Skip to main content

TPM-24.2: Technology Assets, Applications, Services and Data (TAASD) Portability

TPM 7 — High Recover

Mechanisms exist to ensure applicable Technology Assets, Applications, Services and Data (TAASD) can be securely and reliably transferred, migrated or otherwise made available to a replacement third-party or internally-managed service prior to the cessation of third-party services.

Control Question: Does the organization ensure applicable Technology Assets, Applications, Services and Data (TAASD) can be securely and reliably transferred, migrated or otherwise made available to a replacement third-party or internally-managed service prior to the cessation of third-party services?

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

Third-Party Management (TPM) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with TPM domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Third-party management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.

Level 2 — Planned & Tracked

Third-Party Management (TPM) 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 TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM 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 TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset 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

Third-Party Management (TPM) 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 TPM 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 TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor 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 TPM 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

  1. TPM-24.2_A01 the Technology Assets, Applications, Services and Data (TAASD) held, managed or processed by each applicable third-party that must be transferred, migrated or made available upon cessation of services are identified.
  2. TPM-24.2_A02 contractual and/or technical provisions exist that require applicable Technology Assets, Applications, Services and Data (TAASD) to be made available in a documented, usable format that can be consumed by a replacement third-party or internally-managed service.
  3. TPM-24.2_A03 the transfer or migration of Technology Assets, Applications, Services and Data (TAASD) from a third-party uses protected channels and/or encryption consistent with the classification of the data.
  4. TPM-24.2_A04 the completeness and integrity of transferred or migrated Technology Assets, Applications, Services and Data (TAASD) are verified before the third-party services cease.
  5. TPM-24.2_A05 the ability to transfer or migrate applicable Technology Assets, Applications, Services and Data (TAASD) is tested or otherwise validated before it is relied upon during a cessation of third-party services.

Evidence Requirements

E-TPM-08 Third-Party Exit / Transition Plan

Documented evidence of exit strategies and transition plans for third-party relationships, including TAASD portability, disposition, knowledge transfer and exit contingencies.

Third-Party Management

Technology Recommendations

Micro/Small

  • Confirm critical cloud services support data export in standard formats
  • Periodic manual export of critical data

Small

  • Data export capability confirmed in vendor due diligence
  • Annual test export for critical services

Medium

  • Portability requirements in procurement and contract standards
  • Periodic portability testing
  • Secure transfer procedures

Large

  • Portability and interoperability requirements in the C-SCRM program
  • Data migration tooling and validated export procedures
  • Portability tested for critical services

Enterprise

  • Enterprise data portability standards aligned with regulatory expectations (e.g., DORA, GDPR Art. 20 where applicable)
  • Validated migration playbooks for critical services
  • Integrity-verified secure transfer processes

The Secure Controls Framework (SCF) is maintained by SCF Council. Use of SCF content is subject to the SCF Terms & Conditions.

Manage this control in SCF Connect

Track implementation status, collect evidence, and map controls to your compliance frameworks automatically.

Get Started Free