BCD-09.1: Separation from Primary Site

There is no evidence of a capability to separate the alternate processing site from the primary processing site to reduce susceptibility to similar threats.

C|P-CMM1 is N/A, since a structured process is required to separate the alternate processing site from the primary processing site to reduce susceptibility to similar threats.

Business Continuity & Disaster Recovery (BCD) efforts are requirements-driven and 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:

• Business Continuity / Disaster Recovery (BC/DR) management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
• IT/cybersecurity personnel identify cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements for BC/DR management.
• BC/DR roles are formally assigned as an additional duty to existing IT/cybersecurity personnel.
• Recovery Time Objectives (RTOs) identify business-critical systems and services, which are given priority of service in alternate processing and storage sites.
• IT personnel develop Disaster Recovery Plans (DRP) to recover business-critical systems and services.
• Data/process owners conduct a Business Impact Analysis (BIA) at least annually, or after any major technology or process change, to identify assets critical to the business in need of protection, as well as single points of failure.
• IT/cybersecurity personnel work with business stakeholders to develop Business Continuity Plans (BCPs) to ensure business functions are sustainable both during and after an incident within Recovery Time Objectives (RTOs).
• IT personnel use a backup methodology (e.g., grandfather, father & s on rotation) to store backups in a secondary location, separate from the primary storage site.
• IT personnel configure business-critical systems to transfer backup data to the alternate storage site at a rate that is capable of meeting Recovery Time Objectives (RTOs) and Recovery Point Objectives (RPOs).
• organization acquires space to serve as the alternate site that is in a different geographic zone from the inaccessible facility (e.g., dedicated facility or cloud instance).

Business Continuity & Disaster Recovery (BCD) 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 formal Business Continuity & Disaster Recovery (BC/DR) program exists with defined roles and responsibilities to restore functionality in the event of a catastrophe, emergency, or significant disruptive incident that is handled in accordance with a Continuity of Operations Plan (COOP).
• BC/DR personnel work with business stakeholders to identify business-critical systems, services, internal teams and third-party service providers.
• Specific criteria are defined to initiate BC/DR activities that facilitate business continuity operations capable of meeting applicable RTOs and/or RPOs.- Application/system/process owners conduct a Business Impact Analysis (BIA) at least annually, or after any major technology or process change, to identify assets critical to the business in need of protection, as well as single points of failure.
• Recovery Time Objectives (RTOs) are defined for business-critical systems and services.
• Recovery Point Objectives (RPOs) are defined and technologies exist to conduct transaction-level recovery, in accordance with RPOs.
• Controls are assigned to sensitive/regulated assets to comply with specific BC/DR requirements to facilitate recovery operations in accordance with RTOs and RPOs.
• IT personnel work with business stakeholders to develop Disaster Recovery Plans (DRP) to recover business-critical systems and services within RPOs.
• Business stakeholders work with IT personnel to develop Business Continuity Plans (BCPs) to ensure business functions are sustainable both during and after an incident within RTOs.
• The data backup function is formally assigned with defined roles and responsibilities.
• BC/DR personnel have pre-established methods to communicate the status of recovery activities and progress in restoring operational capabilities to designated internal and external stakeholders.
• The integrity of backups and other restoration assets are verified prior to using them for restoration.

See C|P-CMM3. There are no defined C|P-CMM4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to separate the alternate processing site from the primary processing site to reduce susceptibility to similar threats.

See C|P-CMM4. There are no defined C|P-CMM5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to separate the alternate processing site from the primary processing site to reduce susceptibility to similar threats.