PRM-09: Security, Compliance & Resilience Requirements Definition

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.

Project & Resource Management (PRM) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with PRM domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Project management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ IT and/or cybersecurity 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) 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 PRM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with PRM 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 PRM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Project & Resource Management -related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Project & Resource Management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ The Chief Information Officer (CIO), or similar function, analyzes the organization's business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements. ▪ A Project Management Office (PMO), or project management function, enables the implementation of cybersecurity and data protection-related resource planning controls across the System Development Lifecycle (SDLC) for all high-value projects. ▪ 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) 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 PRM 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 PRM domain capabilities are well-documented and kept current by process owners. ▪ A Project Management Office (PMO), or similar function, is appropriately staffed and supported to implement and maintain PRM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of project and resource management operations (e.g., project 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 PRM 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). ▪ The Chief Information Officer (CIO), or similar function, analyzes the organization's business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements. ▪ An implemented and operational capability exists to identify critical system components and functions by performing a criticality analysis for critical Technology Assets, Applications and/or Services (TAAS) at pre-defined decision points in the Secure Development Life Cycle (SDLC).

Project & Resource Management (PRM) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational. ▪ 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. ▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

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.