+Artikel 10 Data och dataförvaltning
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Artikel 10 Data och dataförvaltning
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1. Översikt
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Reglering |
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Artikel 10 1.
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AI-system med hög risk som använder teknik som inbegriper träning av AI-modeller med data ska utvecklas på grundval av tränings-, validerings- och testdataset som uppfyller de kvalitetskriterier som avses i punkterna 2, 3 och 4 i denna artikel och i artikel 4a.1 när sådana dataset används.
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Artikel 10 2.
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Tränings-, validerings- och testdataset ska omfattas av metoder för dataförvaltning och datahantering som är lämpliga för det avsedda ändamålet med AI-systemet med hög risk. Dessa metoder ska särskilt avse
a)
relevanta utformningsval,
b)
datainsamlingsprocesser och uppgifternas ursprung samt, när det gäller personuppgifter, datainsamlingens ursprungliga ändamål,
c)
relevanta åtgärder för datapreparering, såsom annotation, märkning, rensning, uppdatering, förädling och aggregering,
d)
formulering av antaganden, särskilt när det gäller den information som berörda data förväntas beskriva och representera,
e)
en bedömning av tillgängligheten, mängden och lämpligheten avseende de dataset som behövs,
f)
undersökning med avseende på eventuella biaser som sannolikt kommer att påverka människors hälsa och säkerhet, inverka negativt på grundläggande rättigheter eller leda till diskriminering som är förbjuden enligt unionsrätten, särskilt när utdata påverkar indata för framtida drift,
g)
lämpliga åtgärder för att upptäcka, förebygga och begränsa eventuella biaser som identifierats enligt led f,
h)
identifiering av relevanta dataluckor eller brister som hindrar efterlevnad av denna förordning, och hur dessa luckor och brister kan åtgärdas.
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Artikel 10 3.
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Tränings-, validerings- och testdataset ska vara relevanta, tillräckligt representativa, och så långt som möjligt fria från fel och fullständiga i förhållande till det avsedda ändamålet. De ska ha lämpliga statistiska egenskaper, inbegripet, i förekommande fall, vad gäller de personer eller grupper av personer med avseende på vilka AI-systemet med hög risk är avsett att användas. Egenskaperna hos dessa dataset kan uppfyllas på nivån för enskilda dataset eller på nivån av en kombination av dessa.
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Artikel 10 4.
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Dataseten ska, i den mån som krävs med hänsyn till det avsedda ändamålet, beakta de egenskaper eller element som är utmärkande för just den specifika geografiska, kontextuella, beteendemässiga eller funktionsmässiga situation där AI-systemet med hög risk är avsett att användas.
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Artikel 10 6.
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För utvecklingen av AI-system med hög risk som inte använder teknik som inbegriper träning av AI-modeller är punkterna 2, 3 och 4 i denna artikel och artikel 4a.1 endast tillämpliga på testdataseten.
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1.1 Referenser
1.2 Identifierade krav
1.3 Relaterade standarder
2. Identifierade krav
3. Relaterade standarder
Standarder
| Källa |
Krav |
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SCF
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AI TEVV Fairness & Bias Assessment
Description
Mechanisms exist to examine fairness and bias of Artificial Intelligence (AI) and Autonomous Technologies (AAT) to be deployed.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Artificial Intelligence and Autonomous Technology (AAT) 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 AAT 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 AAT domain capabilities are well-documented and kept current by process owners. ▪ An Artificial Intelligence Governance (AIG) team, or similar function, is appropriately staffed and supported to implement and maintain AAT domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of AI governance, risk management and compliance operations (e.g., dedicated AI governance platform). ▪ 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 AAT 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 examine fairness and bias of AAT to be deployed.
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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AI TEVV Fairness & Bias Assessment
Description
Mechanisms exist to examine fairness and bias of Artificial Intelligence (AI) and Autonomous Technologies (AAT) to be deployed.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Artificial Intelligence and Autonomous Technology (AAT) 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 AAT 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 AAT domain capabilities are well-documented and kept current by process owners. ▪ An Artificial Intelligence Governance (AIG) team, or similar function, is appropriately staffed and supported to implement and maintain AAT domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of AI governance, risk management and compliance operations (e.g., dedicated AI governance platform). ▪ 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 AAT 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 examine fairness and bias of AAT to be deployed.
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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AI TEVV Fairness & Bias Assessment
Description
Mechanisms exist to examine fairness and bias of Artificial Intelligence (AI) and Autonomous Technologies (AAT) to be deployed.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Artificial Intelligence and Autonomous Technology (AAT) 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 AAT 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 AAT domain capabilities are well-documented and kept current by process owners. ▪ An Artificial Intelligence Governance (AIG) team, or similar function, is appropriately staffed and supported to implement and maintain AAT domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of AI governance, risk management and compliance operations (e.g., dedicated AI governance platform). ▪ 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 AAT 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 examine fairness and bias of AAT to be deployed.
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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AI TEVV Fairness & Bias Assessment
Description
Mechanisms exist to examine fairness and bias of Artificial Intelligence (AI) and Autonomous Technologies (AAT) to be deployed.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Artificial Intelligence and Autonomous Technology (AAT) 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 AAT 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 AAT domain capabilities are well-documented and kept current by process owners. ▪ An Artificial Intelligence Governance (AIG) team, or similar function, is appropriately staffed and supported to implement and maintain AAT domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of AI governance, risk management and compliance operations (e.g., dedicated AI governance platform). ▪ 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 AAT 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 examine fairness and bias of AAT to be deployed.
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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AI TEVV Fairness & Bias Assessment
Description
Mechanisms exist to examine fairness and bias of Artificial Intelligence (AI) and Autonomous Technologies (AAT) to be deployed.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Artificial Intelligence and Autonomous Technology (AAT) 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 AAT 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 AAT domain capabilities are well-documented and kept current by process owners. ▪ An Artificial Intelligence Governance (AIG) team, or similar function, is appropriately staffed and supported to implement and maintain AAT domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of AI governance, risk management and compliance operations (e.g., dedicated AI governance platform). ▪ 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 AAT 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 examine fairness and bias of AAT to be deployed.
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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AI TEVV Comparable Deployment Settings
Description
Mechanisms exist to evaluate Artificial Intelligence (AI) and Autonomous Technologies (AAT)-related performance against the assurance criteria demonstrated for conditions prior to deployment.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Information Assurance (IA) Program ∙ Artificial Intelligence (AI) / autonomous technologies governance 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Artificial Intelligence and Autonomous Technology (AAT) 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 AAT 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 AAT domain capabilities are well-documented and kept current by process owners. ▪ An Artificial Intelligence Governance (AIG) team, or similar function, is appropriately staffed and supported to implement and maintain AAT domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of AI governance, risk management and compliance operations (e.g., dedicated AI governance platform). ▪ 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 AAT 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 evaluate AAT-related performance or the assurance criteria demonstrated for conditions similar to deployment settings.
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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Non-Conformity Oversight
Description
Mechanisms exist to identify and document instances of non-conformity with statutory, regulatory and/or contractual obligations, in order to develop appropriate risk mitigation actions.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
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
Compliance (CPL) 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 CPL domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with CPL 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 CPL domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Compliance management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Compliance management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ External compliance requirements for cybersecurity and data privacy are identified and documented, based on applicable laws, regulations and contractual obligations. ▪ IT and/or cybersecurity perform an informal annual review of existing compliance requirements and research evolving or new requirements.
Level 3 Well Defined
Compliance (CPL) 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 CPL 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 CPL domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain CPL domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform). ▪ 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 CPL 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 document and review instances of non-compliance with statutory, regulatory and/or contractual obligations to develop appropriate risk mitigation actions.
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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Limit Sensitive / Regulated Data In Testing, Training & Research
Description
Mechanisms exist to minimize the use of sensitive and/or regulated data for research, testing, or training, in accordance with authorized, legitimate business practices.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Limited media handling guidance exists for users. ▪ Requirements exist for limiting the use of sensitive/regulated data in testing, training and research. ▪ Requirements exist for minimizing data collection to what is necessary for business purposes.
Level 2 Planned Tracked
Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data classification and handling 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 formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ Business stakeholders and process owners adhere to applicable compliance requirements to limit the use of sensitive/regulated data in testing, training and research.
Level 3 Well Defined
Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ 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 DCH 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 minimize the use of sensitive/regulated data for research, testing, or training, in accordance with authorized, legitimate business practices.
Level 4 Quantitatively Controlled
Data Classification & Handling (DCH) 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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Limit Sensitive / Regulated Data In Testing, Training & Research
Description
Mechanisms exist to minimize the use of sensitive and/or regulated data for research, testing, or training, in accordance with authorized, legitimate business practices.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Limited media handling guidance exists for users. ▪ Requirements exist for limiting the use of sensitive/regulated data in testing, training and research. ▪ Requirements exist for minimizing data collection to what is necessary for business purposes.
Level 2 Planned Tracked
Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data classification and handling 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 formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ Business stakeholders and process owners adhere to applicable compliance requirements to limit the use of sensitive/regulated data in testing, training and research.
Level 3 Well Defined
Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ 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 DCH 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 minimize the use of sensitive/regulated data for research, testing, or training, in accordance with authorized, legitimate business practices.
Level 4 Quantitatively Controlled
Data Classification & Handling (DCH) 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
|
Limit Sensitive / Regulated Data In Testing, Training & Research
Description
Mechanisms exist to minimize the use of sensitive and/or regulated data for research, testing, or training, in accordance with authorized, legitimate business practices.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Limited media handling guidance exists for users. ▪ Requirements exist for limiting the use of sensitive/regulated data in testing, training and research. ▪ Requirements exist for minimizing data collection to what is necessary for business purposes.
Level 2 Planned Tracked
Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data classification and handling 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 formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ Business stakeholders and process owners adhere to applicable compliance requirements to limit the use of sensitive/regulated data in testing, training and research.
Level 3 Well Defined
Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ 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 DCH 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 minimize the use of sensitive/regulated data for research, testing, or training, in accordance with authorized, legitimate business practices.
Level 4 Quantitatively Controlled
Data Classification & Handling (DCH) 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
|
Limit Sensitive / Regulated Data In Testing, Training & Research
Description
Mechanisms exist to minimize the use of sensitive and/or regulated data for research, testing, or training, in accordance with authorized, legitimate business practices.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Limited media handling guidance exists for users. ▪ Requirements exist for limiting the use of sensitive/regulated data in testing, training and research. ▪ Requirements exist for minimizing data collection to what is necessary for business purposes.
Level 2 Planned Tracked
Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data classification and handling 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 formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ Business stakeholders and process owners adhere to applicable compliance requirements to limit the use of sensitive/regulated data in testing, training and research.
Level 3 Well Defined
Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ 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 DCH 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 minimize the use of sensitive/regulated data for research, testing, or training, in accordance with authorized, legitimate business practices.
Level 4 Quantitatively Controlled
Data Classification & Handling (DCH) 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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Limit Sensitive / Regulated Data In Testing, Training & Research
Description
Mechanisms exist to minimize the use of sensitive and/or regulated data for research, testing, or training, in accordance with authorized, legitimate business practices.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
Data Classification & Handling (DCH) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with DCH domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Limited media handling guidance exists for users. ▪ Requirements exist for limiting the use of sensitive/regulated data in testing, training and research. ▪ Requirements exist for minimizing data collection to what is necessary for business purposes.
Level 2 Planned Tracked
Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data classification and handling 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 formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations. ▪ Business stakeholders and process owners adhere to applicable compliance requirements to limit the use of sensitive/regulated data in testing, training and research.
Level 3 Well Defined
Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ 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 DCH 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 minimize the use of sensitive/regulated data for research, testing, or training, in accordance with authorized, legitimate business practices.
Level 4 Quantitatively Controlled
Data Classification & Handling (DCH) 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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Data Quality Operations
Description
Mechanisms exist to check for Redundant, Obsolete/Outdated, Toxic or Trivial (ROTT) data to ensure the accuracy, relevance, timeliness, impact, completeness and de-identification of information throughout the information lifecycle.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Product / project management ∙ Data governance program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Product / project management ∙ Data governance 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ 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 DCH 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 check for Redundant, Obsolete/Outdated, Toxic or Trivial (ROTT) data to ensure the accuracy, relevance, timeliness, impact, completeness and de-identification of information throughout the information lifecycle.
Level 4 Quantitatively Controlled
Data Classification & Handling (DCH) 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
Data Classification & Handling (DCH) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes. ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
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SCF
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De-Identification (Anonymization)
Description
Mechanisms exist to de-identify sensitive and/or regulated data through (1) Anonymization; (2) De-identification; (3) Pseudonymization; and/or (4) Redaction.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy 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
Data Classification & Handling (DCH) 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 DCH domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH 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 DCH domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data classification and handling-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data classification and handling 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 formalized data classification scheme exists to identify categories of data, based on protection requirements from applicable laws, regulations and/or contractual obligations.
Level 3 Well Defined
Data Classification & Handling (DCH) 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 DCH 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 DCH domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain DCH domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data classification and handling operations (e.g., GRC platform). ▪ 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 DCH 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 mask sensitive and/or regulated data through data anonymization, pseudonymization, redaction and/or de-identification.
Level 4 Quantitatively Controlled
Data Classification & Handling (DCH) 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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Data Privacy Program
Description
Mechanisms exist to facilitate the implementation and operation of data protection controls throughout the data lifecycle to ensure all forms of Personal Data (PD) are processed lawfully, fairly and transparently.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data privacy program
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data privacy program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data privacy program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data privacy program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data privacy 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
Privacy (PRI) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with PRI domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Data privacy-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ No formal data privacy team exists. Privacy roles are assigned to existing IT / cybersecurity. ▪ Data/process owners are expected to take the initiative to work with Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. ▪ No formal data privacy principles are identified for the organization. ▪ Data/process owners perform their own Data Protection Impact Assessment (DPIA).
Level 2 Planned Tracked
Privacy (PRI) 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 PRI domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with PRI 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 PRI domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data privacy management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data privacy 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 qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization's data privacy program. This individual may be assigned to multiple data privacy-related roles. ▪ The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and/or contractual data privacy obligations for Personal Data (PD) are properly identified and implemented.
Level 3 Well Defined
Privacy (PRI) 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 PRI 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 PRI domain capabilities are well-documented and kept current by process owners. ▪ A data privacy team, or similar function, is appropriately staffed and supported to implement and maintain PRI domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data privacy operations (e.g., privacy notice management software and customer 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 PRI domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to facilitate the implementation and operation of data protection controls throughout the data lifecycle to ensure all forms of Personal Data (PD) are processed lawfully, fairly and transparently.
Level 4 Quantitatively Controlled
Privacy (PRI) 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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Documenting Data Processing Activities
Description
Mechanisms exist to document Personal Data (PD) processing activities that covers collection, receiving, processing, storage, transmission, sharing, updating and/or disposal actions with sufficient detail to demonstrate conformity with applicable statutory, regulatory and contractual requirements.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
Privacy (PRI) 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 PRI domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with PRI 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 PRI domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data privacy management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data privacy management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and/or contractual data privacy obligations for Personal Data (PD) are properly identified and implemented.
Level 3 Well Defined
Privacy (PRI) 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 PRI 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 PRI domain capabilities are well-documented and kept current by process owners. ▪ A data privacy team, or similar function, is appropriately staffed and supported to implement and maintain PRI domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data privacy operations (e.g., privacy notice management software and customer 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 PRI 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 document Personal Data (PD) processing activities that covers collection, receiving, processing, storage, transmission, sharing, updating and/or disposal actions with sufficient detail to demonstrate conformity with applicable statutory, regulatory and contractual requirements.
Level 4 Quantitatively Controlled
Privacy (PRI) 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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Personal Data (PD) Categories
Description
Mechanisms exist to define and implement data handling and protection requirements for specific categories of sensitive Personal Data (PD).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
Privacy (PRI) 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 PRI domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with PRI 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 PRI domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data privacy management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data privacy management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and/or contractual data privacy obligations for Personal Data (PD) are properly identified and implemented.
Level 3 Well Defined
Privacy (PRI) 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 PRI 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 PRI domain capabilities are well-documented and kept current by process owners. ▪ A data privacy team, or similar function, is appropriately staffed and supported to implement and maintain PRI domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data privacy operations (e.g., privacy notice management software and customer 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 PRI domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to define and implement data handling and protection requirements for specific categories of sensitive Personal Data (PD).
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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Security of Personal Data (PD)
Description
Mechanisms exist to ensure Personal Data (PD) is protected by logical and physical security safeguards that are sufficient and appropriately scoped to protect the confidentiality and integrity of the PD.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Privacy (PRI) 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 PRI 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 PRI domain capabilities are well-documented and kept current by process owners. ▪ A data privacy team, or similar function, is appropriately staffed and supported to implement and maintain PRI domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data privacy operations (e.g., privacy notice management software and customer 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 PRI domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to ensure Personal Data (PD) is protected by logical and physical security safeguards that are sufficient and appropriately scoped to protect the confidentiality and integrity of the PD.
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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Security of Personal Data (PD)
Description
Mechanisms exist to ensure Personal Data (PD) is protected by logical and physical security safeguards that are sufficient and appropriately scoped to protect the confidentiality and integrity of the PD.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Privacy (PRI) 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 PRI 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 PRI domain capabilities are well-documented and kept current by process owners. ▪ A data privacy team, or similar function, is appropriately staffed and supported to implement and maintain PRI domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data privacy operations (e.g., privacy notice management software and customer 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 PRI domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to ensure Personal Data (PD) is protected by logical and physical security safeguards that are sufficient and appropriately scoped to protect the confidentiality and integrity of the PD.
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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Usage Restrictions of Personal Data (PD)
Description
Mechanisms exist to restrict collecting, receiving, processing, storing, transmitting, sharing and/or updating Personal Data (PD) to: (1) The purpose(s) originally collected, consistent with the data privacy notice(s); (2) What is authorized by the data subject, or authorized agent; and (3) What is consistent with applicable laws, regulations and contractual obligations.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Privacy (PRI) 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 PRI 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 PRI domain capabilities are well-documented and kept current by process owners. ▪ A data privacy team, or similar function, is appropriately staffed and supported to implement and maintain PRI domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data privacy operations (e.g., privacy notice management software and customer 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 PRI 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 restrict collecting, receiving, processing, storing, transmitting, sharing and/or updating Personal Data (PD) to: (1) The purpose(s) originally collected, consistent with the data privacy notice(s); (2) What is authorized by the data subject, or authorized agent; and (3) What is consistent with applicable laws, regulations and contractual obligations.
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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Usage Restrictions of Personal Data (PD)
Description
Mechanisms exist to restrict collecting, receiving, processing, storing, transmitting, sharing and/or updating Personal Data (PD) to: (1) The purpose(s) originally collected, consistent with the data privacy notice(s); (2) What is authorized by the data subject, or authorized agent; and (3) What is consistent with applicable laws, regulations and contractual obligations.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
Privacy (PRI) 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 PRI 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 PRI domain capabilities are well-documented and kept current by process owners. ▪ A data privacy team, or similar function, is appropriately staffed and supported to implement and maintain PRI domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data privacy operations (e.g., privacy notice management software and customer 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 PRI 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 restrict collecting, receiving, processing, storing, transmitting, sharing and/or updating Personal Data (PD) to: (1) The purpose(s) originally collected, consistent with the data privacy notice(s); (2) What is authorized by the data subject, or authorized agent; and (3) What is consistent with applicable laws, regulations and contractual obligations.
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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Personal Data (PD) Retention & Disposal
Description
Mechanisms exist to: (1) Retain Personal Data (PD), including metadata, for an organization-defined time period to fulfill the purpose(s) identified in the notice or as required by law; (2) Dispose of, destroys, erases, and/or anonymizes the PD, regardless of the method of storage; and (3) Use organization-defined techniques or methods to ensure secure deletion or destruction of PD (including originals, copies and archived records).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ 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
Privacy (PRI) 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 PRI domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with PRI 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 PRI domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Data privacy management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Data privacy management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and/or contractual data privacy obligations for Personal Data (PD) are properly identified and implemented.
Level 3 Well Defined
Privacy (PRI) 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 PRI 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 PRI domain capabilities are well-documented and kept current by process owners. ▪ A data privacy team, or similar function, is appropriately staffed and supported to implement and maintain PRI domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of data privacy operations (e.g., privacy notice management software and customer 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 PRI 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: (1) Retain Personal Data (PD), including metadata, for an organization-defined time period to fulfill the purpose(s) identified in the notice or as required by law; (2) Dispose of, destroys, erases, and/or anonymizes the PD, regardless of the method of storage; and (3) Use organization-defined techniques or methods to ensure secure deletion or destruction of PD (including originals, copies and archived records).
Level 4 Quantitatively Controlled
Privacy (PRI) 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
Privacy (PRI) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes. ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
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SCF
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Product Conformity Governance
Description
Mechanisms exist to ensure developed Technology Assets, Applications and/or Services (TAAS) conform to applicable statutory and regulatory requirements, based on the product's and/or service's: (1) Use case(s); and (2) Geographic markets.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Identify laws/regulations applicable to any developed products (e.g., privacy, accessibility)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Regulatory requirements checklist for product development ∙ Legal review before release
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Product compliance requirements defined at project start ∙ Compliance validation before release ∙ Regulatory conformity records
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Product conformity governance program (statutory, regulatory, certification requirements) ∙ Compliance gates in release management ∙ Conformity documentation (e.g., declarations of conformity)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise product compliance program covering statutory/regulatory conformity (e.g., EU CRA, FDA, UL 2900) ∙ Regulatory affairs and product security integration ∙ Conformity assessment and certification 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
Technology Development & Acquisition (TDA) 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 TDA 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 TDA domain capabilities are well-documented and kept current by process owners. ▪ A software development team, or similar function, is appropriately staffed and supported to implement and maintain TDA domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of technology development and acquisition management (e.g., project management software, software escrow solution and software testing tools). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with TDA domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to ensure developed Technology Assets, Applications and/or Services (TAAS) conform to applicable statutory and regulatory requirements, based on the product's and/or service's: (1) Use case(s); and (2) Geographic markets.
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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