+Role-Based Security, Compliance & Resilience Training
---+Practical Exercises
---+Suspicious Communications & Anomalous System Behavior
---+Sensitive / Regulated Data Storage, Handling & Processing
---+Vendor Security, Compliance & Resilience Training
---+Privileged Users
---+Cyber Threat Environment
---+Continuing Professional Education (CPE) - Security, Compliance & Resilience Personnel
---+Continuing Professional Education (CPE) - DevOps Personnel
---+Counterintelligence Training
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Role-Based Security, Compliance & Resilience Training
Description
Mechanisms exist to provide role-based security, compliance and resilience-related training:
(1) Before authorizing access to the system or performing assigned duties;
(2) When required by system changes; and
(3) Annually thereafter.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ KnowB4 (https://knowbe4.com)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ KnowB4 (https://knowbe4.com)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ KnowB4 (https://knowbe4.com)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ KnowB4 (https://knowbe4.com)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ KnowB4 (https://knowbe4.com)
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
Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.
▪ IT/cybersecurity personnel self-manage their professional certification requirements to support their assigned duties.
Level 2 Planned Tracked
Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.
▪ Privileged users receive formal security and/or data privacy awareness training to ensure they understand their unique roles and responsibilities.
▪ The responsibility for training users and enforcing policies may be assigned to user’s immediate supervisor(s)/manager(s), including the definition and enforcement of the user’s specific role(s) and responsibilities.
▪ Security awareness and training methods are role-based (e.g., handling sensitive/regulated data).
Level 3 Well Defined
Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions, 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 SAT 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 role-based security, compliance and resilience-related training:
(1) Before authorizing access to the system or performing assigned duties;
(2) When required by system changes; and
(3) Annually thereafter.
Level 4 Quantitatively Controlled
Security Awareness & Training (SAT) 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
| Summary |
Standard |
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Practical Exercises
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Description
Mechanisms exist to include practical exercises in security, compliance and resilience training that reinforce training objectives.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Provide security training specific to developers
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Developer-specific secure coding training
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal secure coding training program for developers (e.g., OWASP training)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise developer security training (e.g., Secure Code Warrior, Checkmarx)
∙ Security champions program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise developer security training platform (e.g., Secure Code Warrior, Veracode eLearning)
∙ Security champions
∙ Gamified training
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
Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.
Level 2 Planned Tracked
Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
Level 3 Well Defined
Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions, 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 SAT 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 practical exercises in security, compliance and resilience training that reinforce training objectives.
Level 4 Quantitatively Controlled
Security Awareness & Training (SAT) 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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Suspicious Communications & Anomalous System Behavior
|
Description
Mechanisms exist to provide training to personnel on organization-defined indicators of malware to recognize suspicious communications and anomalous behavior.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Provide security training for system administrators
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Role-specific security training for system administrators
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal privileged user security training program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise privileged user security training program
∙ Regular refresher training
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise role-based technical security training (e.g., SANS courses)
∙ Privileged user training tracks
∙ Annual recertification
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
Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.
Level 2 Planned Tracked
Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.
▪ Privileged users receive formal security and/or data privacy awareness training to ensure they understand their unique roles and responsibilities.
▪ The responsibility for training users and enforcing policies may be assigned to user’s immediate supervisor(s)/manager(s), including the definition and enforcement of the user’s specific role(s) and responsibilities.
▪ Security awareness and training methods are role-based (e.g., handling sensitive/regulated data).
▪ Security awareness training covers reporting of unauthorized alterations and evidence of tampering of equipment
Level 3 Well Defined
Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions, 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 SAT 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 training to personnel on organization-defined indicators of malware to recognize suspicious communications and anomalous behavior.
Level 4 Quantitatively Controlled
Security Awareness & Training (SAT) 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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Sensitive / Regulated Data Storage, Handling & Processing
|
Description
Mechanisms exist to ensure that every user accessing a system processing, storing or transmitting sensitive/regulated data is formally trained in data handling requirements.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Provide security training for executives and leadership
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Executive security awareness briefing
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal executive security awareness program
∙ Board-level cybersecurity briefings
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise executive security program
∙ Board cybersecurity education
∙ Executive threat briefings
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise board and executive security education program
∙ Regular threat briefings
∙ Tabletop exercises for leadership
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
Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.
Level 2 Planned Tracked
Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.
▪ Privileged users receive formal security and/or data privacy awareness training to ensure they understand their unique roles and responsibilities.
▪ The responsibility for training users and enforcing policies may be assigned to user’s immediate supervisor(s)/manager(s), including the definition and enforcement of the user’s specific role(s) and responsibilities.
▪ Security awareness and training methods are role-based (e.g., handling sensitive/regulated data).
Level 3 Well Defined
Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions, 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 SAT 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 that every user accessing a system processing, storing or transmitting sensitive/regulated data is formally trained in data handling requirements.
Level 4 Quantitatively Controlled
Security Awareness & Training (SAT) 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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Vendor Security, Compliance & Resilience Training
|
Description
Mechanisms exist to incorporate vendor-specific security, compliance and resilience training in support of new technology initiatives.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Provide security training for third-party vendors with access to systems
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Vendor security training and awareness requirements
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal vendor security training requirements in contracts
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise vendor security training and awareness program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise third-party security awareness program
∙ Contractual training requirements
∙ Vendor compliance monitoring
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
Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.
Level 2 Planned Tracked
Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
Level 3 Well Defined
Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions, 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 SAT 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 incorporate vendor-specific security, compliance and resilience training in support of new technology initiatives.
Level 4 Quantitatively Controlled
Security Awareness & Training (SAT) 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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Privileged Users
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Description
Mechanisms exist to provide specific training for privileged users to ensure privileged users understand their unique roles and responsibilities
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Provide security training for physical security personnel
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Physical security staff security training
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal physical security personnel security training program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise physical security training program
∙ Specialized training for physical security roles
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise physical security training and certification program
∙ Regular exercises and drills
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
Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.
▪ Privileged users receive formal security and/or data privacy awareness training to ensure they understand their unique roles and responsibilities.
▪ The responsibility for training users and enforcing policies may be assigned to user’s immediate supervisor(s)/manager(s), including the definition and enforcement of the user’s specific role(s) and responsibilities.
▪ Security awareness and training methods are role-based (e.g., handling sensitive/regulated data).
Level 3 Well Defined
Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions, 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 SAT 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 specific training for privileged users to ensure privileged users understand their unique roles and responsibilities
Level 4 Quantitatively Controlled
Security Awareness & Training (SAT) 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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Cyber Threat Environment
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Description
Mechanisms exist to provide role-based security, compliance and resilience awareness training that is current and relevant to the cyber threats that users might encounter in day-to-day business operations.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ US-CERT mailing lists & feeds
∙ Internal newsletters
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ US-CERT mailing lists & feeds
∙ Internal newsletters
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ US-CERT mailing lists & feeds
∙ Internal newsletters
∙ InfraGard (https://infragard.org)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ US-CERT mailing lists & feeds
∙ Internal newsletters
∙ InfraGard (https://infragard.org)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ US-CERT mailing lists & feeds
∙ Internal newsletters
∙ InfraGard (https://infragard.org)
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
Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision.
▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations.
▪ Privileged users receive formal security and/or data privacy awareness training to ensure they understand their unique roles and responsibilities.
▪ The responsibility for training users and enforcing policies may be assigned to user’s immediate supervisor(s)/manager(s), including the definition and enforcement of the user’s specific role(s) and responsibilities.
▪ Security awareness and training methods are role-based (e.g., handling sensitive/regulated data).
▪ Business process owners are required to incorporate vendor-specific security training in support of new technology initiatives.
▪ Security awareness training covers recommended practices for securing laptops and mobile devices while traveling.
▪ Security awareness training covers reporting of unauthorized alterations and evidence of tampering of equipment
Level 3 Well Defined
Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions, 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 SAT 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 role-based security, compliance and resilience awareness training that is current and relevant to the cyber threats that users might encounter in day-to-day business operations.
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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Continuing Professional Education (CPE) - Security, Compliance & Resilience Personnel
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Description
Mechanisms exist to ensure security, compliance and resilience personnel receive Continuing Professional Education (CPE) training to maintain currency and proficiency with industry-recognized secure practices that are pertinent to their assigned roles and responsibilities.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Annual security awareness training
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Security awareness training platform (e.g., KnowBe4 free tier)
∙ Annual completion tracking
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Minimum requirements for Continuing Professional Education (CPE)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Minimum requirements for Continuing Professional Education (CPE)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Minimum requirements for Continuing Professional Education (CPE)
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
Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions, 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 SAT 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 security, compliance and resilience personnel receive Continuing Professional Education (CPE) training to maintain currency and proficiency with industry-recognized secure practices that are pertinent to their assigned roles and responsibilities.
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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Continuing Professional Education (CPE) - DevOps Personnel
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Description
Mechanisms exist to ensure application development and operations (DevOps) personnel receive Continuing Professional Education (CPE) training on Secure Software Development Practices (SSDP) to appropriately address evolving threats.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Annual security awareness training
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Security awareness training platform (e.g., KnowBe4 free tier)
∙ Annual completion tracking
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Minimum requirements for Continuing Professional Education (CPE)
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Minimum requirements for Continuing Professional Education (CPE)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Minimum requirements for Continuing Professional Education (CPE)
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
Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions, 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 SAT 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 application development and operations (DevOps) personnel receive Continuing Professional Education (CPE) training on Secure Software Development Practices (SSDP) to appropriately address evolving threats.
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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Counterintelligence Training
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Description
Mechanisms exist to provide specialized counterintelligence awareness training that enables personnel to collect, interpret and act upon a range of data sources that may signal the presence of a hostile actor.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Provide basic privacy awareness training to all staff
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Privacy awareness training for all personnel handling personal data
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Formal privacy awareness training program
∙ Annual completion tracking
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise privacy training program
∙ Role-based privacy training
∙ Compliance tracking
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise privacy training platform (e.g., TrustArc, OneTrust)
∙ Role-specific curricula
∙ Automated completion tracking
∙ 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
Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Security awareness and training methods are often generic, without organization-specific content.
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
Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners.
▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions, 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 SAT 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 specialized counterintelligence awareness training that enables personnel to collect, interpret and act upon a range of data sources that may signal the presence of a hostile actor.
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. II Art. 13 6.
6. Financial entities shall develop ICT security awareness programmes and digital operational resilience training as compulsory modules in their staff training schemes. Those programmes and training shall be applicable to all employees and to senior management staff, and shall have a level of complexity commensurate to the remit of their functions. Where appropriate, financial entities shall also include ICT third-party service providers in their relevant training schemes in accordance with Article 30(2), point (i).
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EULAW
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Article 9 Risk management system
Article 9
1. A risk management system shall be established, implemented, documented and maintained in relation to high-risk AI systems.
2. The risk management system shall be understood as a continuous iterative process planned and run throughout the entire lifecycle of a high-risk AI system, requiring regular systematic review and updating. It shall comprise the following steps:
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(a)
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the identification and analysis of the known and the reasonably foreseeable risks that the high-risk AI system can pose to health, safety or fundamental rights when the high-risk AI system is used in accordance with its intended purpose;
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(b)
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the estimation and evaluation of the risks that may emerge when the high-risk AI system is used in accordance with its intended purpose, and under conditions of reasonably foreseeable misuse;
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(c)
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the evaluation of other risks possibly arising, based on the analysis of data gathered from the post-market monitoring system referred to in Article 72;
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(d)
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the adoption of appropriate and targeted risk management measures designed to address the risks identified pursuant to point (a).
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3. The risks referred to in this Article shall concern only those which may be reasonably mitigated or eliminated through the development or design of the high-risk AI system, or the provision of adequate technical information.
4. The risk management measures referred to in paragraph 2, point (d), shall give due consideration to the effects and possible interaction resulting from the combined application of the requirements set out in this Section, with a view to minimising risks more effectively while achieving an appropriate balance in implementing the measures to fulfil those requirements.
5. The risk management measures referred to in paragraph 2, point (d), shall be such that the relevant residual risk associated with each hazard, as well as the overall residual risk of the high-risk AI systems is judged to be acceptable.
In identifying the most appropriate risk management measures, the following shall be ensured:
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(a)
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elimination or reduction of risks identified and evaluated pursuant to paragraph 2 in as far as technically feasible through adequate design and development of the high-risk AI system;
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(b)
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where appropriate, implementation of adequate mitigation and control measures addressing risks that cannot be eliminated;
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(c)
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provision of information required pursuant to Article 13 and, where appropriate, training to deployers.
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With a view to eliminating or reducing risks related to the use of the high-risk AI system, due consideration shall be given to the technical knowledge, experience, education, the training to be expected by the deployer, and the presumable context in which the system is intended to be used.
6. High-risk AI systems shall be tested for the purpose of identifying the most appropriate and targeted risk management measures. Testing shall ensure that high-risk AI systems perform consistently for their intended purpose and that they are in compliance with the requirements set out in this Section.
7. Testing procedures may include testing in real-world conditions in accordance with Article 60.
8. The testing of high-risk AI systems shall be performed, as appropriate, at any time throughout the development process, and, in any event, prior to their being placed on the market or put into service. Testing shall be carried out against prior defined metrics and probabilistic thresholds that are appropriate to the intended purpose of the high-risk AI system.
9. When implementing the risk management system as provided for in paragraphs 1 to 7, providers shall give consideration to whether in view of its intended purpose the high-risk AI system is likely to have an adverse impact on persons under the age of 18 and, as appropriate, other vulnerable groups.
10. For providers of high-risk AI systems that are subject to requirements regarding internal risk management processes under other relevant provisions of Union law, the aspects provided in paragraphs 1 to 9 may be part of, or combined with, the risk management procedures established pursuant to that law.
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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.
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.
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