+Assigned Security, Compliance & Resilience Responsibilities
---+Stakeholder Accountability Structure
---+Authoritative Chain of Command
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Assigned Security, Compliance & Resilience Responsibilities
Description
Mechanisms exist to assign one or more qualified individuals with the mission and resources to centrally-manage, coordinate, develop, implement and maintain an enterprise-wide Security, Compliance & Resilience Program (SCRP).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Third-party advisors (e.g., virtual CISO (vCISO), Managed Security Services Provider (MSSP))
∙ Designated internal security point of contact
∙ vCISO services (e.g., Truvantis, private vCISO firms)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Third-party advisors (e.g., virtual CISO (vCISO), Managed Security Services Provider (MSSP))
∙ Part-time or shared security manager
∙ vCISO services with defined scope and deliverables
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Dedicated Information Security Manager (ISM) or fractional CISO
∙ Chief Information Security Officer (CISO) or equivalent role
∙ Defined Information Security Management System (ISMS) ownership
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Chief Information Security Officer (CISO) with defined authority and budget
∙ Security leadership team (CISO, DPO, IAM lead, etc.)
∙ Security organizational structure with clear reporting lines
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Chief Information Security Officer (CISO) with C-suite authority and board access
∙ Security leadership organization (CISO, Deputy CISO, DPO, domain leads)
∙ Security Center of Excellence (CoE)
∙ Defined succession planning for key security roles
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
SCR-CMM Level 1 criteria definitions are not available for this control:
▪ A reasonable person would conclude this control requires a structured process.
▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.
Level 2 Planned Tracked
Cybersecurity & Data Protection Governance (GOV) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ A qualified individual is assigned the role and responsibilities to centrally manage, coordinate, develop, implement and maintain a cybersecurity and data protection program (e.g., cybersecurity director or Chief Information Security Officer (CISO)).
▪ The individual assigned the role and responsibilities to centrally manage, coordinate, develop, implement and maintain a cybersecurity and data protection program develops plans to implement the organization's security, compliance and resiliency-related objectives.
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).
▪ A qualified individual is assigned the role and responsibilities to centrally-manage, coordinate, develop, implement and maintain an enterprise-wide Security, Compliance & Resilience Program (SCRP) (e.g., cybersecurity director or Chief Information Security Officer (CISO)).
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. Overview
| Summary |
Standard |
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Stakeholder Accountability Structure
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Description
Mechanisms exist to enforce an accountability structure so that appropriate teams and individuals are empowered, responsible and trained for mapping, measuring and managing Technology Assets, Applications, Services and/or Data (TAASD)-related risks.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Documented roles and responsibilities (RACI matrix or equivalent)
∙ Job descriptions with security duties clearly defined
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Documented RACI matrix for cybersecurity responsibilities
∙ Formal security role assignments in job descriptions
∙ Access control aligned to defined roles
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Documented RACI matrix for cybersecurity responsibilities
∙ Role-based accountability framework
∙ Performance metrics tied to security responsibilities
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Formal accountability framework (RACI/RASCI) maintained in GRC platform
∙ Security role definitions with measurable performance criteria
∙ Control ownership assigned and tracked in GRC platform
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise accountability framework integrated with GRC and HR systems
∙ Control ownership model with documented accountability for each control domain
∙ Security KPIs tied to role-based performance management
∙ Third-party accountability structures for key vendors
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
SCR-CMM Level 1 criteria definitions are not available for this control:
▪ A reasonable person would conclude this control requires a structured process.
▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.
Level 2 Planned Tracked
SCR-CMM Level 2 criteria definitions are not available for this control:
▪ A reasonable person would conclude a well-defined and standardized process is required.
▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization.
▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 Well Defined
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 enforce an accountability structure so that appropriate teams and individuals are empowered, responsible and trained for mapping, measuring and managing Technology Assets, Applications, Services and/or Data (TAASD)-related risks.
Level 4 Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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Authoritative Chain of Command
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Description
Mechanisms exist to establish an authoritative chain of command with clear lines of communication to remove ambiguity from individuals and teams related to managing Technology Assets, Applications, Services and/or Data (TAASD)-related risks.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Organization chart with security escalation paths
∙ Documented incident escalation contact list
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Organization chart with defined security escalation paths
∙ Documented escalation procedures for security decisions
∙ Clear IT/security reporting relationships
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Organization chart with cybersecurity reporting lines
∙ Formal escalation matrix for security decisions and incidents
∙ Defined authority levels for security-related approvals
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Formal organizational structure with clear cybersecurity authority chain
∙ Documented delegation of authority for security decisions
∙ Defined escalation procedures published in the SCRP
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise organizational structure with defined CISO authority and reporting chain
∙ Board-level visibility into security command structure
∙ Integrated HR/org management system reflecting security authority
∙ Formalized delegation of authority matrix for security decisions
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.
▪ Cybersecurity and data privacy governance practices are informally assigned as an additional duty to existing IT/cybersecurity personnel.
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
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 establish an authoritative chain of command with clear lines of communication to remove ambiguity from individuals and teams related to managing Technology Assets, Applications, Services and/or Data (TAASD)-related risks.
Level 4 Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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1.1 References
1.2 Identified Requirements
1.3 Related Regulations
2. Identified Requirements
Requirements
| Source |
Requirement |
3. Related Regulations
Regulations
| Source |
Regulation |
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DORA
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DORA Ch. II Sec. I Art. 5 2.
2. The management body of the financial entity shall define, approve, oversee and be responsible for the implementation of all arrangements related to the ICT risk management framework referred to in Article 6(1).
For the purposes of the first subparagraph, the management body shall:
- (a) bear the ultimate responsibility for managing the financial entity’s ICT risk;
- (b) put in place policies that aim to ensure the maintenance of high standards of availability, authenticity, integrity and confidentiality, of data;
- (c) set clear roles and responsibilities for all ICT-related functions and establish appropriate governance arrangements to ensure effective and timely communication, cooperation and coordination among those functions;
- (d) bear the overall responsibility for setting and approving the digital operational resilience strategy as referred to in Article 6(8), including the determination of the appropriate risk tolerance level of ICT risk of the financial entity, as referred to in Article 6(8), point (b);
- (e) approve, oversee and periodically review the implementation of the financial entity’s ICT business continuity policy and ICT response and recovery plans, referred to, respectively, in Article 11(1) and (3), which may be adopted as a dedicated specific policy forming an integral part of the financial entity’s overall business continuity policy and response and recovery plan;
- (f) approve and periodically review the financial entity’s ICT internal audit plans, ICT audits and material modifications to them;
- (g) allocate and periodically review the appropriate budget to fulfil the financial entity’s digital operational resilience needs in respect of all types of resources, including relevant ICT security awareness programmes and digital operational resilience training referred to in Article 13(6), and ICT skills for all staff;
- (h) approve and periodically review the financial entity’s policy on arrangements regarding the use of ICT services provided by ICT third-party service providers;
- (i) put in place, at corporate level, reporting channels enabling it to be duly informed of the following:
- (i) arrangements concluded with ICT third-party service providers on the use of ICT services,
- (ii) any relevant planned material changes regarding the ICT third-party service providers,
- (iii) the potential impact of such changes on the critical or important functions subject to those arrangements, including a risk analysis summary to assess the impact of those changes, and at least major ICT-related incidents and their impact, as well as response, recovery and corrective measures.
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DORA
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DORA Ch. II Sec. I Art. 5 3.
3. Financial entities, other than microenterprises, shall establish a role in order to monitor the arrangements concluded with ICT third-party service providers on the use of ICT services, or shall designate a member of senior management as responsible for overseeing the related risk exposure and relevant documentation.
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EULAW
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Article 17 Quality management system
Article 17
Quality management system
1. Providers of high-risk AI systems shall put a quality management system in place that ensures compliance with this Regulation. That system shall be documented in a systematic and orderly manner in the form of written policies, procedures and instructions, and shall include at least the following aspects:
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(a)
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a strategy for regulatory compliance, including compliance with conformity assessment procedures and procedures for the management of modifications to the high-risk AI system;
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(b)
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techniques, procedures and systematic actions to be used for the design, design control and design verification of the high-risk AI system;
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(c)
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techniques, procedures and systematic actions to be used for the development, quality control and quality assurance of the high-risk AI system;
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(d)
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examination, test and validation procedures to be carried out before, during and after the development of the high-risk AI system, and the frequency with which they have to be carried out;
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(e)
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technical specifications, including standards, to be applied and, where the relevant harmonised standards are not applied in full or do not cover all of the relevant requirements set out in Section 2, the means to be used to ensure that the high-risk AI system complies with those requirements;
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(f)
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systems and procedures for data management, including data acquisition, data collection, data analysis, data labelling, data storage, data filtration, data mining, data aggregation, data retention and any other operation regarding the data that is performed before and for the purpose of the placing on the market or the putting into service of high-risk AI systems;
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(g)
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the risk management system referred to in Article 9;
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(h)
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the setting-up, implementation and maintenance of a post-market monitoring system, in accordance with Article 72;
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(i)
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procedures related to the reporting of a serious incident in accordance with Article 73;
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(j)
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the handling of communication with national competent authorities, other relevant authorities, including those providing or supporting the access to data, notified bodies, other operators, customers or other interested parties;
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(k)
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systems and procedures for record-keeping of all relevant documentation and information;
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(l)
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resource management, including security-of-supply related measures;
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(m)
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an accountability framework setting out the responsibilities of the management and other staff with regard to all the aspects listed in this paragraph.
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2. The implementation of the aspects referred to in paragraph 1 shall be proportionate to the size of the provider’s organisation. Providers shall, in any event, respect the degree of rigour and the level of protection required to ensure the compliance of their high-risk AI systems with this Regulation.
3. Providers of high-risk AI systems that are subject to obligations regarding quality management systems or an equivalent function under relevant sectoral Union law may include the aspects listed in paragraph 1 as part of the quality management systems pursuant to that law.
4. For providers that are financial institutions subject to requirements regarding their internal governance, arrangements or processes under Union financial services law, the obligation to put in place a quality management system, with the exception of paragraph 1, points (g), (h) and (i) of this Article, shall be deemed to be fulfilled by complying with the rules on internal governance arrangements or processes pursuant to the relevant Union financial services law. To that end, any harmonised standards referred to in Article 40 shall be taken into account.
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Linked Issues
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