+AT 7.2 Tz 2
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AT 7.2 Tz 2
Für die Generierung von Daten und Informationen zu wesentlichen Risikoarten sind angemessene technische und organisatorische Kapazitäten vorzuhalten. Zudem sind effektive Prozesse zur Sicherstellung der Datenqualität einzurichten, die eine korrekte und vollständige Erfassung und Darstellung der wesentlichen Risikokomponenten ermöglichen.
1. Übersicht
1.1 Referenzen
1.2 Identifizierte Anforderungen
1.3 Related Standards
2. Identifizierte Anforderungen
Anforderungen
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Anforderung |
3. Related Standards
Standards
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Anforderung |
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SCF
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Data Governance
Description
Mechanisms exist to facilitate data governance to oversee the organization's policies, standards and procedures so that sensitive/regulated data is effectively managed and maintained in accordance with applicable statutory, regulatory and contractual obligations.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Basic data inventory (spreadsheet)
∙ Designated data owner / data custodian role
∙ Informal data classification policy
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Data governance policy and data classification standard
∙ Designated data owner(s) by data type
∙ Basic data inventory with sensitivity classification
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal data governance program with data classification scheme
∙ Data steward and data owner roles defined
∙ Data catalog tool (e.g., Microsoft Purview free tier, OpenMetadata)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Chief Data Officer (CDO) or equivalent role
∙ Formal data governance committee
∙ Enterprise data catalog and classification tool (e.g., Microsoft Purview, Collibra)
∙ Data quality and lineage management program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Chief Data Officer (CDO) with executive authority
∙ Enterprise Data Governance Council
∙ Enterprise data catalog, classification, and lineage platform (e.g., Collibra, Alation, Informatica)
∙ Data governance integrated with privacy, compliance, and risk programs
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
Cybersecurity & Data Protection Governance (GOV) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with GOV domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Governance-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT/cybersecurity personnel.
▪ Cybersecurity and data protection governance is informally assigned as an additional duty to existing IT/cybersecurity personnel.
▪ Administrative processes require all employees and contractors to apply cybersecurity and data protection principles in their daily work (e.g., policies & standards).
▪ Cybersecurity and data privacy governance practices are informally assigned as an additional duty to existing IT/cybersecurity personnel.
▪ IT /cyber engineering governance is decentralized, with the responsibility for implementing and testing cybersecurity and data protection controls being assigned to the business process owner(s), including the definition and enforcement of roles and responsibilities.
Level 2 Planned Tracked
Cybersecurity & Data Protection Governance (GOV) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
Level 3 Well Defined
Cybersecurity & Data Protection Governance (GOV) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's GRC team, or similar function, is appropriately staffed and supported to implement and maintain GOV domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to facilitate data governance to oversee the organization's policies, standards and procedures so that sensitive/regulated data is effectively managed and maintained in accordance with applicable statutory, regulatory and contractual obligations.
Level 4 Quantitatively Controlled
Cybersecurity & Data Protection Governance (GOV) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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