Data Privacy

Security, Compliance & Resilience (SCR) Principles

Align data privacy practices with industry-recognized data privacy principles to implement appropriate administrative, technical and physical controls to protect regulated personal data throughout the lifecycle of systems, applications and services.

Principle Intent

Organizations align data privacy engineering decisions with the organization's overall data privacy strategy and industry-recognized leading practices to secure Personal Data (PD) that implements the concept of data privacy by design and by default.

1. Übersicht

Bezeichnung	Standard
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, 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, customer management solution, etc.). ▪ 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.
Data Privacy Notice	Description Mechanisms exist to: (1) Make data privacy notice(s) available to individuals upon first interacting with an organization and subsequently as necessary; (2) Ensure that data privacy notices are clear and easy-to-understand, expressing relevant information about how Personal Data (PD) is collected, received, processed, stored, transmitted, shared, updated and/or disposed; (3) Contain all necessary notice-related criteria required by applicable statutory, regulatory and contractual obligations; (4) Define the scope of PD processing activities, including the geographic locations and third-party recipients that process the PD within the scope of the data privacy notice; (5) Periodically, review and update the content of the privacy notice, as necessary; and (6) Retain prior versions of the privacy notice, in accordance with data retention 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. 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. 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, 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. ▪ The CPO, or similar role, develops and ensures data privacy notices are published that include relevant purpose, notice and data privacy program information. 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, customer management solution, etc.). ▪ 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) Make data privacy notice(s) available to individuals upon first interacting with an organization and subsequently as necessary; (2) Ensure that data privacy notices are clear and easy-to-understand, expressing relevant information about how Personal Data (PD) is collected, received, processed, stored, transmitted, shared, updated and/or disposed; (3) Contain all necessary notice-related criteria required by applicable statutory, regulatory and contractual obligations; (4) Define the scope of PD processing activities, including the geographic locations and third-party recipients that process the PD within the scope of the data privacy notice; (5) Periodically, review and update the content of the privacy notice, as necessary; and (6) Retain prior versions of the privacy notice, in accordance with data retention 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 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.
Choice & Consent	Description Mechanisms exist to enable data subjects to authorize the collection, receiving, processing, storage, transmission, sharing, updating and/or disposal of their Personal Data (PD), where prior to collection the data subject is provided with: (1) Plain language to illustrate the potential data privacy risks of the authorization; (2) A means for users to decline the authorization; and (3) All necessary choice and consent-related criteria required by applicable statutory, regulatory 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. 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. 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, 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, customer management solution, etc.). ▪ 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 enable data subjects to authorize the collection, receiving, processing, storage, transmission, sharing, updating and/or disposal of their Personal Data (PD), where prior to collection the data subject is provided with: (1) Plain language to illustrate the potential data privacy risks of the authorization; (2) A means for users to decline the authorization; and (3) All necessary choice and consent-related criteria required by applicable statutory, regulatory and contractual obligations. 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.
Restrict Collection To Identified Purpose	Description Mechanisms exist to minimize the collection of Personal Data (PD) to only what is adequate, relevant and limited to the purposes identified in the data privacy notice, including protections against collecting PD from minors without appropriate parental or legal guardian consent. 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. 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. 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, customer management solution, etc.). ▪ 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 minimize the collection of Personal Data (PD) to only what is adequate, relevant and limited to the purposes identified in the data privacy notice, including protections against collecting PD from minors without appropriate parental or legal guardian consent. 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.
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. 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. 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, 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, customer management solution, etc.). ▪ 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.
Data Subject Empowerment	Description Mechanisms exist to provide authenticated data subjects the ability to: (1) Access their Personal Data (PD) that is being processed, stored and shared, except where the burden, risk or expense of providing access would be disproportionate to the benefit offered to the data subject through granting access; (2) Obtain answers on the specifics of how their PD is collected, received, processed, stored, transmitted, shared, updated and/or disposed; (3) Obtain the source(s) of their PD; (4) Obtain the categories of their PD being collected, received, processed, stored and shared; (5) Request correction to their PD due to inaccuracies; (6) Request erasure of their PD; and (7) Restrict the further collecting, receiving, processing, storing, transmitting, updated and/or sharing of their 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. 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. 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, 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, customer management solution, etc.). ▪ 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 provide authenticated data subjects the ability to: (1) Access their Personal Data (PD) that is being processed, stored and shared, except where the burden, risk or expense of providing access would be disproportionate to the benefit offered to the data subject through granting access; (2) Obtain answers on the specifics of how their PD is collected, received, processed, stored, transmitted, shared, updated and/or disposed; (3) Obtain the source(s) of their PD; (4) Obtain the categories of their PD being collected, received, processed, stored and shared; (5) Request correction to their PD due to inaccuracies; (6) Request erasure of their PD; and (7) Restrict the further collecting, receiving, processing, storing, transmitting, updated and/or sharing of their PD. 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.
Information Sharing With Third Parties	Description Mechanisms exist to disclose Personal Data (PD) to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the data subject. 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. 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. 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, customer management solution, etc.). ▪ 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 disclose Personal Data (PD) to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the data subject. 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.
Personal Data (PD) Control Testing, Training & Monitoring	Description Mechanisms exist to conduct testing, training and monitoring activities for Personal Data (PD) controls. 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. 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. 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, customer management solution, etc.). ▪ 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 conduct testing, training and monitoring activities for Personal Data (PD) controls. 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.
Personal Data (PD) Lineage	Description Mechanisms exist to maintain a process to document the lineage of Personal Data (PD) by recording how the organization collects, receives, processes, stores, transmits, shares, updates and/or disposes 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. 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. 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, customer management solution, etc.). ▪ 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 maintain a process to document the lineage of Personal Data (PD) by recording how the organization collects, receives, processes, stores, transmits, shares, updates and/or disposes PD. 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.
Data Quality Management	Description Mechanisms exist to manage the quality, utility, objectivity, integrity and impact determination and de-identification of sensitive/regulated data across the information lifecycle. 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. 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. 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, customer management solution, etc.). ▪ 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 manage the quality, utility, objectivity, integrity and impact determination and de-identification of sensitive/regulated data across the information lifecycle. 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.
Data Tagging	Description Mechanisms exist to issue data modeling guidelines to support tagging of sensitive/regulated data. 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. 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. 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, customer management solution, etc.). ▪ 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 issue data modeling guidelines to support tagging of sensitive/regulated data. 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.
Updating Personal Data (PD) Process	Description Mechanisms exist to identify and record: (1) The process(es) used to update Personal Data (PD); and (2) The frequency that such updates occur. 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 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. 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, 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, customer management solution, etc.). ▪ 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 identify and record: (1) The process(es) used to update Personal Data (PD); and (2) The frequency that such updates occur. 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.
Data Management Board	Description Mechanisms exist to establish a written charter for a Data Management Board (DMB) and assigned organization-defined roles to the DMB. 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. 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. 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, customer management solution, etc.). ▪ 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 establish a written charter for a Data Management Board (DMB) and assigned organization-defined roles to the DMB. 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.
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. 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. 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, 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, customer management solution, etc.). ▪ 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.
Register As A Data Controller and/or Data Processor	Description Mechanisms exist to register as a data controller and/or data processor, including registering databases containing Personal Data (PD) with the appropriate Data Authority, when necessary. 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. 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. 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, customer management solution, etc.). ▪ 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 register as a data controller and/or data processor, including registering databases containing Personal Data (PD) with the appropriate Data Authority, when necessary. 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.
Potential Human Rights Abuses	Description Mechanisms exist to constrain the supply of physical and/or digital activity logs to the host government that can directly lead to contravention of the Universal Declaration of Human Rights (UDHR), as well as other applicable statutory, regulatory and/or 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 ∙ Board of Directors (Bod) Ethics Committee Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Data classification program ∙ Data privacy program ∙ Data Protection Impact Assessment (DPIA) ∙ Product / project management ∙ Board of Directors (Bod) Ethics Committee SCR-CMM Level 0 Not Performed Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed. Level 1 Performed Informally SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality. 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. 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, customer management solution, etc.). ▪ 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 constrain the supply of physical and/or digital activity logs to the host government that can directly lead to contravention of the Universal Declaration of Human Rights (UDHR), as well as other applicable statutory, regulatory and/or 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.
Data Subject Communications	Description Mechanisms exist to craft disclosures and communications to data subjects in a manner that is concise, unambiguous and understandable by a reasonable person. 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. 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. 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, 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. ▪ Communications with data subjects is designed to be readily accessible and written in a manner that is concise, unambiguous and understandable by a reasonable person. 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, customer management solution, etc.). ▪ 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 craft disclosures and communications to data subjects in a manner that is concise, unambiguous and understandable by a reasonable person. 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.
Data Controller Communications	Description Mechanisms exist to receive and process data controller communications pertaining to: (1) Receiving and responding to data subject requests; (2) Updating/correcting Personal Data (PD); (3) Accounting for disclosures of PD; and (4) Accounting for PD that is stored, processed and/or transmitted on behalf of the data controller. 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. 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. 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, customer management solution, etc.). ▪ 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 receive and process data controller communications pertaining to: (1) Receiving and responding to data subject requests; (2) Updating/correcting Personal Data (PD); (3) Accounting for disclosures of PD; and (4) Accounting for PD that is stored, processed and/or transmitted on behalf of the data controller. 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.
Automated Decision-Making Technology (ADMT) For Data Subject Actions	Description Mechanisms exist to ensure data subject actions utilizing Automated Decision-Making Technology (ADMT) where computation replaces, or substantially replaces, human decisionmaking, conforms with all applicable statutory, regulatory and/or contractual obligations. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Inform users when automated decisions are made about them Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ ADMT disclosure policy in privacy notice Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Formal ADMT governance policy ∙ Disclosure requirements for automated decision-making Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Enterprise ADMT governance program ∙ Transparency requirements ∙ Impact assessments Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Enterprise ADMT governance framework ∙ Automated disclosure mechanisms ∙ GDPR Art. 22 and CCPA compliance ∙ DPIA 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. 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. 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, customer management solution, etc.). ▪ 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 data subject actions utilizing Automated Decision-Making Technology (ADMT) where computation replaces, or substantially replaces, human decisionmaking, conforms with all applicable statutory, regulatory and/or 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.
Data Brokers	Description Mechanisms exist to ensure data brokers that collect Personal Data (PD) from a source other than directly from the data subject adhere to all applicable statutory, regulatory and/or contractual obligations. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Data broker awareness and opt-out process where applicable Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Data broker awareness and opt-out process where applicable Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Data broker awareness and opt-out process where applicable Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Enterprise data broker monitoring and opt-out program Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Enterprise data broker governance program ∙ Automated data broker discovery and opt-out (e.g., DeleteMe) ∙ Regulatory compliance 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. 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. 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, customer management solution, etc.). ▪ 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 data brokers that collect Personal Data (PD) from a source other than directly from the data subject adhere to all applicable statutory, regulatory and/or 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.
Notice of Right To Opt-Out	Description Mechanisms exist to include a notification to data subjects within the data privacy notice of: (1) Their right to direct an organization that sells or shares their Personal Data (PD) to stop selling or sharing their PD; and (2) The methods available to exercise that right. Possible Solutions & Considerations Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2 ∙ Include opt-out right in privacy notice Small Business (10-49 staff) / BLS Firm Size Classes 3-4 ∙ Privacy notice with opt-out rights disclosure Medium Business (50-249 staff) / BLS Firm Size Classes 5-6 ∙ Formal notice of right-to-opt-out policy and procedure Large Business (250-999 staff) / BLS Firm Size Classes 7-8 ∙ Enterprise opt-out rights management program ∙ Automated opt-out processing Enterprise (> 1,000 staff) / BLS Firm Size Class 9 ∙ Enterprise consent management platform (e.g., OneTrust) ∙ Automated opt-out rights notification and processing ∙ CCPA/GDPR compliance 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. 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. 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, 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, customer management solution, etc.). ▪ 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 include a notification to data subjects within the data privacy notice of: (1) Their right to direct an organization that sells or shares their Personal Data (PD) to stop selling or sharing their PD; and (2) The methods available to exercise that right. Level 4 Quantitatively Controlled Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define. Level 5 Continuously Improving Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

1.1 Referenzen

1.2 Identifizierte Anforderungen

1.3 Related Regulations

2. Identifizierte Anforderungen

Anforderungen
Source	Anforderung

3. Related Regulations

Regulations
Source	Regulierung

Secure Controls Framework -
The Secure Controls Framework® (SCF)

"The SCF is the Common Controls Framework™ (CCF), the world's most comprehensive cybersecurity and data privacy metaframework - it is also free to use. The entire concept is building secure, compliant and resilient capabilities in the most efficient and cost-effective manner possible.

The SCF is more than just a unified control catalog, since its included content creates a playbook for Governance, Risk & Compliance (GRC) capabilities. Used globally by organizations of every size, the SCF is a robust and scalable solution for security, compliance and resilience controls. As a comprehensive security framework, the SCF maps 1,400+ controls across 200+ laws, regulations, and industry frameworks so you can implement once and comply everywhere.

Like it or not, cybersecurity is a protracted war on an asymmetric battlefield, where the threats are everywhere and as defenders we have to make the effort to work together to help improve cybersecurity and data privacy practices, since we all suffer when massive data breaches occur or when cyber attacks have physical impacts. Hackers share information on attack methods with other hackers, so why shouldn’t the good guys share information on how to best protect an organization? We decided to take action and make a difference, since we feel it is too important to wait for someone else to fix the problems that exist.

The SCF is made up of volunteers, mainly specialists within the cybersecurity profession, who focus on GRC and the cybersecurity side of data privacy. These are auditors, engineers, architects, incident responders, consultants and other specialists who live and breathe these topics on a daily basis. The end product is "expert-derived content" that makes up the SCF." https://securecontrolsframework.com/

Terms & Conditions

The SCF End User License Agreement (EULA) governs the use of the Secure Controls Framework® (SCF) under the Creative Commons Attribution-No Derivatives 4.0 International Public License.

Data Privacy

Security, Compliance & Resilience (SCR) Principles

Principle Intent

1. Übersicht

Description

Possible Solutions & Considerations

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

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

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

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

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

SCR-CMM

Level 0 Not Performed

Level 1 Performed Informally

Level 2 Planned Tracked

Level 3 Well Defined

Level 4 Quantitatively Controlled

Level 5 Continuously Improving

Description

Possible Solutions & Considerations

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

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

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

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

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

SCR-CMM

Level 0 Not Performed

Level 1 Performed Informally

Level 2 Planned Tracked

Level 3 Well Defined

Level 4 Quantitatively Controlled

Level 5 Continuously Improving

Description

Possible Solutions & Considerations

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

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

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

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

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

SCR-CMM

Level 0 Not Performed

Level 1 Performed Informally

Level 2 Planned Tracked

Level 3 Well Defined

Level 4 Quantitatively Controlled

Level 5 Continuously Improving

Description

Possible Solutions & Considerations

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

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

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

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

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

SCR-CMM

Level 0 Not Performed

Level 1 Performed Informally

Level 2 Planned Tracked

Level 3 Well Defined

Level 4 Quantitatively Controlled

Level 5 Continuously Improving

Description

Possible Solutions & Considerations

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

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

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

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

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

SCR-CMM

Level 0 Not Performed

Level 1 Performed Informally

Level 2 Planned Tracked

Level 3 Well Defined

Level 4 Quantitatively Controlled

Level 5 Continuously Improving

Description

Possible Solutions & Considerations

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

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

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

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