GOV-15: Operationalizing Cybersecurity & Data Protection Practices

There is no evidence of a capability to compel data and/ or process owners to operationalize cybersecurity and data protection practices for each system, application and/ or service under their control.

C|P-CMM1 is N/A, since a structured process is required to compel data and/ or process owners to operationalize cybersecurity and data protection practices for each system, application and/ or service under their control.

C|P-CMM2 is N/A, since a well-defined process is required to compel data and/ or process owners to operationalize cybersecurity and data protection practices for each system, application and/ or service under their control.

Cybersecurity & Privacy Governance (GOV) 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:

• Statutory, regulatory and contractual compliance requirements for cybersecurity and data protection are identified and documented. Recurring testing is utilized to assess adherence to internal standards and/or external compliance requirements.
• A Governance, Risk & Compliance (GRC) function, or similar function, provides scoping guidance to determine control applicability.
• Internal policies and standards address all statutory, regulatory and contractual obligations for cybersecurity and data protection.
• Controls are standardized across the organization to ensure uniformity and consistent execution.
• Corporate governance (executive oversight) exists for the cybersecurity and data protection, which includes regular briefings to ensure executives have sufficient situational awareness to properly govern the organization.
• Procedures are established for sensitive/regulated compliance obligations that are standardized across the organization.
• Defined roles & responsibilities require data/process owners to define, implement and maintain cybersecurity and data protection controls for each system, application and/ or service of which they have accountability.
• The organization designates one or more qualified individuals to govern the cybersecurity and data protection programs (e.g., Chief Information Security Officer or Chief Privacy Officer).
• Risk management processes are defined, to include materiality considerations.

See C|P-CMM3. There are no defined C|P-CMM4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to compel data and/ or process owners to operationalize cybersecurity and data protection practices for each system, application and/ or service under their control.

See C|P-CMM4. There are no defined C|P-CMM5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to compel data and/ or process owners to operationalize cybersecurity and data protection practices for each system, application and/ or service under their control.