CLD-03.1: Customer Responsibility Matrix (CRM)

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.

Cloud Security (CLD) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with CLD domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Cloud management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Provider (CSP) instance.

Cloud Security (CLD) 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 CLD domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with CLD 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 CLD domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Cloud management controls-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Cloud management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Cloud-based Technology Assets, Applications and/or Services (TAAS) are governed according to the same processes used for on-premises TAAS, where no formal, dedicated cloud governance process exists. ▪ A Shared Responsibility Matrix (SRM), or similar Customer Responsibility Matrix (CRM), is documented for each Cloud Service Providers (CSPs) instance that takes into account differences between Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) methodologies.

Cloud Security (CLD) 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 CLD 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 CLD domain capabilities are well-documented and kept current by process owners. ▪ A cloud governance team, or similar function, is appropriately staffed and supported to implement and maintain CLD domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of cloud governance operations (e.g., multi-cloud governance tools, policy enforcement and cost management). ▪ 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 CLD 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 formally document a Customer Responsibility Matrix (CRM), delineating assigned responsibilities for security, compliance and resilience controls between the Cloud Service Provider (CSP) and its customers.

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.

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.