BCD-07: Ongoing Contingency Planning

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.

SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

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. ▪ Production TAASD support business-critical application and services failover. ▪ 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. ▪ Within the BC/DR plans, alternate communications channels are defined if primary means of communication are unavailable. ▪ RTOs are used to identify business-critical TAASD, which are given priority of service in alternate processing and storage sites.

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 update contingency plans due to changes affecting: (1) People (e.g., personnel changes); (2) Processes (e.g., new, altered or decommissioned business practices, including third-party services) (3) Technologies (e.g., new, altered or decommissioned technologies); (4) Data (e.g., changes to data flows and/or data repositories); (5) Facilities (e.g., new, altered or decommissioned physical infrastructure); and/or (6) Feedback from contingency plan testing activities.

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.