+Functional Review Of Security, Compliance & Resilience Controls

Functional Review Of Security, Compliance & Resilience Controls

Description

Mechanisms exist to regularly review Technology Assets, Applications and/or Services (TAAS) for adherence to the organization's security, compliance and/or resilience policies and standards.

Possible Solutions & Considerations

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

∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE)
∙ Regular/yearly policy and standards review process

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

∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE)
∙ Regular/yearly policy and standards review process

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

∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE)
∙ Regular/yearly policy and standards review process

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

∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE)
∙ Regular/yearly policy and standards review process

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

∙ Control Validation Testing (CVT) / Security Test & Evaluation (STE)
∙ Regular/yearly policy and standards review process

SCR-CMM

Level 0 Not Performed

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

Level 1 Performed Informally

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

Level 2 Planned Tracked

Compliance (CPL) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with CPL domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with CPL domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with CPL domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Compliance management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Compliance management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ External compliance requirements for cybersecurity and data privacy are identified and documented, based on applicable laws, regulations and contractual obligations.
▪ IT and/or cybersecurity personnel use an entity-defined set of controls to conduct cybersecurity and data protection control assessments.

Level 3 Well Defined

Compliance (CPL) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with CPL domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with CPL domain capabilities are well-documented and kept current by process owners.
▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain CPL domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with CPL domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to regularly review Technology Assets, Applications and/or Services (TAAS) for adherence to the organization's security, compliance and/or resilience policies and standards.

Level 4 Quantitatively Controlled

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

Level 5 Continuously Improving

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

1. Overview

1.1 References

1.2 Identified Requirements

1.3 Related Regulations

2. Identified Requirements

Requirements

3. Related Regulations

Regulations
EULAW Article 21 Cybersecurity risk-management measures

Article 21

Cybersecurity risk-management measures

1.  
Member States shall ensure that essential and important entities take appropriate and proportionate technical, operational and organisational measures to manage the risks posed to the security of network and information systems which those entities use for their operations or for the provision of their services, and to prevent or minimise the impact of incidents on recipients of their services and on other services.

Taking into account the state-of-the-art and, where applicable, relevant European and international standards, as well as the cost of implementation, the measures referred to in the first subparagraph shall ensure a level of security of network and information systems appropriate to the risks posed. When assessing the proportionality of those measures, due account shall be taken of the degree of the entity’s exposure to risks, the entity’s size and the likelihood of occurrence of incidents and their severity, including their societal and economic impact.

2.  

The measures referred to in paragraph 1 shall be based on an all-hazards approach that aims to protect network and information systems and the physical environment of those systems from incidents, and shall include at least the following:

(a) 

policies on risk analysis and information system security;

(b) 

incident handling;

(c) 

business continuity, such as backup management and disaster recovery, and crisis management;

(d) 

supply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers;

(e) 

security in network and information systems acquisition, development and maintenance, including vulnerability handling and disclosure;

(f) 

policies and procedures to assess the effectiveness of cybersecurity risk-management measures;

(g) 

basic cyber hygiene practices and cybersecurity training;

(h) 

policies and procedures regarding the use of cryptography and, where appropriate, encryption;

(i) 

human resources security, access control policies and asset management;

(j) 

the use of multi-factor authentication or continuous authentication solutions, secured voice, video and text communications and secured emergency communication systems within the entity, where appropriate.

3.  
Member States shall ensure that, when considering which measures referred to in paragraph 2, point (d), of this Article are appropriate, entities take into account the vulnerabilities specific to each direct supplier and service provider and the overall quality of products and cybersecurity practices of their suppliers and service providers, including their secure development procedures. Member States shall also ensure that, when considering which measures referred to in that point are appropriate, entities are required to take into account the results of the coordinated security risk assessments of critical supply chains carried out in accordance with Article 22(1).
4.  
Member States shall ensure that an entity that finds that it does not comply with the measures provided for in paragraph 2 takes, without undue delay, all necessary, appropriate and proportionate corrective measures.
5.  
By 17 October 2024, the Commission shall adopt implementing acts laying down the technical and the methodological requirements of the measures referred to in paragraph 2 with regard to DNS service providers, TLD name registries, cloud computing service providers, data centre service providers, content delivery network providers, managed service providers, managed security service providers, providers of online market places, of online search engines and of social networking services platforms, and trust service providers.

The Commission may adopt implementing acts laying down the technical and the methodological requirements, as well as sectoral requirements, as necessary, of the measures referred to in paragraph 2 with regard to essential and important entities other than those referred to in the first subparagraph of this paragraph.

When preparing the implementing acts referred to in the first and second subparagraphs of this paragraph, the Commission shall, to the extent possible, follow European and international standards, as well as relevant technical specifications. The Commission shall exchange advice and cooperate with the Cooperation Group and ENISA on the draft implementing acts in accordance with Article 14(4), point (e).

Those implementing acts shall be adopted in accordance with the examination procedure referred to in Article 39(2).

Linked Issues

Issuelinks
is related to Quarterly
is related to relative Control Weighting = 08
is related to Process
is related to Detect
is related to SCRM Focus Tier 1 STRATEGIC
is related to SCRM Focus Tier 2 OPERATIONAL
is related to SCRM Focus Tier 3 TACTICAL
blocks Inability to maintain individual accountability
blocks Improper assignment of privileged functions
blocks Privilege escalation
blocks Unauthorized access
blocks Lost, damaged or stolen asset(s)
blocks Loss of integrity through unauthorized changes
blocks Emergent properties and/or unintended consequences
blocks Business interruption
blocks Data loss / corruption
blocks Reduction in productivity
blocks Information loss / corruption or system compromise due to technical attack
blocks Information loss / corruption or system compromise due to non‐technical attack
blocks Loss of revenue
blocks Cancelled contract
blocks Diminished competitive advantage
blocks Diminished reputation
blocks Fines and judgements
blocks Unmitigated vulnerabilities
blocks System compromise
blocks Inability to support business processes
blocks Incorrect controls scoping
blocks Lack of roles & responsibilities
blocks Inadequate internal practices
blocks Inadequate third-party practices
blocks Lack of oversight of internal controls
blocks Lack of oversight of third-party controls
blocks Illegal content or abusive action
blocks Inability to investigate / prosecute incidents
blocks Improper response to incidents
blocks Ineffective remediation actions
blocks Expense associated with managing a loss event
blocks Inability to maintain situational awareness
blocks Lack of a security-minded workforce
blocks Third-party cybersecurity exposure
blocks Third-party physical security exposure
blocks Third-party supply chain relationships, visibility and controls
blocks Third-party compliance / legal exposure
blocks Use of product / service
blocks Reliance on the third-party
  • Secure Controls Framework -

    The Secure Controls Framework® (SCF)

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    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.
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