PRM-04: Cybersecurity & Data Protection In Project Management

There is no evidence of a capability to assess cybersecurity and data protection controls in system project development to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting the requirements.

Project & Resource Management (PRM) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Program/project management is decentralized.
• IT personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Project & Resource Management (PRM) 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:

• Program/project management is 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 Project Management (PM).
• The PM function facilitates the implementation of cybersecurity and data protection-related resource planning controls across the System Development Lifecycle (SDLC) for all projects.
• The responsibility for enforcing cybersecurity and data protection control implementation is assigned to business / process owners and asset custodians.
• The PM function enables project involvement for Information Assurance Program (IAP) as part of the organization's established project management processes to ensure both cybersecurity and data protection principles are identified and implemented.

Project & Resource Management (PRM) 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:

• The Chief Information Security Officer (CISO), or similar function with technical competence to address cybersecurity concerns, analyzes the organization's business strategy to determine prioritized and authoritative guidance for program/project management practices.
• The CISO, or similar function, develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures to apply defense-in-depth techniques across the enterprise with regards to program/project management.
• The CISO, or similar function, leverages a capability maturity model to define and identify targeted capability maturity levels for each of the functions that make up the cybersecurity and data protection program.
• 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 protect the confidentiality, integrity, availability and safety of the organization's applications, systems, services and data for program/project management.
• A steering committee is formally established to provide executive oversight of the cybersecurity and data protection program, including program/project management.
• A Project Management Office (PMO), or project management function, enables the centralized-implementation of cybersecurity and data protection-related resource planning controls across the System Development Lifecycle (SDLC) for all projects.
• The PMO determines the identification and allocation of resources for cybersecurity and data protection requirements within business process planning for projects and other initiatives.
• Project Management (PM) is centrally-managed across the enterprise to implement cybersecurity and data protection controls as part of the project management lifecycle, with the responsibility for enforcing cybersecurity and data protection control implementation assigned to business / process owners and asset custodians.
• Subordinate staff and stakeholders are educated on the capability maturity expectations and those targets are used to task individual contributor work activities in an effort to achieve the targeted maturity levels.

Project & Resource Management (PRM) 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.

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 assess cybersecurity and data protection controls in system project development to determine the extent to which the controls are implemented correctly, operating as intended and producing the desired outcome with respect to meeting the requirements.