BCD-11.2: Separate Storage for Critical Information
Mechanisms exist to store backup copies of critical software and other security-related information in a separate facility or in a fire-rated container that is not collocated with the system being backed up.
Control Question: Does the organization store backup copies of critical software and other security-related information in a separate facility or in a fire-rated container that is not collocated with the system being backed up?
General (22)
| Framework | Mapping Values |
|---|---|
| AICPA TSC 2017:2022 (used for SOC 2) (source) | A1.2 A1.2-POF9 |
| GovRAMP Moderate | CP-09(03) |
| GovRAMP High | CP-09(03) |
| ISO 27002 2022 | 8.13 |
| ISO 27017 2015 | 12.3.1 |
| NIST 800-53 R4 | CP-9(3) |
| NIST 800-53 R4 (high) | CP-9(3) |
| NIST 800-53 R5 (source) | CP-9(3) |
| NIST 800-53B R5 (high) (source) | CP-9(3) |
| NIST 800-82 R3 HIGH OT Overlay | CP-9(3) |
| PCI DSS 4.0.1 (source) | 9.4.1.1 |
| PCI DSS 4.0.1 SAQ A (source) | 9.4.1.1 |
| PCI DSS 4.0.1 SAQ A-EP (source) | 9.4.1.1 |
| PCI DSS 4.0.1 SAQ B (source) | 9.4.1.1 |
| PCI DSS 4.0.1 SAQ B-IP (source) | 9.4.1.1 |
| PCI DSS 4.0.1 SAQ C (source) | 9.4.1.1 |
| PCI DSS 4.0.1 SAQ C-VT (source) | 9.4.1.1 |
| PCI DSS 4.0.1 SAQ D Merchant (source) | 9.4.1.1 |
| PCI DSS 4.0.1 SAQ D Service Provider (source) | 9.4.1.1 |
| PCI DSS 4.0.1 SAQ P2PE (source) | 9.4.1.1 |
| Shared Assessments SIG 2025 | K.4 |
| SCF CORE Mergers, Acquisitions & Divestitures (MA&D) | BCD-11.2 |
US (9)
| Framework | Mapping Values |
|---|---|
| US C2M2 2.1 | RESPONSE-4.K.MIL2 |
| US CISA CPG 2022 | 2.R |
| US FedRAMP R4 | CP-9(3) |
| US FedRAMP R4 (moderate) | CP-9(3) |
| US FedRAMP R4 (high) | CP-9(3) |
| US FedRAMP R5 (source) | CP-9(3) |
| US FedRAMP R5 (high) (source) | CP-9(3) |
| US - TX DIR Control Standards 2.0 | CP-9(3) |
| US - TX TX-RAMP Level 2 | CP-9(3) |
EMEA (7)
| Framework | Mapping Values |
|---|---|
| EMEA EU EBA GL/2019/04 | 3.5(58) |
| EMEA EU DORA | 12.3 |
| EMEA Germany C5 2020 | OPS-06 PSS-12 |
| EMEA Israel CDMO 1.0 | 25.20 |
| EMEA Saudi Arabia OTCC-1 2022 | 2-8-1-4 |
| EMEA Saudi Arabia SACS-002 | TPC-38 |
| EMEA UK DEFSTAN 05-138 | 2505 |
APAC (3)
| Framework | Mapping Values |
|---|---|
| APAC Australia Essential 8 | ML1-P8 ML2-P8 ML3-P8 |
| APAC Australia ISM June 2024 | ISM-1811 |
| APAC Japan ISMAP | 12.3.1 |
Capability Maturity Model
Level 0 — Not Performed
There is no evidence of a capability to store backup copies of critical software and other security-related information in a separate facility or in a fire-rated container that is not collocated with the system being backed up.
Level 1 — Performed Informally
Business Continuity & Disaster Recovery (BCD) 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 work with business stakeholders to identify business-critical systems and services, including internal teams and third-party service providers.
- IT personnel develop limited Disaster Recovery Plans (DRP) to recover business-critical systems and services.
- Business stakeholders develop limited Business Continuity Plans (BCPs) to ensure business-critical functions are sustainable both during and after an incident within Recovery Time Objectives (RTOs).
- Backups are performed ad-hoc and focus on business-critical systems.
- Limited technologies exist to support near real-time network infrastructure failover (e.g., redundant ISPs, redundant power, etc.).
- Backup copies of software or licenses/product keys are stored locally in a fire-rated container.
Level 2 — Planned & Tracked
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).
Level 3 — Well Defined
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.
Level 4 — Quantitatively Controlled
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 store backup copies of critical software and other security-related information in a separate facility or in a fire-rated container that is not collocated with the system being backed up.
Level 5 — Continuously Improving
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 store backup copies of critical software and other security-related information in a separate facility or in a fire-rated container that is not collocated with the system being backed up.
Assessment Objectives
- BCD-11.2_A01 critical system software and other security-related information backups to be stored in a separate facility are defined.
- BCD-11.2_A02 backup copies of critical system software and other security-related information are stored in a separate facility or in a fire rated container that is not collocated with the operational system.
Evidence Requirements
- E-AST-08 Asset Inventories - Sensitive / Regulated Data
-
Documented evidence of an inventory of the organization's sensitive/regulated data (including systems where sensitive/regulated data is stored, processed and/or transmitted) that contains sufficient information to determine the potential impact in the event of a data loss incident.
Asset Management - E-BCM-11 Backups - Local
-
Documented evidence of event logs for the on-site / local data backup solution.
Business Continuity - E-BCM-12 Backups - Remote
-
Documented evidence of event logs for the off-site / remote data backup solution.
Business Continuity - E-BCM-13 Backups - Recovery
-
Documented evidence of a Continuity of Operations Plan (COOP)-related criticality analysis for applications, systems, services, facilities, stakeholders and third-parties.
Business Continuity
Technology Recommendations
Micro/Small
- Disaster Recovery Plan (DRP)
- On-site data backup solution
- Off-site data backup service
Small
- Disaster Recovery Plan (DRP)
- On-site data backup solution
- Off-site data backup service
Medium
- Disaster Recovery Plan (DRP)
- On-site data backup solution
- Off-site data backup service
Large
- Disaster Recovery Plan (DRP)
- On-site data backup solution
- Off-site data backup service
Enterprise
- Disaster Recovery Plan (DRP)
- On-site data backup solution
- Off-site data backup service