BCD-02: Business Continuity Management System (BCMS)

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

Business Continuity & Disaster Recovery (BCD) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with BCD domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Contingency management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Limited technologies exist to support near real-time network infrastructure failover (e.g., redundant ISPs and redundant power). ▪ IT and/or cybersecurity personnel develop limited Disaster Recovery Plans (DRP) to recover business-critical Technology Assets, Applications and/or Services (TAAS) and services.

Business Continuity & Disaster Recovery (BCD) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with BCD domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with BCD domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with BCD domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Business Continuity / Disaster Recovery (BC/DR)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ BC/DR may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Business stakeholders and process owners identify business-critical TAASD and External Service Providers (ESPs). ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to identify single points of failure from a TAASD perspective. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to develop BC/DR plans to recover business-critical TAASD. ▪ Data/process owners conduct a Business Impact Analysis (BIA) at least annually, or after any major technology or process change, to identify TAASD that are critical to the business, as well as single points of failure. ▪ Business stakeholders and process owners designate alternative decision-makers if primary decision-makers are unavailable.

Business Continuity & Disaster Recovery (BCD) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with BCD domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with BCD domain capabilities are well-documented and kept current by process owners. ▪ A Business Continuity & Disaster Recovery (BC/DR) team, or similar function, is appropriately staffed and supported to implement and maintain BCD domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of BC/DR operations (e.g., BC/DR planning software, Disaster Recovery as a Service (DRaaS), Orchestration and Automation Tools). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with BCD domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to facilitate the implementation of contingency planning controls to help ensure resilient Technology Assets, Applications and/or Services (TAAS) (e.g., Continuity of Operations Plan (COOP) or BC/DR playbooks).

Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define. Business Continuity & Disaster Recovery (BCD) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational. ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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