SAT-05.1: Sensitive / Regulated Data Storage, Handling & Processing

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.

Security Awareness & Training (SAT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with SAT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Security awareness and training-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Security awareness and training methods are often generic, without organization-specific content.

Security Awareness & Training (SAT) 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 SAT domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with SAT 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 SAT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Security Awareness & Training-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Security Awareness & Training may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ Users are educated on their responsibilities to protect TAASD assigned to them or under their supervision. ▪ IT and/or cybersecurity personnel create/govern security and awareness training to meet specific statutory, regulatory and/or contractual compliance obligations. ▪ Privileged users receive formal security and/or data privacy awareness training to ensure they understand their unique roles and responsibilities. ▪ The responsibility for training users and enforcing policies may be assigned to user's immediate supervisor(s)/manager(s), including the definition and enforcement of the user's specific role(s) and responsibilities. ▪ Security awareness and training methods are role-based (e.g., handling sensitive/regulated data).

Security Awareness & Training (SAT) 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 SAT 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 SAT domain capabilities are well-documented and kept current by process owners. ▪ A security awareness & training team, or similar function, is appropriately staffed and supported to implement and maintain SAT domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of security awareness and training management (e.g., Computer Based Learning (CBL) solutions). ▪ 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 SAT 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 ensure that every user accessing a system processing, storing or transmitting sensitive/regulated data is formally trained in data handling requirements.

Security Awareness & Training (SAT) 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.