EMB-01: Embedded Technology Policy
Mechanisms exist to establish a formal, documented embedded technology 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, EMB-01 was Embedded Technology Security Program. That control is now EMB-02.
Control Question: Does the organization establish a formal, documented embedded technology 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?
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
Embedded Technology (EMB) 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 EMB domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with EMB 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 EMB domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Embedded technology-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Embedded technology 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
Embedded Technology (EMB) 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 EMB 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 EMB domain capabilities are well-documented and kept current by process owners. ▪ An embedded systems team, or similar function, is appropriately staffed and supported to implement and maintain EMB domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of embedded technology operations (e.g., Configuration Management Database (CMBD) Asset Management solution). ▪ 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 EMB 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
- EMB-01_A01 a formal, documented embedded technology policy is approved by executive management, or a formally delegated authority, and conveys executive management's intent for embedded technology.
- EMB-01_A02 the embedded technology policy provides organizational direction and states the behaviors expected of personnel and other applicable parties with respect to embedded technology.
- EMB-01_A03 the current version of the embedded technology policy is communicated to, and accessible by, the personnel and other applicable parties who are expected to comply with it.
- EMB-01_A04 the embedded technology policy is reviewed at least annually.
- EMB-01_A05 the embedded technology 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-01.13 Embedded Technology Policy
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Documented evidence of a embedded technology 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