BlackAether/Frameworks-and-Controls · Datasets at Hugging Face

Data Privacy

Tailored Consent

PRI-03.1

Mechanisms exist to allow data subjects to modify the use permissions to selected attributes of their Personal Data (PD).

null

Does the organization allow data subjects to modify the use permissions to selected attributes of their Personal Data (PD)?

1

Identify

null

X

null

There is no evidence of a capability to allow data subjects to modify the use permissions to selected attributes of their Personal Data (PD).

SP-CMM1 is N/A, since a structured process is required to allow data subjects to modify the use permissions to selected attributes of their Personal Data (PD).

SP-CMM2 is N/A, since a well-defined process is required to allow data subjects to modify the use permissions to selected attributes of their Personal Data (PD).

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to allow data subjects to modify the use permissions to selected attributes of their Personal Data (PD).

null

P2.1-POF5 P3.2-POF1

null

7.3.4

null

CT.PO-P3

null

IP-(1)

null

PT-4(1)

null

PT-4(1)

null

P.5.4.3

null

IP-(1)

6,502

null

7014(a) 7014(b) 7014(c) 7014(d) 7014(e) 7014(e)(1) 7014(e)(2) 7014(f)(1) 7014(f)(2) 7014(g)(1) 7014(g)(2) 7014(h)

null

6-1-1306(1) 6-1-1306(1)(a)(I)(A) 6-1-1306(1)(a)(I)(B) 6-1-1306(1)(a)(I)(C) 6-1-1306(1)(a)(II) 6-1-1306(1)(a)(III) 6-1-1306(1)(a)(IV)(A) 6-1-1306(1)(a)(IV)(B) 6-1-1306(1)(a)(IV)(C)

null

Art 8 Art 10

Art 7.1 Art 7.2 Art 7.3 Art 7.4 Art 12.2 Art 12.3 Art 12.4 Art 22.1 Art 22.2 Art 22.3 Art 22.4

null

Article 31 Article 31.1 Article 31.2 Article 31.3 Article 31.4

null

Sec 11

null

Article 7(3) Article 18(1)(a) Article 18(1)(b) Article 18(1)(c) Article 18(1)(d)

null

Art 5

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-2

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Just-In-Time Notice & Updated Consent

PRI-03.2

Mechanisms exist to present authorizations to process Personal Data (PD) in conjunction with the data action, when: ▪ The original circumstances under which an individual gave consent have changed; or ▪ A significant amount of time has passed since an individual gave consent.

null

Does the organization present authorizations to process Personal Data (PD) in conjunction with the data action, when: ▪ The original circumstances under which an individual gave consent have changed; or ▪ A significant amount of time has passed since an individual gave consent?

1

Identify

null

X

null

There is no evidence of a capability to present authorizations to process Personal Data (PD) in conjunction with the data action, when: ▪ The original circumstances under which an individual gave consent have changed; or ▪ A significant amount of time has passed since an individual gave consent.

SP-CMM1 is N/A, since a structured process is required to present authorizations to process Personal Data (PD) in conjunction with the data action, when: ▪ The original circumstances under which an individual gave consent have changed; or ▪ A significant amount of time has passed since an individual gave consent.

SP-CMM2 is N/A, since a well-defined process is required to present authorizations to process Personal Data (PD) in conjunction with the data action, when: ▪ The original circumstances under which an individual gave consent have changed; or ▪ A significant amount of time has passed since an individual gave consent.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to present authorizations to process Personal Data (PD) in conjunction with the data action, when: ▪ The original circumstances under which an individual gave consent have changed; or ▪ A significant amount of time has passed since an individual gave consent.

P2.1 P3.2

P2.1-POF4

null

7.3.4

null

CT.PO-P1 CT.PO-P3

null

PT-4(2) PT-5(1)

null

PT-4(2) PT-5(1)

null

P.5.4.3

null

Principle 2

null

7002(f) 7028(a) 7028(b)

null

6-1-1306(1) 6-1-1306(1)(a)(I)(A) 6-1-1306(1)(a)(I)(B) 6-1-1306(1)(a)(I)(C) 6-1-1306(1)(a)(II) 6-1-1306(1)(a)(III) 6-1-1306(1)(a)(IV)(A) 6-1-1306(1)(a)(IV)(B) 6-1-1306(1)(a)(IV)(C)

null

Art 7.1 Art 7.2 Art 7.3 Art 7.4 Art 8.1 Art 8.2 Art 12.2 Art 12.3 Art 12.4 Art 13.3 Art 14.3 Art 21.4

null

Sec 8

null

Art 16

null

32(2) 32(3)

null

Sec 15

null

Article 7(1) Article 13(3) Article 21(1) Article 21(2) Article 21(3) Article 21(4) Article 21(5) Article 21(6)

null

APP 5

null

Article 14 Article 22 Article 23 Article 27

null

Article 16(2) Article 16(3)(i) Article 16(3)(ii) Article 16(3)(iii) Article 16(3)(iv)

null

Art 22

Art 5

Art 27.3

null

Sec 6 Sec 7 Principle 3

null

Art 7

null

Art 5 Art 9

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-2

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Prohibition Of Selling or Sharing Personal Data

PRI-03.3

Mechanisms exist to prevent the sale or sharing of Personal Data (PD) when instructed by the data subject.

null

Does the organization prevent the sale or sharing of Personal Data (PD) when instructed by the data subject?

5

Identify

null

X

null

There is no evidence of a capability to prevent the sale or sharing of Personal Data (PD) when instructed by the data subject.

SP-CMM1 is N/A, since a structured process is required to prevent the sale or sharing of Personal Data (PD) when instructed by the data subject.

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices. • Administrative processes and technologies collect, store, processes, transmit share or use PD only for the purposes identified in the data privacy notice. • The DPO reviews the management of PD to ensure that controls exist to prohibit the sale of PD when instructed by the data principle.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies collect, store, processes, transmit share or use PD only for the purposes identified in the data privacy notice. • The DPO reviews the management of PD to ensure that controls exist to prohibit the sale of PD when instructed by the data principle.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to prevent the sale or sharing of Personal Data (PD) when instructed by the data subject.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to prevent the sale or sharing of Personal Data (PD) when instructed by the data subject.

null

CT.PO-P1 CT.PO-P3

null

P.6.1.7

null

7010(d) 7013(a) 7013(b) 7013(c) 7013(d) 7013(e) 7013(e)(1) 7013(e)(2) 7013(e)(3) 7013(e)(3)(A) 7013(e)(3)(B) 7013(f)(1) 7013(f)(2) 7013(g)(1) 7013(g)(1) 7013(h) 7026(a) 7026(a)(1) 7026(a)(2) 7026(a)(3) 7026(a)(4) 7026(b) 7026(c) 7026(d) 7026(e) 7026(f)(1) 7026(f)(2) 7026(g) 7026(h) 7026(i) 7026(j) 7026(k)

null

6-1-1306(1) 6-1-1306(1)(a)(I)(A) 6-1-1306(1)(a)(I)(B) 6-1-1306(1)(a)(I)(C) 6-1-1306(1)(a)(II) 6-1-1306(1)(a)(III) 6-1-1306(1)(a)(IV)(A) 6-1-1306(1)(a)(IV)(B) 6-1-1306(1)(a)(IV)(C)

Sec 15(c)

null

Sec 2.3

null

59.1-577.A.5(ii) 59.1-578.D

null

Principle 2.2.c Principle 2.2.c(i) Principle 2.2.c(ii)

null

Article 37

null

APP 7

null

Article 10

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-2

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Revoke Consent

PRI-03.4

Mechanisms exist to allow data subjects to revoke consent to the processing of their Personal Data (PD).

null

Does the organization allow data subjects to revoke consent to the processing of their Personal Data (PD)?

3

Respond

null

X

null

There is no evidence of a capability to allow data subjects to revoke consent to the processing of their Personal Data (PD).

SP-CMM1 is N/A, since a structured process is required to allow data subjects to revoke consent to the processing of their Personal Data (PD).

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to allow data subjects to revoke consent to the processing of their Personal Data (PD).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to allow data subjects to revoke consent to the processing of their Personal Data (PD).

null

PT-4(3)

null

PT-4(3)

null

P.5.4.3

null

7015(a) 7015(b) 7015(c)(1) 7015(c)(2)

null

6-1-1306(1) 6-1-1306(1)(a)(I)(A) 6-1-1306(1)(a)(I)(B) 6-1-1306(1)(a)(I)(C) 6-1-1306(1)(a)(II) 6-1-1306(1)(a)(III)

null

26(c) 32(2) 32(3)

null

2.8 2.8(a) 2.8(b)

null

Article 5.1

null

Article 15 Article 37

null

Article 7(3) Article 21(1) Article 21(2) Article 21(3) Article 21(4) Article 21(5) Article 21(6)

null

Article 15

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-2

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Product or Service Delivery Restrictions

PRI-03.5

Mechanisms exist to prohibit the refusal of products and/or services on the grounds that a data subject does not agree to the processing of Personal Data (PD) or withdraws consent.

- Privacy Program

null

Does the organization prohibit the refusal of products and/or services on the grounds that a data subject does not agree to the processing of Personal Data (PD) or withdraws consent?

7

Identify

null

X

There is no evidence of a capability to prohibit the refusal of products and/ or services on the grounds that a data subject does not agree to the processing of Personal Data (PD) or withdraws consent.

SP-CMM1 is N/A, since a structured process is required to prohibit the refusal of products and/ or services on the grounds that a data subject does not agree to the processing of Personal Data (PD) or withdraws consent.

SP-CMM2 is N/A, since a well-defined process is required to prohibit the refusal of products and/ or services on the grounds that a data subject does not agree to the processing of Personal Data (PD) or withdraws consent.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • The PMO and DPO work with data/process owners to prohibit the refusal of products and/ or services on the grounds that a data subject does not agree to the processing of PD or withdraws consent.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to prohibit the refusal of products and/ or services on the grounds that a data subject does not agree to the processing of Personal Data (PD) or withdraws consent.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to prohibit the refusal of products and/ or services on the grounds that a data subject does not agree to the processing of Personal Data (PD) or withdraws consent.

null

P.5.4.3

null

7016(a) 7016(b) 7016(c) 7016(d) 7016(d)(1) 7016(d)(2) 7016(d)(3) 7016(d)(4) 7016(d)(5) 7016(d)(5)(A) 7016(d)(5)(B) 7080(a) 7080(b) 7080(c) 7080(d)(1) 7080(d)(2) 7080(d)(3) 7080(d)(4) 7080(e) 7080(f) 7080(g)

null

6-1-1308(1)(d)

null

Sec 10(b)(2)

null

32(4)

null

Article 16

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Authorized Agent

PRI-03.6

Mechanisms exist to allow data subjects to authorize another person or entity, acting on the data subject's behalf, to make Personal Data (PD) processing decisions.

null

Does the organization allow data subjects to authorize another person or entity, acting on the data subject's behalf, to make Personal Data (PD) processing decisions?

6

Protect

null

X

There is no evidence of a capability to allow data subjects to authorize another pers on or entity, acting on the data subject's behalf, to make Personal Data (PD) processing decisions.

SP-CMM1 is N/A, since a structured process is required to allow data subjects to authorize another pers on or entity, acting on the data subject's behalf, to make Personal Data (PD) processing decisions.

SP-CMM2 is N/A, since a well-defined process is required to allow data subjects to authorize another pers on or entity, acting on the data subject's behalf, to make Personal Data (PD) processing decisions.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to allow data subjects to authorize another pers on or entity, acting on the data subject's behalf, to make Personal Data (PD) processing decisions.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to allow data subjects to authorize another pers on or entity, acting on the data subject's behalf, to make Personal Data (PD) processing decisions.

null

P.5.5.2

null

7063(a) 7063(a)(1) 7063(a)(2) 7063(b) 7063(c) 7063(d)

null

6-1-1306(1)(a)(II)

Sec 15(b)(3)

null

27(a) 27(b) 27(c)

null

Article 17.1 Article 17.2 Article 17.3 Article 17.4 Article 17.5

null

Article 16(3)(i) Article 16(3)(ii) Article 16(3)(iii) Article 16(3)(iv)

null

R-AM-3 R-GV-1 R-GV-5

null

R-AM-3

null

R-GV-1

null

R-GV-5

null

MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Active Participation By Data Subjects

PRI-03.7

Mechanisms exist to compel data subjects to select the level of consent deemed appropriate by the data subject for the relevant business purpose (e.g., opt-in, opt-out, accept all cookies, etc.).

null

Does the organization compel data subjects to select the level of consent deemed appropriate by the data subject for the relevant business purpose (e?g?, opt-in, opt-out, accept all cookies, etc?)?

3

Protect

null

X

There is no evidence of a capability to compel data subjects to select the level of consent deemed appropriate by the data subject for the relevant business purpose (e.g., opt-in, opt-out, accept all cookies, etc.).

SP-CMM1 is N/A, since a structured process is required to compel data subjects to select the level of consent deemed appropriate by the data subject for the relevant business purpose (e.g., opt-in, opt-out, accept all cookies, etc.).

SP-CMM2 is N/A, since a well-defined process is required to compel data subjects to select the level of consent deemed appropriate by the data subject for the relevant business purpose (e.g., opt-in, opt-out, accept all cookies, etc.).

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to compel data subjects to select the level of consent deemed appropriate by the data subject for the relevant business purpose (e.g., opt-in, opt-out, accept all cookies, etc.).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to compel data subjects to select the level of consent deemed appropriate by the data subject for the relevant business purpose (e.g., opt-in, opt-out, accept all cookies, etc.).

null

7004(a)(2) 7004(a)(2)(a) 7004(a)(2)(b) 7004(a)(2)(c) 7004(a)(4) 7004(a)(4)(a) 7004(a)(4)(b) 7004(a)(5) 7004(a)(5)(a) 7004(a)(5)(b) 7004(a)(5)(c) 7010(d) 7015(a) 7015(b) 7015(c)(1) 7015(c)(2)

null

26(a) 26(c)

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-2

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Global Privacy Control (GPC)

PRI-03.8

Automated mechanisms exist to provide data subjects with functionality to exercise pre-selected opt-out preferences (e.g., opt-out signal).

null

Does the organization use automated mechanisms to provide data subjects with functionality to exercise pre-selected opt-out preferences (e?g?, opt-out signal)?

5

Protect

null

X

There is no evidence of a capability to provide data subjects with functionality to exercise pre-selected opt-out preferences (e.g., opt-out signal).

SP-CMM1 is N/A, since a structured process is required to provide data subjects with functionality to exercise pre-selected opt-out preferences (e.g., opt-out signal).

SP-CMM2 is N/A, since a well-defined process is required to provide data subjects with functionality to exercise pre-selected opt-out preferences (e.g., opt-out signal).

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to provide data subjects with functionality to exercise pre-selected opt-out preferences (e.g., opt-out signal).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide data subjects with functionality to exercise pre-selected opt-out preferences (e.g., opt-out signal).

null

7025(a) 7025(b)(1) 7025(b)(2) 7025(c)(1) 7025(c)(2) 7025(c)(3) 7025(c)(4) 7025(c)(5) 7025(c)(6) 7025(c)(7)(A) 7025(c)(7)(B) 7025(c)(7)(C) 7025(c)(7)(D) 7025(c)(7)(E) 7025(d) 7025(e) 7025(f)(1) 7025(f)(2) 7025(f)(3) 7025(g)(1) 7025(g)(2)(A) 7025(g)(2)(B) 7025(g)(2)(C) 7025(g)(2)(D) 7025(g)(3) 7025(g)(3)(A) 7025(g)(3)(B)

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-2

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

null

Data Privacy

Restrict Collection To Identified Purpose

PRI-04

Mechanisms exist to collect Personal Data (PD) only for the purposes identified in the data privacy notice and includes protections against collecting PD from minors without appropriate parental, or legal guardian, consent.

null

E-PRI-02

Does the organization collect Personal Data (PD) only for the purposes identified in the data privacy notice and includes protections against collecting PD from minors without appropriate parental, or legal guardian, consent?

7

Identify

null

X

null

There is no evidence of a capability to collect Personal Data (PD) only for the purposes identified in the data privacy notice and includes protections against collecting PD from minors without appropriate parental, or legal guardian, consent.

SP-CMM1 is N/A, since a structured process is required to collect Personal Data (PD) only for the purposes identified in the data privacy notice and includes protections against collecting PD from minors without appropriate parental, or legal guardian, consent.

SP-CMM2 is N/A, since a well-defined process is required to collect Personal Data (PD)only for the purposes identified in the data privacy notice and includes protections against collecting PD from minors without appropriate parental, or legal guardian, consent.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to collect Personal Data (PD) only for the purposes identified in the data privacy notice and includes protections against collecting PD from minors without appropriate parental, or legal guardian, consent.

P3.0 P3.1

P3.1-POF1 P3.1-POF2 P3.1-POF3 P3.1-POF4

null

4.1.2 9.2.2

null

18.1.4

5.33

18.1.4

A.3

7.2.2 7.3.1 7.3.2 7.4.1 8.2.1

5.4

null

AP-1

null

PT-2

null

P.5.1

null

COMP:SG2.SP1

null

AP-1

null

PT-2

null

45.48.410

null

7010(d) 7070(a) 7070(a)(1) 7070(a)(2)(A) 7070(a)(2)(B) 7070(a)(2)(C) 7070(a)(2)(D) 7070(a)(2)(E) 7070(a)(2)(F) 7070(b) 7070(c) 7071(a) 7071(b) 7072(a) 7072(b)

null

6-1-1305(2)

Sec 15(b)

Sec 10(b)(1) Sec 10(b)(3)

null

59.1-578.A.1

§ 2433(a)(1) § 2433(a)(2)

null

Art 5 Art 8

Art 5.1

null

Principle 2.5.a

Sec 6

Art 4-7

Art 9

Art 6

Sec 6 Sec 7

Art 7

Sec 4

null

Art 4

Sec 4 Sec 5

Sec 2

null

Sec 11

25(c) 25(d) 27(a) 28(2)(a) 28(2)(b) 28(2)(c) 28(2)(d) 28(2)(e) 28(2)(f) 28(2)(f)(i) 28(2)(f)(ii) 28(2)(f)(iii) 28(3)

null

Sec 8

null

Art 23

Art 5

Article 9.1 Article 10 Article 17.1 Article 17.2 Article 17.3 Article 17.4 Article 17.5

Art 5

null

Article 5.1 Article 5.2 Article 6.1 Article 6.2 Article 6.3 Article 6.4 Article 6.5 Article 16

null

Sec 5 Sec 11 Sec 69

Art 8

null

Sec 10

Art 4

Art 10

Sec 9

null

Article 5(1)(b) Article 12(1)

null

APP Part 3

APP 3

null

Article 26 Article 31

null

Sec 5

null

Article 17(1)

18.1.4

null

Principle 1 P1-(1)(a) P1-(1)(b) Principle 3 P3-(1) P3-(1)(a) P3-(1)(b) P3-(1)(c) P3-(1)(d) P3-(1)(d)(i) P3-(1)(d)(ii) P3-(1)(e) P3-(1)(e)(i) P3-(1)(e)(ii) P3-(1)(f) P3-(1)(g) P3-(2) P3-(3) P3-(4) P3-(4)(a) P3-(4)(b) P3-(4)(b)(i) P3-(4)(b)(ii) P3-(4)(b)(iii) P3-(4)(b)(iv) P3-(4)(c) P3-(4)(d) P3-(4)(e) P3-(4)(e)(i) P3-(4)(e)(ii) Principle 4 P4-(a) P4-(b) P4-(b)(i) P4-(b)(ii)

Sec 19

Sec 17

null

Art 3 Art 15 Art 22

Art 5 Art 19

Art 5

Art 4.1 Art 4.2 Art 6

Sec 6

null

Art 6.2

null

Sec 5 Principle 4

null

Art 4

Art 6

Art 7

Art 4 Art 14

null

x

null

x

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-2

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Authority To Collect, Use, Maintain & Share Personal Data

PRI-04.1

Mechanisms exist to determine and document the legal authority that permits the collection, use, maintenance and sharing of Personal Data (PD), either generally or in support of a specific program or system need.

null

E-PRI-02

Does the organization determine and document the legal authority that permits the collection, use, maintenance and sharing of Personal Data (PD), either generally or in support of a specific program or system need?

7

Identify

null

X

null

There is no evidence of a capability to determine and document the legal authority that permits the collection, use, maintenance and sharing of Personal Data (PD), either generally or in support of a specific program or system need.

SP-CMM1 is N/A, since a structured process is required to determine and document the legal authority that permits the collection, use, maintenance and sharing of Personal Data (PD), either generally or in support of a specific program or system need.

SP-CMM2 is N/A, since a well-defined process is required to determine and document the legal authority that permits the collection, use, maintenance and sharing of Personal Data (PD), either generally or in support of a specific program or system need.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies collect, store, processes, transmit share or use PD only for the purposes identified in the data privacy notice.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to determine and document the legal authority that permits the collection, use, maintenance and sharing of Personal Data (PD), either generally or in support of a specific program or system need.

P3.1

P6.7-POF1

null

DSP-12

null

1.2.5 1.2.11 4.2.2

null

7.2.2 7.3.1 7.3.2 7.5 7.5.1 7.5.2 8.1 8.2 8.2.1 8.5.1 8.5.7

5.4

null

MAP 1.6

CT.DP-P4

null

AP-1

null

PT-2

null

P.5

null

COMP:SG2.SP1

null

AP-1

null

1.2 1.4 PT-2

null

7002(a) 7002(e) 7002(f)

null

6-1-1308(4)

Sec 15(b)

Sec 10(b)(1) Sec 10(b)(3)

null

59.1-578.A.1 59.1-578.A.2

§ 2433(a)(2)(A) § 2433(a)(2)(B) § 2433(a)(2)(C)

null

Art 6

Art 5.1

null

Sec 6

Art 4-7

Art 9

Art 6

Sec 6 Sec 7

Art 7

Sec 4

null

Art 4

Sec 4 Sec 5

Sec 2

null

Sec 11

25(c) 28(2)(a) 28(2)(b) 28(2)(c) 28(2)(d) 28(2)(e) 28(2)(f) 28(2)(f)(i) 28(2)(f)(ii) 28(2)(f)(iii) 28(3) 30(1)(a) 30(1)(b)(i) 30(1)(b)(ii) 30(1)(b)(iii) 30(1)(b)(iv) 30(1)(b)(v) 30(1)(b)(vi) 30(1)(b)(vii) 30(1)(b)(viii) 30(2) 30(3) 33(1)(a) 33(1)(b) 33(2) 33(3)(a) 33(3)(b) 33(3)(c) 33(3)(d) 33(3)(e) 33(4) 36 37(1)(a) 37(1)(b) 37(2)

null

Sec 8

2.1(1)(a) 2.1(1)(a)(i) 2.1(1)(a)(ii) 2.2(a) 2.2(b) 2.2(c) 2.2(d) 2.2(e) 2.4(a)

null

Art 23

Art 5

Article 9.2 Article 18.1 Article 18.2 Article 18.3 Article 18.4

Art 5

null

Article 5.1 Article 5.2 Article 6.1 Article 6.2 Article 6.3 Article 6.4 Article 6.5 Article 7 Article 7.1 Article 7.2 Article 14 Article 20

null

Sec 2 Sec 3 Sec 4

Art 8

null

Sec 10

Art 4

Art 10

Sec 9

null

Article 5(1)(a) Article 11(1) Article 11(2) Article 18(2)

null

APP Part 3

APP 3 APP 7

null

Article 5 Article 10 Article 13 Article 13(1) Article 13(2) Article 13(3) Article 13(4) Article 13(5) Article 13(6) Article 13(7) Article 18 Article 26 Article 29 Article 30 Article 47

null

Sec 5

null

Article 17(1) Article 17(2) Article 17(2)(i) Article 17(2)(ii) Article 17(2)(iii) Article 17(2)(iv) Article 17(2)(v) Article 17(2)(vi)

null

Sec 19

Sec 17

null

Art 3 Art 15

Art 5 Art 19

Art 5

Art 5.2 Art 7.1 Art 7.2 Art 7.4 Art 8

Sec 6

null

Art 6.1 Art 10 Art 11

null

Sec 5 Principle 4

null

Art 4

null

Art 7

Art 4 Art 14

Art 5

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-2

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Primary Sources

PRI-04.2

Mechanisms exist to ensure information is directly collected from the data subject, whenever possible.

null

Does the organization ensure information is directly collected from the data subject, whenever possible?

7

Identify

null

X

null

There is no evidence of a capability to ensure information is directly collected from the data subject, whenever possible.

SP-CMM1 is N/A, since a structured process is required to ensure information is directly collected from the data subject, whenever possible.

SP-CMM2 is N/A, since a well-defined process is required to ensure information is directly collected from the data subject, whenever possible.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure information is directly collected from the data subject, whenever possible.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure information is directly collected from the data subject, whenever possible.

null

P3.1-POF3

null

P.5.4

null

28(1) 28(2)(a) 28(2)(b) 28(2)(c) 28(2)(d) 28(2)(e) 28(2)(f) 28(2)(f)(i) 28(2)(f)(ii) 28(2)(f)(iii)

null

Article 10

null

Principle 2 P2-(1) P2-(2) P2-(2)(a) P2-(2)(b) P2-(2)(c) P2-(2)(d) P2-(2)(e)(i) P2-(2)(e)(ii) P2-(2)(e)(iii) P2-(2)(e)(iv) P2-(2)(e)(v) P2-(2)(f) P2-(2)(g)(i) P2-(2)(g)(ii)

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-4 R-GV-6 R-GV-7

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

null

R-GV-4

null

R-GV-6

R-GV-7

null

NT-7 MT-1 MT-2 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Identifiable Image Collection

PRI-04.3

Mechanisms exist to restrict the collection, processing, storage and sharing of photographic and/or video surveillance image collection that can identify individuals to legitimate business needs.

- Privacy Program

null

Does the organization restrict the collection, processing, storage and sharing of photographic and/or video surveillance image collection that can identify individuals to legitimate business needs?

7

Identify

null

X

There is no evidence of a capability to restrict the collection, processing, storage and sharing of photographic and/ or video surveillance image collection that can identify individuals to legitimate business needs.

SP-CMM1 is N/A, since a structured process is required to restrict the collection, processing, storage and sharing of photographic and/ or video surveillance image collection that can identify individuals to legitimate business needs.

SP-CMM2 is N/A, since a well-defined process is required to restrict the collection, processing, storage and sharing of photographic and/ or video surveillance image collection that can identify individuals to legitimate business needs.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to restrict the collection, processing, storage and sharing of photographic and/ or video surveillance image collection that can identify individuals to legitimate business needs.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to restrict the collection, processing, storage and sharing of photographic and/ or video surveillance image collection that can identify individuals to legitimate business needs.

null

P.1.2.2

null

Article 26

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Acquired Personal Data

PRI-04.4

Mechanisms exist to promptly inform data subjects of the utilization purpose when their Personal Data (PD) is acquired and not received directly from the data subject, except where that utilization purpose was disclosed in advance to the data subject.

null

Does the organization promptly inform data subjects of the utilization purpose when their Personal Data (PD) is acquired and not received directly from the data subject, except where that utilization purpose was disclosed in advance to the data subject?

6

Identify

null

X

There is no evidence of a capability to promptly inform data subjects of the utilization purpose when their Personal Data (PD) is acquired and not received directly from the data subject, except where that utilization purpose was disclosed in advance to the data subject.

SP-CMM1 is N/A, since a structured process is required to promptly inform data subjects of the utilization purpose when their Personal Data (PD) is acquired and not received directly from the data subject, except where that utilization purpose was disclosed in advance to the data subject.

SP-CMM2 is N/A, since a well-defined process is required to promptly inform data subjects of the utilization purpose when their Personal Data (PD) is acquired and not received directly from the data subject, except where that utilization purpose was disclosed in advance to the data subject.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to promptly inform data subjects of the utilization purpose when their Personal Data (PD) is acquired and not received directly from the data subject, except where that utilization purpose was disclosed in advance to the data subject.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to promptly inform data subjects of the utilization purpose when their Personal Data (PD) is acquired and not received directly from the data subject, except where that utilization purpose was disclosed in advance to the data subject.

null

P.9.7

null

Article 20

null

Article 18(1) Article 18(2) Article 18(4)(i) Article 18(4)(ii) Article 18(4)(iii) Article 18(4)(iv)

null

R-AM-3 R-GV-1 R-GV-5

null

R-AM-3

null

R-GV-1

null

R-GV-5

null

MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Validate Collected Personal Data

PRI-04.5

Mechanisms exist to ensure that the data subject, or authorized representative, validate Personal Data (PD) during the collection process.

null

Does the organization ensure that the data subject, or authorized representative, validate Personal Data (PD) during the collection process?

1

Identify

null

X

There is no evidence of a capability to ensure that the data subject, or authorized representative, validate Personal Data (PD) during the collection process.

SP-CMM1 is N/A, since a structured process is required to ensure that the data subject, or authorized representative, validate Personal Data (PD) during the collection process.

SP-CMM2 is N/A, since a well-defined process is required to ensure that the data subject, or authorized representative, validate Personal Data (PD) during the collection process.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure that the data subject, or authorized representative, validate Personal Data (PD) during the collection process.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure that the data subject, or authorized representative, validate Personal Data (PD) during the collection process.

null

DI-1(1)

null

DI-1(1)

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-2

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Re-Validate Collected Personal Data

PRI-04.6

Mechanisms exist to ensure that the data subject, or authorized representative, re-validate that Personal Data (PD) acquired during the collection process is still accurate.

null

Does the organization ensure that the data subject, or authorized representative, re-validate that Personal Data (PD) acquired during the collection process is still accurate?

1

Identify

null

X

There is no evidence of a capability to ensure that the data subject, or authorized representative, re-validate that Personal Data (PD) acquired during the collection process is still accurate.

SP-CMM1 is N/A, since a structured process is required to ensure that the data subject, or authorized representative, re-validate that Personal Data (PD) acquired during the collection process is still accurate.

SP-CMM2 is N/A, since a well-defined process is required to ensure that the data subject, or authorized representative, re-validate that Personal Data (PD) acquired during the collection process is still accurate.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure that the data subject, or authorized representative, re-validate that Personal Data (PD) acquired during the collection process is still accurate.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure that the data subject, or authorized representative, re-validate that Personal Data (PD) acquired during the collection process is still accurate.

null

DI-1(2)

null

DI-1(2)

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-2

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Personal Data Retention & Disposal

PRI-05

Mechanisms exist to: ▪ Retain Personal Data (PD), including metadata, for an organization-defined time period to fulfill the purpose(s) identified in the notice or as required by law; ▪ Dispose of, destroys, erases, and/or anonymizes the PD, regardless of the method of storage; and ▪ Use organization-defined techniques or methods to ensure secure deletion or destruction of PD (including originals, copies and archived records).

null

E-AST-11 E-PRI-02

Does the organization: ▪ Retain Personal Data (PD), including metadata, for an organization-defined time period to fulfill the purpose(s) identified in the notice or as required by law; ▪ Dispose of, destroys, erases, and/or anonymizes the PD, regardless of the method of storage; and ▪ Use organization-defined techniques or methods to ensure secure deletion or destruction of PD (including originals, copies and archived records)?

8

Identify

null

X

There is no evidence of a capability to: ▪ Retain Personal Data (PD), including metadata, for an organization-defined time period to fulfill the purpose(s) identified in the notice or as required by law; ▪ Dispose of, destroys, erases, and/ or anonymizes the PD, regardless of the method of storage; and ▪ Use organization-defined techniques or methods to ensure secure deletion or destruction of PD (including originals, copies and archived records).

Privacy (PRI) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • No formal data privacy team exists. Privacy roles are assigned to existing IT / cybersecurity. • Formal roles and responsibilities for data privacy may exist. • No formal data privacy principles are identified for the organization. • An ad hoc approach to Data Protection Impact Assessment (DPIA) exists.

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices. • Administrative processes and technologies retain PD, including metadata, for an organization-defined time period to fulfill the purpose(s) identified in the data privacy notice, or as required by law. • Administrative processes and technologies dispose of, destroy, erase, and/ or anonymize the PD, regardless of the method of storage.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies retain PD, including metadata, for an organization-defined time period to fulfill the purpose(s) identified in the data privacy notice, or as required by law. • Administrative processes and technologies dispose of, destroy, erase, and/ or anonymize the PD, regardless of the method of storage.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Privacy (PRI) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

CC6.5 C1.2 P4.0 P4.2 P4.3

CC6.5-POF1 C1.2-POF2 P4.2-POF1 P4.3-POF2 P4.3-POF3

null

3.5

null

DSP-16

null

5.2.2 5.2.3

null

18.1.4

5.33 8.10

18.1.4

A.4.1 A.9.2 A.9.3 A.10.2 A.10.7 A.10.8 A.10.9

7.4.2 7.4.8 8.2.3 8.4.2

5.6

null

CT.DM-P5

null

DM-2

null

AC-4(25) SI-12 SI-12(3)

SI-12 SI-12(3)

SI-12

AC-4(25)

null

SI-12

3.4.14

SI-12

null

SI-12

null

3.2 3.2.1 3.2.2 3.2.3

9.4.6 9.4.7 10.5.1

9.4.6

9.4.6 10.5.1

9.4.6

9.4.6 10.5.1

9.4.6

9.4.6 9.4.7 10.5.1

9.4.6

P.7.1

null

KIM:SG4.SP3

null

4.2.2 4.2.3.1 4.2.3.2 4.3

null

DM-2

null

§ 1232g

null

314.4(c)(6)(i)

164.502 164.502(a) 164.502(a)(1) 164.502(a)(2) 164.502(a)(3) 164.502(a)(4) 164.502(a)(5) 164.502(b) 164.502(b)(1) 164.502(b)(2) 164.502(c) 164.502(d) 164.502(d)(1) 164.502(d)(2) 164.502(e) 164.502(e)(1) 164.502(e)(2) 164.502(f) 164.502(g) 164.502(g)(1) 164.502(g)(2) 164.502(g)(3) 164.502(g)(4) 164.502(g)(5) 164.502(h) 164.502(i) 164.502(j) 164.504 164.506 164.508 164.510 164.512 164.514

null

9.L.C

2.F.1 2.F.3 SI-12

null

Principle 5

null

5.8

null

45.48.500

null

Sec 15(a) Sec 15(b)(2)

null

Sec 40(a) Sec 40(b) Sec 40(b)(1) Sec 40(b)(2) Sec 40(c) Sec 40(d) Sec 40(e) Sec 40(f)

null

500.13

Sec 4(2)(b)(ii)(C)(4)

null

Sec. 521.052(b)

null

SI-12

null

Art 5 Art 7 Art 8 Art 13

Art 5.1 Art 18.1 Art 18.2 Art 21.1 Art 21.2 Art 21.3

null

Art 24

Principle 2.5.b

Sec 7

Art 4-7 Art 21

Art 5 Art 6 Art 20

Art 6

Sec 11 Sec 21 Sec 34 Sec 35

Art 6 Art 36

Sec 3a Sec 5 Sec 13 Sec 14 Sec 20

null

OPS-11 OPS-12 PI-03

Art 4 Art 7

Sec 5

Sec 2

15.4

Sec 8

Sec 11

25(g) 34(3) 39(1) 39(1)(a) 39(1)(b) 39(1)(c) 39(1)(d) 39(2)

Art 5-1

Sec 6 Sec 7 Sec 9 Sec 10 Sec 12

2.1(1)(c)

Sec 8 Sec 11 Sec 15 Sec 27 Sec 28

Art 23 Art 26

Art 5

null

Art 5

null

3.3.11

null

Article 5.5 Article 8

Sec 5 Sec 6

Sec 4 Sec 14 Sec 16

Art 8 Art 22

null

Sec 9

Art 4

Art 5 Art 7

Sec 8

null

Chapter29-Schedule1-Part1-Principle 5

null

APP Part 3 APP Part 6

APP 4 APP 6

null

Article 10 Article 19 Article 47 Article 47(1) Article 47(2) Article 47(3) Article 47(4) Article 47(5)

Principle 2 Sec 26 Principle 3 Sec 4

Sec 5

Art 46

Article 19

18.1.4

Sec 5 Sec 6 Sec 10

null

Sec 19 Sec 21

Sec 23 Sec 25

null

11.1.7

Art 3 Art 4 Art 15 Art 19 Art 21 Art 37

Art 5 Art 19

Art 4

Art 5.1 Art 4.3 Art 9.2

Sec 6 Sec 12

null

Art 6.2 Art 6.9 Art 13 Art 14 Art 15 Art 21

null

Sec 7 Sec 8 Principle 5 Principle 6

Art 9

Art 4

Art 6

Art 7 Art 8 Art 9 Art 11 Art 12 Art 13 Art 14

Art 7 Art 8 Art 14

Art 5 Art 6 Art 20 Art 21 Art 22

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Internal Use of Personal Data For Testing, Training and Research

PRI-05.1

Mechanisms exist to address the use of Personal Data (PD) for internal testing, training and research that: ▪ Takes measures to limit or minimize the amount of PD used for internal testing, training and research purposes; and ▪ Authorizes the use of PD when such information is required for internal testing, training and research.

null

E-PRI-02

Does the organization address the use of Personal Data (PD) for internal testing, training and research that: ▪ Takes measures to limit or minimize the amount of PD used for internal testing, training and research purposes; and ▪ Authorizes the use of PD when such information is required for internal testing, training and research?

8

Identify

null

X

null

There is no evidence of a capability to address the use of Personal Data (PD) for internal testing, training and research that: ▪ Takes measures to limit or minimize the amount of PD used for internal testing, training and research purposes; and ▪ Authorizes the use of PD when such information is required for internal testing, training and research.

SP-CMM1 is N/A, since a structured process is required to address the use of Personal Data (PD) for internal testing, training and research that: ▪ Takes measures to limit or minimize the amount of PD used for internal testing, training and research purposes; and ▪ Authorizes the use of PD when such information is required for internal testing, training and research.

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices. • Administrative processes and technologies collect, store, processes, transmit share or use PD only for the purposes identified in the data privacy notice.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies collect, store, processes, transmit share or use PD only for the purposes identified in the data privacy notice.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to address the use of Personal Data (PD) for internal testing, training and research that: ▪ Takes measures to limit or minimize the amount of PD used for internal testing, training and research purposes; and ▪ Authorizes the use of PD when such information is required for internal testing, training and research.

P4.1

null

DSP-12 DSP-15

null

7.2.2 9.2.1 9.2.2

null

18.1.4

5.33

18.1.4

null

7.4.2

5.6

null

MAP 1.6

CT.PO-P1 CT.PO-P2

null

DM-1 DM-3 DM-3(1)

null

PM-25 PT-2 PT-3 SI-12(1) SI-12(2)

PM-25 PT-2 SI-12(1) SI-12(2)

null

PM-25

null

PM-25

null

6.4 6.4.3

6.5.5

null

6.5.5

null

P.7.4

null

9.2 9.4

null

COMP:SG2.SP1 COMP:SG3.SP1 KIM:SG2.SP1 KIM:SG2.SP2

null

4.2.2 4.2.3.1 4.2.3.2 4.3

null

DM-1 DM-3 DM-3(1)

6,502

null

§ 1232g

null

1.2 1.4 PT-2 SI-12(2)

null

5.8

null

7002(d) 7002(d)(1) 7002(d)(2) 7002(d)(3)

null

6-1-1308(4)

null

Sec 2.3

null

59.1-578.A.2 59.1-578.A.4 59.1-578.A.5

null

Art 5 Art 7

Art 5.1 Art 11.1 Art 18.1 Art 18.2

null

Principle 2.5.a Principle 2.5.b

Sec 12

Art 4-7 Art 21

Art 9 Art 13

null

Art 8 Art 9

null

Sec 9

null

Sec 8

Sec 13 Sec 20

25(a) 25(b) 25(c) 28(2)(a) 28(2)(b) 28(2)(c) 28(2)(d) 28(2)(e) 28(2)(f) 28(2)(f)(i) 28(2)(f)(ii) 28(2)(f)(iii) 28(3) 30(1)(a) 30(1)(b)(i) 30(1)(b)(ii) 30(1)(b)(iii) 30(1)(b)(iv) 30(1)(b)(v) 30(1)(b)(vi) 30(1)(b)(vii) 30(1)(b)(viii) 30(2) 30(3) 33(1)(a) 33(1)(b) 33(2) 33(3)(a) 33(3)(b) 33(3)(c) 33(3)(d) 33(3)(e) 33(4) 34(1)(a) 34(1)(b) 34(1)(c) 34(1)(d) 34(2)(a) 34(2)(b) 34(3) 36 37(1)(a) 37(1)(b) 37(2) 53(1) 53(2) 53(3)(a) 53(3)(b) 53(4)

null

Sec 11

2.1(1)(b) 3.1(12)

Sec 11 Sec 27

Art 26

null

Article 8.2 Article 9.4

null

Article 5.1 Article 5.3 Article 7 Article 7.1 Article 7.2 Article 20

null

Sec 10

Art 8

null

Sec 8

null

Chapter29-Schedule1-Part1-Principle 3

Article 5(1)(c)

null

APP Part 3

APP 6

null

Article 13 Article 13(1) Article 13(2) Article 13(3) Article 13(4) Article 13(5) Article 13(6) Article 13(7) Article 28 Article 47

null

Article 16-2

18.1.4

null

Principle 10 P10-(1) P10-(1)(a) P10-(1)(b)(i) P10-(1)(b)(ii) P10-(1)(c) P10-(1)(d) P10-(1)(e)(i) P10-(1)(e)(ii) P10-(1)(e)(iii) P10-(1)(e)(iv) P10-(1)(f)(i) P10-(1)(f)(ii) P10-(2)

Sec 19

null

Art 3

null

Art 4

Art 7.3 Art 9.2

Sec 6

null

Art 4

null

Art 5 Art 6 Art 20 Art 21 Art 22

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Personal Data Accuracy & Integrity

PRI-05.2

Mechanisms exist to confirm the accuracy and relevance of Personal Data (PD) throughout the information lifecycle.

null

Does the organization confirm the accuracy and relevance of Personal Data (PD) throughout the information lifecycle?

5

Identify

null

X

null

There is no evidence of a capability to confirm the accuracy and relevance of Personal Data (PD) throughout the information lifecycle.

SP-CMM1 is N/A, since a structured process is required to confirm the accuracy and relevance of Personal Data (PD) throughout the information lifecycle.

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • A Chief Data Officer (CDO), or similar function, oversees processes to ensure the quality, utility, objectivity, integrity, impact determination and de-identification of PD across the information lifecycle, including methods to identify and eliminate potential biases.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to confirm the accuracy and relevance of Personal Data (PD) throughout the information lifecycle.

null

9.2.1

null

7.4.3

5.7

null

PR.DS-P6

null

DI-2

null

PM-24

null

P.5.3

null

COMP:SG2.SP3 EXD:SG3.SP4 KIM:SG5.SP3

null

DI-2

null

Principle 5

null

Art 7

Art 5.1

null

25(f)

null

Sec 11

null

Sec 11

null

Article 5.4

null

Sec 14 Sec 16

Art 8

null

Sec 8

null

APP Part 10

APP 10

null

Article 8

null

Article 19

null

Sec 11

null

Principle 9

null

Sec 23

null

Art 3

null

Art 4

Art 4.5

Sec 6

null

Principle 6

null

Art 4

Art 6

Art 9

Art 8

null

x

null

R-AM-3 R-BC-1 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5

null

R-AM-3

R-BC-1

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Data Masking

PRI-05.3

Mechanisms exist to mask sensitive information through data anonymization, pseudonymization, redaction or de-identification.

null

Does the organization mask sensitive information through data anonymization, pseudonymization, redaction or de-identification?

8

Identify

null

X

There is no evidence of a capability to mask sensitive information through data anonymization, pseudonymization, redaction or de-identification.

SP-CMM1 is N/A, since a structured process is required to mask sensitive information through data anonymization, pseudonymization, redaction or de-identification.

SP-CMM2 is N/A, since a well-defined process is required to mask sensitive information through data anonymization, pseudonymization, redaction or de-identification.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Technologies are configured to mask sensitive/regulated data that is displayed or printed.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to mask sensitive information through data anonymization, pseudonymization, redaction or de-identification.

null

8.11

null

SI-19(4)

null

SI-19(4)

null

3.3

3.4.1

null

3.4.1

null

P.7.7

null

Art 7

Art 5.1

null

APP Part 2

null

Art 3

null

Art 4.4

null

x

null

R-AM-3 R-BC-1 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5

null

R-AM-3

R-BC-1

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Usage Restrictions of Sensitive Personal Data

PRI-05.4

Mechanisms exist to restrict the use of Personal Data (PD) to only the authorized purpose(s) consistent with applicable laws, regulations and in data privacy notices.

null

Does the organization restrict the use of Personal Data (PD) to only the authorized purpose(s) consistent with applicable laws, regulations and in data privacy notices?

8

Identify

null

X

There is no evidence of a capability to restrict the use of Personal Data (PD) to only the authorized purpose(s) consistent with applicable laws, regulations and in data privacy notices.

SP-CMM1 is N/A, since a structured process is required to restrict the use of Personal Data (PD) to only the authorized purpose(s) consistent with applicable laws, regulations and in data privacy notices.

SP-CMM2 is N/A, since a well-defined process is required to restrict the use of Personal Data (PD) to only the authorized purpose(s) consistent with applicable laws, regulations and in data privacy notices.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to restrict the use of Personal Data (PD) to only the authorized purpose(s) consistent with applicable laws, regulations and in data privacy notices.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to restrict the use of Personal Data (PD) to only the authorized purpose(s) consistent with applicable laws, regulations and in data privacy notices.

P4.0 P4.1

P4.1-POF1

null

DSP-12 DSP-17

null

5.2.1 9.2.2

null

18.1.4

5.33

18.1.4

null

7.4.2 7.4.4 8.2.3

5.6

null

T1005, T1025, T1041, T1048, T1048.002, T1048.003, T1052, T1052.001, T1133, T1213, T1213.001, T1213.002, T1552.007, T1567

null

CT.DM-P8 CT.DP-P4 CT.PO-P1 CT.PO-P2

null

DM-3(1) UL-1

null

AC-23 PM-25 PT-2 PT-7

PM-25 PT-2 PT-7

null

AC-23

null

AC-23 PM-25

null

AC-23

null

AC-23 PM-25

AC-23

null

6.4 6.4.3

6.5.5

null

6.5.5

null

P.1.5

null

9.2 9.4

null

COMP:SG2.SP1 COMP:SG3.SP1 KIM:SG2.SP1 KIM:SG2.SP2

null

4.2.2 4.2.3.1 4.2.3.2 4.3

null

DM-3(1) UL-1

6,502

null

§ 1232g

null

AC-23 PT-2

null

Principle 5

null

5.8

null

7002(d) 7002(d)(1) 7002(d)(2) 7002(d)(3) 7027(a) 7027(b) 7027(b)(1) 7027(b)(2) 7027(b)(3) 7027(b)(4) 7027(c) 7027(d) 7027(e) 7027(f) 7027(g)(1) 7027(g)(2) 7027(g)(3) 7027(h) 7027(i) 7027(j) 7027(k) 7027(l) 7027(m) 7027(m)(1) 7027(m)(2) 7027(m)(3) 7027(m)(4) 7027(m)(5) 7027(m)(6) 7027(m)(7) 7027(m)(8)

null

6-1-1305(2) 6-1-1308(4) 6-1-1308(7)

Sec 15(b)(2)

null

Sec 2.3

null

59.1-578.A.2 59.1-578.A.4 59.1-578.A.5

null

Art 5 Art 7

Art 5.1 Art 9.1 Art 9.2 Art 10 Art 11.1 Art 18.1 Art 18.2

null

Principle 2.2.c Principle 2.2.c(i) Principle 2.2.c(ii) Principle 2.5.a Principle 2.5.b

Sec 12

Art 4-7 Art 21

Art 9 Art 13

null

Art 8 Art 9

null

Sec 9

null

Sec 8

Sec 13 Sec 20

44 45(a) 45(a)(i) 45(a)(ii) 45(b) 45(c)(i) 45(c)(ii) 45(c)(iii) 46(1)(a) 46(1)(b) 46(2)(a) 46(2)(b) 47(1) 47(2)(a) 47(2)(b) 47(2)(c) 47(2)(d) 47(3)

null

Sec 9

3.1(12)

Sec 9

Art 27

Art 7

Article 8.2 Article 9.4 Article 10 Article 16 Article 22

Art 6 Art 10

null

Article 5.1 Article 5.3 Article 17 Article 17.1 Article 17.2 Article 17.3 Article 17.4 Article 17.5 Article 17.6 Article 17.7 Article 17.8 Article 17.9 Article 17.10 Article 18.1 Article 18.2 Article 18.3 Article 19

null

Sec 15 Sec 26

null

Sec 13

null

Art 6

Sec 10

null

Chapter29-Schedule1-Part1-Principle 3

Article 9(1) Article 10

null

APP Part 3

APP 6 APP 7 APP 9

null

Article 13 Article 13(1) Article 13(2) Article 13(3) Article 13(4) Article 13(5) Article 13(6) Article 13(7) Article 18 Article 28 Article 29 Article 30 Article 31 Article 32

null

Article 16-2

18.1.4

Sec 34

null

Principle 10 P10-(1) P10-(1)(a) P10-(1)(b)(i) P10-(1)(b)(ii) P10-(1)(c) P10-(1)(d) P10-(1)(e)(i) P10-(1)(e)(ii) P10-(1)(e)(iii) P10-(1)(e)(iv) P10-(1)(f)(i) P10-(1)(f)(ii) P10-(2)

Sec 19 Sec 22 Sec 34

Sec 14

null

Art 16 Art 18 Art 23

Art 5

Art 6 Art 7

Art 4.3

Sec 12

null

Art 10

Art 4 Art 5 Art 6 Art 7

Art 9

Art 7 Art 9

null

Art 5 Art 6 Art 18 Art 19 Art 20 Art 21 Art 22

null

x

null

x

R-AM-3 R-BC-1 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-SA-1 R-SA-2

null

R-AM-3

R-BC-1

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Inventory of Personal Data

PRI-05.5

Mechanisms exist to establish, maintain and update an inventory that contains a listing of all programs and systems identified as collecting, using, maintaining, or sharing Personal Data (PD).

null

E-AST-08

Does the organization establish, maintain and update an inventory that contains a listing of all programs and systems identified as collecting, using, maintaining, or sharing Personal Data (PD)?

8

Identify

null

X

null

There is no evidence of a capability to establish, maintain and update an inventory that contains a listing of all programs and systems identified as collecting, using, maintaining, or sharing Personal Data (PD).

SP-CMM1 is N/A, since a structured process is required to establish, maintain and update an inventory that contains a listing of all programs and systems identified as collecting, using, maintaining, or sharing Personal Data (PD).

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices. • Administrative processes and technologies establish, maintain and update an inventory that contains a listing of all systems, applications, services and third-parties that store, process and/ or transmit PD.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies establish, maintain and update an inventory that contains a listing of all systems, applications, services and third-parties that store, process and/ or transmit PD.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to establish, maintain and update an inventory that contains a listing of all programs and systems identified as collecting, using, maintaining, or sharing Personal Data (PD).

null

7.2.2

null

ID.IM-P1 ID.IM-P3 ID.IM-P6

null

SE-1

null

PM-5(1)

null

ID.AM-07

null

D.1.1

null

ADM:SG2.SP1 ADM:SG3.SP1 MON:SG2.SP3 MON:SG2.SP4

null

SE-1

null

PM-5(1)

null

Art 3

null

B3.e

null

Art 33

null

3.1.4

null

x

null

R-AC-1 R-AC-2 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-4 R-SA-1

R-AC-1

R-AC-2

null

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Personal Data Inventory Automation Support

PRI-05.6

Automated mechanisms exist to determine if Personal Data (PD) is maintained in electronic form.

null

Does the organization use automated mechanisms to determine if Personal Data (PD) is maintained in electronic form?

1

Identify

null

X

There is no evidence of a capability to determine if Personal Data (PD) is maintained in electronic form.

SP-CMM1 is N/A, since a structured process is required to determine if Personal Data (PD) is maintained in electronic form.

SP-CMM2 is N/A, since a well-defined process is required to determine if Personal Data (PD) is maintained in electronic form.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to determine if Personal Data (PD) is maintained in electronic form.

null

ID.IM-P1 ID.IM-P3 ID.IM-P6

null

PM-5(1)

null

P.1.6.4

null

Art 13

null

Art 16

null

Sec 29

null

R-AC-1 R-AC-2 R-AC-4 R-AM-3 R-BC-1 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-IR-1 R-IR-2 R-IR-4 R-SA-1

R-AC-1

R-AC-2

null

R-AC-4

null

R-AM-3

R-BC-1

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-1

R-IR-2

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

null

Data Privacy

Personal Data Categories

PRI-05.7

Mechanisms exist to define and implement data handling and protection requirements for specific categories of sensitive Personal Data (PD).

null

E-PRI-07

Does the organization define and implement data handling and protection requirements for specific categories of sensitive Personal Data (PD)?

5

Identify

null

X

null

There is no evidence of a capability to define and implement data handling and protection requirements for specific categories of sensitive Personal Data (PD).

SP-CMM1 is N/A, since a structured process is required to define and implement data handling and protection requirements for specific categories of sensitive Personal Data (PD).

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to define and implement data handling and protection requirements for specific categories of sensitive Personal Data (PD).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to define and implement data handling and protection requirements for specific categories of sensitive Personal Data (PD).

null

PT-7 PT-7(1) PT-7(2)

null

D.3.1

null

7002(f)

null

59.1-578.C.1 59.1-578.C.2 59.1-578.C.3 59.1-578.C.4 59.1-578.C.5

null

47(1) 47(2)(a) 47(2)(b) 47(2)(c) 47(2)(d) 47(3)

null

Article 9 Article 9.1 Article 9.2 Article 9.3 Article 9.4 Article 9.5 Article 10 Article 13

null

APP 9

null

Article 51(2)

null

R-AM-3 R-BC-1 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5

null

R-AM-3

R-BC-1

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Data Subject Access

PRI-06

Mechanisms exist to provide data subjects the ability to access their Personal Data (PD) maintained in organizational systems of records.

null

E-PRI-06

Does the organization provide data subjects the ability to access their Personal Data (PD) maintained in organizational systems of records?

6

Identify

null

X

null

There is no evidence of a capability to provide data subjects the ability to access their Personal Data (PD) maintained in organizational systems of records.

SP-CMM1 is N/A, since a structured process is required to provide data subjects the ability to access their Personal Data (PD) maintained in organizational systems of records.

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices. • Administrative processes and technologies provide data subjects the ability to access their PD maintained in organizational systems of records.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies provide data subjects the ability to access their PD maintained in organizational systems of records.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide data subjects the ability to access their Personal Data (PD) maintained in organizational systems of records.

P5.0 P5.1

P5.1-POF1 P5.1-POF2 P5.1-POF3

null

DSP-11

null

6.2.1 6.2.2 6.2.3 6.2.4 6.2.5 6.2.6

null

A.8

7.3.6 8.2.5

5.9

null

CT.DM-P1

null

IP-2

null

AC-3(14) SI-18(4)

null

P.5.5.6.3

null

AM:SG1.SP1 COMP:SG3.SP1 EF:SG2.SP1 EF:SG2.SP2

null

IP-2

null

§ 1232g

null

164.522 164.522(a) 164.522(a)(1) 164.522(a)(2) 164.522(a)(3) 164.524 164.524(a) 164.524(b) 164.524(c) 164.524(d) 164.524(e)

null

Principle 6

null

7024(a) 7024(b) 7024(c) 7024(c)(1) 7024(c)(2) 7024(c)(3) 7024(c)(4) 7024(d) 7024(e) 7024(f) 7024(g) 7024(h) 7024(i) 7024(j) 7024(k) 7024(k)(1) 7024(k)(2) 7024(k)(3) 7024(k)(4) 7024(k)(5) 7024(k)(6) 7024(l)

null

6-1-1306(1)(b)

null

Sec 2.1

null

59.1-577.A 59.1-577.A.1 59.1-577.A.2 59.1-577.A.3 59.1-577.A.4 59.1-577.A.5 59.1-577.B 59.1-577.B.1 59.1-577.B.2 59.1-577.B.3 59.1-577.B.4 59.1-577.B.5 59.1-577.C 59.1-581.C 59.1-581.C.1 59.1-581.C.2 59.1-581.C.3

null

Art 12.1 Art 12.2 Art 13.2 Art 14.2 Art 15.1 Art 15.2 Art 15.3 Art 15.4 Art 16 Art 26.3

null

Principle 2.6.a

Sec 26

Art 10 Art 12

Art 12

null

Sec 24 Sec 26

Art 39

Sec 19

null

Art 11 Art 12

Sec 14 Sec 15

Sec 2

null

Sec 13

Sec 7

26(a) 26(b) 26(c) 26(d) 26(e)

null

Sec 35

3.1(1) 3.1(3) 3.1(3)(a) 3.1(3)(b)

Sec 18

Art 32

Art 10 Art 11

Article 6 Article 21.1 Article 21.2

Art 14

null

Article 21 Article 23 Article 24 Article 25 Article 26 Article 28.1 Article 28.2 Article 28.3 Article 28.4 Article 28.5

null

Sec 23

Art 23 Art 24 Art 27 Art 28 Art 29

null

Art 8

Art 11

Sec 17

null

Article 5(1)(e) Article 12(1) Article 12(2) Article 12(3) Article 12(4) Article 12(5) Article 12(6) Article 12(7) Article 15(1)(a) Article 15(1)(b) Article 15(1)(c) Article 15(1)(d) Article 15(1)(e) Article 15(1)(f) Article 15(1)(g) Article 15(1)(h) Article 15(3) Article 15(4)

null

APP Part 12

APP 12

null

Article 45 Article 46 Article 49

Principle 6 Sec 17A Sec 18

null

Article 27(1) Article 27(1)(i) Article 27(1)(ii) Article 27(1)(iii) Article 27(1)(iv) Article 27(2)(i) Article 27(2)(ii) Article 27(3) Article 28(1) Article 28(2) Article 28(2)(i) Article 28(2)(ii) Article 28(2)(iii) Article 28(3) Article 28(4) Article 28(5)

null

Sec 12 Sec 30

null

Principle 6 P6-(1) P6-(1)(a) P6-(1)(b) P6-(2) P6-(3)

Sec 34

Sec 21

null

Art 4 Art 35

Art 3

Art 14 Art 15

Art 4.6 Art 13 Art 14.1 Art 14.2 Art 14.3 Art 14.4

Sec 8

null

Art 6.4 Art 9 Art 17 Art 18.1 Art 18.2 Art 20

null

Principle 8 Principle 9

Art 12

Art 8 Art 11

Art 7

Art 15 Art 22 Art 23 Art 25

Art 10 Art 18 Art 19

Art 14

null

x

null

x

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Correcting Inaccurate Personal Data

PRI-06.1

Mechanisms exist to establish and implement a process for: ▪ Data subjects to have inaccurate Personal Data (PD) maintained by the organization corrected or amended; and ▪ Disseminating corrections or amendments of PD to other authorized users of the PD.

- Data Protection Impact Assessment (DPIA)

null

Does the organization establish and implement a process for: ▪ Data subjects to have inaccurate Personal Data (PD) maintained by the organization corrected or amended; and ▪ Disseminating corrections or amendments of PD to other authorized users of the PD?

5

Respond

null

X

null

There is no evidence of a capability to establish and implement a process for: ▪ Data subjects to have inaccurate Personal Data (PD) maintained by the organization corrected or amended; and ▪ Disseminating corrections or amendments of PD to other authorized users of the PD.

SP-CMM1 is N/A, since a structured process is required to establish and implement a process for: ▪ Data subjects to have inaccurate Personal Data (PD) maintained by the organization corrected or amended; and ▪ Disseminating corrections or amendments of PD to other authorized users of the PD.

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices. • Administrative processes exist for data subjects to have inaccurate PD maintained by the organization corrected or amended.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • The CPO and DPO develop and implement a process for data subjects to have inaccurate PD maintained by the organization corrected or amended.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to establish and implement a process for: ▪ Data subjects to have inaccurate Personal Data (PD) maintained by the organization corrected or amended; and ▪ Disseminating corrections or amendments of PD to other authorized users of the PD.

P5.1 P5.2

P5.2-POF2

null

6.2.5 6.2.6 10.2.1 10.2.2

null

7.3.6

5.9

null

CM.AW-P8 CT.DM-P3

null

IP-3

null

SI-18(4) SI-18(5)

SI-18(4)

null

SI-18(5)

null

P.1.4.3

null

COMM:SG1.SP3 KIM:SG5.SP1

null

IP-3

null

164.526 164.526(a) 164.526(b) 164.526(c) 164.526(d) 164.526(e) 164.526(f)

null

Principle 7

null

7023(a) 7023(b) 7023(b)(1) 7023(b)(1)(A) 7023(b)(1)(B) 7023(b)(1)(C) 7023(b)(2) 7023(c) 7023(d)(1) 7023(d)(2) 7023(d)(2)(A) 7023(d)(2)(B) 7023(d)(2)(C) 7023(d)(2)(D) 7023(d)(3) 7023(d)(4) 7023(e) 7023(f) 7023(f)(1) 7023(f)(2) 7023(f)(3) 7023(f)(4) 7023(g) 7023(h) 7023(i) 7023(j) 7023(k)

null

6-1-1306(1)(c)

null

59.1-577.A.2

null

Art 12.3 Art 14.2 Art 16 Art 18.1 Art 26.3

null

Principle 2.6

Sec 27

Art 10 Art 12

Art 21

Art 24 Art 37

Sec 29

Art 38 Art 39

Sec 20

null

Art 13

Sec 14 Sec 15 Sec 17

Sec 2

null

Sec 14

Sec 7

25(f) 26(d) 40(1)(a) 40(2)(a)

null

Sec 36

null

Sec 27

Art 32

Art 12

Article 5.4 Article 6.2

Art 17

null

Article 5.4 Article 11 Article 29

null

Sec 24

Art 23 Art 24 Art 31 Art 32

null

Sec 28

Art 5

null

Sec 17

null

Article 5(1)(d) Article 16 Article 19

null

APP Part 13

APP 13

null

Sec 8

Article 46 Article 49

Sec 22

null

Article 26(1) Article 26(1)(i) Article 26(1)(ii) Article 29(1) Article 29(2) Article 29(3)

null

Sec 34

null

P6-(2) Principle 7 P7-(1) P7-(2) P7-(3)(a) P7-(3)(b) P7-(4) P7-(5) P7-(6)

Sec 34

Sec 22

null

Art 4 Art 36

Art 3

Art 16

Art 16.1 Art 16.3

Sec 10

null

Art 18.3

null

Principle 10

Art 13

Art 8 Art 11

Art 7

Art 24 Art 28 Art 29

Art 20

Art 15 Art 16

null

x

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

R-BC-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Notice of Correction or Processing Change

PRI-06.2

Mechanisms exist to notify affected data subjects if their Personal Data (PD) has been corrected or amended.

The organization should, in the case of having general written authorization, inform the customer of any intended changes concerning the addition or replacement of subcontractors to process PD, thereby giving the customer the opportunity to object to such changes.

null

Does the organization notify affected data subjects if their Personal Data (PD) has been corrected or amended?

4

Respond

null

X

null

There is no evidence of a capability to notify affected data subjects if their Personal Data (PD) has been corrected or amended.

SP-CMM1 is N/A, since a structured process is required to notify affected data subjects if their Personal Data (PD) has been corrected or amended.

SP-CMM2 is N/A, since a well-defined process is required to notify affected data subjects if their Personal Data (PD) has been corrected or amended.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies notify affected data subjects if their PD has been corrected or amended.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to notify affected data subjects if their Personal Data (PD) has been corrected or amended.

P5.2

P3.1-POF4 P5.2-POF2 P5.2-POF3

null

8.5.8

5.9

null

CM.AW-P1 CM.PO-P1 CT.PO-P4

null

SI-18(5)

null

SI-18(5)

null

P.5.5.6.4

null

7023(j)

null

Art 12.3 Art 18.3 Art 19 Art 26.3

null

Art 16

Art 37

null

Art 39

null

Sec 14 Sec 15 Sec 17 Sec 18

Sec 2

null

Sec 10

null

Sec 38

3.1(13)

null

Art 32

null

Article 6.2

Art 18

null

Article 34 Article 34.1 Article 34.2 Article 34.3 Article 34.4 Article 34.5

null

Sec 24

Art 23 Art 24 Art 31 Art 32

null

Article 18(3)

null

APP Part 13

APP 13

null

Article 22 Article 46 Article 49

null

Article 18(3) Article 18(4)(i) Article 18(4)(ii) Article 18(4)(iii) Article 18(4)(iv) Article 29(1) Article 29(2) Article 29(3)

null

P6-(2)

Sec 34

Sec 23

null

Art 4 Art 36

null

Art 16

Art 16.2

Sec 11

null

Art 18.9

null

Art 8 Art 11

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Appeal Adverse Decision

PRI-06.3

Mechanisms exist to provide an organization-defined process for data subjects to appeal an adverse decision and have incorrect information amended.

null

Does the organization provide an organization-defined process for data subjects to appeal an adverse decision and have incorrect information amended?

4

Respond

null

X

There is no evidence of a capability to provide an organization-defined process for data subjects to appeal an adverse decision and have incorrect information amended.

SP-CMM1 is N/A, since a structured process is required to provide an organization-defined process for data subjects to appeal an adverse decision and have incorrect information amended.

SP-CMM2 is N/A, since a well-defined process is required to provide an organization-defined process for data subjects to appeal an adverse decision and have incorrect information amended.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies provide a process for data subjects to appeal an adverse decision and have incorrect information amended.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide an organization-defined process for data subjects to appeal an adverse decision and have incorrect information amended.

P5.2

null

5.9

null

CM.AW-P8

null

PM-26

null

PM-26

null

PM-26

null

P.5.5.6.7

null

Principle 7

null

6-1-1306(3)(a) 6-1-1306(3)(b) 6-1-1306(3)(c)

null

59.1-577.C

null

Art 21.1 Art 21.2 Art 21.3 Art 26.3

null

Sec 28

null

Art 35

null

Art 38 Art 39

null

Art 13

Sec 14 Sec 15 Sec 17 Sec 18

Sec 2

null

Sec 40

null

Art 17

null

Sec 63 Sec 74

Art 23 Art 24

null

Sec 17

null

Article 31

null

Sec 34

null

Art 38

null

Art 18.9

null

Sec 11

null

Art 15

null

Art 22

Art 16

null

x

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

User Feedback Management

PRI-06.4

Mechanisms exist to implement a process for receiving and responding to complaints, concerns or questions from data subjects about the organizational data privacy practices.

null

Does the organization implement a process for receiving and responding to complaints, concerns or questions from data subjects about the organizational data privacy practices?

5

Respond

null

X

There is no evidence of a capability to implement a process for receiving and responding to complaints, concerns or questions from individuals about the organizational data privacy practices.

SP-CMM1 is N/A, since a structured process is required to implement a process for receiving and responding to complaints, concerns or questions from individuals about the organizational data privacy practices.

SP-CMM2 is N/A, since a well-defined process is required to implement a process for receiving and responding to complaints, concerns or questions from individuals about the organizational data privacy practices.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies empower data subjects to edit and/ or revoke authorizations for the organization to collect, store, processes, transmit share or use their PD.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to implement a process for receiving and responding to complaints, concerns or questions from individuals about the organizational data privacy practices.

P5.2 P8.1

P4.3-POF1 P5.1-POF4 P5.2-POF1 P5.2-POF3 P6.7-POF2 P8.1-POF1 P8.1-POF2 P8.1-POF3

null

6.2.5 6.2.6 7.1.2 10.2.1 10.2.2

null

7.3.9

5.9

null

GV.MT-P4 GV.MT-P7 CM.AW-P2 CT.PO-P4

null

IP-4 IP-4(1)

null

PM-26

null

PM-26

null

PM-26

null

P.10.1

null

OPD:SG1.SP1

null

IP-4 IP-4(1)

null

164.530(d) 164.530(d)(1) 164.530(d)(2)

null

Principle 7

null

7020(a) 7020(b) 7020(c) 7020(e) 7020(f) 7020(g) 7020(h) 7021(a) 7021(b) 7060(a) 7060(b) 7060(c)(1) 7060(c)(2) 7060(c)(3)(A) 7060(c)(3)(B) 7060(c)(3)(C) 7060(c)(3)(D) 7060(c)(3)(E) 7060(c)(3)(F) 7060(d) 7060(e) 7060(f) 7060(g) 7060(h) 7061(a) 7061(b) 7062(a) 7062(b) 7062(c) 7062(d) 7062(e) 7062(e)(1) 7062(e)(2) 7062(f) 7062(g)

null

6-1-1306(2)(a) 6-1-1306(2)(b) 6-1-1306(2)(c) 6-1-1306(2)(d)

null

Sec 2.1 Sec 2.2 Sec 2.4

null

59.1-577.A 59.1-577.A.1 59.1-577.A.2 59.1-577.A.3 59.1-577.A.4 59.1-577.A.5 59.1-577.B 59.1-577.B.1 59.1-577.B.2 59.1-577.B.3 59.1-577.B.4 59.1-577.B.5 59.1-577.C

null

Art 18.1 Art 18.2 Art 18.3 Art 19 Art 21.1 Art 21.6 Art 22 Art 26.3

null

Principle 2.6 Principle 2.7.a.i Principle 2.7.a.ii Principle 2.7.a.iii Principle 2.7.b Principle 2.7.c Principle 2.7.d

null

Art 21

null

Sec 14 Sec 15 Sec 17

null

Sec 9

40(1)(b)

null

2.8 2.8(a) 2.8(b) 3.1(2) 3.1(4) 3.1(5) 3.1(11)(a) 3.1(11)(b) 3.1(11)(c) 3.1(11)(d) 3.1(13)

null

Article 5.3 Article 5.4 Article 6.3

null

Article 21 Article 21.1 Article 21.2 Article 22 Article 22.1 Article 22.2 Article 23 Article 23.x Article 24 Article 24.x Article 25 Article 25.x Article 26 Article 26.1 Article 26.2 Article 26.3 Article 26.4 Article 26.5 Article 26.6 Article 26.7 Article 26.8 Article 27.1 Article 27.2 Article 27.3 Article 27.4 Article 27.5 Article 27.6 Article 27.7

null

Art 26

null

Article 12(4) Article 18(3)

null

APP Part 13

APP 12 APP 13

null

Article 45 Article 46 Article 50

null

Article 27(3) Article 28(2) Article 28(2)(i) Article 28(2)(ii) Article 28(2)(iii) Article 28(3) Article 28(4) Article 28(5) Article 31 Article 32(1) Article 32(2) Article 32(3) Article 32(4)

null

Art 37

null

Art 16.2 Art 16.6

Sec 11

null

Art 18 Art 19 Art 21

null

Art 12 Art 15

null

Art 30

Art 10

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Right to Erasure

PRI-06.5

Mechanisms exist to erase personal data of a data subject, without delay.

null

Does the organization erase personal data of a data subject, without delay?

5

Respond

null

X

null

There is no evidence of a capability to erase personal data of an individual, without delay.

SP-CMM1 is N/A, since a structured process is required to erase personal data of an individual, without delay.

SP-CMM2 is N/A, since a well-defined process is required to erase personal data of an individual, without delay.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies empower data subjects to edit and/ or revoke authorizations for the organization to collect, store, processes, transmit share or use their PD. • Up on legitimate request, administrative processes exist to erase PD of an individual, without undue delay.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to erase personal data of an individual, without delay.

null

P4.3-POF1

null

7.3.6

null

CT.DM-P4

null

P.1.6.3

null

7022(a) 7022(b)(1) 7022(b)(2) 7022(b)(3) 7022(c)(1) 7022(c)(2) 7022(c)(3) 7022(c)(4) 7022(d) 7022(e) 7022(f)(1) 7022(f)(2) 7022(f)(3) 7022(f)(4) 7022(g) 7022(h)

null

6-1-1306(1)(d)

null

59.1-577.A.3

null

Art 17.1 Art 17.2 Art 17.3

null

Principle 2.6

null

26(e) 40(1)(b) 40(2)(b) 40(3)

null

3.1(13)

null

Article 5.3

null

Article 30 Article 30.x Article 32 Article 32.1 Article 32.2

null

Article 17(1) Article 17(1)(a) Article 17(1)(b) Article 17(1)(c) Article 17(1)(d) Article 17(1)(e) Article 17(1)(f)

null

Article 47 Article 47(1) Article 47(2) Article 47(3) Article 47(4) Article 47(5) Article 49

null

Article 30(1) Article 30(2) Article 30(3) Article 30(4) Article 30(5) Article 30(6) Article 30(7) Article 33(1) Article 33(2) Article 34 Article 34(1) Article 34(2) Article 34(3) Article 35(1) Article 35(2)

null

Art 16.5 Art 16.7

null

Art 18.4 Art 18.6

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Data Portability

PRI-06.6

Mechanisms exist to export Personal Data (PD) in a structured, commonly used and machine-readable format that allows the data subject to transmit the data to another controller without hindrance.

null

Does the organization export Personal Data (PD) in a structured, commonly used and machine-readable format that allows the data subject to transmit the data to another controller without hindrance?

3

Identify

null

X

There is no evidence of a capability to export Personal Data (PD) in a structured, commonly used and machine-readable format that allows the data subject to transmit the data to another controller without hindrance.

SP-CMM1 is N/A, since a structured process is required to export Personal Data (PD) in a structured, commonly used and machine-readable format that allows the data subject to transmit the data to another controller without hindrance.

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to export Personal Data (PD) in a structured, commonly used and machine-readable format that allows the data subject to transmit the data to another controller without hindrance.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to export Personal Data (PD) in a structured, commonly used and machine-readable format that allows the data subject to transmit the data to another controller without hindrance.

null

P6.7-POF2

null

ID.DE-P4 CT.DM-P2 CT.DM-P6

null

P.5.5.6.11

null

6-1-1306(1)(e)

null

59.1-577.A.4

null

Art 20.1 Art 20.2 Art 20.3 Art 20.4

null

38(1) 38(2) 38(3) 38(4) 38(5)(a) 38(5)(b) 38(6) 38(7)

null

3.1(6) 3.1(14) 3.1(14)(a) 3.1(14)(b) 3.1(14)(c) 3.1(15)

null

Article 6.3

null

4-2-3-1

null

Article 21 Article 22 Article 36 Article 36.1 Article 36.2

null

Article 20(1) Article 20(1)(a) Article 20(1)(b) Article 20(2)

null

Art 15.1 Art 15.2 Art 15.3

null

Art 18.5 Art 40

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Personal Data Exportability

PRI-06.7

Mechanisms exist to digitally export Personal Data (PD) in a secure manner upon request by the data subject.

null

Does the organization digitally export Personal Data (PD) in a secure manner upon request by the data subject?

5

Identify

null

X

null

There is no evidence of a capability to digitally export Personal Data (PD) in a secure manner up on request by the data subject.

SP-CMM1 is N/A, since a structured process is required to digitally export Personal Data (PD) in a secure manner up on request by the data subject.

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices. • Administrative processes and technologies export PD in a structured, commonly used and machine-readable format that allows the data subject to transmit the data to another controller without hindrance.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes and technologies export PD in a structured, commonly used and machine-readable format that allows the data subject to transmit the data to another controller without hindrance.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to digitally export Personal Data (PD) in a secure manner up on request by the data subject.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to digitally export Personal Data (PD) in a secure manner up on request by the data subject.

null

P6.7-POF2

null

7.3.8

null

CT.DM-P2 CT.DM-P6

null

P.5.5.6.5

null

6-1-1306(1)(e)

null

59.1-577.A.4

null

38(1) 38(2) 38(3) 38(4) 38(5)(a) 38(5)(b) 38(6) 38(7)

null

3.1(6) 3.1(14) 3.1(14)(a) 3.1(14)(b) 3.1(14)(c)

null

Article 6.3

null

Article 21 Article 22

null

Article 45

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Information Sharing With Third Parties

PRI-07

Mechanisms exist to disclose Personal Data (PD) to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the data subject.

- Veris (incident sharing) (http://veriscommunity.net)

E-PRI-05 E-TPM-01

Does the organization disclose Personal Data (PD) to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the data subject?

9

Identify

X

null

There is no evidence of a capability to disclose Personal Data (PD) to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the data subject.

SP-CMM1 is N/A, since a structured process is required to disclose Personal Data (PD) to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the data subject.

SP-CMM2 is N/A, since a well-defined process is required to disclose Personal Data (PD) to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the data subject.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes exist disclose PD to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the individual. • Administrative processes exist include data privacy requirements in contracts and other acquisition-related documents that establish data privacy roles and responsibilities for contractors and service providers.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to disclose Personal Data (PD) to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the data subject.

P6.1

P6.1-POF1

null

DSP-13

null

7.2.1 7.2.2 7.2.3

null

18.1.4

5.33

18.1.4

A.5.1

7.4.9 7.5 8.4.3 8.5.1 8.5.7

null

T1213, T1213.001, T1213.002

null

CT.PO-P2

null

UL-2

null

AC-21

null

AC-21

null

AC-21

null

AC-21

null

AC-21

null

P.5.4.1

2.5A 2.11A

null

COMP:SG1.SP3 COMP:SG3.SP1 EXD:SG3.SP1 OTA:SG3.SP2

null

5.1.1.2 5.1.1.3 5.1.1.4 5.1.1.5 5.1.1.6 5.1.1.7 5.1.1.8 5.1.4

null

UL-2

null

§ 1232g

null

1.9.4 AC-21

null

Principle 3

null

5.1

null

45.48.420 45.48.430

null

7012(g) 7012(g)(1) 7012(g)(2) 7012(g)(3)(A) 7012(g)(3)(B) 7012(g)(3)(C) 7022(c)(3) 7022(c)(4) 7050(a)(1) 7050(a)(2) 7050(a)(3) 7050(a)(3)(A) 7050(a)(3)(B) 7050(a)(4) 7050(a)(5) 7050(b) 7050(b)(1) 7050(b)(2) 7050(c) 7050(d) 7050(e) 7050(f) 7050(g) 7051(a)(1) 7051(a)(2) 7051(a)(3) 7051(a)(4) 7051(a)(5) 7051(a)(6) 7051(a)(7) 7051(a)(8) 7051(a)(9) 7051(a)(10) 7051(b) 7051(c) 7052(a) 7052(b) 7053(a)(1) 7053(a)(2) 7053(a)(3) 7053(a)(4) 7053(a)(5) 7053(a)(6) 7053(b)

null

6-1-1305(7) 6-1-1305(8)(a) 6-1-1305(8)(b) 6-1-1307(2) 6-1-1307(3)

null

59.1-577.A.5 59.1-577.A.5(i) 59.1-577.A.5(ii) 59.1-577.A.5(iii)

null

Art 6.1 Art 6.4 Art 15.2 Art 20.2 Art 26.1 Art 26.2 Art 26.3 Art 44 Art 45.1 Art 45.2 Art 46.1 Art 46.2 Art 46.3 Art 47.1 Art 47.2 Art 48 Art 49.1 Art 49.2 Art 49.6

null

Principle 2.3.a Principle 2.3.b(i) Principle 2.3.b(ii) Principle 2.3.b(iii) Principle 2.3.b(iv) Principle 2.3.b(v) Principle 2.3.b(vi) Principle 2.7.d

Sec 10

null

Art 14 Art 27

null

10.5

null

25(h) 42(2)(a) 42(2)(b) 42(3)

null

2.4(b)

null

Article 5

null

Sec 18 Sec 28 Sec 30 Sec 31

null

Article 15(2)

null

APP 7 APP 8

null

Article 20 Article 21 Article 22 Article 27 Article 38(3) Article 41 Article 42 Article 49

null

Article 23(1)(i) Article 23(1)(ii) Article 23(1)(iii) Article 23(1)(iv) Article 23(2) Article 23(2)(i) Article 23(2)(ii) Article 23(2)(iii) Article 23(2)(iv) Article 23(2)(v) Article 23(2)(vi) Article 23(2)(vii) Article 23(2)(viii) Article 23(3) Article 23(4) Article 23(5)(i) Article 23(5)(ii) Article 23(5)(iii) Article 23(6) Article 23(1) Article 26(1) Article 26(1)(i) Article 26(1)(ii) Article 26(2) Article 26(3) Article 26(4) Article 26-2(1) Article 26-2(1)(i) Article 26-2(1)(ii) Article 26-2(2) Article 26-2(3)

18.1.4

Sec 9

null

20.1.6.C.01 20.1.6.C.02 20.1.7.C.01 20.1.7.C.02 20.1.8.C.01 20.1.9.C.01 20.1.10.C.01 20.1.10.C.02 20.1.11.C.01 20.1.12.C.01 20.1.13.C.01 20.2.3.C.01 20.2.4.C.01 20.2.5.C.01 20.2.6.C.01 20.2.6.C.02 20.2.6.C.03 20.2.7.C.01 20.2.8.C.01 20.2.9.C.01 20.2.9.C.02 20.2.9.C.03 20.2.9.C.04 20.2.10.C.01 20.2.10.C.02 20.2.11.C.01 20.2.11.C.02 20.2.11.C.03

null

Sec 26

null

Art 17 Art 26 Art 27

null

Art 11.1 Art 11.2 Art 11.3 Art 11.4 Art 12.1 Art 16.4

null

Sec 20 Sec 23

null

Art 26

null

Art 17 Art 23

null

x

null

x

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Data Privacy Requirements for Contractors & Service Providers

PRI-07.1

Mechanisms exist to include data privacy requirements in contracts and other acquisition-related documents that establish data privacy roles and responsibilities for contractors and service providers.

null

E-PRI-05 E-TPM-01

Does the organization include data privacy requirements in contracts and other acquisition-related documents that establish data privacy roles and responsibilities for contractors and service providers?

10

Identify

X

There is no evidence of a capability to include data privacy requirements in contracts and other acquisition-related documents that establish data privacy roles and responsibilities for contractors and service providers.

SP-CMM1 is N/A, since a structured process is required to include data privacy requirements in contracts and other acquisition-related documents that establish data privacy roles and responsibilities for contractors and service providers.

SP-CMM2 is N/A, since a well-defined process is required to include data privacy requirements in contracts and other acquisition-related documents that establish data privacy roles and responsibilities for contractors and service providers.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes exist disclose PD to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the individual. • Administrative processes exist include data privacy requirements in contracts and other acquisition-related documents that establish data privacy roles and responsibilities for contractors and service providers.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to include data privacy requirements in contracts and other acquisition-related documents that establish data privacy roles and responsibilities for contractors and service providers.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to include data privacy requirements in contracts and other acquisition-related documents that establish data privacy roles and responsibilities for contractors and service providers.

P6.4

P6.1-POF1

null

15.4

null

15.4

null

DSP-13 IPY-04 STA-04 STA-09

CLS-04

null

4.2.3 7.2.4

null

18.1.4

5.31 5.33

18.1.4

A.7.1

7.2.6 8.2.5 8.5.8

null

ID.DE-P3

null

AR-3

null

PO.1 PO.1.1 PO.1.2 PO.1.3

null

GV.SC-10

A01:2021 A02:2021 A03:2021 A04:2021 A05:2021 A06:2021 A07:2021 A08:2021 A09:2021 A10:2021

null

P.9.2

2.8A

9.2

null

AM:SG1.SP1 EXD:SG3.SP1 SC:SG1.SP2

null

5.1.1.2 5.1.1.3 5.1.1.4 5.1.1.5 5.1.1.6 5.1.1.7 5.1.1.8 5.1.4

null

AR-3

null

§ 1232g

null

164.308(b)(3)

null

1.9.3 1.9.5

null

Principle 3

null

7012(g) 7012(g)(1) 7012(g)(2) 7012(g)(3)(A) 7012(g)(3)(B) 7012(g)(3)(C) 7050(a)(1) 7050(a)(2) 7050(a)(3) 7050(a)(3)(A) 7050(a)(3)(B) 7050(a)(4) 7050(a)(5) 7050(b) 7050(b)(1) 7050(b)(2) 7050(c) 7050(d) 7050(e) 7050(f) 7050(g) 7051(a)(1) 7051(a)(2) 7051(a)(3) 7051(a)(4) 7051(a)(5) 7051(a)(6) 7051(a)(7) 7051(a)(8) 7051(a)(9) 7051(a)(10) 7051(b) 7051(c) 7052(a) 7052(b) 7053(a)(1) 7053(a)(2) 7053(a)(3) 7053(a)(4) 7053(a)(5) 7053(a)(6) 7053(b)

null

6-1-1305(3)(b) 6-1-1305(5) 6-1-1305(5)(a) 6-1-1305(5)(b) 6-1-1305(5)(c) 6-1-1305(5)(d) 6-1-1305(5)(d)(I) 6-1-1305(5)(d)(I)(A) 6-1-1305(5)(d)(I)(B) 6-1-1305(6) 6-1-1305(7) 6-1-1307(2) 6-1-1307(3)

null

Sec 45(a) Sec 45(b) Sec 45(c) Sec 45(d) Sec 50

null

59.1-578.B 59.1-579.A 59.1-579.A.1 59.1-579.A.2 59.1-579.A.3 59.1-579.B 59.1-579.B.1 59.1-579.B.2 59.1-579.B.3 59.1-579.B.4 59.1-579.B.5 59.1-579.C 59.1-579.D 59.1-581.A.3 59.1-582.A.1 59.1-582.A.2 59.1-582.A.3 59.1-582.A.4 59.1-582.A.5 59.1-582.A.6 59.1-582.A.7 59.1-582.A.8 59.1-582.A.9 59.1-582.B.1 59.1-582.B.2 59.1-582.B.3 59.1-582.B.4 59.1-582.C 59.1-582.D 59.1-582.E 59.1-582.F 59.1-582.G 59.1-582.H

null

Art 6.1 Art 6.4 Art 26.1 Art 26.2 Art 26.3 Art 28.1 Art 28.2 Art 28.3 Art 28.4 Art 28.5 Art 28.6 Art 28.9 Art 28.10 Art 29

null

Principle 2.3.b(i) Principle 2.3.b(ii) Principle 2.3.b(iii) Principle 2.3.b(iv) Principle 2.3.b(v) Principle 2.3.b(vi) Principle 2.7.a.i Principle 2.7.a.ii Principle 2.7.a.iii Principle 2.7.b Principle 2.7.c Principle 2.7.d Principle 3.10.a.i Principle 3.10.a.ii Principle 3.10.a.ii.1 Principle 3.10.a.ii.2 Principle 3.10.a.ii.3 Principle 3.10.a.iii Principle 3.10.b.i Principle 3.10.c.i

Sec 10

null

Art 14 Art 27

null

HR-06 PI-02

null

11.1

null

25(h) 40(2) 40(2)(a) 40(2)(b) 40(3) 42(2)(a) 42(2)(b) 42(3)

null

2.4(b) 2.7

null

Article 12

null

TPC-25

null

Article 5 Article 11 Article 30 Article 30.x Article 32 Article 32.1 Article 32.2 Article 33 Article 45 Article 45.x Article 46

null

Sec 11 Sec 20 Sec 21

null

A4.a

null

Article 3 Article 28(1) Article 28(2) Article 28(3)(a) Article 28(3)(b) Article 28(3)(c) Article 28(3)(d) Article 28(3)(e) Article 28(3)(f) Article 28(3)(g) Article 28(3)(h) Article 28(4) Article 28(5) Article 28(6) Article 28(7) Article 28(8) Article 28(9) Article 28(10) Article 29

null

APP 7

null

Article 20 Article 21 Article 27 Article 38(3) Article 42

null

Article 22 Article 23(1)(i) Article 23(1)(ii) Article 23(1)(iii) Article 23(1)(iv) Article 23(2) Article 23(2)(i) Article 23(2)(ii) Article 23(2)(iii) Article 23(2)(iv) Article 23(2)(v) Article 23(2)(vi) Article 23(2)(vii) Article 23(2)(viii) Article 23(3) Article 23(4) Article 23(5)(i) Article 23(5)(ii) Article 23(5)(iii) Article 23(6) Article 23(1) Article 26(1) Article 26(1)(i) Article 26(1)(ii) Article 26(2) Article 26(3) Article 26(4) Article 26-2(1) Article 26-2(1)(i) Article 26-2(1)(ii) Article 26-2(2) Article 26-2(3)

18.1.4

null

Principle 5 P5-(a) P5-(a)(i) P5-(a)(ii) P5-(a)(iii) P5-(b)

null

Art 26 Art 27

null

Art 11.4

null

Art 35 Art 39

null

Sec 20 Sec 23

null

Art 17 Art 23

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Joint Processing of Personal Data

PRI-07.2

Mechanisms exist to clearly define and communicate the organization's role in processing Personal Data (PD) in the data processing ecosystem.

null

E-PRI-05 E-TPM-01

Does the organization clearly define and communicate the organization's role in processing Personal Data (PD) in the data processing ecosystem?

5

Identify

null

X

null

There is no evidence of a capability to clearly define and communicate the organization's role in processing Personal Data (PD) in the data processing ecosystem.

SP-CMM1 is N/A, since a structured process is required to clearly define and communicate the organization's role in processing Personal Data (PD) in the data processing ecosystem.

SP-CMM2 is N/A, since a well-defined process is required to clearly define and communicate the organization's role in processing Personal Data (PD) in the data processing ecosystem.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes exist disclose PD to third-parties only for the purposes identified in the data privacy notice and with the implicit or explicit consent of the individual. • Administrative processes exist include data privacy requirements in contracts and other acquisition-related documents that establish data privacy roles and responsibilities for contractors and service providers.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to clearly define and communicate the organization's role in processing Personal Data (PD) in the data processing ecosystem.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to clearly define and communicate the organization's role in processing Personal Data (PD) in the data processing ecosystem.

null

DSP-13

null

7.2.7 7.4.9 8.4.3 8.5.7

null

ID.BE-P1

null

C.1

null

7012(g) 7012(g)(1) 7012(g)(2) 7012(g)(3)(A) 7012(g)(3)(B) 7012(g)(3)(C) 7050(a)(1) 7050(a)(2) 7050(a)(3) 7050(a)(3)(A) 7050(a)(3)(B) 7050(a)(4) 7050(a)(5) 7050(b) 7050(b)(1) 7050(b)(2) 7050(c) 7050(d) 7050(e) 7050(f) 7050(g) 7051(a)(1) 7051(a)(2) 7051(a)(3) 7051(a)(4) 7051(a)(5) 7051(a)(6) 7051(a)(7) 7051(a)(8) 7051(a)(9) 7051(a)(10) 7051(b) 7051(c) 7052(a) 7052(b) 7053(a)(1) 7053(a)(2) 7053(a)(3) 7053(a)(4) 7053(a)(5) 7053(a)(6) 7053(b)

null

6-1-1305(7)

null

59.1-579.A 59.1-579.A.1 59.1-579.A.2 59.1-579.A.3 59.1-579.B 59.1-579.B.1 59.1-579.B.2 59.1-579.B.3 59.1-579.B.4 59.1-579.B.5 59.1-579.C 59.1-579.D

null

Principle 2.3.b(i) Principle 2.3.b(ii) Principle 2.3.b(iii) Principle 2.3.b(iv) Principle 2.3.b(v) Principle 2.3.b(vi)

null

42(2)(a) 42(2)(b) 42(3)

null

Article 5 Article 11 Article 30 Article 30.x Article 32 Article 32.1 Article 32.2 Article 33 Article 43

null

Article 15(2) Article 26(1) Article 26(2) Article 26(3)

null

Article 20 Article 21 Article 27 Article 38(3)

null

Article 22 Article 23(1)(i) Article 23(1)(ii) Article 23(1)(iii) Article 23(1)(iv) Article 23(2) Article 23(2)(i) Article 23(2)(ii) Article 23(2)(iii) Article 23(2)(iv) Article 23(2)(v) Article 23(2)(vi) Article 23(2)(vii) Article 23(2)(viii) Article 23(3) Article 23(4) Article 23(5)(i) Article 23(5)(ii) Article 23(5)(iii) Article 23(6) Article 23(1) Article 26(1) Article 26(1)(i) Article 26(1)(ii) Article 26(2) Article 26(3) Article 26(4) Article 26-2(1) Article 26-2(1)(i) Article 26-2(1)(ii) Article 26-2(2) Article 26-2(3)

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Obligation To Inform Third-Parties

PRI-07.3

Mechanisms exist to inform applicable third-parties of any modification, deletion or other change that affects shared Personal Data (PD).

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/)

null

Does the organization inform applicable third-parties of any modification, deletion or other change that affects shared Personal Data (PD)?

5

Identify

null

X

null

There is no evidence of a capability to inform applicable third-parties of any modification, deletion or other change that affects shared Personal Data (PD).

SP-CMM1 is N/A, since a structured process is required to inform applicable third-parties of any modification, deletion or other change that affects shared Personal Data (PD).

SP-CMM2 is N/A, since a well-defined process is required to inform applicable third-parties of any modification, deletion or other change that affects shared Personal Data (PD).

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes exist include data privacy requirements in contracts and other acquisition-related documents to inform applicable third-parties of any modification, deletion or other change that affects shared PD.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to inform applicable third-parties of any modification, deletion or other change that affects shared Personal Data (PD).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to inform applicable third-parties of any modification, deletion or other change that affects shared Personal Data (PD).

null

DSP-13

null

7.3.7 7.4.9 8.4.3

null

CM.AW-P5 CM.AW-P7

null

P.5.5.6.4

null

7022(c)(3) 7022(c)(4) 7050(a)(1) 7050(a)(2) 7050(a)(3) 7050(a)(3)(A) 7050(a)(3)(B) 7050(a)(4) 7050(a)(5) 7050(b) 7050(b)(1) 7050(b)(2) 7050(c) 7050(d) 7050(e) 7050(f) 7050(g) 7051(a)(1) 7051(a)(2) 7051(a)(3) 7051(a)(4) 7051(a)(5) 7051(a)(6) 7051(a)(7) 7051(a)(8) 7051(a)(9) 7051(a)(10) 7051(b) 7051(c) 7052(a) 7052(b) 7053(a)(1) 7053(a)(2) 7053(a)(3) 7053(a)(4) 7053(a)(5) 7053(a)(6) 7053(b)

null

Principle 2.3.b(i) Principle 2.3.b(ii) Principle 2.3.b(iii) Principle 2.3.b(iv) Principle 2.3.b(v) Principle 2.3.b(vi)

null

40(2) 40(2)(a) 40(2)(b) 40(3)

null

3.1(10)

null

Article 30 Article 30.x Article 32 Article 32.1 Article 32.2 Article 33

null

Article 46

null

Article 22 Article 23(1)(i) Article 23(1)(ii) Article 23(1)(iii) Article 23(1)(iv) Article 23(2) Article 23(2)(i) Article 23(2)(ii) Article 23(2)(iii) Article 23(2)(iv) Article 23(2)(v) Article 23(2)(vi) Article 23(2)(vii) Article 23(2)(viii) Article 23(3) Article 23(4) Article 23(5)(i) Article 23(5)(ii) Article 23(5)(iii) Article 23(6) Article 23(1)

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-SA-1

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-SA-1

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Reject Unauthorized Disclosure Requests

PRI-07.4

Mechanisms exist to reject unauthorized disclosure requests.

- Authorized Agent

null

Does the organization reject unauthorized disclosure requests?

5

Identify

null

X

null

There is no evidence of a capability to reject unauthorized disclosure requests.

SP-CMM1 is N/A, since a structured process is required to reject unauthorized disclosure requests.

SP-CMM2 is N/A, since a well-defined process is required to reject unauthorized disclosure requests.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • The CPO and DPO establish criteria for when it is necessary to reject a disclosure requests (e.g., unauthorized / fraudulent request).

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to reject unauthorized disclosure requests.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to reject unauthorized disclosure requests.

null

P5.1-POF4 P5.2-POF1 P5.2-POF3

null

DSP-11 DSP-18

null

8.2.4 8.5.5

null

CT.DM-P1

null

P.5.5.6.10

null

7023(h)

null

6-1-1306(1)

null

59.1-577.B.4

null

Principle 3.8.c.i Principle 3.8.c.ii Principle 3.8.e.i Principle 3.8.e.i.1 Principle 3.8.e.i.2 Principle 3.8.e.i.3 Principle 3.8.e.i.4 Principle 3.8.e.i.5 Principle 3.8.c.ii Principle 3.8.f.i Principle 3.8.f.ii Principle 3.8.f.iii Principle 3.8.g.i Principle 3.8.h.i

null

Article 21.2 Article 22.2

null

Article 12(6)

null

Article 45 Article 46 Article 49

null

R-AC-4 R-AM-2 R-AM-3 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-SA-1

null

R-AC-4

null

R-AM-2

R-AM-3

null

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Testing, Training & Monitoring

PRI-08

Mechanisms exist to conduct cybersecurity & data privacy testing, training and monitoring activities

null

Does the organization conduct cybersecurity & data privacy testing, training and monitoring activities

8

Identify

X

null

There is no evidence of a capability to conduct cybersecurity & data privacy testing, training and monitoring activities

SP-CMM1 is N/A, since a structured process is required to conduct cybersecurity & data privacy testing, training and monitoring activities

SP-CMM2 is N/A, since a well-defined process is required to conduct cybersecurity & data privacy testing, training and monitoring activities

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes exist address the use of PD for internal testing, training and research that complies with applicable statutory, regulatory and contractual obligations.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to conduct cybersecurity & data privacy testing, training and monitoring activities

P6.5 P8.0

P8.1-POF6

null

1.2.6 10.2.3 10.2.4 10.2.5

null

18.2.2 18.2.3

5.36 8.8

18.2.2 18.2.3

A.10.3

6.15.2.2 6.15.2.3

null

AR-4

null

PM-14

null

PM-14

null

PM-14

null

E.1.6.1

null

COMP:SG3.SP1 COMP:SG3.SP3 EXD:SG4.SP1 IMC:SG2.SP1

null

AR-4

null

PM-14

null

Art 32.1 Art 32.2

null

Sec 19

null

18.2.2 18.2.3

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Personal Data Lineage

PRI-09

Mechanisms exist to utilize a record of processing activities to maintain a record of Personal Data (PD) that is stored, transmitted and/or processed under the organization's responsibility.

The organization should determine and securely maintain the necessary records in support of its obligations for the processing of PD.

null

Does the organization utilize a record of processing activities to maintain a record of Personal Data (PD) that is stored, transmitted and/or processed under the organization's responsibility?

5

Identify

null

X

null

There is no evidence of a capability to utilize a record of processing activities to maintain a record of Personal Data (PD) that is stored, transmitted and/ or processed under the organization's responsibility.

SP-CMM1 is N/A, since a structured process is required to utilize a record of processing activities to maintain a record of Personal Data (PD) that is stored, transmitted and/ or processed under the organization's responsibility.

SP-CMM2 is N/A, since a well-defined process is required to utilize a record of processing activities to maintain a record of Personal Data (PD) that is stored, transmitted and/ or processed under the organization's responsibility.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to utilize a record of processing activities to maintain a record of Personal Data (PD) that is stored, transmitted and/ or processed under the organization's responsibility.

null

DAT-03

null

7.2.8 8.2.6 8.5.3

null

CM.AW-P4 CM.AW-P6

null

SA-4(12)

null

SA-4(12)

null

P.5.2

null

SA-4(12)

null

Art 30.1 Art 30.2 Art 30.3 Art 30.4 Art 30.5

null

Sec 17

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Data Quality Management

PRI-10

Mechanisms exist to issue guidelines ensuring and maximizing the quality, utility, objectivity, integrity, impact determination and de-identification of Personal Data (PD) across the information lifecycle.

null

Does the organization issue guidelines ensuring and maximizing the quality, utility, objectivity, integrity, impact determination and de-identification of Personal Data (PD) across the information lifecycle?

5

Identify

X

null

There is no evidence of a capability to issue guidelines ensuring and maximizing the quality, utility, objectivity, integrity, impact determination and de-identification of Personal Data (PD) across the information lifecycle.

SP-CMM1 is N/A, since a structured process is required to issue guidelines ensuring and maximizing the quality, utility, objectivity, integrity, impact determination and de-identification of Personal Data (PD) across the information lifecycle.

SP-CMM2 is N/A, since a well-defined process is required to issue guidelines ensuring and maximizing the quality, utility, objectivity, integrity, impact determination and de-identification of Personal Data (PD) across the information lifecycle.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • A Chief Data Officer (CDO), or similar function, oversees processes to ensure the quality, utility, objectivity, integrity, impact determination and de-identification of PD across the information lifecycle, including methods to identify and eliminate potential biases.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to issue guidelines ensuring and maximizing the quality, utility, objectivity, integrity, impact determination and de-identification of Personal Data (PD) across the information lifecycle.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to issue guidelines ensuring and maximizing the quality, utility, objectivity, integrity, impact determination and de-identification of Personal Data (PD) across the information lifecycle.

P7.0 P7.1

P7.1-POF1 P7.1-POF2

null

9.2.1

null

7.4.3

5.7

null

CT.PO-P4 CT.DM-P8

null

PM-22 PM-23 PM-24

PM-24

null

PM-22 PM-23

null

PM-22 PM-23

null

PM-22 PM-23

PM-22

null

P.5.3.1

null

Art 5.1

null

Article 5.4 Article 11

null

Sec 4

null

Article 8

null

Art 6.5

null

Art 7

null

x

null

x

null

R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Automation

PRI-10.1

Automated mechanisms exist to support the evaluation of data quality across the information lifecycle.

null

Does the organization use automated mechanisms to support the evaluation of data quality across the information lifecycle?

1

Identify

null

X

There is no evidence of a capability to support the evaluation of data quality across the information lifecycle.

SP-CMM1 is N/A, since a structured process is required to support the evaluation of data quality across the information lifecycle.

SP-CMM2 is N/A, since a well-defined process is required to support the evaluation of data quality across the information lifecycle.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to support the evaluation of data quality across the information lifecycle.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to support the evaluation of data quality across the information lifecycle.

null

PT-3(2)

null

PT-3(2)

null

P.7.6

null

Art 5.1 Art 21.5 Art 22

null

x

null

R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

null

Data Privacy

Data Analytics Bias

PRI-10.2

Mechanisms exist to evaluate its analytical processes for potential bias.

null

Does the organization evaluate its analytical processes for potential bias?

5

Identify

null

X

null

There is no evidence of a capability to evaluate its analytical processes for potential bias.

SP-CMM1 is N/A, since a structured process is required to evaluate its analytical processes for potential bias.

SP-CMM2 is N/A, since a well-defined process is required to evaluate its analytical processes for potential bias.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to evaluate its analytical processes for potential bias.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to evaluate its analytical processes for potential bias.

null

ID.RA-P2

null

P.7.6.4

null

R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Data Tagging

PRI-11

Mechanisms exist to issue data modeling guidelines to support tagging of sensitive/regulated data.

null

Does the organization issue data modeling guidelines to support tagging of sensitive/regulated data?

3

Identify

null

X

There is no evidence of a capability to issue data modeling guidelines to support tagging of sensitive/regulated data.

SP-CMM1 is N/A, since a structured process is required to issue data modeling guidelines to support tagging of sensitive/regulated data.

SP-CMM2 is N/A, since a well-defined process is required to issue data modeling guidelines to support tagging of sensitive/regulated data.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to issue data modeling guidelines to support tagging of sensitive/regulated data.

null

CT.DM-P7

null

PT-3(1)

null

PT-3(1)

null

P.7.6

null

R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Updating Personal Data (PD)

PRI-12

Mechanisms exist to develop processes to identify and record the method under which Personal Data (PD) is updated and the frequency that such updates occur.

null

Does the organization develop processes to identify and record the method under which Personal Data (PD) is updated and the frequency that such updates occur?

9

Identify

null

X

There is no evidence of a capability to develop processes to identify and record the method under which Personal Data (PD) is updated and the frequency that such updates occur.

SP-CMM1 is N/A, since a structured process is required to develop processes to identify and record the method under which Personal Data (PD) is updated and the frequency that such updates occur.

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices. • IT/cybersecurity personnel develop and publish processes to identify and record the method under which PD is updated and the frequency that such updates occur.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • The CPO and DPO develop and publish processes to identify and record the method under which PD is updated and the frequency that such updates occur.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to develop processes to identify and record the method under which Personal Data (PD) is updated and the frequency that such updates occur.

P5.2

P5.2-POF2

null

7.4.3

5.7

null

CT.DM-P3

null

P.2.3.1

null

164.526 164.526(a) 164.526(b) 164.526(c) 164.526(d) 164.526(e) 164.526(f)

null

Sec 2.3

null

Art 5.1

null

Sec 16

null

x

null

R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Data Management Board

PRI-13

Mechanisms exist to establish a written charter for a Data Management Board (DMB) and assigned organization-defined roles to the DMB.

- Data Management Board (DMB)

null

Does the organization establish a written charter for a Data Management Board (DMB) and assigned organization-defined roles to the DMB?

3

Identify

X

null

There is no evidence of a capability to establish a written charter for a Data Management Board (DMB) and assigned organization-defined roles to the DMB.

SP-CMM1 is N/A, since a structured process is required to establish a written charter for a Data Management Board (DMB) and assigned organization-defined roles to the DMB.

SP-CMM2 is N/A, since a well-defined process is required to establish a written charter for a Data Management Board (DMB) and assigned organization-defined roles to the DMB.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • The CPO establishes a written charter for a Data Management Board (DMB) and assigns formal roles to selected stakeholders. • The CPO operates a reporting process to internal senior management, as well as external oversight bodies, as appropriate, to demonstrate accountability with specific statutory and regulatory data privacy program mandates.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to establish a written charter for a Data Management Board (DMB) and assigned organization-defined roles to the DMB.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to establish a written charter for a Data Management Board (DMB) and assigned organization-defined roles to the DMB.

null

7.4.3

null

CT.DM-P8

null

PM-23 PM-24

PM-24

null

PM-23

null

P.7

null

Art 5.1 Art 30.1 Art 30.2 Art 30.3 Art 30.4 Art 30.5

null

x

null

R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Data Privacy Records & Reporting

PRI-14

Mechanisms exist to maintain data privacy-related records and develop, disseminate and update reports to internal senior management, as well as external oversight bodies, as appropriate, to demonstrate accountability with specific statutory and regulatory data privacy program mandates.

null

Does the organization maintain data privacy-related records and develop, disseminate and update reports to internal senior management, as well as external oversight bodies, as appropriate, to demonstrate accountability with specific statutory and regulatory data privacy program mandates?

8

Identify

null

X

There is no evidence of a capability to maintain data privacy-related records and develop, disseminate and update reports to internal senior management, as well as external oversight bodies, as appropriate, to demonstrate accountability with specific statutory and regulatory data privacy program mandates.

SP-CMM1 is N/A, since a structured process is required to maintain data privacy-related records and develop, disseminate and update reports to internal senior management, as well as external oversight bodies, as appropriate, to demonstrate accountability with specific statutory and regulatory data privacy program mandates.

SP-CMM2 is N/A, since a well-defined process is required to maintain data privacy-related records and develop, disseminate and update reports to internal senior management, as well as external oversight bodies, as appropriate, to demonstrate accountability with specific statutory and regulatory data privacy program mandates.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Technologies are configured to support records management of for data subject authorizations.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to maintain data privacy-related records and develop, disseminate and update reports to internal senior management, as well as external oversight bodies, as appropriate, to demonstrate accountability with specific statutory and regulatory data privacy program mandates.

CC2.3

P8.1-POF4 P8.1-POF5

null

Principle 15

null

10.2.3 10.2.5

null

A.5.2

null

CM.AW-P4 CM.AW-P6 CM.AW-P7

null

M-5

null

AR-6

null

PM-27

null

PM-27

null

PM-27

null

L.1

null

COMP:SG3.SP2 MON:SG2.SP3 MON:SG2.SP4

null

AR-6

null

7101(a) 7101(b) 7101(c) 7101(d) 7101(e) 7102(a)(1)(A) 7102(a)(1)(B) 7102(a)(1)(C) 7102(a)(1)(D) 7102(a)(1)(E) 7102(a)(1)(F) 7102(a)(2) 7102(b)

null

Art 31

null

Art 3

null

Article 6.2

null

Article 47 Article 47.x Article 48 Article 52 Article 52.1 Article 52.2 Article 52.3 Article 52.4

null

Article 30(1) Article 30(1)(a) Article 30(1)(b) Article 30(1)(c) Article 30(1)(d) Article 30(1)(e) Article 30(1)(f) Article 30(1)(g) Article 30(2) Article 30(2)(a) Article 30(2)(b) Article 30(2)(c) Article 30(2)(d) Article 30(3) Article 30(4) Article 30(5)

null

Art 38

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

null

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Accounting of Disclosures

PRI-14.1

Mechanisms exist to develop and maintain an accounting of disclosures of Personal Data (PD) held by the organization and make the accounting of disclosures available to the person named in the record, upon request.

null

E-PRI-01

Does the organization develop and maintain an accounting of disclosures of Personal Data (PD) held by the organization and make the accounting of disclosures available to the person named in the record, upon request?

8

Identify

X

null

There is no evidence of a capability to develop and maintain an accounting of disclosures of Personal Data (PD) held by the organization and make the accounting of disclosures available to the pers on named in the record, up on request.

SP-CMM1 is N/A, since a structured process is required to develop and maintain an accounting of disclosures of Personal Data (PD) held by the organization and make the accounting of disclosures available to the pers on named in the record, up on request.

SP-CMM2 is N/A, since a well-defined process is required to develop and maintain an accounting of disclosures of Personal Data (PD) held by the organization and make the accounting of disclosures available to the pers on named in the record, up on request.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • The CPO and DPO develop a process for maintaining an accounting of disclosures of PD held by the organization and make the accounting of disclosures available to the pers on named in the record, up on request.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to develop and maintain an accounting of disclosures of Personal Data (PD) held by the organization and make the accounting of disclosures available to the pers on named in the record, up on request.

P6.2 P6.3

P6.2-POF1 P6.3-POF1

null

DSP-18

null

7.2.1 7.2.4

null

7.2.8 7.5.3 7.5.4

null

CM.AW-P4

null

AR-8

null

PM-21

null

PM-21

null

PM-21

null

P.5.5.6.12

null

COMP:SG3.SP1 KIM:SG4.SP2 KIM:SG4.SP3

null

AR-8

null

164.528 164.528(a) 164.528(b) 164.528(c) 164.528(d)

null

2.A.4 2.D.4 PM-21

null

Art 30.1 Art 30.2 Art 30.3 Art 30.4 Art 30.5

null

Article 6.2

null

Article 33

null

Sec 17

null

Article 15(2)

null

Article 25(1) Article 25(2)

null

Sec 20

null

Art 18.7 Art 37

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-IR-3 R-SA-1

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-3

null

R-SA-1

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Notification of Disclosure Request To Data Subject

PRI-14.2

Mechanisms exist to notify data subjects of applicable legal requests to disclose Personal Data (PD).

null

Does the organization notify data subjects of applicable legal requests to disclose Personal Data (PD)?

5

Identify

null

X

null

There is no evidence of a capability to notify data subjects of applicable legal requests to disclose Personal Data (PD).

SP-CMM1 is N/A, since a structured process is required to notify data subjects of applicable legal requests to disclose Personal Data (PD).

SP-CMM2 is N/A, since a well-defined process is required to notify data subjects of applicable legal requests to disclose Personal Data (PD).

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to notify data subjects of applicable legal requests to disclose Personal Data (PD).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to notify data subjects of applicable legal requests to disclose Personal Data (PD).

null

DSP-18

null

8.5.4

null

P.9.7

null

Article 6.2

null

Article 33 Article 35

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-IR-3 R-SA-1

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-3

null

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Register As A Data Controller and/or Data Processor

PRI-15

Mechanisms exist to register as a data controller and/or data processor, including registering databases containing Personal Data (PD) with the appropriate Data Authority, when necessary.

null

E-PRI-03

Does the organization register as a data controller and/or data processor, including registering databases containing Personal Data (PD) with the appropriate Data Authority, when necessary?

3

Identify

null

X

null

There is no evidence of a capability to register databases containing Personal Data (PD) with the appropriate Data Authority, when necessary.

SP-CMM1 is N/A, since a structured process is required to register databases containing Personal Data (PD) with the appropriate Data Authority, when necessary.

SP-CMM2 is N/A, since a well-defined process is required to register databases containing Personal Data (PD) with the appropriate Data Authority, when necessary.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Administrative processes exist register databases containing PD with the appropriate Data Authority, when necessary.

Privacy (PRI) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to register databases containing Personal Data (PD) with the appropriate Data Authority, when necessary.

null

P.1.6.5

null

§ 2446(a) § 2446(a)(1) § 2446(a)(2) § 2446(a)(3) § 2446(a)(3)(A) § 2446(a)(3)(B) § 2446(a)(3)(B)(i) § 2446(a)(3)(B)(ii) § 2446(a)(3)(B)(iii) § 2446(a)(3)(C) § 2446(a)(3)(D) § 2446(a)(3)(E) § 2446(a)(3)(F) § 2446(a)(3)(G)

null

Art 30.4

null

Sec 16 Sec 17

Art 17

Art 16

Art 50

Sec 36

Art 25

Sec 4d Sec 4e

null

Art 6

Sec 65 Sec 66

Sec 17

null

Sec 8 Sec 9

Sec 26 Sec 37

18(1) 18(2) 18(2)(a) 18(2)(b) 18(2)(c) 18(2)(d) 19(1) 19(2) 19(2)(a) 19(2)(b) 19(2)(c) 19(2)(d) 19(2)(e) 19(2)(f) 19(2)(g) 19(3) 19(4) 19(5) 19(6) 19(7) 20

null

Sec 30

null

Sec 33

Art 40

null

Art 23

null

Art 60

null

Sec 36

Art 11

Art 16

Sec 19

null

Sec 15

null

Art 5 Art 37

null

Sec 14 Sec 15

null

Sec 46 Sec 47 Sec 48

Sec 39

null

Art 32

null

Art 21

Art 21.1 Art 21.2 Art 21.3 Art 24

null

Art 25

Art 21

null

Art 29

Art 6 Art 29

null

x

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-IR-3 R-SA-1

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

null

R-IR-3

null

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Potential Human Rights Abuses

PRI-16

Mechanisms exist to constrain the supply of physical and/or digital activity logs to the host government that can directly lead to contravention of the Universal Declaration of Human Rights (UDHR), as well as other applicable statutory, regulatory and/or contractual obligations.

- Board of Directors (Bod) Ethics Committee

null

Does the organization constrain the supply of physical and/or digital activity logs to the host government that can directly lead to contravention of the Universal Declaration of Human Rights (UDHR), as well as other applicable statutory, regulatory and/or contractual obligations?

10

Protect

X

null

There is no evidence of a capability to constrain the supply of physical and/ or digital activity logs to the host government that can directly lead to contravention of the Universal Declaration of Human Rights (UDHR), as well as other applicable statutory, regulatory and/ or contractual obligations.

SP-CMM1 is N/A, since a structured process is required to constrain the supply of physical and/ or digital activity logs to the host government that can directly lead to contravention of the Universal Declaration of Human Rights (UDHR), as well as other applicable statutory, regulatory and/ or contractual obligations.

SP-CMM2 is N/A, since a well-defined process is required to constrain the supply of physical and/ or digital activity logs to the host government that can directly lead to contravention of the Universal Declaration of Human Rights (UDHR), as well as other applicable statutory, regulatory and/ or contractual obligations.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • The Chief Information Officer (CIO), Chief Information Security Officer (CISO) and CPO collaborate on methods to constrain the supply of physical and/ or digital activity logs to the host government that can directly lead to contravention of the Universal Declaration of Human Rights (UDHR), as well as other applicable statutory, regulatory and/ or contractual obligations.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to constrain the supply of physical and/ or digital activity logs to the host government that can directly lead to contravention of the Universal Declaration of Human Rights (UDHR), as well as other applicable statutory, regulatory and/ or contractual obligations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to constrain the supply of physical and/ or digital activity logs to the host government that can directly lead to contravention of the Universal Declaration of Human Rights (UDHR), as well as other applicable statutory, regulatory and/ or contractual obligations.

null

O.12

null

Article 7 Article 8 Article 9 Article 11 Article 14 Article 15 Article 16 Article 18 Article 19 Article 20 Article 28 Article 31 Article 32 Article 33 Article 36 Article 37 Article 38 Article 48 Article 53

null

Article 11 Article 12 Article 18 Article 26 Article 38(4) Article 40 Article 47(5)

null

R-AM-3 R-EX-1 R-EX-2 R-EX-4 R-GV-4 R-GV-5 R-GV-6 R-GV-7

null

R-AM-3

null

R-EX-1

R-EX-2

null

R-EX-4

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

MT-1 MT-2 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

MT-1

MT-2

null

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Data Subject Communications

PRI-17

Mechanisms exist to craft disclosures and communications to data subjects such that the material is readily accessible and written in a manner that is concise, unambiguous and understandable by a reasonable person.

null

Does the organization craft disclosures and communications to data subjects such that the material is readily accessible and written in a manner that is concise, unambiguous and understandable by a reasonable person?

6

Protect

null

X

There is no evidence of a capability to craft disclosures and communications to data subjects such that the material is readily accessible and written in a manner that is concise, unambiguous and understandable by a reasonable person.

SP-CMM1 is N/A, since a structured process is required to craft disclosures and communications to data subjects such that the material is readily accessible and written in a manner that is concise, unambiguous and understandable by a reasonable person.

Privacy (PRI) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Privacy management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • The data privacy program is developed to work with IT and cybersecurity staff to ensure that applicable statutory, regulatory and contractual data privacy obligations for Personal Data (PD) are properly identified and implemented across the enterprise. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for data privacy management. • A qualified individual is formally assigned as the Chief Privacy Officer (CPO), or similar role, to lead the organization’s data privacy program. This individual may be assigned to multiple duties, including that as a Data Protection Officer (DPO). • The CPO, or similar role, identifies “data privacy principles” that systems, applications, services, processes and third-parties must adhere to, based on leading data privacy practices. • Communications with data subjects is designed to be readily accessible and written in a manner that is concise, unambiguous and understandable by a reasonable person.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Communications with data subjects is designed to be readily accessible and written in a manner that is concise, unambiguous and understandable by a reasonable person.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to craft disclosures and communications to data subjects such that the material is readily accessible and written in a manner that is concise, unambiguous and understandable by a reasonable person.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to craft disclosures and communications to data subjects such that the material is readily accessible and written in a manner that is concise, unambiguous and understandable by a reasonable person.

null

7003(a) 7003(b)(1) 7003(b)(2) 7003(b)(3) 7011(c) 7102(a)(2)

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Conspicuous Link To Data Privacy Notice

PRI-17.1

Mechanisms exist to include a conspicuous link to the organization's data privacy notice on all consumer-facing websites and mobile applications.

null

Does the organization include a conspicuous link to the organization's data privacy notice on all consumer-facing websites and mobile applications?

4

Protect

null

X

There is no evidence of a capability to include a conspicuous link to the organization's data privacy notice on all consumer-facing websites and mobile applications.

SP-CMM1 is N/A, since a structured process is required to include a conspicuous link to the organization's data privacy notice on all consumer-facing websites and mobile applications.

SP-CMM2 is N/A, since a well-defined process is required to include a conspicuous link to the organization's data privacy notice on all consumer-facing websites and mobile applications.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects. • Communications with data subjects is designed to be readily accessible and written in a manner that is concise, unambiguous and understandable by a reasonable person.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to include a conspicuous link to the organization's data privacy notice on all consumer-facing websites and mobile applications.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to include a conspicuous link to the organization's data privacy notice on all consumer-facing websites and mobile applications.

null

7003(c) 7003(d) 7010(d) 7010(e) 7011(d)

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Data Privacy

Notice of Financial Incentive

PRI-17.2

Mechanisms exist to provide data subjects with a Notice of Financial Incentive that explains the material terms of a financial incentive, price or service difference so the data subject can make an informed decision about whether to participate.

null

Does the organization provide data subjects with a Notice of Financial Incentive that explains the material terms of a financial incentive, price or service difference so the data subject can make an informed decision about whether to participate?

2

Identify

null

X

There is no evidence of a capability to provide data subjects with a Notice of Financial Incentive that explains the material terms of a financial incentive, price or service difference so the data subject can make an informed decision about whether to participate.

SP-CMM1 is N/A, since a structured process is required to provide data subjects with a Notice of Financial Incentive that explains the material terms of a financial incentive, price or service difference so the data subject can make an informed decision about whether to participate.

SP-CMM2 is N/A, since a well-defined process is required to provide data subjects with a Notice of Financial Incentive that explains the material terms of a financial incentive, price or service difference so the data subject can make an informed decision about whether to participate.

Privacy (PRI) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Privacy program, run by a Chief Privacy Officer (CPO), or similar role, ensures that applicable statutory, regulatory and contractual data privacy obligations are properly identified and implemented to limit and secure Personal Data (PD) that the organization stores, transmits and processes. • A data privacy team oversees the centralized-management of physical security controls across the enterprise. • Data Protection Officers (DPOs) are assigned to work closely with business units and project teams to ensure data privacy principles are being implemented. • CPO and DPO determine and document the legal authority that permits the collection, use, maintenance and sharing of PD, either generally or in support of a specific program or system need. • As part of the organization’s data privacy program, the CPO publishes a clear set of “data privacy principles”, based on leading data privacy practices, that systems, applications, services, processes and third-parties must adhere to. • A Project Management Office (PMO), or project management function, ensures both cybersecurity & data privacy principles are identified and implemented within ongoing or planned projects.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to provide data subjects with a Notice of Financial Incentive that explains the material terms of a financial incentive, price or service difference so the data subject can make an informed decision about whether to participate.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to provide data subjects with a Notice of Financial Incentive that explains the material terms of a financial incentive, price or service difference so the data subject can make an informed decision about whether to participate.

null

7010(d) 7013(a) 7013(b) 7013(c) 7013(d) 7013(e) 7013(e)(1) 7013(e)(2) 7013(e)(3) 7013(e)(3)(A) 7013(e)(3)(B) 7013(f)(1) 7013(f)(2) 7013(g)(1) 7013(g)(1) 7013(h) 7080(a) 7080(b) 7080(c) 7080(d)(1) 7080(d)(2) 7080(d)(3) 7080(d)(4) 7080(e) 7080(f) 7080(g) 7081(a) 7081(a)(1) 7081(a)(2) 7081(a)(3) 7081(a)(4) 7081(a)(5) 7081(a)(6) 7081(a)(7) 7081(a)(8) 7081(b)

null

R-AM-3 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5

null

R-AM-3

null

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Project & Resource Management

Cybersecurity & Data Privacy Portfolio Management

PRM-01

Mechanisms exist to facilitate the implementation of cybersecurity & data privacy-related resource planning controls that define a viable plan for achieving cybersecurity & data privacy objectives.

null

E-PRM-02

Does the organization facilitate the implementation of cybersecurity & data privacy-related resource planning controls that define a viable plan for achieving cybersecurity & data privacy objectives?

8

Identify

X

null

There is no evidence of a capability to facilitate the implementation of cybersecurity & data privacy-related resource planning controls that define a viable plan for achieving cybersecurity & data privacy objectives.

Project & Resource Management (PRM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized. • IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Project & Resource Management (PRM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for Project Management (PM). • The PM function facilitates the implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The responsibility for enforcing cybersecurity & data privacy control implementation is assigned to business / process owners and asset custodians. • The Chief Information Officer (CIO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements.

Project & Resource Management (PRM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy to determine prioritized and authoritative guidance for program/project management practices. • The CISO, or similar function, develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures to apply defense-in-depth techniques across the enterprise with regards to program/project management. • A Governance, Risk & Compliance (GRC) function, or similar function, provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data for program/project management. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including program/project management. • A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The PMO determines the identification and allocation of resources for cybersecurity & data privacy requirements within business process planning for projects and other initiatives. • Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity & data privacy controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity & data privacy control implementation assigned to business / process owners and asset custodians. • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives of the security function, based on business requirements. • The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity & data privacy program. • Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to facilitate the implementation of cybersecurity & data privacy-related resource planning controls that define a viable plan for achieving cybersecurity & data privacy objectives.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the implementation of cybersecurity & data privacy-related resource planning controls that define a viable plan for achieving cybersecurity & data privacy objectives.

CC2.2 CC3.1 CC3.4 CC5.2 P5.0

CC3.1-POF4

8.2

null

EDM02.01 EDM02.02 EDM02.03 EDM02.04 EDM04.01 EDM04.02 EDM04.03 APO05.01 APO05.02 APO05.03 APO05.04 APO05.05

Principle 6 Principle 9 Principle 11 Principle 14

null

RQ-05-04 RQ-05-05.a RQ-05-05.b

8.3.4

6.1.1

5.1(e)

6.1.5

5.4 5.8

6.1.5

null

6.3.1.5

null

4.3.1 4.3.2

null

MANAGE 2.0 MANAGE 2.1 MANAGE 2.2

null

PO.2.3

null

PL-1

null

PL-1

3.2 3.2.1 3.2.2 3.2.3 3.2.4 3.2.5 3.2.6 3.3 3.3.1 3.3.2

PL-1

null

PL-1

null

NFO - PL-1

3.16.1

null

A.03.16.01

null

GV.RM-07 GV.RR-03

null

K.1.4.1

null

11.1

null

EF:SG3.SP3 EF:SG4.SP1 FRM:SG1.SP2 FRM:SG2.SP1 FRM:SG2.SP2 FRM:SG2.SP3 FRM:SG4.SP2 FRM:SG5.SP1 FRM:SG5.SP2 FRM:SG5.SP3 GG2.GP3

null

PL-1

null

PL-1

null

PL-1

null

8-101 8-311

null

PL-1

null

Sec 12

PL-1

null

3.2.1(6) 3.6.1(61) 3.6.1(62) 3.6.1(64) 3.6.1(65) 3.6.1(66)

Art 7(a) Art 7(b) Art 7(c) Art 7(d)

null

Art 32.1 Art 32.2

null

Sec 14 Sec 15

Art 16

null

2.3 7.4 7.5 8.3

null

17.5

null

1-1

null

1-1-3 1-2-3

null

Sec 19

null

9

null

0720 0732

null

25

13 15

null

4.1 6.1.5

null

11.1

3.2.15.C.01

null

5.1.1 5.1.2 5.1.3 5.1.4

null

1.1 6.22

1.2.1 2.3.1

null

x

null

R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-6 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-EX-6

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Project & Resource Management

Strategic Plan & Objectives

PRM-01.1

Mechanisms exist to establish a strategic cybersecurity & data privacy-specific business plan and set of objectives to achieve that plan.

null

E-PRM-01

Does the organization establish a strategic cybersecurity & data privacy-specific business plan and set of objectives to achieve that plan?

5

Identify

X

null

There is no evidence of a capability to establish a strategic cybersecurity & data privacy-specific business plan and set of objectives to achieve that plan.

SP-CMM1 is N/A, since a structured process is required to establish a strategic cybersecurity & data privacy-specific business plan and set of objectives to achieve that plan.

Project & Resource Management (PRM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for Project Management (PM). • The PM function facilitates the implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The responsibility for enforcing cybersecurity & data privacy control implementation is assigned to business / process owners and asset custodians. • The Chief Information Officer (CIO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements.

Project & Resource Management (PRM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The PMO determines the identification and allocation of resources for cybersecurity & data privacy requirements within business process planning for projects and other initiatives. • Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity & data privacy controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity & data privacy control implementation assigned to business / process owners and asset custodians. • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives of the security function, based on business requirements. • The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity & data privacy program. • Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to establish a strategic cybersecurity & data privacy-specific business plan and set of objectives to achieve that plan.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to establish a strategic cybersecurity & data privacy-specific business plan and set of objectives to achieve that plan.

null

8.1

null

APO01.01 APO01.02 APO01.03 APO02.02 APO02.05 APO02.06

null

Sec 4(D)(2)(b)

MAP 1.3 MAP 1.4

null

PO.2.3

null

GV.RM-04 GV.RM-07

null

C.5.6

null

PROGRAM-1.A.MIL1 PROGRAM-1.B.MIL2 PROGRAM-1.C.MIL2 PROGRAM-1.D.MIL2 PROGRAM-1.E.MIL2 PROGRAM-1.F.MIL2 PROGRAM-1.G.MIL2 PROGRAM-1.H.MIL3

EF:SG1.SP1

null

38-99-20(D)(2)(b)

null

3.2.1(4) 3.2.1(5)(a) 3.2.1(5)(b) 3.2.1(5)(c)

Art 6.8 Art 6.8(a) Art 6.8(b) Art 6.8(c) Art 6.8(d) Art 6.8(e) Art 6.8(f) Art 6.8(g) Art 6.8(h)

null

1.1 1.2 1.2(a) 1.2(b) 1.2(c) 1.2(d) 1.2(e) 1.2(f)

null

1-1 1-1-1

null

3.1.2

1-1-1 1-1-2

null

A1.a

null

0039 0720

null

13 15

null

4.1 5.1 5.1.1 5.1.2

null

2.3.25.C.01 2.3.25.C.02 2.3.29.C.01

null

3.1.4 3.1.5

null

1.1 6.7

1.2 1.2.1

null

NAIC

null

R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-6 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-EX-6

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Project & Resource Management

Targeted Capability Maturity Levels

PRM-01.2

Mechanisms exist to define and identify targeted capability maturity levels.

null

E-PRM-04

Does the organization define and identify targeted capability maturity levels?

5

Identify

X

null

There is no evidence of a capability to define and identify targeted capability maturity levels.

SP-CMM1 is N/A, since a structured process is required to define and identify targeted capability maturity levels.

Project & Resource Management (PRM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for Project Management (PM). • The PM function facilitates the implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The responsibility for enforcing cybersecurity & data privacy control implementation is assigned to business / process owners and asset custodians. • The Chief Information Officer (CIO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements. • IT/cybersecurity personnel develop plans to implement security-related objectives, based on defined capability maturity levels (e.g., SCF SP-CMM).

Project & Resource Management (PRM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The PMO determines the identification and allocation of resources for cybersecurity & data privacy requirements within business process planning for projects and other initiatives. • Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity & data privacy controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity & data privacy control implementation assigned to business / process owners and asset custodians. • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives of the security function, based on business requirements. • The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity & data privacy program. • Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to define and identify targeted capability maturity levels.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to define and identify targeted capability maturity levels.

null

CC5.1-POF5

8.2

null

APO02.03 APO02.05

null

MAP 1.4

null

PO.2.3

null

G.2.18

null

15

null

6.7

null

R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-6 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-EX-6

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Project & Resource Management

Cybersecurity & Data Privacy Resource Management

PRM-02

Mechanisms exist to address all capital planning and investment requests, including the resources needed to implement the cybersecurity & data privacy programs and document all exceptions to this requirement.

null

E-PRM-02

Does the organization address all capital planning and investment requests, including the resources needed to implement the cybersecurity & data privacy programs and document all exceptions to this requirement?

8

Identify

X

There is no evidence of a capability to address all capital planning and investment requests, including the resources needed to implement the cybersecurity & data privacy programs and document all exceptions to this requirement.

Project & Resource Management (PRM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized. • IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Project & Resource Management (PRM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for Project Management (PM). • The PM function facilitates the implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The responsibility for enforcing cybersecurity & data privacy control implementation is assigned to business / process owners and asset custodians.

Project & Resource Management (PRM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The PMO determines the identification and allocation of resources for cybersecurity & data privacy requirements within business process planning for projects and other initiatives. • Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity & data privacy controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity & data privacy control implementation assigned to business / process owners and asset custodians. • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives of the security function, based on business requirements. • The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity & data privacy program. • Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels.

Project & Resource Management (PRM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to address all capital planning and investment requests, including the resources needed to implement the cybersecurity & data privacy programs and document all exceptions to this requirement.

CC1.4

null

5

null

EDM02.01 EDM02.02 EDM02.03 EDM02.04 EDM04.01 EDM04.02 EDM04.03

Principle 4

null

8.3.4

6.2

5.1(c) 7.1

null

5.4

null

4.3.1 4.3.2

null

MANAGE 2.1

null

PO.2.3

null

PM-3

null

PM-3

null

PM-3

null

3.3.2 3.3.3

PM-3

null

PM-3

null

ID.BE-2

GV.RR-03

null

C.6.2

null

1.2.3

null

ASSET-5.B.MIL2 THREAT-3.A.MIL2 RISK-5.B.MIL2 ACCESS-4.B.MIL2 SITUATION-4.B.MIL2 RESPONSE-5.B.MIL2 THIRD-PARTIES-3.B.MIL2 WORKFORCE-4.B.MIL2 ARCHITECTURE-5.B.MIL2 PROGRAM-3.B.MIL2

EF:SG3.SP1 FRM:SG1.SP2 FRM:SG2.SP2

null

PM-3

null

PM-3

null

Sec 12

PM-3

null

3.6.1(61) 3.6.1(62)

Art 7(a) Art 7(b) Art 7(c) Art 7(d)

null

2.3

null

17.5 17.8 17.9

null

1-1

null

1-1-3

1-4 1-4-1 1-4-1-1

null

0732

null

25

13 15

null

4.4.5 4.5.1 4.5.1.1 4.5.1.2

null

3.2.15.C.01

null

5.1.1 5.1.2 5.1.3 5.1.4 5.2.1 5.2.2 5.5.1 5.5.2

null

1.1 6.22

1.1.2

null

x

null

x

R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-6 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-EX-6

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Project & Resource Management

Allocation of Resources

PRM-03

Mechanisms exist to identify and allocate resources for management, operational, technical and data privacy requirements within business process planning for projects / initiatives.

null

E-PRM-01 E-PRM-02

Does the organization identify and allocate resources for management, operational, technical and data privacy requirements within business process planning for projects / initiatives?

8

Identify

X

null

There is no evidence of a capability to identify and allocate resources for management, operational, technical and data privacy requirements within business process planning for projects / initiatives.

Project & Resource Management (PRM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized. • IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Project & Resource Management (PRM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for Project Management (PM). • The PM function facilitates the implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The responsibility for enforcing cybersecurity & data privacy control implementation is assigned to business / process owners and asset custodians.

Project & Resource Management (PRM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The PMO determines the identification and allocation of resources for cybersecurity & data privacy requirements within business process planning for projects and other initiatives. • Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity & data privacy controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity & data privacy control implementation assigned to business / process owners and asset custodians. • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives of the security function, based on business requirements. • The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity & data privacy program. • Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels.

Project & Resource Management (PRM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify and allocate resources for management, operational, technical and data privacy requirements within business process planning for projects / initiatives.

CC1.4 CC4.1

CC3.1-POF4

8.2

null

EDM02.01 EDM02.02 EDM02.03 EDM02.04 EDM04.01 EDM04.02 EDM04.03 APO06.01 APO06.02 APO06.03 APO06.04 APO06.05

Principle 4 Principle 16

null

RQ-05-04

7.1 8.3.4

7.1

null

4.3.1 4.3.2

null

MANAGE 2.1

null

PO.2.3

null

SA-2

null

SA-2

3.2 3.2.1 3.2.2 3.2.3 3.2.4 3.2.5 3.2.6 3.3 3.3.1 3.3.2

SA-2

null

SA-2

null

NFO - SA-2

null

ID.BE-3

GV.RR-03

null

K.1.4.1

null

11.1

null

ASSET-5.B.MIL2 THREAT-3.A.MIL2 RISK-5.B.MIL2 ACCESS-4.B.MIL2 SITUATION-4.B.MIL2 RESPONSE-5.B.MIL2 THIRD-PARTIES-3.B.MIL2 WORKFORCE-4.B.MIL2 ARCHITECTURE-5.B.MIL2 PROGRAM-3.B.MIL2

EXD:SG3.SP1 EXD:SG3.SP3 FRM:SG1.SP1 FRM:SG1.SP2 FRM:SG3.SP1 RRD:SG2.SP1 RRM:SG1.SP2 FRM:SG4.SP1 GG2.GP3

null

SA-2

null

SA-2

null

D1.G.SP.E.2 D1.G.Ov.Int.5 D1.G.SP.Int.3

null

SA-2

null

8-100 8-200

null

SA-2

null

Sec 12

SA-2

null

3.2.1(3)

Art 7(a) Art 7(b) Art 7(c) Art 7(d)

null

2.3

null

17.5

null

1-1

null

1-6-4

null

0732

null

25

15

null

4.5.1 4.5.1.1 4.5.1.2

null

5.2.1 5.2.2

null

6.22

null

x

null

x

R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-6 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-EX-6

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Project & Resource Management

Cybersecurity & Data Privacy In Project Management

PRM-04

Mechanisms exist to assess cybersecurity & data privacy controls in system project development to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting the requirements.

null

E-PRM-03

Does the organization assess cybersecurity & data privacy controls in system project development to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting the requirements?

10

Identify

null

X

There is no evidence of a capability to assess cybersecurity & data privacy controls in system project development to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting the requirements.

Project & Resource Management (PRM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized. • IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Project & Resource Management (PRM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for Project Management (PM). • The PM function facilitates the implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The responsibility for enforcing cybersecurity & data privacy control implementation is assigned to business / process owners and asset custodians. • The PM function enables project involvement for Information Assurance Program (IAP) as part of the organization’s established project management processes to ensure both cybersecurity & data privacy principles are identified and implemented.

Project & Resource Management (PRM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The PMO determines the identification and allocation of resources for cybersecurity & data privacy requirements within business process planning for projects and other initiatives. • Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity & data privacy controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity & data privacy control implementation assigned to business / process owners and asset custodians. • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives of the security function, based on business requirements. • The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity & data privacy program. • Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels. • The PM function enables project involvement for Information Assurance Program (IAP) as part of the organization’s established project management processes to ensure both cybersecurity & data privacy principles are identified and implemented. • A Governance, Risk & Compliance (GRC), or security engineering function, conducts functional testing of all applicable administrative, physical and technical controls as part of “business as usual” pre-production testing to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting the defined business requirements.

Project & Resource Management (PRM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to assess cybersecurity & data privacy controls in system project development to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting the requirements.

CC3.1 CC4.1 CC5.2

null

8.2

null

EDM03.01 BAI01.01 BAI01.02 BAI01.03 BAI01.04 BAI01.05 BAI01.06 BAI01.07 BAI01.08 BAI01.09 BAI02.01 BAI02.02 BAI02.03 BAI02.04 BAI03.01 BAI03.02 BAI03.03 BAI03.04 BAI03.05 BAI03.06 BAI03.07 BAI03.08 BAI03.09 BAI03.10 BAI03.11 BAI03.12 BAI04.01 BAI04.02 BAI04.03 BAI04.04 BAI04.05 BAI11.01 BAI11.02 BAI11.03 BAI11.04 BAI11.05 BAI11.06 BAI11.07 BAI11.08 BAI11.09

Principle 6 Principle 11 Principle 16

null

LGL-02 SET-05

null

RQ-05-05.a RQ-05-05.b RC-05-10 RC-05-15 RC-05-16 RQ-06-01 RQ-06-05.a RQ-06-05.b RQ-06-11 RQ-06-12

null

7.1 7.2 7.3 7.4 7.5.1 7.5.2 7.5.3

null

6.1.5

5.8

6.1.5

null

6.3.1.5

null

4.3.1 4.3.2

T1190, T1195, T1195.001, T1195.002, T1210

TS-1.12

null

CM.AW-P3 CT.PO-P1 CT.DM-P1 CT.DM-P2 CT.DM-P3 CT.DM-P4 CT.DM-P5 CT.DM-P6 CT.DM-P7 CT.DM-P8 CT.DM-P9 CT.DM-P10 CT.PO-P4

PO.1 PO.2 RV.3 RV.3.1 RV.3.2

null

CA-2

null

CA-2

3.4 3.4.1 3.4.2 3.4.3 3.4.4 3.4.5 3.4.6 3.4.7 3.4.8 3.4.9 3.4.10 3.4.11 3.4.12 3.4.13 3.4.14

CA-2

null

CA-2

null

PO.2.3

null

1.1

null

C.6.3

null

1.2.3 8.2.2 8.2.3 8.4.3 8.5.1 8.5.2 9.2

11.1

7.2.2.1(a) 7.2.2.1(b) 7.2.2.1(c) 7.2.2.2(a) 7.2.2.2(b) 7.2.2.2(c) 7.2.2.2(d) 7.2.2.2(e) 7.2.2.2(f) 7.2.2.2(g) 7.2.2.2(h) 7.2.2.3 7.2.2.4(a) 7.2.2.4(b) 7.2.2.5 7.3.4

ASSET-5.B.MIL2 THREAT-3.A.MIL2 RISK-5.B.MIL2 ACCESS-4.B.MIL2 SITUATION-4.B.MIL2 RESPONSE-5.B.MIL2 THIRD-PARTIES-3.B.MIL2 WORKFORCE-4.B.MIL2 ARCHITECTURE-5.B.MIL2 PROGRAM-3.B.MIL2

EC:SG4.SP5 FRM:SG1.SP2 RISK:SG3.SP1

null

CA-2

null

5.S.B

5.M.B

CA-2

null

8-610

12.1

null

17.03(2)(h)

null

622(2)(B)(i) 622(2)(B)(ii) 622(2)(B)(iii) 622(2)(B)(iv)

null

Sec 12

CA-2

null

3.3.1(10) 3.3.1(13)(f) 3.6.1(62) 3.6.1(61) 3.6.1(63)(a) 3.6.1(63)(b) 3.6.1(63)(c) 3.6.1(63)(d) 3.6.1(63)(e) 3.6.1(63)(f) 3.6.1(64) 3.6.1(65) 3.6.1(66)

Art 7(a) Art 7(b) Art 7(c) Art 7(d)

null

Article 21.3

null

7.1 7.2 7.3

null

17.5 17.8 17.9

null

1-3 2-13-1 2-13-2 2-13-3-1 2-13-3-2 2-13-3-3 2-13-3-4

TPC-74

3.1.5

1-6-1 1-6-4

1-4-1-2

null

1739

null

4.4.1 4.4.5 4.5.1 4.5.1.1 4.5.1.2 4.5.2 4.5.3 4.6 4.6.1 4.8.1 4.8.2 6.1.5

null

5.1.1 5.1.2 5.1.3 5.1.4 5.2.1 5.2.2 5.4.1 5.4.2 5.4.3 5.4.4 5.8.1 5.8.2

null

Art 6.8

6.7

2.3.1 2.4.3

null

x

MA 201 CMR 17 OR 6464A

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Project & Resource Management

Cybersecurity & Data Privacy Requirements Definition

PRM-05

Mechanisms exist to identify critical system components and functions by performing a criticality analysis for critical systems, system components or services at pre-defined decision points in the Secure Development Life Cycle (SDLC).

- Secure Development Life Cycle (SDLC)

E-PRM-03

Does the organization identify critical system components and functions by performing a criticality analysis for critical systems, system components or services at pre-defined decision points in the Secure Development Life Cycle (SDLC)?

9

Identify

X

There is no evidence of a capability to identify critical system components and functions by performing a criticality analysis for critical systems, system components or services at pre-defined decision points in the Secure Development Life Cycle (SDLC).

Project & Resource Management (PRM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized. • IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Project & Resource Management (PRM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for Project Management (PM). • The PM function facilitates the implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The responsibility for enforcing cybersecurity & data privacy control implementation is assigned to business / process owners and asset custodians.

Project & Resource Management (PRM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The PMO determines the identification and allocation of resources for cybersecurity & data privacy requirements within business process planning for projects and other initiatives. • Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity & data privacy controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity & data privacy control implementation assigned to business / process owners and asset custodians. • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives of the security function, based on business requirements. • The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity & data privacy program. • Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels. • A Governance, Risk & Compliance (GRC), or security engineering function, conducts functional testing of all applicable administrative, physical and technical controls as part of “business as usual” pre-production testing to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting the defined business requirements.

Project & Resource Management (PRM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify critical system components and functions by performing a criticality analysis for critical systems, system components or services at pre-defined decision points in the Secure Development Life Cycle (SDLC).

CC2.2 CC4.1 CC5.2

PI1.1-POF1 PI1.1-POF2 PI1.1-POF3

8.2

15.7

null

15.7

APO01.10 APO08.01 BAI02.01

Principle 11 Principle 14 Principle 16

null

LGL-01 LGL-02 LGL-03 LGL-04 LGL-05 LGL-06 LGL-07 LGL-08

null

RC-05-10 RQ-06-01 RQ-06-02.a RQ-06-02.b RQ-06-02.c RQ-06-06 RQ-09-09 RQ-10-01.a RQ-10-01.b RQ-10-01.c RQ-10-02

6.2.1 6.2.2

null

14.1.1

5.8 5.9 8.26

14.1.1

null

6.11 6.11.1

null

4.3.1 4.3.2

T1195.003, T1495, T1542, T1542.001, T1542.003, T1542.004, T1542.005, T1553, T1553.006, T1601, T1601.001, T1601.002

null

Sec 3

MAP 1.6

CT.PO-P1 CT.DM-P9 CT.DM-P10

PO.1 PO.1.1

null

SA-14

null

RA-9

null

RA-9

null

RA-9

3.4 3.4.3 3.4.4 3.4.5 3.4.6

RA-9

null

RA-9

null

3.16.1

null

A.03.16.01 A.03.16.01.ODP[01] A.03.16.03.ODP[01] A.03.17.03.b

null

PO.1 PO.1.1 PO.1.2 PO.1.3

ID.BE-4 ID.BE-5

null

1.1

null

I.1.7.7

null

1.2.3 8.2.2 8.2.3 8.4.3 8.5.1 8.5.2 9.2

null

7.2.2.1(a) 7.2.2.1(b) 7.2.2.1(c) 7.2.2.2(a) 7.2.2.2(b) 7.2.2.2(c) 7.2.2.2(d) 7.2.2.2(e) 7.2.2.2(f) 7.2.2.2(g) 7.2.2.2(h) 7.2.2.3 7.2.2.4(a) 7.2.2.4(b) 7.2.2.5 7.3.4

ASSET-5.B.MIL2 THREAT-3.A.MIL2 RISK-5.B.MIL2 ACCESS-4.B.MIL2 SITUATION-4.B.MIL2 RESPONSE-5.B.MIL2 THIRD-PARTIES-3.B.MIL2 WORKFORCE-4.B.MIL2 ARCHITECTURE-5.B.MIL2 PROGRAM-3.B.MIL2

COMM:SG1.SP2 COMM:SG3.SP1 RRD:SG3.SP1 RTSE:SG2.SP1 RTSE:SG2.SP2 RTSE:SG3.SP1 RTSE:SG3.SP2 TM:SG1.SP1

null

RA-9

null

RA-9

null

D4.C.Co.B.1 D1.G.IT.B.2 D5.IR.Pl.B.5 D5.IR.Pl.E.3

null

5.S.B

5.M.B

null

12.1

null

6-1-1308(1)(c)(I) 6-1-1308(1)(c)(II)

null

38-99-10

null

Sec 12

null

3.5(51) 3.6.1(64) 3.6.1(65) 3.6.2(68)

Art 7(a) Art 7(b) Art 7(c) Art 7(d)

null

Article 21.3

null

Principle 2.4.a

null

17.5 17.6

null

Article 11.1 Article 11.2 Article 11.3 Article 11.4 Article 11.5 Article 11.6 Article 11.7 Article 11.8

null

1-3-1-2 2-13-1 2-13-2 2-13-3-1 2-13-3-2 2-13-3-3 2-13-3-4

TPC-43

null

1-6-1

1-4-1 1-4-1-1 1-4-2

null

7.1.3 [OP.PL.3]

null

0720 1739

null

4.4.3 4.4.3.1 14.1.1

null

12.1.30.C.01 12.1.30.C.02 12.1.30.C.03 12.1.32.C.01 12.1.32.C.02 12.1.32.C.03

null

5.1.1 5.1.2 5.1.3 5.1.4 5.3.3 5.5.1 5.5.2 5.6.1 5.6.2 5.6.3

null

Art 27

null

6.7

2.4.2

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

null

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Project & Resource Management

Business Process Definition

PRM-06

Mechanisms exist to define business processes with consideration for cybersecurity & data privacy that determines: ▪ The resulting risk to organizational operations, assets, individuals and other organizations; and ▪ Information protection needs arising from the defined business processes and revises the processes as necessary, until an achievable set of protection needs is obtained.

null

E-PRM-03

Does the organization define business processes with consideration for cybersecurity & data privacy that determines: ▪ The resulting risk to organizational operations, assets, individuals and other organizations; and ▪ Information protection needs arising from the defined business processes and revises the processes as necessary, until an achievable set of protection needs is obtained?

7

Identify

X

There is no evidence of a capability to define business processes with consideration for cybersecurity & data privacy that determines: ▪ The resulting risk to organizational operations, assets, individuals and other organizations; and ▪ Information protection needs arising from the defined business processes and revises the processes as necessary, until an achievable set of protection needs is obtained.

Project & Resource Management (PRM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized. • IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Project & Resource Management (PRM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for Project Management (PM). • The PM function facilitates the implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The responsibility for enforcing cybersecurity & data privacy control implementation is assigned to business / process owners and asset custodians.

Project & Resource Management (PRM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The PMO determines the identification and allocation of resources for cybersecurity & data privacy requirements within business process planning for projects and other initiatives. • Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity & data privacy controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity & data privacy control implementation assigned to business / process owners and asset custodians. • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives of the security function, based on business requirements. • The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity & data privacy program. • Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels.

Project & Resource Management (PRM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to define business processes with consideration for cybersecurity & data privacy that determines: ▪ The resulting risk to organizational operations, assets, individuals and other organizations; and ▪ Information protection needs arising from the defined business processes and revises the processes as necessary, until an achievable set of protection needs is obtained.

CC1.3 CC3.1 CC3.4 CC4.1 CC5.1 CC5.2 PI1.1

CC3.1-POF7 CC3.1-POF8 CC3.1-POF9 CC3.1-POF10 CC3.1-POF11 CC3.1-POF12 CC3.1-POF13 CC3.1-POF14 CC3.1-POF15 CC3.1-POF16 PI1.1-POF1 PI1.3-POF1 PI1.3-POF2 PI1.3-POF3 PI1.3-POF4 PI1.3-POF5 PI1.4-POF1 PI1.4-POF2 PI1.4-POF3 PI1.4-POF4 PI1.5-POF1 PI1.5-POF2 PI1.5-POF3 PI1.5-POF4 P6.7-POF1

null

15.7

null

15.7

APO01.10 APO08.01 BAI02.01

Principle 3 Principle 6 Principle 9 Principle 10 Principle 11 Principle 16

null

LGL-01 LGL-02 LGL-03 LGL-04 LGL-05 LGL-06 LGL-07 LGL-08

null

RC-05-10 RQ-06-01 RQ-06-11 RQ-06-12

6.2.1 6.2.2

null

4.3.1 4.3.2

null

MAP 1.0 MAP 1.1 MAP 1.4 MAP 2.1

ID.IM-P5 CT.PO-P1 CT.DM-P9 CT.DM-P10

PO.1

null

PM-11

null

PM-11

null

PM-11

null

3.4 3.4.1 3.4.2

PM-11

null

PM-11

null

ID.BE-4

null

A.1.3.1

null

ADM:SG2.SP1 COMM:SG1.SP2 COMM:SG3.SP1 EC:SG4.SP1 EF:SG1.SP3 OPD:SG1.SP1 PM:SG3.SP2 PM:SG3.SP4 PM:SG3.SP5 RRD:SG3.SP1 SC:SG1.SP1 SC:SG3.SP1 TM:SG5.SP1

null

PM-11

null

8-303

null

6-1-1308(1)(c)(I) 6-1-1308(1)(c)(II)

null

Sec 12

null

3.5(51) 3.6.1(64) 3.6.1(65) 3.6.2(68)

Art 8.1

null

Principle 2.4.a

null

17.5 17.6

null

Article 11.4 Article 11.5 Article 11.6

null

4.4.3 4.4.3.1 4.4.4 4.4.4.1

null

12.1.32.C.01 12.1.32.C.02 12.1.32.C.03

null

5.5.1 5.5.2

null

x

null

x

R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-6 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-EX-6

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Project & Resource Management

Secure Development Life Cycle (SDLC) Management

PRM-07

Mechanisms exist to ensure changes to systems within the Secure Development Life Cycle (SDLC) are controlled through formal change control procedures.

- CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/)

E-PRM-03

Does the organization ensure changes to systems within the Secure Development Life Cycle (SDLC) are controlled through formal change control procedures?

10

Protect

X

There is no evidence of a capability to ensure changes to systems within the Secure Development Life Cycle (SDLC) are controlled through formal change control procedures.

Project & Resource Management (PRM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized. • IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Project & Resource Management (PRM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for Project Management (PM). • The PM function facilitates the implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • Administrative processes exist to ensure changes to systems within the SDLC are controlled through formal change control procedures. • The responsibility for enforcing cybersecurity & data privacy control implementation is assigned to business / process owners and asset custodians.

Project & Resource Management (PRM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • Administrative processes exist to ensure changes to systems within the SDLC are controlled through formal change control procedures. • The PMO determines the identification and allocation of resources for cybersecurity & data privacy requirements within business process planning for projects and other initiatives. • Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity & data privacy controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity & data privacy control implementation assigned to business / process owners and asset custodians. • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives of the security function, based on business requirements. • The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity & data privacy program. • Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels. • A Governance, Risk & Compliance (GRC), or security engineering function, conducts functional testing of all applicable administrative, physical and technical controls as part of “business as usual” pre-production testing to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting the defined business requirements.

Project & Resource Management (PRM) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure changes to systems within the Secure Development Life Cycle (SDLC) are controlled through formal change control procedures.

CC5.2 CC8.1

CC8.1-POF1

null

15.7

null

15.7

BAI01.01 BAI01.02 BAI01.03 BAI01.04 BAI01.05 BAI01.06 BAI01.07 BAI01.08 BAI01.09

Principle 11

AIS-04

LGL-01 LGL-02 LGL-03 LGL-04 LGL-05 LGL-06 LGL-07 LGL-08 POL-04 SET-05

null

RC-05-10 RC-05-13 RC-05-15 RC-05-16 RQ-06-01 RQ-12-01 RQ-14-02

null

7.1 7.2 7.3 7.4

null

14.2.2

5.8 8.25 8.32

14.2.2

null

6.11.2.2

null

4.3.1 4.3.2 6.1 6.2 6.3 6.4 6.5

T1078, T1078.001, T1078.003, T1078.004, T1213.003, T1574.002

TS-1.12

null

GOVERN 1.7 MANAGE 2.2 MANAGE 2.3

CM.AW-P3 CT.PO-P1 CT.DM-P7 CT.DM-P8 CT.PO-P4

PO.1 RV.3.4

P-13

null

SA-3

SA-3 SA-3(1) SA-8(30)

SA-3

SA-3(1) SA-8(30)

null

SA-3

3.2.1

SA-3

null

SA-3

NFO - SA-3

null

PO.2 PO.2.1 PO.2.2 PO.2.3 RV.3 RV.3.1 RV.3.2 RV.3.3 RV.3.4

PR.IP-2

ID.AM-08

null

I.2.5

null

7.2.2.1(a) 7.2.2.1(b) 7.2.2.1(c) 7.2.2.2(a) 7.2.2.2(b) 7.2.2.2(c) 7.2.2.2(d) 7.2.2.2(e) 7.2.2.2(f) 7.2.2.2(g) 7.2.2.2(h) 7.2.2.3 7.2.2.4(a) 7.2.2.4(b) 7.2.2.5 7.3.4

ASSET-3.E.MIL3

EXD:SG3.SP3 EXD:SG3.SP4 EXD:SG4.SP1 EXD:SG4.SP2 RTSE:SG2.SP2

null

SA-3

null

SA-3

null

D3.PC.Se.B.1 D3.PC.Se.E.1

null

1.S.A

1.M.A

SA-3

null

8-311 8-610

12.1

null

SA-3

null

Sec 12

SA-3

null

3.3.1(13)(f) 3.5(55) 3.6.1(63)(a) 3.6.1(63)(b) 3.6.1(63)(c) 3.6.1(63)(d) 3.6.1(63)(e) 3.6.1(63)(f)

Art 7(a) Art 7(b) Art 7(c) Art 7(d)

null

Article 21.3

null

Principle 2.4.a

null

7.1 7.2 7.3

null

17.4 17.5 17.8

null

Article 11.4 Article 11.5 Article 11.6

null

2-13-4

TPC-74

null

A3.a

null

1526 1739

null

21(c)

null

4.5.1 4.5.2 4.5.3 14.2.2

null

5.1.2 5.1.3 5.1.4 5.4.1 5.4.2 5.4.3 5.4.4

null

2.4.1 2.4.2

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Project & Resource Management

Manage Organizational Knowledge

PRM-08

Mechanisms exist to manage the organizational knowledge of the cybersecurity & data privacy staff.

null

Does the organization manage the organizational knowledge of the cybersecurity & data privacy staff?

5

Protect

X

null

There is no evidence of a capability to manage the organizational knowledge of the cybersecurity & data privacy staff.

SP-CMM1 is N/A, since a structured process is required to manage the organizational knowledge of the cybersecurity & data privacy staff.

Project & Resource Management (PRM) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Program/project management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • IT/cybersecurity personnel identify cybersecurity & data privacy controls that are appropriate to address applicable statutory, regulatory and contractual requirements for Project Management (PM). • The PM function facilitates the implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The responsibility for enforcing cybersecurity & data privacy control implementation is assigned to business / process owners and asset custodians. • Critical business functions are documented in “run books” or Standardized Operating Procedures (SOPs) to capture the knowledge in documentation form.

Project & Resource Management (PRM) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity & data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all projects. • The PMO determines the identification and allocation of resources for cybersecurity & data privacy requirements within business process planning for projects and other initiatives. • Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity & data privacy controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity & data privacy control implementation assigned to business / process owners and asset custodians. • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy and prioritizes the objectives of the security function, based on business requirements. • The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity & data privacy program. • Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels. • Line of Business (LOB) stakeholders are identified and tasked with documenting business-critical functions in “run books” or Standardized Operating Procedures (SOPs) to capture the knowledge in documentation form from both a business and technology perspective.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to manage the organizational knowledge of the cybersecurity & data privacy staff.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to manage the organizational knowledge of the cybersecurity & data privacy staff.

null

APO01.08

null

CT.PO-P1 CT.DM-P7 CT.DM-P8

RV.3 RV.3.1 RV.3.2

null

P.3.1.1

null

KIM:SG6.SP2

null

B4.c

null

3.2.19.C.01

null

R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-6 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-4 R-SA-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

null

R-EX-6

null

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

null

R-IR-4

null

R-SA-2

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Risk Management

Risk Management Program

RSK-01

Mechanisms exist to facilitate the implementation of risk management controls.

- Risk Management Program (RMP)

E-RSK-01

Does the organization facilitate the implementation of risk management controls?

10

Identify

X

There is no evidence of a capability to facilitate the implementation of risk management controls.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • The Chief Information Security Officer (CISO), or similar function, o Analyzes the organization’s business strategy to determine prioritized and authoritative guidance for Risk Management (RM) practices. o Develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures to apply defense-in-depth techniques across the enterprise for RM. • A Governance, Risk & Compliance (GRC) function, or similar function; o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to RM. o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data.

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the implementation of risk management controls.

CC1.3 CC3.1 CC4.1 CC5.1

CC3.1-POF3 CC3.2-POF3 CC3.2-POF5 CC3.4-POF1 CC3.4-POF2 CC3.4-POF3 CC3.4-POF4 CC3.4-POF5

10.2.1

16.6

null

16.6

EDM03.01 EDM03.02 EDM03.03 APO12.01 APO12.02 APO12.03 APO12.04 APO12.05 APO12.06

Principle 3 Principle 6 Principle 10 Principle 16 Principle 20

CEK-07 GRC-02

RSM-01 RSM-02

SO2

null

RQ-06-23 RQ-06-24 RQ-06-25 RQ-06-26 RQ-06-27 RQ-06-28.a RQ-06-28.b RQ-06-29 RQ-06-30.a RQ-06-30.b RQ-06-30.c RQ-06-30.d RQ-06-31 RQ-06-32

8.2 8.2.1

6.1 6.1.2

6.1 6.1.1 6.1.1(a) 6.1.1(b) 6.1.1(c) 6.1.1(d) 6.1.1(e)(1) 6.1.1(e)(2) 6.1.2 6.1.2(a) 6.1.2(a)(1) 6.1.2(a)(2) 6.1.2(b) 6.1.2(c) 6.1.2(c)(1) 6.1.2(c)(2) 6.1.2(d) 6.1.2(d)(1) 6.1.2(d)(2) 6.1.2(d)(3) 6.1.2(e) 6.1.2(e)(1) 6.1.2(e)(2) 8.2

11.1.4

7.5

11.1.4

null

6.8.1.4

5.10 5.11 5.12

4.1 4.2 4.3 4.4 4.5 4.6

4.1 4.2 4.3.1 4.3.2 5.1

null

OR-2.0

Sec 4(D)(3)

GOVERN 1.0 GOVERN 1.3 GOVERN 1.4 GOVERN 1.5 MANAGE 1.0

ID.DE-P1 GV.PO-P6 GV.RM-P1

null

P-2

2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8

PM-9 RA-1

RA-1

PM-9 PM-29 RA-1

RA-1

PM-9 PM-29

null

RA-1

3.3.4

PM-9 PM-29 RA-1

RA-1

null

PM-9 PM-29 RA-1

RA-1

NFO - RA-1

3.11.1.a 3.11.1.b 3.17.1.a

null

ID.GV-4 ID.RM-1 ID.RM-2 ID.RM-3

GV.RM GV.RM-01 GV.RM-03 GV.RM-06 GV.RM-07 GV.SC-03 GV.SC-09 ID.RA

null

12.2

12.3

null

A.1

7.4A

1.4 1.4.1

null

RISK-1.A.MIL1 RISK-1.B.MIL2 RISK-1.C.MIL2 RISK-1.D.MIL2 RISK-1.E.MIL2 RISK-1.F.MIL2 RISK-1.G.MIL3 RISK-1.H.MIL3 RISK-5.A.MIL2

RISK:SG1.SP2 RISK:SG2.SP1 RISK:SG2.SP2 RISK:SG3.SP1 RISK:SG3.SP2 RISK:SG4.SP1 RISK:SG4.SP2 RISK:SG4.SP3 RISK:SG5.SP1 RISK:SG5.SP2 RISK:SG6.SP1 RISK:SG6.SP2

null

PM-9 RA-1

null

RA-1

null

D1.G.Ov.B.1 D1.G.Ov.B.3 D1.G.Ov.E.1 D1.G.SP.E.1 D1.G.Ov.Int.1 D1.G.Ov.Int.3 D1.G.SP.A.4

null

314.4(b)

null

PM-9 RA-1

null

8-103 8-610

14.1

null

17 CFR 229.106(B)(1) 17 CFR 229.106(B)(1)(i) 17 CFR 229.106(B)(1)(ii) 17 CFR 229.106(B)(1)(iii) 17 CFR 229.106(B)(2)

Sec 404

5.6

RA-1

null

17.03(2)(b)

null

500.09

Sec 4(2)(b)(ii)(A)(2) Sec 4(2)(b)(ii)(A)(3) Sec 4(2)(b)(ii)(B)(1) Sec 4(2)(b)(ii)(B)(2) Sec 4(2)(b)(ii)(C)(1)

622(2)(d)(A)(ii)

38-99-20(D)(3)

null

Sec 7

PM-9 RA-1

RA-1

null

§ 2447(b)(2)

3.2.3(7) 3.3.1(10) 3.3.1(13)(a) 3.3.1(13)(b) 3.3.1(13)(c) 3.3.1(13)(d) 3.3.1(13)(e) 3.3.1(13)(f) 3.3.1(14)

Art 6.1 Art 6.2 Art 6.3 Art 6.4 Art 6.5 Art 6.6 Art 6.7 Art 6.8 Art 6.8(a) Art 6.8(b) Art 6.8(c) Art 6.8(d) Art 6.8(e) Art 6.8(f) Art 6.8(g) Art 6.8(h) Art 6.9 Art 6.10

Art 17

Art 32.1 Art 32.2

Article 21.1 Article 21.2(a) Article 21.2(d) Article 21.2(f)

null

Sec 14 Sec 15

Art 16

null

3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.11 12.3

OIS-06

null

1.2 2.1 2.2

null

1-2

TPC-31

3.2.1

1-5-1 1-5-2 1-5-4

1-3 1-3-1 1-3-1-1

null

Sec 19

null

A2.a

A2

null

0726

null

12(a) 12(c) 13 16(a) 16(b) 16(c) 16(d) 16(e) 16(f) 17 18 19(a) 19(b) 19(c) 19(d) 19(e)

null

Art 13

null

4.4.6 4.4.6.1 4.4.7 11.1.4

null

1.4 1.4.1 1.4.2 1.4.3

5.1.9.C.01 5.3.6.C.01 5.3.7.C.01 5.3.8.C.01 5.3.9.C.01

null

4.1.1 4.1.2 4.1.5

null

5.3 5.8

null

1.3 6.4 6.8 6.16 6.24

1.3 1.3.1 1.3.2 3.1

null

x

NAIC MA 201 CMR 17 OR 6464A

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Risk Management

Risk Framing

RSK-01.1

Mechanisms exist to identify: ▪ Assumptions affecting risk assessments, risk response and risk monitoring; ▪ Constraints affecting risk assessments, risk response and risk monitoring; ▪ The organizational risk tolerance; and ▪ Priorities and trade-offs considered by the organization for managing risk.

- Risk Management Program (RMP)

null

Does the organization identify: ▪ Assumptions affecting risk assessments, risk response and risk monitoring; ▪ Constraints affecting risk assessments, risk response and risk monitoring; ▪ The organizational risk tolerance; and ▪ Priorities and trade-offs considered by the organization for managing risk?

9

Identify

X

null

There is no evidence of a capability to identify: ▪ Assumptions affecting risk assessments, risk response and risk monitoring; ▪ Constraints affecting risk assessments, risk response and risk monitoring; ▪ The organizational risk tolerance; and ▪ Priorities and trade-offs considered by the organization for managing risk.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify: ▪ Assumptions affecting risk assessments, risk response and risk monitoring; ▪ Constraints affecting risk assessments, risk response and risk monitoring; ▪ The organizational risk tolerance; and ▪ Priorities and trade-offs considered by the organization for managing risk.

CC3.2

CC3.1-POF1 CC3.1-POF6 CC3.2-POF2 CC3.2-POF8

null

16.6

null

16.6

APO12.04

Principle 7

A&A-06 CEK-07 TVM-08

RSM-01 RSM-02

null

RQ-06-30.a RQ-06-30.b RQ-06-30.c RQ-06-30.d

null

6.1.2 6.1.2(a) 6.1.2(a)(1) 6.1.2(a)(2) 6.1.2(b) 6.1.2(c) 6.1.2(c)(1) 6.1.2(c)(2) 6.1.2(d) 6.1.2(d)(1) 6.1.2(d)(2) 6.1.2(d)(3) 6.1.2(e) 6.1.2(e)(1) 6.1.2(e)(2)

null

5.8

null

5.1 5.2 5.3

4.3.3

null

OR-2.0

Sec 4(D)(3)

GOVERN 1.3 GOVERN 1.4 MANAGE 1

ID.DE-P1 GV.RM-P1 GV.RM-P2 GV.RM-P3

null

3.1

null

PM-28

null

PM-28

null

PM-28

null

ID.RM-2 ID.RM-3

GV.RM-06

null

12.3.1 12.3.2

null

12.3.1

null

12.3.1

null

12.3.1 12.3.2

12.3.1

null

A.1.13

7.4A

1.4.1

null

RISK-2.C.MIL2

null

17 CFR 229.106(B)(1) 17 CFR 229.106(B)(1)(i) 17 CFR 229.106(B)(1)(ii) 17 CFR 229.106(B)(1)(iii) 17 CFR 229.106(B)(2)

null

38-99-20(D)(3)

null

3.3.1(10) 3.6.1(66) 3.7.2(82)

Art 8.2

null

2.2

null

1-3-1-4 1-3-1-5

null

A2.a

null

4.4.7.1 4.4.7.2 4.4.7.3 4.4.7.4

null

23.2.16.C.01 23.2.17.C.01

null

4.2.1 4.3.2

null

5.5

null

6.15 6.24

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Management Resourcing

RSK-01.2

Mechanisms exist to reduce the magnitude or likelihood of potential impacts by resourcing the capability required to manage technology-related risks.

null

Does the organization reduce the magnitude or likelihood of potential impacts by resourcing the capability required to manage technology-related risks?

8

Protect

X

null

There is no evidence of a capability to reduce the magnitude or likelihood of potential impacts by resourcing the capability required to manage technology-related risks.

SP-CMM1 is N/A, since a structured process is required to reduce the magnitude or likelihood of potential impacts by resourcing the capability required to manage technology-related risks.

SP-CMM2 is N/A, since a well-defined process is required to reduce the magnitude or likelihood of potential impacts by resourcing the capability required to manage technology-related risks.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to reduce the magnitude or likelihood of potential impacts by resourcing the capability required to manage technology-related risks.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to reduce the magnitude or likelihood of potential impacts by resourcing the capability required to manage technology-related risks.

null

GOVERN 1.3 GOVERN 1.4 MANAGE 2.1

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

null

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Tolerance

RSK-01.3

Mechanisms exist to define organizational risk tolerance, the specified range of acceptable results.

- Defined risk tolerance

E-RSK-06

Does the organization define organizational risk tolerance, the specified range of acceptable results?

9

Identify

X

There is no evidence of a capability to define organizational risk tolerance(s).

SP-CMM1 is N/A, since a structured process is required to define organizational risk tolerance(s).

SP-CMM2 is N/A, since a well-defined process is required to define organizational risk tolerance(s).

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to define organizational risk tolerance(s).

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to define organizational risk tolerance(s).

null

CC3.1-POF2 CC3.1-POF15

null

GOVERN 1.3 MAP 1.5

null

GV.RM-02

null

17 CFR 229.106(B)(1) 17 CFR 229.106(B)(1)(i)

null

3.3.1(10)

null

A2.a

null

26

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

null

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Threshold

RSK-01.4

Mechanisms exist to define organizational risk threshold, the level of risk exposure above which risks are addressed and below which risks may be accepted.

- Defined risk threshold

E-RSK-07

Does the organization define organizational risk threshold, the level of risk exposure above which risks are addressed and below which risks may be accepted?

9

Identify

X

There is no evidence of a capability to define organizational risk threshold.

SP-CMM1 is N/A, since a structured process is required to define organizational risk threshold.

SP-CMM2 is N/A, since a well-defined process is required to define organizational risk threshold.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to define organizational risk threshold.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to define organizational risk threshold.

null

MAP 1.5 MAP 3.2

null

GV.RM-06

null

17 CFR 229.106(B)(1) 17 CFR 229.106(B)(1)(i)

null

3.3.1(10)

null

A2.a

null

26

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

null

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Appetite

RSK-01.5

Mechanisms exist to define organizational risk appetite, the degree of uncertainty the organization is willing to accept in anticipation of a reward.

- Defined risk tolerance

E-RSK-08

Does the organization define organizational risk appetite, the degree of uncertainty the organization is willing to accept in anticipation of a reward?

9

Identify

X

There is no evidence of a capability to define organizational risk appetite.

SP-CMM1 is N/A, since a structured process is required to define organizational risk appetite.

SP-CMM2 is N/A, since a well-defined process is required to define organizational risk appetite.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to define organizational risk appetite.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to define organizational risk appetite.

null

GV.RM-02

null

17 CFR 229.106(B)(1) 17 CFR 229.106(B)(1)(i)

null

3.3.1(10) 3.3.1(13)(a)

null

26

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

null

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk-Based Security Categorization

RSK-02

Mechanisms exist to categorize systems and data in accordance with applicable local, state and Federal laws that: ▪ Document the security categorization results (including supporting rationale) in the security plan for systems; and ▪ Ensure the security categorization decision is reviewed and approved by the asset owner.

- Risk Management Program (RMP)

null

Does the organization categorize systems and data in accordance with applicable local, state and Federal laws that: ▪ Document the security categorization results (including supporting rationale) in the security plan for systems; and ▪ Ensure the security categorization decision is reviewed and approved by the asset owner?

9

Identify

X

There is no evidence of a capability to categorize systems and data in accordance with applicable local, state and Federal laws that: ▪ Document the security categorization results (including supporting rationale) in the security plan for systems; and ▪ Ensure the security categorization decision is reviewed and approved by the asset owner.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to categorize systems and data in accordance with applicable local, state and Federal laws that: ▪ Document the security categorization results (including supporting rationale) in the security plan for systems; and ▪ Ensure the security categorization decision is reviewed and approved by the asset owner.

CC3.2

null

16.6

null

16.6

null

Principle 7

BCR-02

RSM-01 RSM-02

null

RQ-15-06

null

6.1.2(d)(3)

null

5.1 5.2 5.3

null

OR-2.0

Sec 4(D)(3)

null

3.1

RA-2

null

RA-2

null

RA-2

null

RA-2

null

RA-2

null

ID.RA-6

GV.RM-06

null

9.6.1

9.4.2

null

D.7

7.4A

null

RISK-2.C.MIL2 RISK-3.A.MIL1 RISK-3.B.MIL2 RISK-3.C.MIL2 RISK-3.D.MIL2 RISK-3.E.MIL2

ADM:SG1.SP1 ADM:SG2.SP1 RISK:SG1.SP1

null

RA-2

null

RA-2

null

8-402

null

RA-2

null

38-99-20(D)(3)

null

RA-2

null

Art 17

null

2.2

null

1-3-1-4 1-3-1-5

null

A2.a

null

4.4.7.1 4.4.7.2 4.4.7.3 4.4.7.4

null

4.2.1

null

6.24

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Impact-Level Prioritization

RSK-02.1

Mechanisms exist to prioritize the impact level for systems, applications and/or services to prevent potential disruptions.

null

Does the organization prioritize the impact level for systems, applications and/or services to prevent potential disruptions?

9

Identify

X

null

There is no evidence of a capability to prioritize the impact level for systems, applications and/ or services to prevent potential disruptions.

SP-CMM1 is N/A, since a structured process is required to prioritize the impact level for systems, applications and/ or services to prevent potential disruptions.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to prioritize the impact level for systems, applications and/ or services to prevent potential disruptions.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to prioritize the impact level for systems, applications and/ or services to prevent potential disruptions.

null

CC3.2-POF4

null

16.6

null

16.6

null

A&A-06 BCR-02 CEK-07 TVM-08

RSM-01 RSM-02

null

FR 2 (6.1)

null

OR-2.0

null

MANAGE 1 MANAGE 1.2

null

RA-2(1)

null

RA-2(1)

null

ID.RA-6

GV.RM-06

null

A.1.13

7.4A

1.4.1

null

RISK-2.C.MIL2 RISK-3.A.MIL1 RISK-3.B.MIL2 RISK-3.C.MIL2 RISK-3.D.MIL2 RISK-3.E.MIL2

null

17 CFR 229.106(B)(1)

null

1-3-1-4 1-3-1-5

null

A2.a

null

4.4.7.1 4.4.7.2 4.4.7.3 4.4.7.4

null

23.2.16.C.01 23.2.17.C.01

null

4.2.1 4.3.1 4.3.2

null

5.5

null

6.24

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Identification

RSK-03

Mechanisms exist to identify and document risks, both internal and external.

- Risk Management Program (RMP)

null

Does the organization identify and document risks, both internal and external?

9

Identify

null

X

null

There is no evidence of a capability to identify and document risks, both internal and external.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify and document risks, both internal and external.

CC3.2 CC7.2 A1.2

CC3.2-POF6 CC3.4-POF1 CC3.4-POF2 CC3.4-POF3 CC3.4-POF4 CC3.4-POF5

null

APO12.01

Principle 7 Principle 10

CEK-07 TVM-07

RSM-01

null

6.1.2

6.1.2(c) 6.1.2(c)(1) 6.1.2(c)(2)

null

5.8

null

5.4.1.2

null

5.1 5.2 5.3

5.2

null

OR-2.0

Sec 4(C)(2)

MANAGE 1.0 MANAGE 2.3

ID.DE-P1

null

P-3 P-14 R-2

3.1 3.2

null

RV.3 RV.3.1 RV.3.2 RV.3.3 RV.3.4

ID.RA-3

GV.RM-07

null

12.3 12.3.1 12.3.2

null

12.3.1

null

12.3.1

null

12.3.1 12.3.2

12.3.1

null

A.1.3

7.4A

1.4.1

null

7.3.3

RISK-2.A.MIL1 RISK-2.B.MIL2 RISK-2.G.MIL2 RISK-2.H.MIL3 RISK-2.I.MIL3 RISK-2.J.MIL3 RISK-2.K.MIL3 RISK-2.M.MIL3

null

8.2

null

D3.DC.An.B.1 D2.MA.Ma.E.1 D2.MA.Ma.E.4 D2.MA.Ma.Int.2

null

314.4(c)(2)

null

14.1

null

17 CFR 229.106(B)(1)

null

Sec 4(2)(b)(ii)(A)(2) Sec 4(2)(b)(ii)(A)(3) Sec 4(2)(b)(ii)(B)(1) Sec 4(2)(b)(ii)(B)(2) Sec 4(2)(b)(ii)(C)(1)

null

38-99-20(C)(2)

null

Sec 7

null

3.3.1(10) 3.3.1(13)(b) 3.7.2(82)

Art 8.2

Art 17

null

SP-03

null

1.2 2.2

null

TPC-31

3.2.1.1

null

Sec 19

null

A2.a

A2

null

1526

null

4.4.7 4.4.7.2

null

2.4.13.C.01 2.4.13.C.02 2.4.13.C.03 2.4.13.C.04 2.4.13.C.05 2.4.13.C.06 2.4.13.C.07

null

4.1.3 4.1.4(a)

null

5.5

null

6.24

3.1 3.1.1

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Catalog

RSK-03.1

Mechanisms exist to develop and keep current a catalog of applicable risks associated with the organization's business operations and technologies in use.

null

Does the organization develop and keep current a catalog of applicable risks associated with the organization's business operations and technologies in use?

5

Protect

X

There is no evidence of a capability to develop and keep current a catalog of applicable risks associated with the organization's business operations and technologies in use.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to develop and keep current a catalog of applicable risks associated with the organization's business operations and technologies in use.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to develop and keep current a catalog of applicable risks associated with the organization's business operations and technologies in use.

null

ID.RA-04

null

3.3

null

R-BC-1 R-BC-2 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-4 R-SA-1 R-SA-2

null

R-BC-1

R-BC-2

null

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Assessment

RSK-04

Mechanisms exist to conduct recurring assessments of risk that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data.

- Risk Management Program (RMP) - Risk assessment - Business Impact Analysis (BIA) - Data Protection Impact Assessment (DPIA)

E-RSK-04

Does the organization conduct recurring assessments of risk that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data?

10

Identify

X

There is no evidence of a capability to conduct recurring assessments of risk that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to conduct recurring assessments of risk that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data.

CC3.2 CC7.3 A1.2

CC3.2-POF1 CC3.2-POF6 CC3.4-POF1 CC3.4-POF2 CC3.4-POF3 CC3.4-POF4 CC3.4-POF5

null

APO12.02

Principle 7 Principle 11

CEK-07

RSM-01

SO2

1.2.4

null

RQ-06-23 RQ-06-24 RQ-06-25 RQ-06-26 RQ-06-27 RQ-06-28.a RQ-06-28.b RQ-06-29 RQ-06-30.a RQ-06-30.b RQ-06-30.c RQ-06-30.d RQ-06-31 RQ-06-32

8.2.3

6.1.2 8.2

6.1.2(d) 6.1.2(d)(1) 6.1.2(d)(2) 6.1.2(d)(3) 6.1.2(e) 6.1.2(e)(1) 6.1.2(e)(2) 8.2

11.1.4

5.8 7.5

11.1.4

null

5.4.1.2 6.8.1.2

5.12

5.4

4.3.4 5.3.1 5.3.4 5.3.5 5.3.6 5.4 5.5 6.7

null

OR-2.0

Sec 4(C)(3) Sec 4(C)(4)

GOVERN 1.5 MANAGE 1.0 MAP 5.1

ID.DE-P1 ID.DE-P5 GV.MT-P1

null

P-3 P-14 R-2

3.2

RA-3

null

RA-3

null

RA-3

null

RA-3

3.11.1

3.11.1.a

3.11.1[a] 3.11.1[b]

A.03.11.01.a A.03.11.01.b

3.11.5e 3.11.6e

RV.3 RV.3.1 RV.3.2 RV.3.3 RV.3.4

ID.RA-5

GV.RM-06

null

12.2

12.3 12.3.1 12.3.2

null

12.3.1

null

12.3.1

null

12.3.1 12.3.2

12.3.1

null

A.3.2

7.4A

1.4.1

5.1

7.3.3

RISK-2.G.MIL2 RISK-3.A.MIL1

RISK:SG2.SP1 RISK:SG2.SP2 RISK:SG3.SP1 RISK:SG3.SP2 RISK:SG4.SP1 RISK:SG4.SP2 RISK:SG4.SP3 RISK:SG5.SP1 RISK:SG5.SP2

null

RA.L2-3.11.1

RA.L2-3.11.1 TBD - 3.11.5e TBD - 3.11.6e

null

RA.L2-3.11.1

RA.L2-3.11.1 RA.L3-3.11.5e RA.L3-3.11.6e

RA-3

null

RA-3

null

D1.RM.RA.B.1 D1.RM.RA.E.2 D1.RM.RA.E.1

null

314.4(b) 314.4(b)(1) 314.4(b)(1)(i) 314.4(b)(1)(ii) 314.4(b)(1)(iii)

164.308(a)(1)(ii)(A) 164.308(a)(1)(ii)(B) 164.308(a)(1)(ii)(D)

null

7.M.C

7.M.C 9.L.A

RA-3

null

CIP-014-2 R1

8-402

14.1

null

17 CFR 229.106(B)(1) 17 CFR 229.106(B)(1)(i) 17 CFR 229.106(B)(1)(ii) 17 CFR 229.106(B)(1)(iii) 17 CFR 229.106(B)(2)

null

5.6

RA-3

null

17.03(2)(b)

null

Sec 4(2)(b)(ii)(A)(2) Sec 4(2)(b)(ii)(A)(3) Sec 4(2)(b)(ii)(B)(1) Sec 4(2)(b)(ii)(B)(2) Sec 4(2)(b)(ii)(C)(1)

622(b)(A)(ii)

38-99-20(C)(3) 38-99-20(C)(4)

null

Sec 7 Sec 11

RA-3

null

3.3.1(10) 3.3.1(13)(b) 3.3.3(20) 3.7.2(82)

Art 8.3 Art 8.7

Art 17

Art 35.1 Art 35.2 Art 35.3 Art 35.7 Art 35.8 Art 35.9 Art 35.11

Article 21.1

null

3.10

OIS-07 SP-03

null

1.2 2.2

null

1-2-1-1

TPC-31

3.2.1.2

1-5-3

1-3-1-2

null

Sec 19

null

7.1.1 [OP.PL.1]

null

A2.a

A2

null

1587

null

27(a) 27(b) 27(c) 28

null

4.4.7 4.4.7.1 4.4.7.3 4.4.7.4 4.5.5 4.5.5.1 4.6 4.6.1 11.1.4

null

1.4.1

2.3.27.C.01 2.3.27.C.02 5.9.23.C.01 23.2.16.C.02

null

4.1.4(b) 4.3.2

null

5.5

null

2.1 6.8

null

x

NAIC MA 201 CMR 17 OR 6464A

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Register

RSK-04.1

Mechanisms exist to maintain a risk register that facilitates monitoring and reporting of risks.

- Risk Management Program (RMP) - Risk register - Governance, Risk and Compliance Solution (GRC) tool (SCFConnect, SureCloud,Ostendio, ZenGRC, Archer, RSAM, MetricStream, etc.)

E-RSK-03

Does the organization maintain a risk register that facilitates monitoring and reporting of risks?

10

Identify

null

X

null

There is no evidence of a capability to maintain a risk register that facilitates monitoring and reporting of risks.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Risk Management efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.

CC3.2

CC4.2-POF3

null

APO12.03 APO12.05

Principle 7

A&A-06 CEK-07 TVM-09

GVN-08

null

RQ-09-05 RQ-09-06.a RQ-09-06.b

null

8.3

null

5.12

5.6 5.7

4.3.6 5.5

null

OR-2.0

Sec 4(D)(3)

GOVERN 1.5 MANAGE 1.4 MANAGE 2.0 MEASURE 3.0

ID.DE-P1

null

3.4

null

3.12.2.a 3.12.2.a.1 3.12.2.a.2 3.12.2.b

null

12.3.1 12.3.2

null

12.3.1

null

12.3.1

null

12.3.1 12.3.2

12.3.1

null

A.3.8

7.4A

1.4.1

7.1.2

7.3.3

RISK-2.E.MIL2 RISK-2.F.MIL2 RISK-3.F.MIL2

null

314.4(c)(2)

null

2.E.5

null

38-99-20(D)(3)

null

Sec 7

null

3.3.1(10) 3.3.1(13)(d)

null

Art 17

Art 35.1

null

SP-03

null

2.2 6.8

null

1-2-1-2

TPC-31

3.2.1.4

null

1-3-1-3 1-3-1-6

null

Sec 19

null

A2.a

null

4.4.7.2 4.5.5

null

4.1.3 4.1.4(d) 4.5.2 4.5.3

null

5.5

null

6.24

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Ranking

RSK-05

Mechanisms exist to identify and assign a risk ranking to newly discovered security vulnerabilities that is based on industry-recognized practices.

- Risk Management Program (RMP)

null

Does the organization identify and assign a risk ranking to newly discovered security vulnerabilities that is based on industry-recognized practices?

9

Identify

null

X

null

There is no evidence of a capability to identify and assign a risk ranking to newly discovered security vulnerabilities that is based on industry-recognized practices.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify and assign a risk ranking to newly discovered security vulnerabilities that is based on industry-recognized practices.

CC3.2

CC3.1-POF6 CC3.2-POF4 CC3.2-POF8

null

APO12.03

Principle 7 Principle 12

BCR-02 CEK-07

RSM-01 RSM-02

null

8.3

null

5.5

4.3.5

null

OR-2.0

Sec 4(D)(3)

MANAGE 1.2

ID.DE-P1

RV.3 RV.3.1 RV.3.2

R-2

3.3

null

GV.RM-06

null

6.1

12.3

null

I.1.7.2

7.4A

1.4.1

7.1.3

null

RISK-2.C.MIL2 RISK-3.C.MIL2 RISK-3.D.MIL2 RISK-3.E.MIL2

null

314.4(c)(2)

null

17 CFR 229.106(B)(1) 17 CFR 229.106(B)(2)

null

38-99-20(D)(3)

null

3.3.1(10)

null

Art 17

null

2.2

null

TPC-31

3.2.1.2

null

Sec 19

null

A2.a

null

4.4.7.3 4.4.7.4 4.5.5

null

4.2.1

null

5.5

null

2.2

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Remediation

RSK-06

Mechanisms exist to remediate risks to an acceptable level.

- Risk Management Program (RMP) - CimTrak Integrity Suite (https://www.cimcor.com/cimtrak/)

null

Does the organization remediate risks to an acceptable level?

10

Identify

X

There is no evidence of a capability to remediate risks to an acceptable level.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to remediate risks to an acceptable level.

CC3.2 CC4.2 CC7.4

CC1.1-POF4 CC5.3-POF4

null

18.3

null

18.3

APO12.06

Principle 7 Principle 13 Principle 17

CEK-07

RSM-01 RSM-02

null

RQ-08-08 RQ-09-05 RQ-09-06.a RQ-09-06.b RQ-09-07.a RQ-09-07.b RQ-09-07.c RQ-09-07.d RQ-15-17.a RQ-15-17.b RQ-15-17.c RQ-15-17.d

null

6.1.3 8.3 10.1

6.1.3 6.1.3(a) 6.1.3(b) 6.1.3(c) 6.1.3(d) 6.1.3(e) 6.1.3(f) 8.3

null

5.8

null

5.4.1.3

null

5.5

4.3.5

null

OR-2.0

Sec 4(D)(3)

MANAGE 1.2 MANAGE 2.0 MANAGE 4.0

ID.DE-P1 ID.RA-P5

null

A-5

3.3

null

3.11.3

null

ID.RA-6

ID.RA-06

null

10.7 10.7.1 10.7.2 10.7.3 12.3 A3.3.1.2

null

10.7.2 10.7.3

10.7.1 10.7.2 10.7.3

null

P.4.4

null

1.4.1

7.1.1

7.3.3 7.3.4

RISK-4.A.MIL1 RISK-4.B.MIL2 RISK-4.C.MIL3 RISK-4.D.MIL3 RISK-4.E.MIL3

null

RA.L2-3.11.3

null

RA.L2-3.11.3

null

D5.IR.Pl.B.1 D5.DR.Re.E.1 D5.IR.Pl.E.1

null

314.4(c)(2)

null

6.11

null

5.6

null

38-99-20(D)(3)

null

3.3.1(13)(c)

null

Art 17

null

Article 21.4

null

TPC-31

null

Sec 19

null

A2.a

null

31

null

4.4.8 4.4.8.1 4.4.8.2 4.4.8.3 4.4.8.4 4.4.8.5 4.5.5 4.5.5.2 4.5.5.3 4.7.1 4.7.1.1 4.7.1.2 4.7.1.3 4.7.1.4 4.7.1.5 4.7.1.6 4.7.1.7

null

4.1.3 4.1.4(c) 4.4.1 4.4.2 4.4.3 13.6.1 13.6.1(a) 13.6.1(b) 13.6.1(c)

null

5.5

null

2.2 2.7 6.8

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Response

RSK-06.1

Mechanisms exist to respond to findings from cybersecurity & data privacy assessments, incidents and audits to ensure proper remediation has been performed.

- Risk Management Program (RMP)

null

Does the organization respond to findings from cybersecurity & data privacy assessments, incidents and audits to ensure proper remediation has been performed?

9

Identify

X

There is no evidence of a capability to respond to findings from cybersecurity & data privacy assessments, incidents and audits to ensure proper remediation has been performed.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to respond to findings from cybersecurity & data privacy assessments, incidents and audits to ensure proper remediation has been performed.

CC3.2 CC3.3

CC3.2-POF5

null

APO12.06

Principle 7 Principle 8

A&A-06 CEK-07

RSM-01 RSM-02

null

RQ-08-08 RQ-09-05 RQ-09-06.a RQ-09-06.b RQ-09-07.a RQ-09-07.b RQ-09-07.c RQ-09-07.d RQ-15-17.a RQ-15-17.b RQ-15-17.c RQ-15-17.d

null

8.3

6.1.3 6.1.3(a) 6.1.3(b) 6.1.3(c) 6.1.3(d) 6.1.3(e) 6.1.3(f) 8.3

null

5.8

null

5.5

4.3.5

null

OR-2.0

Sec 4(D)(3)

MANAGE 1.3 MANAGE 2.0 MANAGE 2.3 MANAGE 2.4 MANAGE 4.0

ID.DE-P1 ID.RA-P5

null

M-3 R-3

3.3

null

RA-7

null

RA-7

null

RA-7

null

RA-7

null

GV.RM-04

null

10.7 10.7.1 10.7.2 10.7.3

null

10.7.2 10.7.3

10.7.1 10.7.2 10.7.3

null

A.3.4

null

1.4.1

null

7.3.3 7.3.4

RISK-4.A.MIL1 RISK-4.B.MIL2 RISK-4.C.MIL3 RISK-4.D.MIL3 RISK-4.E.MIL3 SITUATION-3.G.MIL3

null

RA-7

null

314.4(c)(2)

null

RA-7

null

17 CFR 229.106(B)(1)

null

38-99-20(D)(3)

null

RA-7

null

3.3.1(13)(c)

null

Art 17

null

TPC-31

3.2.1.3

null

Sec 19

null

A2.a

null

4.4.8 4.4.8.1 4.4.8.2 4.4.8.3 4.4.8.4 4.4.8.5 4.5.5 4.5.5.2 4.5.5.3

null

4.1.5 4.5.3

null

5.5

null

6.24

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Compensating Countermeasures

RSK-06.2

Mechanisms exist to identify and implement compensating countermeasures to reduce risk and exposure to threats.

null

Does the organization identify and implement compensating countermeasures to reduce risk and exposure to threats?

9

Respond

null

X

null

There is no evidence of a capability to identify and implement compensating countermeasures to reduce risk and exposure to threats.

SP-CMM1 is N/A, since a structured process is required to identify and implement compensating countermeasures to reduce risk and exposure to threats.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to identify and implement compensating countermeasures to reduce risk and exposure to threats.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify and implement compensating countermeasures to reduce risk and exposure to threats.

null

CC9.1-POF1 CC9.1-POF2

null

CCSC 2 (4.3)

PM-06-13 RQ-06-14

null

OR-2.0

null

MANAGE 2.1

null

ID.RA-07

null

1.2.6 2.2.4 12.3.1 12.3.2

null

1.2.6 2.2.4 12.3.1

null

1.2.6

2.2.4 12.3.1

2.2.4

1.2.6 2.2.4 12.3.1 12.3.2

1.2.6 2.2.4 12.3.1

null

A.1.3.1

null

314.4(c)(2)

null

III.C.1.b III.C.2 III.C.3 III.E.3

null

3.3.1(13)(c)

null

TPC-31

null

1-3-1-6 1-3-1-7

null

Sec 19

null

A2.a

null

1809

null

12.4.5.C.01

null

4.2(b) 4.3(c)

4.2.1 4.4.2 4.4.3

null

5.8

null

6.16 6.24

3.2.6

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Assessment Update

RSK-07

Mechanisms exist to routinely update risk assessments and react accordingly upon identifying new security vulnerabilities, including using outside sources for security vulnerability information.

- Risk Management Program (RMP)

null

Does the organization routinely update risk assessments and react accordingly upon identifying new security vulnerabilities, including using outside sources for security vulnerability information?

9

Identify

null

X

null

There is no evidence of a capability to routinely update risk assessments and react accordingly up on identifying new security vulnerabilities, including using outside sources for security vulnerability information.

SP-CMM1 is N/A, since a structured process is required to routinely update risk assessments and react accordingly up on identifying new security vulnerabilities, including using outside sources for security vulnerability information.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to routinely update risk assessments and react accordingly up on identifying new security vulnerabilities, including using outside sources for security vulnerability information.

CC3.2

null

APO12.05

Principle 7

null

GVN-08

SO2

null

8.2

null

5.4 5.6

4.3.4

null

OR-2.0

null

ID.DE-P5 GV.MT-P1

null

M-2

3.2 3.3 3.4

null

3.11.1.b

null

6.1

12.3.1 12.3.2

null

12.3.1

null

12.3.1

null

12.3.1 12.3.2

12.3.1

null

A.3.1

7.4A

null

RISK-3.G.MIL3

null

314.4(b)(2)

null

5.6

null

17.03(2)(i) 17.03(2)(b)(3)

null

622(2)(A)(iv)

null

Sec 7

null

3.3.1(13)(f)

null

Art 17

null

2.2

null

TPC-31

null

1-5-3-2 1-5-4

null

Sec 19

null

A2.a

null

4.5.5 4.6 4.6.1

null

4.1.5

null

x

MA 201 CMR 17 OR 6464A

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Business Impact Analysis (BIA)

RSK-08

Mechanisms exist to conduct a Business Impact Analysis (BIA) to identify and assess cybersecurity and data protection risks.

- Risk Management Program (RMP) - Data Protection Impact Assessment (DPIA) - Business Impact Analysis (BIA)

E-CHG-01

Does the organization conduct a Business Impact Analysis (BIA) to identify and assess cybersecurity and data protection risks?

8

Identify

null

X

There is no evidence of a capability to conduct a Business Impact Analysis (BIA) to identify and assess cybersecurity and data protection risks.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to conduct a Business Impact Analysis (BIA) to identify and assess cybersecurity and data protection risks.

CC3.2 CC5.2 PI1.1

CC9.1-POF1 CC9.1-POF2

null

APO12.03 BAI04.02

Principle 7 Principle 11

BCR-02

RSM-01 RSM-02 RSM-03

null

RQ-15-01

8.2 8.2.1 8.2.2

8.2

null

5.30

null

5.12

5.4

4.3.4 5.3.3 5.5

null

Sec 4(D)(3)

null

3.2

null

ID.RA-4

null

A3.2.2

null

K.11

null

5.1

null

SC:SG7.SP1

null

D5.RE.Re.B.1 D5.ER.Er.Ev.1

null

7.M.C

null

38-99-20(D)(3)

null

3.7.1(78)

Art 11.5

Art 17

Art 35.1 Art 35.2 Art 35.3 Art 35.6 Art 35.8 Art 35.9 Art 35.11 Art 36.3

null

Art 21

null

BCM-02

null

6.8 16.6

null

1-5-3-4

null

Sec 19

null

21(d)

null

4.5.5 4.6 4.6.1

null

5.1.3 5.3.3

Art 33

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Supply Chain Risk Management (SCRM) Plan

RSK-09

Mechanisms exist to develop a plan for Supply Chain Risk Management (SCRM) associated with the development, acquisition, maintenance and disposal of systems, system components and services, including documenting selected mitigating actions and monitoring performance against those plans.

- Risk Management Program (RMP)

E-RSK-02

Does the organization develop a plan for Supply Chain Risk Management (SCRM) associated with the development, acquisition, maintenance and disposal of systems, system components and services, including documenting selected mitigating actions and monitoring performance against those plans?

10

Identify

X

There is no evidence of a capability to develop a plan for Supply Chain Risk Management (SCRM) associated with the development, acquisition, maintenance and disposal of systems, system components and services, including documenting selected mitigating actions and monitoring performance against those plans.

SP-CMM1 is N/A, since a structured process is required to develop a plan for Supply Chain Risk Management (SCRM) associated with the development, acquisition, maintenance and disposal of systems, system components and services, including documenting selected mitigating actions and monitoring performance against those plans.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to develop a plan for Supply Chain Risk Management (SCRM) associated with the development, acquisition, maintenance and disposal of systems, system components and services, including documenting selected mitigating actions and monitoring performance against those plans.

CC3.1 CC3.2 CC4.1

CC3.2-POF7 CC9.2-POF1 CC9.2-POF2 CC9.2-POF3 CC9.2-POF4 CC9.2-POF5 CC9.2-POF6 CC9.2-POF7 CC9.2-POF8 CC9.2-POF9 CC9.2-POF10 CC9.2-POF11 CC9.2-POF12

null

15.2

null

15.2

APO12.01 APO12.02 APO12.03 APO12.04

Principle 6 Principle 7 Principle 16

STA-02 STA-03 STA-07 STA-08 STA-12 STA-13

SDV-02

null

5.21 8.30

null

5.1 5.2 5.3

4.3.3

null

Sec 4(D)(3)

MANAGE 3.0

ID.DE-P2 ID.DE-P3

PW.4.1

null

3.1

SA-12

null

SA-12

PM-29 PM-30 SR-2 SR-7

null

SR-2

PM-29 PM-30 SR-7

null

SR-2

null

PM-29 PM-30 SR-2 SR-7

SR-2

null

PM-29 PM-30

PM-30 SR-7

SR-2 SR-7

null

3.11.1.a 3.11.1.b 3.17.1.a 3.17.1.b 3.17.1.c 3.17.3.a 3.17.3.b

null

A.03.17.01.a[01] A.03.17.01.a[02] A.03.17.01.a[03] A.03.17.01.a[04] A.03.17.01.a[05] A.03.17.01.a[06] A.03.17.01.a[07] A.03.17.01.a[08] A.03.17.01.a[09] A.03.17.01.b[01] A.03.17.01.b[02] A.03.17.01.c

3.11.7e

null

ID.SC-1 ID.SC-3

GV.SC GV.SC-10

null

I.2.2.8

null

7.2.2.5

THIRD-PARTIES-1.C.MIL2

null

6.1 6.2

null

TBD - 3.11.7e

null

RA.L3-3.11.7e

null

SR-2

null

5.S.B

5.M.B

5.M.B 9.L.C

SR-2

null

17 CFR 229.106(B)(1)(iii)

null

38-99-20(D)(3)

null

SR-2

null

Art 28.1 Art 28.1(a) Art 28.1(b) Art 28.1(b)(i) Art 28.1(b)(ii) Art 28.2 Art 28.3 Art 28.4(a) Art 28.4(b) Art 28.4(c) Art 28.4(d) Art 28.4(e) Art 28.5 Art 28.6 Art 28.7(a) Art 28.7(b) Art 28.7(c) Art 28.7(d) Art 28.8 Art 28.8(a) Art 28.8(b) Art 28.8(c)

null

Article 21.2(d) Article 21.3

null

OIS-07

null

16.3 17.3 17.11

null

1-5-3-3

null

A4.a

A4

null

0731 1567 1785

null

15.1.1.16.B 15.1.2.18.PB

null

2.2.7.C.01 12.7.14.C.01 12.7.14.C.02 12.7.14.C.03 12.7.15.C.01 12.7.15.C.02 12.7.16.C.01 12.7.16.C.02 12.7.16.C.03 12.7.17.C.01 12.7.18.C.01 12.7.18.C.02 12.7.19.C.01 12.7.19.C.02 12.7.20.C.01 12.7.20.C.02 12.7.20.C.03 12.7.20.C.04 12.7.20.C.05 12.7.21.C.01

null

5.3.1

null

2.3 4.25

null

x

NAIC

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Risk Management

Supply Chain Risk Assessment

RSK-09.1

Mechanisms exist to periodically assess supply chain risks associated with systems, system components and services.

- Risk Management Program (RMP) - Data Protection Impact Assessment (DPIA)

E-RSK-05

Does the organization periodically assess supply chain risks associated with systems, system components and services?

9

Identify

X

null

There is no evidence of a capability to periodically assess supply chain risks associated with systems, system components and services.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to periodically assess supply chain risks associated with systems, system components and services.

CC3.2 CC9.2

CC3.2-POF7 CC9.2-POF1 CC9.2-POF2 CC9.2-POF3 CC9.2-POF4 CC9.2-POF5 CC9.2-POF6 CC9.2-POF7 CC9.2-POF8 CC9.2-POF9 CC9.2-POF10 CC9.2-POF11 CC9.2-POF12

null

APO12.01 APO12.02 APO12.03 APO12.04

Principle 7

STA-07 STA-08 STA-13 STA-14

null

8.2

null

8.30

null

5.12

5.4

4.3.4

null

MANAGE 3.1

ID.DE-P5 GV.MT-P1

null

3.2

null

RA-3(1)

null

RA-3(1)

null

RA-3(1)

null

3.11.1.b 3.17.3.a

null

3.11.6e

null

GV.SC-01 GV.SC-06 ID.IM-02

null

I.2.2.8

null

7.2.2.5

null

TBD - 3.11.6e

null

RA.L3-3.11.6e

null

RA-3(1)

null

5.S.B

5.M.B

5.M.B 9.L.C

RA-3(1)

null

17 CFR 229.106(B)(1)(iii)

null

RA-3(1)

null

Art 28.4(a) Art 28.4(b) Art 28.4(c) Art 28.4(d) Art 28.4(e)

Art 17

Art 35.1 Art 35.2 Art 35.3 Art 35.6 Art 35.8 Art 35.9 Art 35.11 Art 36.3

null

16.6 17.3 17.11

null

1-5-3-3

null

A4.a

A4

null

1452

null

4.5.5 4.6 4.6.1

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Risk Management

AI & Autonomous Technologies Supply Chain Impacts

RSK-09.2

Mechanisms exist to address Artificial Intelligence (AI) and Autonomous Technologies (AAT)-related risks and benefits arising from the organization's supply chain, including third-party software and data.

null

Does the organization address Artificial Intelligence (AI) and Autonomous Technologies (AAT)-related risks and benefits arising from the organization's supply chain, including third-party software and data?

8

Protect

X

null

There is no evidence of a capability to address Artificial Intelligence (AI) and Autonomous Technologies (AAT)-related risks and benefits arising from the organization's supply chain, including third-party software and data.

SP-CMM1 is N/A, since a structured process is required to address Artificial Intelligence (AI) and Autonomous Technologies (AAT)-related risks and benefits arising from the organization's supply chain, including third-party software and data.

SP-CMM2 is N/A, since a well-defined process is required to address Artificial Intelligence (AI) and Autonomous Technologies (AAT)-related risks and benefits arising from the organization's supply chain, including third-party software and data.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to address Artificial Intelligence (AI) and Autonomous Technologies (AAT)-related risks and benefits arising from the organization's supply chain, including third-party software and data.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to address Artificial Intelligence (AI) and Autonomous Technologies (AAT)-related risks and benefits arising from the organization's supply chain, including third-party software and data.

null

GOVERN 6.0

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Data Protection Impact Assessment (DPIA)

RSK-10

Mechanisms exist to conduct a Data Protection Impact Assessment (DPIA) on systems, applications and services that store, process and/or transmit Personal Data (PD) to identify and remediate reasonably-expected risks.

- Risk Management Program (RMP) - Data Protection Impact Assessment (DPIA) - Privacy Impact Assessment (PIA)

E-PRI-04

Does the organization conduct a Data Protection Impact Assessment (DPIA) on systems, applications and services that store, process and/or transmit Personal Data (PD) to identify and remediate reasonably-expected risks?

9

Identify

null

X

There is no evidence of a capability to conduct a Data Protection Impact Assessment (DPIA) on systems, applications and services that store, process and/ or transmit Personal Data (PD) to identify and remediate reasonably-expected risks.

Risk Management efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to identify, assess, remediate and report on risk. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Risk management processes (e.g., risk assessments) focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

Risk Management efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to conduct a Data Protection Impact Assessment (DPIA) on systems, applications and services that store, process and/ or transmit Personal Data (PD) to identify and remediate reasonably-expected risks.

CC3.2 CC5.2 PI1.1

null

APO12.01 APO12.02 APO12.03 APO12.04

Principle 7 Principle 11

DSP-09 STA-14

GVN-07 GVN-08 LGL-01 LGL-03

null

1.2.4 4.2.3

null

8.2

null

18.1.4

5.33

18.1.4

A.11.1 A.11.2

7.2.5

5.12

5.4

4.3.4 5.3.3 5.5

null

Sec 4(D)(3)

null

ID.IM-P7 ID.RA-P1 ID.RA-P2 ID.RA-P3 ID.RA-P4 ID.RA-P5 ID.DE-P2 ID.DE-P3 GV.PO-P6 GV.MT-P1 GV.MT-P4 GV.MT-P5

null

3.2

AR-2

null

RA-8

null

A3.2.2

null

P.4

null

5.1

null

OPD:SG1.SP1 RISK:SG5.SP1 RISK:SG5.SP2

null

AR-2

6,502

null

7.M.C

7.M.C 4.L.B

RA-8

null

6-1-1305(2)(c) 6-1-1305(4) 6-1-1309(1) 6-1-1309(2) 6-1-1309(2)(a) 6-1-1309(2)(a)(I) 6-1-1309(2)(a)(II) 6-1-1309(2)(a)(III) 6-1-1309(2)(a)(IV) 6-1-1309(2)(b) 6-1-1309(2)(c) 6-1-1309(3) 6-1-1309(4) 6-1-1309(5) 6-1-1309(6)

null

38-99-20(D)(3)

null

59.1-580.A 59.1-580.A.1 59.1-580.A.2 59.1-580.A.3 59.1-580.A.3(i) 59.1-580.A.3(ii) 59.1-580.A.3(iii) 59.1-580.A.3(iv) 59.1-580.A.4 59.1-580.A.5 59.1-580.B 59.1-580.C 59.1-580.D 59.1-580.E 59.1-580.F

null

Art 17

Art 35.1 Art 35.2 Art 35.3 Art 35.6 Art 35.8 Art 35.9 Art 35.11 Art 36.1 Art 36.2 Art 36.3

null

BCM-02

null

16.6 17.3

null

31(1) 31(2)(a) 31(2)(b) 31(2)(c) 31(2)(d) 31(3) 31(4) 31(5) 31(6)

null

Article 8.2

null

1-5-3-4

null

Article 54 Article 54.x

null

Sec 19

null

Article 35(1) Article 35(2) Article 35(3)(a) Article 35(3)(b) Article 35(3)(c) Article 35(7)(a) Article 35(7)(b) Article 35(7)(c) Article 35(7)(d) Article 35(8) Article 35(9) Article 35(10) Article 35(11)

null

21(d)

null

Article 55 Article 55(1) Article 55(2) Article 55(3) Article 55(4) Article 55(5) Article 56 Article 56(1) Article 56(2) Article 56(3)

null

4.5.5 4.6 4.6.1 18.1.4

null

5.1.3 5.3.3

Art 33

null

x

NAIC

null

x

R-AC-4 R-BC-2 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-SA-2

null

R-AC-4

null

R-BC-2

null

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Monitoring

RSK-11

Mechanisms exist to ensure risk monitoring as an integral part of the continuous monitoring strategy that includes monitoring the effectiveness of cybersecurity & data privacy controls, compliance and change management.

null

Does the organization ensure risk monitoring as an integral part of the continuous monitoring strategy that includes monitoring the effectiveness of cybersecurity & data privacy controls, compliance and change management?

9

Detect

null

X

null

There is no evidence of a capability to ensure risk monitoring as an integral part of the continuous monitoring strategy that includes monitoring the effectiveness of cybersecurity & data privacy controls, compliance and change management.

SP-CMM1 is N/A, since a structured process is required to ensure risk monitoring as an integral part of the continuous monitoring strategy that includes monitoring the effectiveness of cybersecurity & data privacy controls, compliance and change management.

Risk Management efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Risk management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • Data/process owners are expected to self-manage risks associated with their systems, applications, services and data, based on the organization’s published policies and standards, including the identification, remediation and reporting of risks. • Data/process owners work with IT/cybersecurity personnel and Data Protection Officers (DPOs) to ensure applicable statutory, regulatory and contractual obligations are properly addressed, including the storage, transmission and processing of sensitive/regulated data. • IT/cybersecurity personnel: o Identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for risk management. o Implement and maintain a form of Risk Management Program (RMP) that provides operational guidance on how risk is identified, assessed, remediated and reported. • Risk management processes (e.g., risk assessments) and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure risk monitoring as an integral part of the continuous monitoring strategy that includes monitoring the effectiveness of cybersecurity & data privacy controls, compliance and change management.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure risk monitoring as an integral part of the continuous monitoring strategy that includes monitoring the effectiveness of cybersecurity & data privacy controls, compliance and change management.

null

OR-2.0

null

CA-7(4)

null

CA-7(4)

null

A.4.5

null

CA-7(4)

null

CA-7(4)

null

CA-7(4)

null

Sec 4

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Risk Management

Risk Culture

RSK-12

Mechanisms exist to ensure teams are committed to a culture that considers and communicates technology-related risk.

null

Does the organization ensure teams are committed to a culture that considers and communicates technology-related risk?

4

Identify

X

null

There is no evidence of a capability to ensure teams are committed to a culture that considers and communicates technology-related risk.

SP-CMM1 is N/A, since a structured process is required to ensure teams are committed to a culture that considers and communicates technology-related risk.

SP-CMM2 is N/A, since a well-defined process is required to ensure teams are committed to a culture that considers and communicates technology-related risk.

Risk Management efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including appropriately resourcing risk management operations. • A formal Risk Management Program (RMP) provides enterprise-wide guidance on how risk is to be identified, framed (e.g., risk appetite, risk tolerance, risk thresholds, etc.). assessed, mitigated/remediated and reported. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes, applying the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function: o Maintains a common taxonomy of risk-relevant terminology to minimize assumptions and misunderstandings. o Enables data/process owners to conduct annual risk assessment of their operations that includes the likelihood and magnitude of harm, from unauthorized access, use, disclosure, disruption, modification or destruction of the organization's systems and data. o Assists users in making informed risk decisions to ensure data and processes are appropriately protected. o Enables the documentation of risk assessments, risk response and risk monitoring to support statutory, regulatory and contractual obligations for risk management practices. o Maintains a centralized risk register to reflect an active recording and disposition of identified risks. The risk register identifies and assigns a risk ranking to vulnerabilities and risks that is based on industry-recognized practices and facilitates monitoring and reporting of those risks. o Governs supply chain risks associated with the development, acquisition, maintenance and disposal of systems, system components and services

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to ensure teams are committed to a culture that considers and communicates technology-related risk.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to ensure teams are committed to a culture that considers and communicates technology-related risk.

null

GOVERN 4.0

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

MT-11 MT-12 MT-13 MT-14 MT-15

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Secure Engineering Principles

SEA-01

Mechanisms exist to facilitate the implementation of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services.

null

E-TDA-01 E-TDA-02 E-TDA-04 E-TDA-08 E-TDA-09

Does the organization facilitate the implementation of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services?

10

Protect

X

There is no evidence of a capability to facilitate the implementation of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services.

Secure Engineering & Architecture (SEA) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure solutions. • IT /cyber engineering governance is decentralized, with the responsibility for implementing and testing cybersecurity & data privacy controls being assigned to the business process owner(s), including the definition and enforcement of roles and responsibilities. • Configurations mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides).

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • The Chief Information Security Officer (CISO), or similar function, analyzes the organization’s business strategy to determine prioritized and authoritative guidance for secure engineering practices. • The CISO, or similar function, develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures to apply defense-in-depth techniques across the enterprise for secure engineering. • A Governance, Risk & Compliance (GRC) function, or similar function, provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity & data privacy controls to protect the confidentiality, integrity, availability and safety of the organization’s applications, systems, services and data with regards to secure engineering. • A steering committee is formally established to provide executive oversight of the cybersecurity & data privacy program, including secure engineering. • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

Secure Engineering & Architecture (SEA) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to facilitate the implementation of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services.

CC2.2 CC3.2 CC5.1 CC5.2

null

12.2 12.6 16.0 16.10

null

12.2 12.6 16.10

APO03.01 APO03.02 APO03.03 APO03.04 APO03.05 APO04.05

Principle 7 Principle 10 Principle 11 Principle 14 Principle 17

DSP-07 DSP-08 IVS-01 IVS-09

CLS-05 GVN-01 GVN-02 SWS-04

SO12

4.2.3 6.2.2 7.2.2 7.2.3

CCSC 1 (4.2)

RC-05-10

null

14.1.2 14.2.5

8.12 8.26 8.27

14.1.2 14.2.5

A.10.1 A.10.4 A.10.5 A.10.6

6.11.2.5 7.4 8.4

5.10 5.11

null

T1005, T1025, T1041, T1048, T1048.002, T1048.003, T1052, T1052.001, T1078, T1078.001, T1078.003, T1078.004, T1134.005, T1190, T1213.003, T1482, T1547.011, T1567, T1574.002

OR-1.0

Sec 4(C)(5) Sec 4(D)(1)

GOVERN 1.0 GOVERN 1.2 GOVERN 1.3 GOVERN 1.4 GOVERN 2.2 GOVERN 3.2 GOVERN 4.1 GOVERN 5.1 GOVERN 6.0 GOVERN 6.1 MAP 3.5

ID.DE-P4 GV.PO-P2 CT.PO-P1 CT.DM-P7 CT.DM-P8 CM.AW-P3

null

P-15

2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8

AR-7 SA-8 SA-13 SC-1 SC-7(18) SI-1

SC-1 SI-1

SA-8 SC-1 SI-1

SA-8 SC-1 SC-7(18) SI-1

PT-1 SA-8 SC-1 SC-7(18) SI-1 SA-15(5)

PT-1 SI-1

SA-8 SC-1 SI-1

SA-8 SC-1 SC-7(18) SI-1

SA-15(5)

null

SA-8 SC-1 SI-1

SA-8 SC-1 SC-7(18) SI-1

2.1 2.2 2.3 2.4

SA-8 SC-1 SI-1

null

SA-8 SC-1 SI-1

3.13.2

3.1.12.a 3.1.16.a 3.1.16.b 3.1.16.c 3.1.18.a

3.13.2[a] 3.13.2[c] 3.13.2[d] 3.13.2[f]

null

3.14.3e

null

PR.IP-1 PR.PT-5

PR.IR PR.IR-01 PR.IR-02 PR.IR-03

A01:2021 A04:2021 A05:2021

2.2

1.2 8.5 8.5.1

null

8.5.1

null

8.5.1

null

8.5.1

null

I.2.2

1.3 2.9

5.3.2

null

ARCHITECTURE-1.A.MIL1 ARCHITECTURE-1.B.MIL2 ARCHITECTURE-1.C.MIL2 ARCHITECTURE-1.D.MIL2 ARCHITECTURE-1.E.MIL2 ARCHITECTURE-1.F.MIL2 ARCHITECTURE-1.I.MIL3 ARCHITECTURE-1.J.MIL3 ARCHITECTURE-1.K.MIL3

EXD:SG3.SP2 EXD:SG3.SP4 EXD:SG4.SP1 RRD:SG2.SP1 RRD:SG3.SP2 RRD:SG3.SP3 RTSE:SG1.SP2 RTSE:SG1.SP3 TM:SG1.SP2 TM:SG2.SP1

5.4

5.10.3.2

null

SC.L2-3.13.2

SC.L2-3.13.2 TBD - 3.14.3e

SC.L1-b.1.x

SC.L2-3.13.2

SC.L2-3.13.2 SI.L3-3.14.3e

AR-7 SA-8 SC-1 SC-7(18) SI-1

null

52.204-21(b)(1)(x) 52.204-21(b)(2)

null

§ 11.30 § 11.50 § 11.70 § 11.100 § 11.100(a) § 11.100(b)

SC-1 SA-8 SC-7(18) SI-1

SC-1 SI-1

SC-1 SA-8 SC-7(18) SI-1

SC-1 SI-1

SA-8 SC-1 SC-7(18) SI-1

SA-8 SC-1 SI-1

SA-8 SC-1 SC-7(18) SI-1

SA-8 SC-1 SI-1

null

§45(a) §45b(d)(1)

314.4(c)

164.306(b) 164.306(c) 164.306(d) 164.308(a) 164.312 164.314(b) 164.314(b)(1) 164.314(b)(2) 164.314(b)(2)(i) 164.314(b)(2)(ii) 164.314(b)(2)(iii) 164.314(b)(2)(iv) 164.530(c) 164.530(c)(1) 164.530(c)(2)

1.S.A 2.S.A 3.S.A 5.S.A 5.S.B 5.S.C 6.S.A 6.S.C 9.S.A

1.M.A 5.M.B 9.M.B

1.M.A 5.M.B 9.M.B 1.L.A

PT-1 SA-8 SC-1 SC-7(18) SI-1

null

8-101 8-302 8-311

16.2

null

Principle 4

null

5.6

SC-1 SI-1

SC-1 SA-8 SC-7(18) SI-1

null

1798.91.04(a) 1798.91.04(a)(1) 1798.91.04(a)(2) 1798.91.04(a)(3) 1798.91.04(b) 1798.91.04(b)(1) 1798.91.04(b)(2)

null

6-1-1305(4) 6-1-1308(5)

null

Sec 4(2)(b)(ii)(B)(1) Sec 4(2)(b)(ii)(B)(2) Sec 4(2)(b)(ii)(B)(3) Sec 4(2)(b)(ii)(B)(4)

null

38-99-20(C)(5) 38-99-20(D)(1)

Sec. 521.052

null

SA-8 SC-1 SI-1

SC-1 SI-1

SA-8 SC-1 SC-7(18) SI-1

null

59.1-578.3

§ 2447(a) § 2447(a)(1) § 2447(a)(1)(A) § 2447(a)(1)(B) § 2447(a)(1)(C) § 2447(a)(1)(D) § 2447(a)(2)

3.7.1(79)

Art 9.3(a) Art 9.3(b) Art 9.3(c) Art 9.3(d)

Art 10 Art 14

Art 5.2 Art 24.1 Art 24.2 Art 24.3 Art 25.1 Art 25.2 Art 25.3 Art 32.1 Art 32.2 Art 40.2

Article 21.1 Article 21.5

null

Sec 14 Sec 15

Art 16

Art 13 Art 27

Art 27 Art 41

Sec 5 Sec 32 Sec 33 Sec 34 Sec 35

Art 34

Sec 4b Sec 9 Sec 9a Sec 16 Annex

12.1

COS-01

Art 9

Sec 7 Sec 8

Sec 2

2.1 15.6 17.7

Sec 16 Sec 17

Sec 31 Sec 33 Sec 34 Sec 35 Sec 42

null

Art 3 Art 4

Sec 12 Sec 13 Sec 14

null

Sec 13 Sec 14 Sec 29

Art 1 Art 36 Art 47

Art 14 Art 15 Art 16 Art 17 Art 18 Art 19

null

Art 7 Art 12 Art 19

null

TPC-43

3.3.4 3.3.8 3.3.13

1-6-3-4 2-4-3 2-15-3-3

1-1-2

null

Sec 19 Sec 21

null

7.1.2 [OP.PL.2]

Sec 31 Sec 33

Art 6 Art 7

Art 8 Art 12

Sec 11 Sec 15 Sec 16

B4.a B5.b

B4 B5

null

Article 5(1)(f) Article 25(1) Article 25(2) Article 25(3) Article 32(1) Article 32(1)(a) Article 32(1)(b) Article 32(1)(c) Article 32(1)(d) Article 32(2) Article 32(3) Article 32(4)

null

Principle 5.6

Principle 5.7

APP Part 8 APP Part 11

null

1739 1743

Principle 4 Principle 5 Principle 6 Principle 7

null

15 18

null

Sec 4

null

Principle 4 Sec 33

Sec 7 Sec 8

null

Article 20

14.1.2 14.2.5

Sec 9

1.5 1.6 1.7

1.2.13.C.01 1.2.13.C.02

null

Sec 25 Sec 29

Sec 24 Sec 26

null

5.6.1 5.6.2 5.6.3 11.2.8

Art 3 Art 29

Art 21

Art 9 Art 12

null

Sec 6 Sec 12

4

Art 6.7 Art 46 Art 37 Art 49

null

2.1 2.1.1 2.1.2 3.2.1

Principle 7

Art 7

Art 4 Art 26

Art 10 Art 14

Art 19 Art 36 Art 37

Art 9 Art 11 Art 15 Art 16 Art 17

Art 5 Art 10

null

x

FAR 52.204-21 NAIC

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1 R-SA-2

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

R-SA-2

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15 MT-16

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

MT-16

null

Secure Engineering & Architecture

Centralized Management of Cybersecurity & Data Privacy Controls

SEA-01.1

Mechanisms exist to centrally-manage the organization-wide management and implementation of cybersecurity & data privacy controls and related processes.

null

Does the organization centrally-manage the organization-wide management and implementation of cybersecurity & data privacy controls and related processes?

9

Protect

X

null

There is no evidence of a capability to centrally-manage the organization-wide management and implementation of cybersecurity & data privacy controls and related processes.

SP-CMM1 is N/A, since a structured process is required to centrally-manage the organization-wide management and implementation of cybersecurity & data privacy controls and related processes.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

Secure Engineering & Architecture (SEA) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to centrally-manage the organization-wide management and implementation of cybersecurity & data privacy controls and related processes.

CC5.1

null

16.10

null

16.10

APO03.01 APO03.03

Principle 10 Principle 17

null

CLS-05 GVN-01 GVN-02

null

RC-05-10

null

8.12

CLD.13.1.4

null

5.10 5.11

null

Sec 4(C)(5) Sec 4(D)(1)

GOVERN 1.0 GOVERN 1.2 GOVERN 1.3 GOVERN 1.4 GOVERN 2.2 GOVERN 3.2 GOVERN 4.1 GOVERN 5.1 GOVERN 6.0 GOVERN 6.1 MAP 3.5

GV.PO-P2

null

PL-9

null

PL-9

null

3.4 3.4.3 3.4.4 3.4.5 3.4.6 3.4.7 3.4.8 3.4.9 3.4.10 3.4.11 3.4.12 3.4.13 3.4.14

PL-9

null

PL-9

null

A01:2021 A04:2021 A05:2021

null

1.1 10.7 10.7.1 10.7.2 10.7.3

null

10.7.2 10.7.3

10.7.1 10.7.2 10.7.3

null

C.7

null

ARCHITECTURE-1.G.MIL2

EF:SG2.SP2

null

314.4(c)

null

1.S.A 2.S.A 3.S.A 5.S.A 5.S.B 5.S.C 6.S.A 6.S.C 9.S.A

1.M.A 5.M.B 9.M.B

1.M.A 5.M.B 9.M.B 1.L.A

null

15.1 15.2 15.3 15.4

null

III.B III.C.1 III.C.1.a III.C.1.b III.C.3

null

6-1-1305(4) 6-1-1308(5)

null

38-99-20(C)(5) 38-99-20(D)(1)

null

Art 5.2 Art 24.1 Art 24.2 Art 24.3 Art 25.1 Art 25.2 Art 25.3 Art 32.1 Art 32.2 Art 40.2

null

Sec 8

null

B4.a

null

Article 24(1) Article 24(2) Article 24(3)

null

18

null

1.5 1.6 1.7

4.3.19.C.01

null

4.5.1

null

Art 9.1

null

2.1 2.1.1 2.1.2 3.2.1

null

Art 5 Art 10

null

x

NAIC

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Achieving Resilience Requirements

SEA-01.2

Mechanisms exist to achieve resilience requirements in normal and adverse situations.

null

Does the organization achieve resilience requirements in normal and adverse situations?

4

Protect

X

null

There is no evidence of a capability to achieve resilience requirements in normal and adverse situations.

SP-CMM1 is N/A, since a structured process is required to achieve resilience requirements in normal and adverse situations.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to achieve resilience requirements in normal and adverse situations.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to achieve resilience requirements in normal and adverse situations.

null

PR.IR-04

null

R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-GV-1 R-GV-4 R-GV-5 R-IR-4

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

null

R-GV-1

null

R-GV-4

R-GV-5

null

R-IR-4

null

MT-1 MT-2 MT-3 MT-4 MT-5 MT-6 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

MT-1

MT-2

MT-3

MT-4

MT-5

MT-6

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Alignment With Enterprise Architecture

SEA-02

Mechanisms exist to develop an enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles that addresses risk to organizational operations, assets, individuals, other organizations.

- Administrative controls through corporate policies, standards & procedures. - NIST 800-160 - Enterprise architecture committee

E-TDA-04 E-TDA-09

Does the organization develop an enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles that addresses risk to organizational operations, assets, individuals, other organizations?

9

Protect

X

There is no evidence of a capability to develop an enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles that addresses risk to organizational operations, assets, individuals, other organizations.

SP-CMM1 is N/A, since a structured process is required to develop an enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles that addresses risk to organizational operations, assets, individuals, other organizations.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

Secure Engineering & Architecture (SEA) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to develop an enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations.

CC3.1 CC4.1 CC5.1

null

12.2 16.10

null

12.2 16.10

APO02.01 APO03.01 APO03.02 APO03.03 APO03.04 APO03.05 APO04.02 APO04.03 APO04.04 APO04.05 APO04.06

Principle 6 Principle 10 Principle 16 Principle 18

null

CLS-05 GVN-01 GVN-02 SWS-04

null

14.1.1

5.8 8.26

CLD.13.1.4 14.1.1

null

6.11.1.1

null

GV.PO-P2

null

P-16

2.7 2.8

PL-8 PM-7

null

PL-8

PL-8 PM-7

PL-8

null

PL-8

PM-7

null

PL-8

3.4 3.4.1 3.4.2 3.4.3 3.4.4 3.4.5 3.4.6

PL-8 PM-7

null

PM-7

PL-8 PM-7

PL-8

NFO - PL-8

3.1.12.a 3.1.16.a 3.1.18.a

null

3.13.1e

null

PR.IR-01

null

2.2

1.2

null

C.5.1

1.3

5.3.2

null

ARCHITECTURE-1.A.MIL1 ARCHITECTURE-1.B.MIL2 ARCHITECTURE-1.H.MIL3

CTRL:SG2.SP1 EC:SG3.SP1 EC:SG3.SP2 EF:SG1.SP2 EF:SG1.SP3 EF:SG2.SP1 EXD:SG1.SP1 KIM:SG3.SP1 PM:SG2.SP1 PM:SG2.SP2 RRD:SG2.SP2 RRM:SG1.SP1 RRM:SG1.SP5 RTSE:SG1.SP3 RTSE:SG2.SP2 SC:SG1.SP2 TM:SG1.SP2 TM:SG2.SP2 TM:SG3.SP1 TM:SG3.SP2

5.4

null

TBD - 3.13.1e

null

PL-8 PM-7

null

PL-8

null

PL-8

null

PL-8

null

9.M.E

PL-8 PM-7

null

8-103

16.2

null

PL-8

null

PM-7

null

PL-8

null

3.7.1(79)

Art 9.3(a) Art 9.3(b) Art 9.3(c) Art 9.3(d)

null

2.1 17.7

null

TPC-43

null

7.1.2 [OP.PL.2]

null

B4.a B5.b

B4

null

1739

null

14.1.1

null

2.3.28.C.01 19.5.26.C.01 19.5.26.C.02 19.5.26.C.03 19.5.26.C.04 19.5.26.C.05 19.5.26.C.06 19.5.26.C.07 19.5.26.C.08 19.5.26.C.09 19.5.26.C.10 19.5.26.C.11 19.5.26.C.12

null

5.6.1 5.6.2 5.6.3 11.2.8

null

2.1 2.1.1 2.1.2 3.2.1

null

x

null

x

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Standardized Terminology

SEA-02.1

Mechanisms exist to standardize technology and process terminology to reduce confusion amongst groups and departments.

null

Does the organization standardize technology and process terminology to reduce confusion amongst groups and departments?

3

Protect

null

X

null

There is no evidence of a capability to standardize technology and process terminology to reduce confusion amongst groups and departments.

SP-CMM1 is N/A, since a structured process is required to standardize technology and process terminology to reduce confusion amongst groups and departments.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data. • A Governance, Risk & Compliance (GRC) function, or similar function, enables the use of standardized technology and process terminology to reduce confusion amongst groups and departments.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to standardize technology and process terminology to reduce confusion amongst groups and departments.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to standardize technology and process terminology to reduce confusion amongst groups and departments.

CC2.2

null

Principle 14

null

3.0

null

GV.PO-P2

null

C.1

null

ADM:SG1.SP2

null

252.204-7008(a) 252.204-7012(a) 252.204-7019(a) 252.204-7020(a) 252.204-7021(a)

null

52.204-21(a)

52.204-27(a)

null

§ 11.3

null

164.304

null

1.8.1 1.8.1.1 1.8.1.2

null

1798.91.05

7001

null

59.1-575

null

Art 4.1 Art 4.2 Art 4.3 Art 4.4 Art 4.5 Art 4.6 Art 4.7 Art 4.8 Art 4.9 Art 4.10 Art 4.11 Art 4.12 Art 4.13 Art 4.14 Art 4.15 Art 4.16 Art 4.17 Art 4.18 Art 4.19 Art 4.20 Art 4.21 Art 4.22 Art 4.23 Art 4.24 Art 4.25 Art 4.26

null

Article 1.8

null

2

null

1.3

null

Article 1

null

4.3

null

6.4

null

x

FAR 52.204-21

null

R-BC-3 R-EX-4 R-GV-1 R-GV-4 R-GV-5 R-SA-1

null

R-BC-3

null

R-EX-4

null

R-GV-1

null

R-GV-4

R-GV-5

null

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

- updated DFARS mapping

Secure Engineering & Architecture

Outsourcing Non-Essential Functions or Services

SEA-02.2

Mechanisms exist to identify non-essential functions or services that are capable of being outsourced to external service providers and align with the organization's enterprise architecture and security standards.

null

Does the organization identify non-essential functions or services that are capable of being outsourced to external service providers and align with the organization's enterprise architecture and security standards?

3

Protect

null

X

null

There is no evidence of a capability to identify non-essential functions or services that are capable of being outsourced to third-party service providers and align with the organization's enterprise architecture and security standards.

SP-CMM1 is N/A, since a structured process is required to identify non-essential functions or services that are capable of being outsourced to third-party service providers and align with the organization's enterprise architecture and security standards.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to identify non-essential functions or services that are capable of being outsourced to third-party service providers and align with the organization's enterprise architecture and security standards.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to identify non-essential functions or services that are capable of being outsourced to third-party service providers and align with the organization's enterprise architecture and security standards.

null

PM-7(1)

null

PM-7(1)

null

B.1.1.1

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Technical Debt Reviews

SEA-02.3

Mechanisms exist to conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/or unsupported technologies.

null

Does the organization conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/or unsupported technologies?

9

Protect

null

X

There is no evidence of a capability to conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/ or unsupported technologies.

SP-CMM1 is N/A, since a structured process is required to conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/ or unsupported technologies.

SP-CMM2 is N/A, since a well-defined process is required to conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/ or unsupported technologies.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/ or unsupported technologies.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/ or unsupported technologies.

null

GOVERN 1.7

null

12.3.4 A3.3.2

null

12.3.4

null

D.8.2

2.2

null

Art 8.7

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-1 NT-2 NT-3 NT-4 NT-5 NT-6 NT-7 NT-8 NT-9 NT-10 NT-11 NT-12 NT-13 NT-14 MT-8 MT-9 MT-12 MT-13 MT-14 MT-15

NT-1

NT-2

NT-3

NT-4

NT-5

NT-6

NT-7

NT-8

NT-9

NT-10

NT-11

NT-12

NT-13

NT-14

null

MT-8

MT-9

null

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Defense-In-Depth (DiD) Architecture

SEA-03

Mechanisms exist to implement security functions as a layered structure minimizing interactions between layers of the design and avoiding any dependence by lower layers on the functionality or correctness of higher layers.

null

E-TDA-04 E-TDA-09

Does the organization implement security functions as a layered structure minimizing interactions between layers of the design and avoiding any dependence by lower layers on the functionality or correctness of higher layers?

10

Protect

X

null

There is no evidence of a capability to implement security functions as a layered structure minimizing interactions between layers of the design and avoiding any dependence by lower layers on the functionality or correctness of higher layers.

SP-CMM1 is N/A, since a structured process is required to implement security functions as a layered structure minimizing interactions between layers of the design and avoiding any dependence by lower layers on the functionality or correctness of higher layers.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

Secure Engineering & Architecture (SEA) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to implement security functions as a layered structure minimizing interactions between layers of the design and avoiding any dependence by lower layers on the functionality or correctness of higher layers.

null

APO03.01 APO04.05

null

IVS-09

null

CLD.13.1.4

null

PL-8(1) SC-3(5)

null

PL-8(1) SC-3(5)

null

PL-8(1) SC-3(5)

null

3.4 3.4.1 3.4.2 3.4.3 3.4.4 3.4.5 3.4.6

null

3.13.2

null

PR.IR-01

A01:2021 A05:2021

1.3.7

1.2.1 1.4.1

null

1.2.1 1.4.1

null

1.2.1 1.4.1

null

N.2.4.6

null

ARCHITECTURE-1.A.MIL1 ARCHITECTURE-1.B.MIL2 ARCHITECTURE-1.C.MIL2 ARCHITECTURE-1.D.MIL2 ARCHITECTURE-1.E.MIL2 ARCHITECTURE-1.F.MIL2 ARCHITECTURE-1.I.MIL3 ARCHITECTURE-1.J.MIL3 ARCHITECTURE-1.K.MIL3

null

5.4

null

SC.L2-3.13.2

null

SC.L2-3.13.2

null

PL-8(1)

null

16.2

null

Art 9.3(a) Art 9.3(b) Art 9.3(c) Art 9.3(d)

null

10.8

null

2-15-3-2

null

7.1.2 [OP.PL.2]

null

B4.a B5.b

null

11.2.1 11.2.8

null

3.2.3 3.2.4

null

x

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-GV-8 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

R-GV-8

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

System Partitioning

SEA-03.1

Mechanisms exist to partition systems so that partitions reside in separate physical domains or environments.

null

Does the organization partition systems so that partitions reside in separate physical domains or environments?

8

Protect

null

X

There is no evidence of a capability to partition systems so that partitions reside in separate physical domains or environments.

Secure Engineering & Architecture (SEA) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure solutions. • IT /cyber engineering governance is decentralized, with the responsibility for implementing and testing cybersecurity & data privacy controls being assigned to the business process owner(s), including the definition and enforcement of roles and responsibilities.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

Secure Engineering & Architecture (SEA) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist: ▪ 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 & data privacy 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. ▪ Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to partition systems so that partitions reside in separate physical domains or environments.

null

3.12

null

3.12

null

SC-32

null

SC-32

null

SC-32

null

I.3.3

null

5.10.3.1

null

SC-32

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-4 R-BC-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-IR-1 R-IR-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Application Partitioning

SEA-03.2

Mechanisms exist to separate user functionality from system management functionality.

- Separate interface for non-privileged users.

null

Does the organization separate user functionality from system management functionality?

8

Protect

null

X

There is no evidence of a capability to separate user functionality from system management functionality.

Secure Engineering & Architecture (SEA) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure solutions. • IT /cyber engineering governance is decentralized, with the responsibility for implementing and testing cybersecurity & data privacy controls being assigned to the business process owner(s), including the definition and enforcement of roles and responsibilities.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to separate user functionality from system management functionality.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to separate user functionality from system management functionality.

null

T1068, T1189, T1190, T1203, T1210, T1211, T1212, T1611

null

SC-2 SC-2(1)

null

SC-2

SC-2 SC-2(1)

null

SC-2

SC-2(1)

null

SC-2

null

3.13.3

null

3.13.3[a] 3.13.3[b] 3.13.3[c]

null

3.14.3e

null

A01:2021 A05:2021

11.3.4

null

H.12

null

AM:SG1.SP1 KIM:SG2.SP1 KIM:SG2.SP2 TM:SG2.SP1

null

5.10.3.1

null

SC.L2-3.13.3

SC.L2-3.13.3 TBD - 3.14.3e

null

SC.L2-3.13.3

SC.L2-3.13.3 SI.L3-3.14.3e

SC-2

null

SC-2

null

SC-2

null

SC-2

null

SC-2

null

SC-2 SC-2(1)

null

SC-2

null

SC-2

null

x

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-4 R-BC-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-IR-1 R-IR-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Process Isolation

SEA-04

Mechanisms exist to implement a separate execution domain for each executing process.

null

Does the organization implement a separate execution domain for each executing process?

7

Protect

null

X

There is no evidence of a capability to implement a separate execution domain for each executing process.

Secure Engineering & Architecture (SEA) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure solutions. • IT /cyber engineering governance is decentralized, with the responsibility for implementing and testing cybersecurity & data privacy controls being assigned to the business process owner(s), including the definition and enforcement of roles and responsibilities.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to implement a separate execution domain for each executing process.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to implement a separate execution domain for each executing process.

null

T1003, T1003.001, T1003.002, T1003.003, T1003.004, T1003.005, T1003.006, T1003.007, T1003.008, T1068, T1189, T1190, T1203, T1210, T1211, T1212, T1547.002, T1547.005, T1547.008, T1556, T1556.001, T1611

null

SC-39

null

SC-39

null

SC-39

null

NFO - SC-39

null

A01:2021 A05:2021

null

D.16.5

null

TM:SG2.SP2

null

SC-39

null

SC-39

null

SC-39

null

SC-39

null

SC-39

null

Principle 5.6

Principle 5.7

null

x

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-4 R-BC-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-IR-1 R-IR-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

null

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Security Function Isolation

SEA-04.1

Mechanisms exist to isolate security functions from non-security functions.

null

Does the organization isolate security functions from non-security functions?

7

Protect

null

X

There is no evidence of a capability to isolate security functions from non-security functions.

Secure Engineering & Architecture (SEA) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure solutions. • IT /cyber engineering governance is decentralized, with the responsibility for implementing and testing cybersecurity & data privacy controls being assigned to the business process owner(s), including the definition and enforcement of roles and responsibilities.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to isolate security functions from non-security functions.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to isolate security functions from non-security functions.

null

T1003.001, T1021.003, T1047, T1068, T1134.005, T1189, T1190, T1203, T1210, T1211, T1212, T1559, T1559.001, T1559.002, T1602, T1602.001, T1602.002, T1611

null

SC-3

null

SC-3

null

SC-3

null

SC-3

null

3.14.3e

null

A01:2021 A05:2021

1.2 1.3.1 2.2.1 11.3.4 11.3.4.1

2.2.3 10.7.1 11.4.5 11.4.6

null

2.2.3 11.4.5

null

11.4.5

2.2.3 11.4.5

null

2.2.3 11.4.5

2.2.3 10.7.1 11.4.5 11.4.6

null

D.16.5

null

TBD - 3.14.3e

null

SI.L3-3.14.3e

null

SC-3

null

SC-3

null

SC-3

null

SC-3

null

8-105

null

x

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-3 R-BC-4 R-BC-5 R-EX-1 R-EX-2 R-EX-3 R-EX-4 R-EX-5 R-EX-6 R-EX-7 R-GV-1 R-GV-2 R-GV-3 R-GV-4 R-GV-5 R-GV-6 R-GV-7 R-IR-1 R-IR-2 R-IR-3 R-IR-4 R-SA-1

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

R-BC-3

R-BC-4

R-BC-5

R-EX-1

R-EX-2

R-EX-3

R-EX-4

R-EX-5

R-EX-6

R-EX-7

R-GV-1

R-GV-2

R-GV-3

R-GV-4

R-GV-5

R-GV-6

R-GV-7

null

R-IR-1

R-IR-2

R-IR-3

R-IR-4

R-SA-1

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Hardware Separation

SEA-04.2

Mechanisms exist to implement underlying hardware separation mechanisms to facilitate process separation.

null

Does the organization implement underlying hardware separation mechanisms to facilitate process separation?

7

Protect

null

X

There is no evidence of a capability to implement underlying hardware separation mechanisms to facilitate process separation.

Secure Engineering & Architecture (SEA) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure solutions. • IT /cyber engineering governance is decentralized, with the responsibility for implementing and testing cybersecurity & data privacy controls being assigned to the business process owner(s), including the definition and enforcement of roles and responsibilities.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to implement underlying hardware separation mechanisms to facilitate process separation.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to implement underlying hardware separation mechanisms to facilitate process separation.

null

SC-39(1)

null

SC-39(1)

null

SC-39(1)

null

A01:2021 A05:2021

null

D.16.4

null

x

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-BC-1 R-BC-2 R-BC-4 R-BC-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-IR-1 R-IR-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

null

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null

Secure Engineering & Architecture

Thread Separation

SEA-04.3

Mechanisms exist to maintain a separate execution domain for each thread in multi-threaded processing.

null

Does the organization maintain a separate execution domain for each thread in multi-threaded processing?

7

Protect

null

X

There is no evidence of a capability to maintain a separate execution domain for each thread in multi-threaded processing.

Secure Engineering & Architecture (SEA) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT personnel use an informal process to design, build and maintain secure solutions. • IT /cyber engineering governance is decentralized, with the responsibility for implementing and testing cybersecurity & data privacy controls being assigned to the business process owner(s), including the definition and enforcement of roles and responsibilities.

Secure Engineering & Architecture (SEA) efforts are requirements-driven and formally governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: • Architecture/engineering management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure and compliant practices. • A Change Advisory Board (CAB), or similar function, exists to govern changes to systems, applications and services, ensuring their stability, reliability and predictability. • Administrative processes and technologies focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed. • IT/cybersecurity personnel identify cybersecurity & data privacy controls to address applicable statutory, regulatory and contractual requirements for architecture/engineering management. • IT personnel implement secure engineering practices to protect the confidentiality, integrity, availability and safety of the organization’s technology assets, data and network(s). • Technologies are configured to protect data with the strength and integrity commensurate with the classification or sensitivity of the information and mostly conform to industry-recognized standards for hardening (e.g., DISA STIGs, CIS Benchmarks or OEM security guides), including cryptographic protections for sensitive/regulated data.

Secure Engineering & Architecture (SEA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: • IT/cybersecurity architects, or a similar function, enable the implementation a “layered defense” network architecture that enables a resilient defense-in-depth approach through the use of industry-recognized cybersecurity & data privacy practices in the specification, design, development, implementation and modification of systems and services (e.g., DISA STIGs, CIS Benchmarks or OEM security guides). • IT/cybersecurity engineers, or a similar function, operationalize enterprise architecture, aligned with industry-recognized leading practices, with consideration for cybersecurity & data privacy principles, including resiliency expectations, that addresses risk to organizational operations, assets, individuals, other organizations. • A Validated Architecture Design Review (VADR), or similar process, is used to evaluate design criteria for secure practices and conformance with requirements for applicable statutory, regulatory and contractual controls to determine if the system/application/service is designed, built and operated in a secure and resilient manner. • A Change Advisory Board (CAB), or similar function, governs changes to systems, applications and services to ensure their stability, reliability and predictability. • A formal Change Management (CM) program helps to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently. • An Identity & Access Management (IAM) function, or similar function, enables the implementation of identification and access management controls for “least privileges” practices, allowing for the management of user, group and system accounts, including privileged accounts. • An IT Asset Management (ITAM) function, or similar function, categorizes assets according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.

See SP-CMM3. SP-CMM4 is N/A, since a quantitatively-controlled process is not necessary to maintain a separate execution domain for each thread in multi-threaded processing.

See SP-CMM4. SP-CMM5 is N/A, since a continuously-improving process is not necessary to maintain a separate execution domain for each thread in multi-threaded processing.

null

SC-39(2)

null

SC-39(2)

null

SC-39(2)

null

A01:2021 A05:2021

null

D.16.7

null

x

null

x

null

R-AC-1 R-AC-2 R-AC-3 R-AC-4 R-AM-1 R-AM-2 R-AM-3 R-BC-1 R-BC-2 R-BC-4 R-BC-5 R-EX-7 R-GV-1 R-GV-2 R-GV-4 R-GV-5 R-IR-1 R-IR-4

R-AC-1

R-AC-2

R-AC-3

R-AC-4

R-AM-1

R-AM-2

R-AM-3

R-BC-1

R-BC-2

null

R-BC-4

R-BC-5

null

R-EX-7

R-GV-1

R-GV-2

null

R-GV-4

R-GV-5

null

R-IR-1

null

R-IR-4

null

NT-7 MT-1 MT-2 MT-7 MT-8 MT-9 MT-10 MT-11 MT-12 MT-13 MT-14 MT-15

null

NT-7

null

MT-1

MT-2

null

MT-7

MT-8

MT-9

MT-10

MT-11

MT-12

MT-13

MT-14

MT-15

null