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CHG-01: Change Management Policy

CHG 10 — Critical Govern

Mechanisms exist to establish a formal, documented change management policy that: (1) Conveys executive management's intent; (2) Provides organizational direction and expected behaviors; (3) Is reviewed at least annually; and (4) Is updated, as necessary, to adapt to evolving risks, threats and other changes that affect the organization.

Code reused: In SCF 2025.4 and earlier, CHG-01 was Change Management Program. That control is now CHG-02.

Control Question: Does the organization establish a formal, documented change management policy that: (1) Conveys executive management's intent; (2) Provides organizational direction and expected behaviors; (3) Is reviewed at least annually; and (4) Is updated, as necessary, to adapt to evolving risks, threats and other changes that affect the organization?

General (1)
Framework Mapping Values
CSA CCM 4.1.0 CCC-01

Capability Maturity Model

Level 0 — Not Performed

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.

Level 1 — Performed Informally

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.

Level 2 — Planned & Tracked

Change Management (CHG) 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 CHG domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with CHG 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 CHG domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Change management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Change management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.

Level 3 — Well Defined

Change Management (CHG) 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 CHG 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 CHG domain capabilities are well-documented and kept current by process owners. ▪ A centralized Change Management Office (CMO), or similar function, is appropriately staffed and supported to implement and maintain CHG domain capabilities. ▪ Technical procedures (e.g., ITIL change enablement) are utilized along with change management governance capabilities (e.g., Change Advisory Board (CAB)) to ensure successful, efficient and secure change management operations. ▪ 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 CHG 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).

Level 4 — Quantitatively Controlled

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.

Level 5 — Continuously Improving

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.

Assessment Objectives

  1. CHG-01_A01 a formal, documented change management policy is approved by executive management, or a formally delegated authority, and conveys executive management's intent for change management.
  2. CHG-01_A02 the change management policy provides organizational direction and states the behaviors expected of personnel and other applicable parties with respect to change management.
  3. CHG-01_A03 the current version of the change management policy is communicated to, and accessible by, the personnel and other applicable parties who are expected to comply with it.
  4. CHG-01_A04 the change management policy is reviewed at least annually.
  5. CHG-01_A05 the change management policy is updated, as necessary, in response to changes in risks, threats, business practices and/or statutory, regulatory and contractual obligations that affect the organization.

Evidence Requirements

E-GOV-01.6 Change Management Policy

Documented evidence of a change management policy.

Security, Compliance & Resilience Governance

Technology Recommendations

Micro/Small

  • ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
  • Executive-approved written policy with documented annual review

Small

  • ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
  • Executive-approved written policy with documented annual review
  • Policy acknowledgement tracking (e.g., HR onboarding records)

Medium

  • ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
  • GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.) for policy lifecycle management
  • Documented annual policy review with version control

Large

  • ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
  • GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.) for policy lifecycle management
  • Policy governance committee with formal annual review and approval workflow
  • Automated policy attestation and acknowledgement tracking

Enterprise

  • Steering committee
  • ComplianceForge - Security, Compliance & Resilience Program (SCRP) (https://complianceforge.com)
  • Enterprise GRC platform (e.g., Cyturus, Archer, MetricStream, ServiceNow IRM) for policy lifecycle management
  • Automated policy attestation, exception tracking and change history
  • Annual executive approval and board-level reporting

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