CPL-02.2: Periodic Audits

There is no evidence of a capability to conduct periodic audits of cybersecurity and data protection controls to evaluate conformity with its documented policies, standards and procedures.

C|P-CMM1 is N/A, since a structured process is required to conduct periodic audits of cybersecurity and data protection controls to evaluate conformity with its documented policies, standards and procedures.

Compliance (CPL) 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:

• Compliance activities are 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 compliance activities.
• Cybersecurity personnel use a defined set of controls to conduct cybersecurity and data privacy control assessments, as defined by the applicable statutory, regulatory and contractual requirements.
• Cybersecurity personnel generate a formal report for each security assessment to document the assessment of cybersecurity and data protection controls.
• Compliance reporting is performed, as required.

Compliance (CPL) 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: o Ensures data/process owners understand their requirements to manage applicable cybersecurity and data protection controls through oversight and written guidance. o Provides applicable stakeholders with status reports on control execution to enable security controls oversight. o Works with data/process owners and asset custodians to document and validate the scope of cybersecurity and data protection controls to ensure statutory, regulatory and/ or contractual compliance obligations are met. o Conducts cybersecurity and data privacy control assessments, on a regular cadence that is defined by the applicable statutory, regulatory and contractual requirements. o Reviews the findings from security assessments and oversees long-term remediation efforts, when applicable. o Provides senior leaders with insights into the appropriateness of the organization's technology and information governance processes through recurring audits on pertinent cybersecurity and data privacy-related topics. o Governs changes to compliance operations to ensure its stability, reliability and ongoing improvement.

• A Governance, Risk & Compliance (GRC) function, or similar function, provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity and data protection controls to ensure compliance requirements are identified and documented.
• The GRC function, or similar function:
• Cybersecurity and data privacy controls are centrally managed through a technology solution (e.g., GRC solution) to assign controls, track control activities and report on compliance efforts.
• An Audit Committee, or similar function:

Compliance (CPL) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• 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.
• Both business and technical stakeholders are involved in reviewing and approving proposed changes.

Cloud Security (CLD) efforts are “world-class” capabilities that leverage predictive analysis (e.g., machine learning, AI, etc.). In addition to CMM Level 4 criteria, CMM Level 5 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions.
• Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.