss
blocks Contractual Default / Termination
blocks Loss of Competitive Advantage
blocks Reputational Harm / Loss of Stakeholder Trust
blocks Regulatory / Legal / Contractual Financial Liability
blocks Exposure from Unaddressed Vulnerabilities
blocks System / Service Compromise
blocks Failure to Support Business / Mission Objectives
blocks Unaddressed Security / Compliance Exposure
blocks Unperformed / Unowned Control Responsibilities
blocks Uncontrolled Internal Security / Privacy Exposure
blocks Uncontrolled Third-Party Security / Privacy Exposure
blocks Lack of oversight of internal controls
blocks Lack of oversight of third-party controls
blocks Harm from Illegal, Abusive or Unsafe Content / Conduct
blocks Loss of Investigative / Evidentiary Capability
blocks Delayed Containment / Increased Incident Impact
blocks Incident Persistence / Recurrence
blocks Incident Response / Recovery Cost
blocks Undetected / Delayed Detection of Adverse Activity
blocks Third-Party Cybersecurity Compromise / Exposure
blocks Third-Party Physical Security Disruption / Exposure
blocks Sub-Tier / Fourth-Party Supply Chain Exposure
blocks Third-Party Legal / Compliance Exposure
blocks Harm from Unauthorized / Unintended Product or Service Use
blocks Third-Party Dependency Failure
is related to relative Control Weighting = 07
blocks Failure to Achieve Strategic / Mission Objectives
blocks Loss of Authorization / Certification / License
blocks Inability to Demonstrate Due Diligence / Due Care
blocks Unreliable Assurance / Decision Information
blocks Drought & Water Shortage
blocks Earthquakes
blocks Fire & Wildfires
blocks Floods
blocks Hurricanes & Tropical Storms
blocks Landslides & Debris Flow
blocks Pandemic (Disease) Outbreaks
blocks Severe Weather
blocks Space Weather
blocks Thunderstorms & Lightning
blocks Tornadoes
blocks Tsunamis
blocks Volcanoes
blocks Winter Storms & Extreme Cold
blocks Dysfunctional Management Practices
blocks Human Error
blocks Statutory / Regulatory / Contractual Change
blocks Data Quality Degradation / Data Poisoning
blocks Fraud, Corruption and/or Intentional Criminal Conduct
blocks Conflict of Interest (COI) / Undue Influence / Insider Misconduct
blocks Economic Shock / Market Disruption
blocks Foreign Ownership, Control, or Influence (FOCI)
blocks Workforce Shortage / Loss of Critical Skills / Labor Disruption
is blocked by GOV-09 Steering Committee & Program Oversight – Assessment Procedure
blocks 03.12.03 Continuous Monitoring
blocks GV.RM-01 Risk management objectives are established and agreed to by organizational stakeholders
blocks GV.RM-03 Cybersecurity risk management activities and outcomes are included in enterprise risk management processes
blocks GV.RR-01 Organizational leadership is responsible and accountable for cybersecurity risk and fosters a culture that is risk-aware, ethical, and continually …
blocks GV.OV Oversight
blocks GV.OV-01 Cybersecurity risk management strategy outcomes are reviewed to inform and adjust strategy and direction
blocks GV.OV-02 The cybersecurity risk management strategy is reviewed and adjusted to ensure coverage of organizational requirements and risks
blocks GV.OV-03 Organizational cybersecurity risk management performance is evaluated and reviewed for adjustments needed
blocks GV.SC Cybersecurity Supply Chain Risk Management
blocks GV.SC-01 A cybersecurity supply chain risk management program, strategy, objectives, policies, and processes are established and agreed to by organizational …
blocks GV.SC-03 Cybersecurity supply chain risk management is integrated into cybersecurity and enterprise risk management, risk assessment, and improvement processes
blocks GV.SC-09 Supply chain security practices are integrated into cybersecurity and enterprise risk management programs, and their performance is monitored …
blocks ID IDENTIFY
blocks ID.RA Risk Assessment
blocks PR PROTECT
blocks PR.IR Technology Infrastructure Resilience
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