CPL-04.2: Designated Certifying Official
Mechanisms exist to designate an individual with the authority to make statements of conformity on behalf of the organization.
Control Question: Does the organization designate an individual the authority to make statements of conformity on behalf of the organization?
US (1)
| Framework | Mapping Values |
|---|---|
| USA Federal SOX 2002 | 302(a) 302(a)(4) 302(a)(4)(A) 302(a)(4)(B) 302(a)(4)(C) 302(a)(4)(D) |
EMEA (1)
| Framework | Mapping Values |
|---|---|
| EMEA EU Cyber Resiliency Act 2024 | Article 18(1) |
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
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 — Well Defined
Compliance (CPL) 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 CPL 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 CPL domain capabilities are well-documented and kept current by process owners. ▪ A Governance, Risk & Compliance (GRC) team, or similar function, is appropriately staffed and supported to implement and maintain CPL domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform). ▪ 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 CPL 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 designate an individual the authority to make statements of conformity on behalf of the organization.
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
- CPL-04.2_A01 an individual is assigned the authority to make statements of conformity on behalf of the organization.
- CPL-04.2_A02 the designated individual is provided formal guidance on the limitations of statements of conformity that can be made on behalf of the organization.
Evidence Requirements
- E-CPL-14 Conformity Attestations & Declarations
-
Documented evidence of conformity assessment results, attestations and/or declarations of conformity, including the designated certifying official.
Compliance
Technology Recommendations
Micro/Small
- Document applicable regulatory requirements in a checklist
Small
- Compliance checklist
- Annual compliance review
Medium
- Compliance management program
- Regulatory mapping
- Compliance calendar
Large
- GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
- Compliance team
Enterprise
- GRC solution (e.g., SCFConnect, Cyturus, SureCloud, SimpleRisk, Ignyte, ZenGRC, Galvanize, MetricStream, Archer, etc.)
- Dedicated compliance team
- Automated compliance monitoring