+Materiality Determination
---+Material Risks
---+Material Threats
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Materiality Determination
Description
Mechanisms exist to define materiality threshold criteria capable of designating an incident as material.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Simple materiality threshold definition (document what constitutes a material incident)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Documented materiality criteria aligned to business impact and applicable regulations
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Documented materiality thresholds (financial, reputational, operational, regulatory)
∙ SEC cybersecurity disclosure rules considered (if applicable)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Formal materiality determination process aligned to SEC cybersecurity disclosure rules (if public)
∙ Cross-functional materiality review team (Legal, Finance, CISO, Operations)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Enterprise materiality determination framework (SEC Item 1.05, PCAOB, SOX alignment)
∙ Board-approved materiality thresholds with regular review cycle
∙ Automated materiality scoring integrated with incident response workflows
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 define materiality threshold criteria capable of designating an incident as material.
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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Material Risks
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Description
Mechanisms exist to define criteria necessary to designate a risk as a material risk.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Basic risk register with materiality threshold criteria
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Risk register with documented materiality criteria
∙ Defined risk scoring methodology
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Formal risk register with quantitative/qualitative materiality thresholds
∙ GRC platform risk management module
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Formal materiality criteria for risks aligned to risk appetite
∙ Board-approved material risk thresholds
∙ GRC platform with automated risk scoring and materiality flagging
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Enterprise material risk framework aligned to SEC, SOX, and applicable regulators
∙ Quantitative risk analysis (e.g., FAIR methodology)
∙ Automated material risk identification and escalation
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 define criteria necessary to designate a risk as a material risk.
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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Material Threats
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Description
Mechanisms exist to define criteria necessary to designate a threat as a material threat.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Basic threat assessment against organizational context
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Documented threat assessment with materiality criteria
∙ CISA Known Exploited Vulnerabilities (KEV) catalog reference
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Formal threat assessment with materiality thresholds
∙ MITRE ATT&CK framework threat modeling
∙ Threat intelligence integration (e.g., CISA advisories, sector ISAC feeds)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Formal material threat designation process with executive review
∙ Threat intelligence platform (e.g., Recorded Future, Anomali, MISP)
∙ MITRE ATT&CK-based threat modeling
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ SCF Secure, Compliant & Resilient (SCR) Risk Management Model (SCR-RMM) (https://securecontrolsframework.com/risk-management-model)
∙ Enterprise material threat framework integrated with SEC disclosure process
∙ Dedicated threat intelligence platform (e.g., Recorded Future, Mandiant Threat Intelligence)
∙ Board-level material threat reporting cadence
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 define criteria necessary to designate a threat as a material threat.
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 |
Linked Issues
- Secure Controls Framework -
"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.
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