Independent thinking. Informed defence.

CISO Times

Intelligence for the people behind the defence.

The CISO Decision Brief

Maturity Findings & Improvement Tracker

Tracks improvement actions from assessment findings through to re-assessment.

Available soon

Format
Excel
Size
109 KB
Length
12 sheets
Version
1.3
Updated

What's inside

What changed

  1. 1.3

    DM-14 names P23.

  2. 1.2

    DM-14 Recovery and continuity names P22.

  3. 1.1

    MP-24 names the monthly restore check of the ordering platform (P10 EA-04).

Earlier versions (1)
  1. 1.0

    Published.

Changes across this pack

Preview

The workbook's sheets as you will receive them, with its example rows and the values its formulas calculate. Highlighted [[text]] is for you to replace; rows marked EXAMPLE are for you to delete. Wide sheets scroll sideways. The cover, document control and changelog sheets are in the file.

Instructions

How to use this workbook

StepWhat to do
1What this tracker is. The record of what an assessment found and what is being done about it, kept by the Head of Information Security (Internal Security Assessment Procedure, phase PH-7). It starts when the lead decides the results (PH-5) and runs until the next full assessment, at most [[12]] months later (MA-17).
2On the Measures sheet, set the As-at date: the date every overdue flag and measure is worked out at. For the quarterly progress report, use the quarter's last day. Enter the last day of fieldwork of the last full assessment, and confirm the settings.
3On the Domain Results sheet, enter the target the sponsor approved for each domain before scoring, with its reason (MA-09). Never change a target to fit the results.
4On the Findings sheet, copy each practice's decided result from the Assessment Evidence Request Checklist or the Security Programme Maturity Assessment: owner, who rated it, the level the evidence supports, the confidence and whether it is self-assessed. The workbook applies the caps of MA-13 and MA-14. Write what was found, and name any risk outside appetite or recorded unmet obligation that rests on the practice.
5Read the Findings sheet. Every practice below its domain's target is a finding and needs an action (MA-11). The Action order column gives the order MA-11 sets; the first [[5]] take priority. 'What the next level needs' says what the action must produce.
6On the Actions sheet, add one row per finding: the practice and its level now. The target level calculates as one level up, never two (MA-12). Write the action, the owner, the due date, the effort and the evidence that will show it is done. Where the action cannot start until another step closes, name that step in 'Waits for'.
7Add the later steps a domain's target needs, such as Defined to Managed, as their own rows naming the step they follow. Managed can be claimed only after [[6]] months at Defined; the Sequence check flags a due date earlier than that.
8Take the Actions sheet, with the Target-State Maturity Roadmap, to the approver for approval (PH-8). Then set every approved action to Open.
9Owners move their actions to In progress, then to Ready for re-assessment with the evidence. Name a re-assessor who is not the owner. Where no one else can judge it, use the options in the Internal Security Assessment Procedure (MA-14).
10The re-assessor checks the practice against the level aimed for, as the assessment did: evidence in the window, a sample they choose. Enter who, when and the level found, and set Closed or Not achieved. The Closure check flags any action closed without a re-assessment, or by its owner (MA-18).
11Every quarter, report the Measures sheet to the sponsor: the four headline measures, the actions overdue and the domains at target. Levels on the Findings and Domain Results sheets follow the latest re-assessments.
12To start your own tracker, delete the contents of the first column and of every yellow cell on the Findings and Actions sheets, and the targets on the Domain Results sheet. The practices and formulas stay. Rows at the foot of the Findings sheet take practices you add.

Legend

Yellow cells are inputs. Everything else is calculated or fixed — do not overwrite formulas.

EXAMPLERows marked EXAMPLE in the first column show how a completed row looks. Delete them before approval.

Limitations: This document helps you judge how well your security practices work. It is not legal advice, and a maturity result is not a statement that you comply with NIS2, DORA, the GDPR or any standard. Where a law or a certification asks for an assessment or an audit, confirm with counsel or your certification body what it must include.

A maturity result is not an internal audit, a certification or a statement of compliance, and is never presented as one. It can feed the management review, the internal audit programme and the risk register. An action closed here means the practice reached a level on re-assessment. It is not an audit finding closed, and not evidence of compliance.

MA-14 and MA-18 apply P08's IS-07: "Internal auditors must not audit their own work." Closing your own action is the same as auditing your own work.

EXAMPLE: a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders, an important entity under NIS2 in its Member State. Its first assessment, ASM-2026-1, led by its Internal Audit Manager, had fieldwork from 7 Sep 2026 to 18 Sep 2026. 2 of 14 domains are at target. The tracker, as at 30 Sep 2026, holds 18 actions, one for each practice below target, and the roadmap's two second steps. Nothing is due yet, and every action is Open.

Domains with no published pack: DM-11 Protection of systems and data and DM-12 Detection and monitoring. Their actions rest on what the practice's next level needs, on the Findings sheet.

Tailoring — small organisation: one person may own most actions. Re-assessment still needs someone else: a colleague from another function, or a reciprocal assessor.

Tailoring — findings from other sources: an internal audit, a supplier review or a regulator may find the same weakness. Keep their findings in their own trackers, and note the link here; one action may answer both.

Tailoring — financial entity under DORA: where the internal audit of the ICT risk management framework finds a weakness in a practice, follow up that finding by the audit's own rules. This tracker can show the practice's level; it does not replace the audit's follow-up.

This workbook is your own record. Keep it with the assessment report and the roadmap.

Findings

One row per practice, from the decided results. A practice below its domain's target is a finding and needs an action (MA-11). Yellow columns are yours; the others calculate.

RowPractice IDDomainPracticePractice ownerRated byLevel the evidence supportsConfidenceSelf-assessedLevel decided (calc)Check (calc)Domain target (calc)Below target? (calc)What was foundRisk outside appetite or unmet obligation that rests on itWhat the next level needs (calc)Order key (working)Action order (MA-11, calc)Priority (calc)Level now, after re-assessments (calc)
EXAMPLEMP-01Governance and accountabilityAccountable personChief Operating OfficerInternal Audit ManagerDefinedSeenNoDefinedOKDefinedNoThe Head of Information Security's role description, approved by the Executive Committee, sets out the role's reporting line and authority. Objectives are not yet reviewed against results each year.Defined
EXAMPLEMP-02Governance and accountabilityManagement reportingHead of Information SecurityInternal Audit ManagerDefinedTestedNoDefinedOKDefinedNoThe last four quarterly board reports and their minutes each record decisions, such as the approval of the security measures on 30 Jul 2026 (P12). The decisions are not yet tracked back to the board as a list.Defined
EXAMPLEMP-03Governance and accountabilitySecurity objectivesHead of Information SecurityInternal Audit ManagerDefinedSeenNoDefinedOKDefinedNoThe 2026 security plan has nine milestones with owners and dates, reported to the board each quarter (P03: 7 of 9 on track).Defined
EXAMPLEMP-04PolicyPolicy setHead of Information SecurityInternal Audit ManagerInformalSeenNoInformalOKDefinedYesRecent policies were approved at the right level, such as classification on 14 Jul 2026 (P15). There is no cryptography policy, and no register shows when each policy is due for review.The board recorded NIS2 measure (h), cryptography, as outstanding until its policy is approved (P12, 30 Jul 2026)A policy set, each policy approved at the level its tier requires, with an owner and a review date, published where staff can read it.2202041YesInformal
EXAMPLEMP-05PolicyPolicy acknowledgementHR DirectorInternal Audit ManagerDefinedToldNoInformalCapped by confidence (MA-13)DefinedYesHR said every joiner acknowledges the policies at induction, but could not show the records during fieldwork, so the result is capped at Informal (MA-13).Records of acknowledgement for the policies staff must follow, taken on joining and after each material change.12202057NoInformal
EXAMPLEMP-06Risk management and exceptionsRisk registerHead of Information SecurityInternal Audit ManagerDefinedTestedNoDefinedOKDefinedNoTwelve risks, each with an owner and a rating by the written method. R-04 was re-rated on 20 Aug 2026 after the August ransomware incident (P05).Defined
EXAMPLEMP-07Risk management and exceptionsRisk appetiteHead of Information SecurityInternal Audit ManagerDefinedSeenNoDefinedOKDefinedNoThe board approved the appetite on 30 Jul 2026. Both risks outside it, R-01 and R-02, carry a decision to treat them; R-01's funding goes to the board on 29 Oct 2026 (P05 TA-01).Defined
EXAMPLEMP-08Risk management and exceptionsExceptionsHead of Information SecurityInternal Audit ManagerInformalTestedNoInformalOKDefinedYesFour exceptions are open, and one of them expired and is still in use without a renewal decision (P03).An exception register in which every exception has a risk owner, an approver at the level its rating requires, compensating controls and an expiry date.12203088NoInformal
EXAMPLEMP-09Third-party securitySupplier tiering and contractsProcurementInternal Audit ManagerDefinedSeenNoDefinedOKDefinedNoEvery supplier with access to data or systems is tiered (14 in Tier 1, 22 in Tier 2, 31 in Tier 3, 45 in Tier 4), and the three Tier 1 contracts sampled carry the incident notification clause (P06 CL-07).Defined
EXAMPLEMP-10Third-party securitySupplier assessmentInformation Security ManagerInternal Audit ManagerInformalSeenNoInformalOKDefinedYes9 of 14 Tier 1 suppliers were assessed by the end of fieldwork; the other 5 are planned from 20 Oct to 8 Dec 2026 (P06). One High finding is past its deadline.R-02, payment fraud through a compromised supplier email account, is outside appetite (P05)An assessment on record before contract for every supplier in the highest tiers, and a periodic review at the interval the tier sets.2204102YesInformal
EXAMPLEMP-11Legal and regulatory obligationsObligations known and ownedHead of Information SecurityInternal Audit ManagerDefinedSeenNoDefinedOKDefinedNoThe NIS2 scope assessment, approved by the board on 21 May 2026, records the company as an important entity (P12). The applicability profile approved on 15 Sep 2026 records its GDPR role and that DORA does not apply (P18).Defined
EXAMPLEMP-12Legal and regulatory obligationsCompliance checkedHead of Information SecurityInternal Audit ManagerInformalSeenNoInformalOKDefinedYesThe board approved the NIS2 measures on 30 Jul 2026, but no check of whether they are in place had been made by the end of fieldwork. The first readiness self-assessment is set for 30 Sep 2026 (P12).A check against each obligation at least each year, with gaps recorded and assigned.12205129NoInformal
EXAMPLEMP-13Measurement and assessmentSecurity metricsHead of Information SecurityInternal Audit ManagerDefinedTestedNoDefinedOKDefinedNoEvery reported metric has an approved definition card and a validator who is not its supplier, and data quality checks ran in the July and August cycles (P11).Defined
EXAMPLEMP-14Measurement and assessmentAssessment and follow-upHead of Information SecurityInternal Audit ManagerNot in placeSeenNoNot in placeOKDefinedYesNo assessment or audit of the security programme had been made before this one (P12).Someone can describe how it is done and show at least one instance, but there is no agreed written way of doing it, or the records are not kept consistently.11106145YesNot in place
EXAMPLEMP-15Assets and informationAsset inventoryHead of ITInformation Security ManagerInformalSeenNoInformalOKDefinedYesDevices and cloud services are listed in IT's tools, in separate lists, with no owner for each and no set process to keep them current.An inventory of devices, software and cloud services, each with an owner, kept current by a set process.122071510NoInformal
EXAMPLEMP-16Assets and informationInformation classificationHead of Information SecurityInternal Audit ManagerDefinedTestedNoDefinedOKDefinedNoThe classification policy was approved on 14 Jul 2026, the information register built on 28 Aug, and the first handling check made on 17 Sep 2026 (P15).Defined
EXAMPLEMP-17Vulnerabilities and patchingFinding and prioritising vulnerabilitiesHead of ITInformation Security ManagerDefinedSeenNoDefinedOKDefinedNoScans cover the in-scope systems, and findings are prioritised by the written method. The board receives the share of the most urgent fixes made on time (P03).Defined
EXAMPLEMP-18Vulnerabilities and patchingFixing on timeHead of ITInformation Security ManagerInformalTestedNoInformalOKDefinedYesThe most urgent fixes made on time fell to 81% against a target of 95% (P03). Two of the five findings sampled missed their June deadline with no approved deferral; deferrals have been approved as exceptions only since the patch standard was approved on 3 Sep 2026 (P17).Written remediation deadlines by priority, records showing fixes against them, and a deferral approved as an exception whenever a deadline is missed.122081811NoInformal
EXAMPLEMP-19Identity and accessJoiners, movers and leaversHead of ITInformation Security ManagerDefinedTestedNoDefinedOKDefinedNoFive leavers sampled from HR records: four had their access removed in time. The fifth was found by the monthly reconciliation and removed, so the practice caught its own failure (MA-05) (P13).Defined
EXAMPLEMP-20Identity and accessAccess reviewsHead of Information SecurityInternal Audit ManagerInformalSeenNoInformalOKDefinedYesThe first review campaign under the procedure started on 1 Sep 2026 and had not closed by the end of fieldwork (P07). Earlier reviews were made by system owners in their own way, with no record of removals. Disagreement recorded: The Head of Information Security held that the earlier reviews count. The lead kept Informal: they left no record of what was removed (MA-02).Access reviews of the in-scope systems at the interval the procedure sets, with removals made and recorded.122092012NoInformal
EXAMPLEMP-21Identity and accessPrivileged accessHead of ITInformation Security ManagerInformalSeenNoInformalOKDefinedYesThe privileged account inventory was built on 16 Sep and the standard approved on 18 Sep 2026, but separate administrator accounts went live only on 21 Sep, after fieldwork (P14).A list of privileged accounts with an owner and approval for each, separate accounts for privileged work, and strong authentication on them.122092113NoInformal
EXAMPLEMP-22Awareness and trainingTrainingInformation Security ManagerInternal Audit ManagerDefinedTestedNoDefinedOKDefinedNoA training plan by audience for July 2026 to June 2027, approved on 26 Jun 2026 (P16). Completion records for the ten people sampled were complete.Defined
EXAMPLEMP-23Awareness and trainingBehaviour measuredInformation Security ManagerInternal Audit ManagerDefinedSeenNoDefinedOKDefinedNoThe reporting rate of simulated phishing is measured each month from July 2026 (P16). It has no target yet.Defined
EXAMPLEMP-24Protection of systems and dataBackups restoredHead of ITInformation Security ManagerInformalSeenNoInformalOKDefinedYesCritical data is backed up daily, and an offline copy is kept. Since May 2026 IT has restored and checked one backup of the ordering platform each month (P10 EA-04), and the August incident restores worked (P09). No restore test is set for the rest of the critical data, so restoring it is not yet routine.R-01, ransomware takes online ordering offline, is outside appetite (P05)A backup schedule for critical data, a copy protected from the systems it backs up, and records of restore tests at the interval set.2211243YesInformal
EXAMPLEMP-25Protection of systems and dataSecure configurationHead of ITInformation Security ManagerInformalSeenNoInformalOKDefinedYesServers are built to a checklist. Office PCs had local administrator rights until the August incident, and their removal is due by 31 Oct 2026 (P09 PIA-01).Written configuration baselines for the main system types, and records showing new systems are built to them.122112514NoInformal
EXAMPLEMP-26Detection and monitoringLoggingInformation Security ManagerInformation Security ManagerInformalSeenYesInformalOKDefinedYesLogs from the ordering platform and the firewalls reach the managed provider's store; the warehouse systems' logs stay on the systems. There is no list of the sources required. Self-assessed: no one independent could judge the technical evidence in the time.A list of the systems whose logs are collected, central collection protected from change, and retention as the organisation has decided.122122615NoInformal
EXAMPLEMP-27Detection and monitoringAlert handlingInformation Security ManagerInformation Security ManagerInformalSeenYesInformalOKDefinedYesAlerts go to the managed provider and the Information Security Manager, with no written criteria or response times. Self-assessed, for the same reason as MP-26.Written criteria for the alerts that must be reviewed, a response time, and records of triage.122122716NoInformal
EXAMPLEMP-28Incident response and notificationIncident procedureInformation Security ManagerInternal Audit ManagerDefinedTestedNoDefinedOKManagedYesThe Q3 incidents followed the procedure's severity levels and roles, and the August ransomware incident had a post-incident review on 27 Aug 2026 (P09).All of Defined, and: Response measures are reported, and post-incident reviews lead to changes that are tracked to closure.131132817NoDefined
EXAMPLEMP-29Incident response and notificationNotification readinessHead of Information SecurityInternal Audit ManagerInformalSeenNoInformalOKManagedYesThe notification procedure was adopted on 15 Sep 2026; its first readiness check, on 18 Sep 2026, was Not ready (P18). The re-check on 25 Sep 2026 falls after fieldwork.A record of which regimes apply, a written way of deciding whether to report, named people with tested access to each authority's channel, and records of decisions made.12113296NoInformal
EXAMPLEMP-30Incident response and notificationExercisesInformation Security ManagerInternal Audit ManagerDefinedSeenNoDefinedOKManagedYesThe tabletop of 18 Mar 2026 has an after-action report, approved on 31 Mar 2026, with an owner for each lesson (P10). Raised from Informal at validation, when the owner added the after-action report on 23 Sep 2026.All of Defined, and: Lessons are tracked to closure and reported, and the programme varies scenarios and participants from year to year.131133018NoDefined
EXAMPLEMP-31Recovery and continuityRecovery plansHead of ITInformation Security ManagerDefinedSeenNoDefinedOKDefinedNoThe 5 critical services have recovery objectives agreed by their business owners, and a recovery plan each.Defined
EXAMPLEMP-32Recovery and continuityRecovery testedHead of ITInformation Security ManagerInformalTestedNoInformalOKDefinedYes2 of the 5 critical services were restored within their objectives in a test in the last 12 months (P03). The ordering platform cannot yet be restored within 24 hours; P05's TA-01 would rebuild its recovery.R-01, ransomware takes online ordering offline, is outside appetite (P05)Recovery tests at the interval set, with the time achieved recorded against the objective.2214324YesInformal

Actions

One row per action, each moving one practice one level (MA-12). An action closes only when someone other than its owner re-assesses the practice at the level aimed for (MA-18). Due status is worked out at the As-at date on the Measures sheet.

RowAction IDPractice IDPractice (calc)Domain (calc)Level fromLevel to (calc, one up)Step (calc)Order (MA-11, calc)Priority (calc)ActionAction ownerDueEffort (S, M, L)External spend (EUR)Waits for (in this tracker)Waits for (outside this tracker)Evidence that will show it is doneStatusRe-assessed by (not the owner)Re-assessed onLevel foundClosure check (MA-18, calc)Due status (calc)Days overdue (calc)Earliest Managed claim (MA-12, calc)Sequence check (calc)Re-assessment key (working)Notes
EXAMPLEMF-01MP-04Policy setPolicyInformalDefinedFirst step1YesApprove a cryptography policy, and keep a policy register with an approval and review date for every policyHead of Information Security18 Dec 2026M0The register, and the cryptography policy with its approvalOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-02MP-10Supplier assessmentThird-party securityInformalDefinedFirst step2YesAssess the five remaining Tier 1 suppliers on P06's plan, and agree a date for the overdue High findingInformation Security Manager8 Dec 2026M0Five assessments on record, and the finding's agreed dateOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-03MP-24Backups restoredProtection of systems and dataInformalDefinedFirst step3YesProtect the backup copy from the systems it backs up, and restore critical data in a test each quarterHead of IT29 Jan 2027M9,000The restore test records of two quartersOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-04MP-32Recovery testedRecovery and continuityInformalDefinedFirst step4YesTest the recovery of every critical service against its objective once the ordering platform's recovery is rebuiltHead of IT26 Mar 2027L0MF-03P05 TA-01A recovery test record for each critical service, with the time achievedOpenNot ready for re-assessmentNot dueStarts after MF-030
EXAMPLEMF-05MP-14Assessment and follow-upMeasurement and assessmentNot in placeInformalFirst step5YesSet the 2027 assessment in the plan, and report progress on this assessment's actions to the Executive Committee each quarterHead of Information Security18 Dec 2026S0The 2027 assessment in the plan, and the first quarterly progress reportOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-06MP-29Notification readinessIncident response and notificationInformalDefinedFirst step6NoClose P18's open readiness actions and rehearse a report in the October tabletopHead of Information Security31 Oct 2026S0A readiness check at Ready, and the tabletop's record of the rehearsed reportOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-07MP-05Policy acknowledgementPolicyInformalDefinedFirst step7NoKeep policy acknowledgements in the HR system for every joiner and after each material changeHR Director18 Dec 2026S0MF-01Acknowledgement records for ten people chosen by the assessorOpenNot ready for re-assessmentNot dueStarts after MF-010
EXAMPLEMF-08MP-08ExceptionsRisk management and exceptionsInformalDefinedFirst step8NoDecide the expired exception, and check the exception register for expiries each monthHead of Information Security30 Oct 2026S0The decision, and three monthly checksOpenNot ready for re-assessmentDue soonOK0
EXAMPLEMF-09MP-12Compliance checkedLegal and regulatory obligationsInformalDefinedFirst step9NoRepeat the NIS2 readiness self-assessment each half year, with gaps assignedHead of Information Security31 Mar 2027S0Two readiness self-assessments with their gapsOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-10MP-15Asset inventoryAssets and informationInformalDefinedFirst step10NoBuild one inventory of devices, software and services with an owner for each, and keep it current from purchasing and discoveryHead of IT30 Jun 2027L12,000The inventory, and the process that keeps it currentOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-11MP-18Fixing on timeVulnerabilities and patchingInformalDefinedFirst step11NoBring the most urgent fixes back to deadline, with every miss deferred as an exceptionHead of IT29 Jan 2027M0Five sampled findings fixed on time or deferred with approvalOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-12MP-20Access reviewsIdentity and accessInformalDefinedFirst step12NoComplete two review campaigns under the procedure, with removals recordedHead of Information Security31 Mar 2027M0Two campaign records with their removalsOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-13MP-21Privileged accessIdentity and accessInformalDefinedFirst step13NoMove every administrator to separate accounts with strong authentication, as P14's Tier 1 plan setsHead of IT18 Dec 2026M0The account list, and three approval recordsOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-14MP-25Secure configurationProtection of systems and dataInformalDefinedFirst step14NoWrite configuration baselines for servers and office PCs, and build new systems to themHead of IT30 Jun 2027M0The baselines, and three build recordsOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-15MP-26LoggingDetection and monitoringInformalDefinedFirst step15NoList the log sources required and collect them all centrally, protected from changeInformation Security Manager10 Sep 2027L38,000The source list, and three sources reaching the storeOpenNot ready for re-assessmentNot dueOK0
EXAMPLEMF-16MP-27Alert handlingDetection and monitoringInformalDefinedFirst step16NoWrite alert criteria and response times with the managed provider, and record triageInformation Security Manager10 Sep 2027M0MF-15The criteria, and five triage recordsOpenNot ready for re-assessmentNot dueStarts after MF-150
EXAMPLEMF-17MP-28Incident procedureIncident response and notificationDefinedManagedFirst step17NoReport incident response measures each month, and have post-incident actions checked by internal auditInformation Security Manager30 Jun 2027M0Six months of measures, and internal audit's checksOpenNot ready for re-assessmentNot due18 Mar 2027OK0
EXAMPLEMF-18MP-30ExercisesIncident response and notificationDefinedManagedFirst step18NoTrack exercise lessons to closure and report them, and vary scenarios and participants each yearInformation Security Manager30 Jun 2027S0The lessons log closed and reported, and the 2027 programmeOpenNot ready for re-assessmentNot due18 Mar 2027OK0
EXAMPLERS-01MP-14Assessment and follow-upMeasurement and assessmentInformalDefinedLater stepNoThe 2027 assessment follows up this one's findings.Head of Information Security17 Sep 2027S0MF-05A planned assessment or internal audit at least each year, its findings in a tracker with owners and dates, and closure checked by someone other than the action owner.OpenNot ready for re-assessmentNot dueStarts after MF-050Second step in the Target-State Maturity Roadmap.
EXAMPLERS-02MP-29Notification readinessIncident response and notificationDefinedManagedLater stepNoSix months of decisions and reports on time, measured, with readiness re-checked.Head of Information Security30 Jun 2027S0MF-06All of Defined, and: Decisions and reports on time are measured, and readiness is re-checked at a set interval.OpenNot ready for re-assessmentNot due30 Apr 2027Starts after MF-060Second step in the Target-State Maturity Roadmap.

Domain Results

Domain results

Each domain's level is the lowest level among its practices that apply (MA-06), and its gap the target minus that level, counted in levels (MA-10). 'At the assessment' uses the decided results; 'now' uses the latest re-assessments on the Actions sheet. No overall score, percentage or weighting (MA-07).

EXAMPLE: the results of ASM-2026-1 and the targets approved on 21 Aug 2026, before scoring.

Domain IDDomainPracticesLevel at the assessment (lowest)TargetGap at the assessmentLevel now (lowest)Gap nowActionsClosedOverdueReason for the target
DM-01Governance and accountability3DefinedDefined0Defined0000Default. NIS2 makes the management body answerable for the security measures (P12).
DM-02Policy2InformalDefined1Informal1200Default. The board recorded the cryptography policy as outstanding on 30 Jul 2026 (P12, measure (h)).
DM-03Risk management and exceptions3InformalDefined1Informal1100Default.
DM-04Third-party security2InformalDefined1Informal1100Default. Supplier payment fraud, R-02, is outside appetite (P05).
DM-05Legal and regulatory obligations2InformalDefined1Informal1100Default.
DM-06Measurement and assessment2Not in placeDefined2Not in place2200Default. NIS2 asks for policies and procedures to assess whether the security measures are effective.
DM-07Assets and information2InformalDefined1Informal1100Default.
DM-08Vulnerabilities and patching2InformalDefined1Informal1100Default.
DM-09Identity and access3InformalDefined1Informal1200Default.
DM-10Awareness and training2DefinedDefined0Defined0000Default.
DM-11Protection of systems and data2InformalDefined1Informal1200Default. Ransomware taking ordering offline, R-01, is outside appetite (P05).
DM-12Detection and monitoring2InformalDefined1Informal1200Default.
DM-13Incident response and notification3InformalManaged2Informal2400Incidents test the programme most often, NIS2's reporting deadlines rest on the response, and R-01 is outside appetite. Response must be measured and checked by someone other than the team that runs it.
DM-14Recovery and continuity2InformalDefined1Informal1100Default. R-01 is outside appetite (P05).

A gap of 0 means the domain is at or above its target. "Not all judged": a practice has no level yet. "Left out (MA-08)": every practice is Not applicable; say why in the report. Changing a target after scoring breaks MA-09.

The packs that show how to raise each domain

Domain IDDomainPacks
DM-01Governance and accountabilityP03 Board Cybersecurity Reporting
DM-02PolicyP04 Security Policy Management
DM-03Risk management and exceptionsP05 Information Security Risk Management; P02 Security Exception, Waiver & Segregation of Duties
DM-04Third-party securityP06 Third-Party Security Risk Management
DM-05Legal and regulatory obligationsP12 NIS2 Implementation & Readiness; P08 ISO 27001 Implementation & Certification Readiness
DM-06Measurement and assessmentP11 Cybersecurity Metrics & Reporting Programme; P19 Security Maturity & Internal Assessment (this pack)
DM-07Assets and informationP15 Information Classification & Handling
DM-08Vulnerabilities and patchingP01 Vulnerability & Exposure Management; P17 Patch Management
DM-09Identity and accessP13 Joiner-Mover-Leaver & Access Provisioning; P07 User Access Review; P14 Privileged Access Management
DM-10Awareness and trainingP16 Security Awareness Programme
DM-11Protection of systems and dataNo published pack covers this domain yet. Its actions rest on the practice's own evidence.
DM-12Detection and monitoringNo published pack covers this domain yet. Its actions rest on the practice's own evidence.
DM-13Incident response and notificationP09 Security Incident Management; P18 Regulatory Incident Notification & Reporting; P10 Cyber Incident Exercises & Tabletop Scenario Library
DM-14Recovery and continuityP22 Cyber Resilience & Recovery; P23 Backup & Restore Assurance

Measures

Measures and settings

Every figure is worked out from the Findings, Actions and Domain Results sheets at the As-at date. Report them to the sponsor each quarter. Counts are written "n of m"; nothing is added across domains into a score (MA-07).

Settings

As-at date30 Sep 2026Every overdue flag and measure is worked out at this date. For the quarterly report, the quarter's last day.
Period start (calc)1 Jul 2026The first day of the calendar quarter of the As-at date.
Last day of fieldwork, last full assessment18 Sep 2026MAM-04 counts from this date; the next full assessment is due within the cycle (MA-17).
Actions that take priority in one cycle5MA-11. The first actions in MA-11's order take priority.
Months at Defined before Managed can be claimed6MA-12. Sets the earliest Managed claim on the Actions sheet.
Months between full assessments (at most)12MA-17.
Due soon (days before the due date)30An open action due within this many days of the As-at date shows Due soon.
Next full assessment's fieldwork ends by (calc)17 Sep 2027MA-17: the last day of the cycle. Re-assess a domain sooner after a significant incident or major change.

Headline measures

MeasureResultTargetStatusWhat it means
MAM-01 Domains at target2 of 14Rising each cycle—Domains at or above their target level, out of the domains assessed. Uses each domain's level now, after re-assessments.
MAM-02 Priority actions on timeNone due yetAll—Priority actions closed by their due date, re-assessed, out of those due in the period. The period is the quarter of the As-at date. On time means closed on re-assessment by the due date (MA-18).
MAM-03 Self-assessed results2 of 32None; never more than a thirdWithin a thirdPractice results marked self-assessed, out of all results. Above a third, the sponsor decides whether to commission an independent assessment and records the decision (Internal Security Assessment Procedure, IT-3).
MAM-04 Months since the last full assessment0[[12]] or fewerOn targetMonths from the end of the last full assessment's fieldwork to the period end. Whole months.

EXAMPLE, as at 30 Sep 2026: MAM-01 2 of 14; MAM-02 None due yet; MAM-03 2 of 32; MAM-04 0.

Actions

CountResultWhat it counts
Actions in the tracker20Every row with an action ID: first steps and later steps.
Practices below target (findings)18Each needs one first-step action (MA-11).
Findings with no first-step action0Should be 0. Add an action for each.
Priority actions5 of 20MA-11: the first [[5]] in order.
Open20 of 20The action is agreed, with an owner, a due date and the evidence that will show it is done. Work has not started.
In progress0 of 20Work has started. The practice is not yet at the level the action aims for.
Ready for re-assessment0 of 20The owner says the work is done and the evidence is ready. The action is not closed: the level has not been checked yet.
Closed0 of 20A re-assessment by someone other than the action owner found the practice at the level the action aimed for, or higher (MA-18).
Not achieved0 of 20A re-assessment found the practice below the level the action aimed for. Agree what is missing and a new due date, or record the approver's decision to stop.
Overdue0 of 20Due before the As-at date and not closed.
Due soon1 of 20Due within the days set above.
Closed without a valid re-assessment (MA-18)0Should be 0. Re-open the action and arrange a re-assessment by someone other than its owner.
Waiting for another step5Actions that cannot start until the step they name is closed.
Sequence problems (MA-12)0Should be 0. A later step must fall after the step it follows, and Managed after its months at Defined.

Actions due each quarter

QuarterFromToDuePriority dueClosedOverdue now
Q3 2026 (this quarter)1 Jul 202630 Sep 20260000
Q4 20261 Oct 202631 Dec 20267300
Q1 20271 Jan 202731 Mar 20275200
Q2 20271 Apr 202730 Jun 20275000
Q3 20271 Jul 202730 Sep 20273000
Later1 Oct 20270000

Counts of actions by due date, for the quarterly progress report. Actions due earlier than this quarter are in the Overdue count above until they close.

Quarterly progress record

ItemEntry
Reported to the sponsor by (name, role) and date[[Name, role, YYYY-MM-DD]]
Actions overdue, and why[[e.g. none; or the action, the reason and the new date agreed]]
Re-assessments that found a lower level, and what follows[[e.g. none; or the practice, the level found and the new action]]
Decisions asked of the approver[[e.g. a new date, more effort, or stopping an action]]

How to Close

How an action moves, and when it closes

An action closes when the level has moved, checked by someone other than its owner. Finishing the work is not enough.

The states of an action

StateWhat it meansWho sets it
OpenThe action is agreed, with an owner, a due date and the evidence that will show it is done. Work has not started.Head of Information Security, when the approver approves the plan
In progressWork has started. The practice is not yet at the level the action aims for.The action owner
Ready for re-assessmentThe owner says the work is done and the evidence is ready. The action is not closed: the level has not been checked yet.The action owner, who also names the re-assessor with the assessment lead
ClosedA re-assessment by someone other than the action owner found the practice at the level the action aimed for, or higher (MA-18).The re-assessor, who is not the action owner
Not achievedA re-assessment found the practice below the level the action aimed for. Agree what is missing and a new due date, or record the approver's decision to stop.The re-assessor, who is not the action owner

The rules the tracker follows

RuleWhat it says
MA-10A domain's gap is its target level minus its current level, counted in levels. A domain at or above its target has no gap.
MA-11Every practice below its domain's target gets an action. Actions take priority first where a risk outside appetite, or an obligation the organisation has recorded as not met, rests on the practice; then the practice at the lower level; then the domain with the larger gap; then domain and practice order. Up to [[5]] actions take priority in one cycle.
MA-12A practice moves up one level per action. Managed can be claimed only after the practice has run at Defined, with records, for at least [[6]] months. A roadmap never plans a jump of two levels in one step.
MA-14No one rates a practice they own or run (P08 IS-07). Where no independent assessor is available for a practice, the result is marked self-assessed and cannot be above Defined until someone independent checks the evidence.
MA-15Results are compared over time only when the model, the scope and the evidence window are the same. Any change is a break in series, marked in the report as P11's MR-09 marks a changed metric.
MA-17A full assessment runs at least every [[12]] months. A domain is re-assessed sooner after a significant incident, a major change to the systems or the organisation, or a new obligation that rests on it.
MA-18An action closes only when a re-assessment, by someone other than the action's owner, shows that the practice reached the level the action aimed for.
MA-19A maturity result is not an internal audit, a certification or a statement of compliance, and is never presented as one. It can feed the management review, the internal audit programme and the risk register.

Mistakes to avoid

MistakeWhat goes wrongThe fix
PF-06Planning to jump from Not in place to Managed in one step.Move one level per action, and claim Managed only after [[6]] months at Defined (MA-12).
PF-07Closing an action when the work is done, not when the level moved.Close only on re-assessment by someone other than the owner (MA-18).
PF-08Comparing this year's result with last year's after the model changed.Mark the break in series and compare only like with like (MA-15).

When a re-assessment finds a lower level

StepWhat to do
1Check that the re-assessment used the same practice wording, evidence window and sampling as the assessment. If it did not, the two results cannot be compared: mark a break in series (MA-15).
2If they are comparable, the lower level is the result. Record it in 'Level found' and set the action to Not achieved. The practice's level on the Findings and Domain Results sheets follows this re-assessment.
3Ask what changed: a person left, a tool was replaced, a process was dropped under pressure, or the first result rested on thin evidence.
4Agree a new action, one level up from the level found (MA-12). If the domain's level falls, the gap grows: the action may now take priority (MA-11).
5Where the fall followed a significant incident or a major change, re-assess the rest of the domain too, without waiting for the next full assessment (MA-17).
6Report the fall in the next quarterly progress report, with the reason and the new action. Do not hide it in a total.

What the re-assessor checks

CheckWhat it means
The level aimed forThe evidence the Findings sheet's 'What the next level needs' names, in full. For Defined, the practice's written way of doing it and records that it was done routinely; for Managed, a measure with a target, an independent check and an improvement made because of them.
The windowRecords dated since the action started, and enough of them to show the practice is routine, not done once for the re-assessment (MA-04).
The sampleRecords the re-assessor chooses from the full list, [[3]] or all of them if fewer (MA-05).
The confidenceSeen at least for Defined; Tested for Managed (MA-13).
IndependenceThe re-assessor is not the action owner and does not run the practice (MA-14, MA-18). Where that cannot be arranged, the result is self-assessed and capped at Defined, and the action stays at Ready for re-assessment until someone independent checks it.

Lists

LevelAnswerConfidenceConfidenceCapYesNoStateEffortEffortDaysDomainPracticeIDLevelNeedsPracticeDefinedPracticeManaged
Not in placeNot in placeTold2YesOpenSSmall: [[up to 5]] person-daysGovernance and accountabilityMP-01Nothing. This is the level when there is no evidence that the practice happens, or it happens only by chance.A role description or appointment, approved by management, that names the person accountable for security, their reporting line and their authority.Their objectives are reviewed each year against results by the person they report to, and the role was changed at least once because of a review.
InformalInformalSeen3NoIn progressMMedium: [[6 to 20]] person-daysPolicyMP-02Someone can describe how it is done and show at least one instance, but there is no agreed written way of doing it, or the records are not kept consistently.A security report to the board or its equivalent at least every quarter, and minutes that record the decisions taken on it.The report's measures have targets, and the decisions and actions it leads to are tracked to closure and reported back.
DefinedDefinedTested4Ready for re-assessmentLLarge: [[21 to 60]] person-daysRisk management and exceptionsMP-03The practice's Defined evidence, seen by the assessor: a written, agreed way of doing it, and records in the evidence window showing it was done routinely. Where the assessor checks a sample, every sampled record must pass (MA-05).Written security objectives for the year, approved by management, each with an owner, a date and how it will be measured.Progress is reported at least each quarter, and an objective that will be missed leads to a recorded decision.
ManagedManagedClosedThird-party securityMP-04All of Defined, and the practice's Managed evidence: a measure with a target that is reported, a check by someone other than the person who does the work, and a record of at least one improvement made because of them.A policy set, each policy approved at the level its tier requires, with an owner and a review date, published where staff can read it.Reviews are measured as on time or late and reported, and policy breaches and exceptions are used to revise the policies.
Not applicableNot achievedLegal and regulatory obligationsMP-05Records of acknowledgement for the policies staff must follow, taken on joining and after each material change.The acknowledgement rate is measured and reported, and those who have not acknowledged are followed up to a deadline.
Measurement and assessmentMP-06A written risk method, a register in which every risk has an owner and a rating made by that method, and a review of the register at the interval the method sets.Treatment progress and risks outside appetite are measured and reported, and the method was changed at least once because of what the reviews found.
Assets and informationMP-07An appetite statement approved by the approver, and a decision recorded at the right level for every risk outside it: treat, or accept with the reason.Appetite is reviewed each year, and the number of risks outside it, and their age, is reported to management each quarter.
Vulnerabilities and patchingMP-08An exception register in which every exception has a risk owner, an approver at the level its rating requires, compensating controls and an expiry date.Expired and renewed exceptions are counted and reported, and an exception renewed more than the rules allow goes to the next level up.
Identity and accessMP-09A supplier register in which every supplier with access to data or systems has a tier, and the contracts of the highest tier carry the security clauses the tier requires.The share of high-tier suppliers whose contracts carry the required clauses is measured, and gaps are closed at renewal to a plan.
Awareness and trainingMP-10An assessment on record before contract for every supplier in the highest tiers, and a periodic review at the interval the tier sets.Overdue reviews are counted and reported, and assessment findings are tracked to closure with the supplier.
Protection of systems and dataMP-11A register of the security obligations that apply, each with an owner and the date it was last confirmed, including whether NIS2, DORA or the GDPR apply and in which role.The register is reviewed at least each year and whenever the business changes, and a new obligation reaches the register within a set time.
Detection and monitoringMP-12A check against each obligation at least each year, with gaps recorded and assigned.Gaps are tracked to closure and reported, and the checks are made by someone other than the obligation's owner.
Incident response and notificationMP-13A written definition for every reported metric, a named owner, and data quality checks recorded before each report.Metrics are reviewed each year against the decisions they serve, and failed data checks are used to fix their sources.
Recovery and continuityMP-14A planned assessment or internal audit at least each year, its findings in a tracker with owners and dates, and closure checked by someone other than the action owner.Overdue findings are counted and reported to management, and the assessment method was improved at least once because of what an assessment showed.
MP-15An inventory of devices, software and cloud services, each with an owner, kept current by a set process.Completeness is checked against another source, such as network discovery or purchasing records, and differences are measured and fixed.
MP-16A classification scheme approved by management, handling rules for each level, and records showing information is labelled and handled by them.Handling is checked on a sample at a set interval, and the results are reported and used to change the rules or the training.
MP-17Scan coverage of the in-scope assets on record, and a written prioritisation method applied to every finding.Coverage is measured against the inventory and reported, and the method was adjusted because of what the measures showed.
MP-18Written remediation deadlines by priority, records showing fixes against them, and a deferral approved as an exception whenever a deadline is missed.Fixes within deadline are measured and reported, and fixes are verified by a rescan before closure.
MP-19A written process with approval before access, and records showing leavers' access removed within the time it sets.Removal times are measured and reported, and the process was changed because of a late removal.
MP-20Access reviews of the in-scope systems at the interval the procedure sets, with removals made and recorded.Completion and removal rates are measured and reported, and reviews are checked by someone other than the reviewer.
MP-21A list of privileged accounts with an owner and approval for each, separate accounts for privileged work, and strong authentication on them.Privileged activity is logged and reviewed, and the number of privileged accounts is measured and reported.
MP-22A training plan by audience, records of completion, and additional training for roles at higher risk.Completion is measured and followed up, and the plan is changed each year from incidents and risks.
MP-23A written measure of behaviour, such as the reporting rate of suspicious emails, collected at a set interval.The measure has a target, it is reported, and the programme was changed because of it.
MP-24A backup schedule for critical data, a copy protected from the systems it backs up, and records of restore tests at the interval set.Restore success and time are measured and reported, and failed restores lead to recorded changes.
MP-25Written configuration baselines for the main system types, and records showing new systems are built to them.Drift from the baseline is detected and measured, and the baselines are reviewed at a set interval.
MP-26A list of the systems whose logs are collected, central collection protected from change, and retention as the organisation has decided.Missing log sources are detected and reported, and the list is reviewed when systems change.
MP-27Written criteria for the alerts that must be reviewed, a response time, and records of triage.Triage times and missed alerts are measured and reported, and the criteria are tuned from incidents and false positives.
MP-28An approved incident procedure with severity levels and named roles, and incident records that follow it.Response measures are reported, and post-incident reviews lead to changes that are tracked to closure.
MP-29A record of which regimes apply, a written way of deciding whether to report, named people with tested access to each authority's channel, and records of decisions made.Decisions and reports on time are measured, and readiness is re-checked at a set interval.
MP-30An exercise programme, at least one exercise held in the evidence window, and its lessons recorded with owners.Lessons are tracked to closure and reported, and the programme varies scenarios and participants from year to year.
MP-31A list of critical services with recovery time objectives agreed by their business owners, and a recovery plan for each.The objectives are reviewed each year, and plans are updated after each test or real recovery.
MP-32Recovery tests at the interval set, with the time achieved recorded against the objective.Results are reported, and every missed objective leads to a recorded change.

Definitions

Definitions

TermMeaning in this workbook
FindingA practice below its domain's target, written as what was found, what the level needs, and the evidence seen.
ActionThe work that will move one practice up one level, with an owner, a due date and the evidence that will show it is done.
Re-assessmentChecking a practice again after its action closes, by someone other than the action's owner, to confirm the level moved (MA-18).
PracticeOne thing the programme does, stated as a question with the evidence each level needs (MP-01 to MP-32). Practices are what the assessor rates.
DomainOne area of the security programme, such as risk management or identity and access, made up of two to three practices (DM-01 to DM-14).
LevelOne of the four levels of the scale: Not in place, Informal, Defined or Managed. The scale is P01-A09's, and P11 uses it too.
Not in placeThe practice does not exist, or happens only by chance.
InformalIt happens, but depends on particular people and is not written down or not done consistently.
DefinedIt is written down, agreed and done routinely, and leaves a record.
ManagedAs Defined, and it is also measured, checked by someone else and improved.
Domain levelThe lowest level among a domain's practices that apply. One weak practice limits the domain, and an average would hide it (MA-06).
TargetThe level management decides a domain should reach, set before the evidence is scored, with the reason for it (MA-09).
GapThe number of levels between a domain's level and its target: 0 when the target is met, up to 3 (MA-10).
PressingSaid of a practice on which a risk outside appetite, or an obligation the organisation has recorded as not met, rests. Its action takes priority (MA-11).
ConfidenceHow a result was evidenced: Told, Seen or Tested (MA-13).
Self-assessedA result given by someone who owns or does the practice. It is marked as such and cannot be above Defined until someone independent checks the evidence (MA-14).
Break in seriesA change to the model, the scope or the evidence window that means a result cannot be compared with an earlier one. It is marked, as P11's MR-09 marks a change to a metric (MA-15).
OpenThe action is agreed, with an owner, a due date and the evidence that will show it is done. Work has not started.
In progressWork has started. The practice is not yet at the level the action aims for.
Ready for re-assessmentThe owner says the work is done and the evidence is ready. The action is not closed: the level has not been checked yet.
ClosedA re-assessment by someone other than the action owner found the practice at the level the action aimed for, or higher (MA-18).
Not achievedA re-assessment found the practice below the level the action aimed for. Agree what is missing and a new due date, or record the approver's decision to stop.
Level decidedThe level after the caps of MA-13 and MA-14: the practice's result at the assessment.
Level nowThe level found at the practice's latest re-assessment, or the level decided if it has not been re-assessed.
First stepAn action that starts from the practice's decided level. Its order and priority come from MA-11.
Later stepAn action that starts from a level the practice has not reached yet, such as Defined to Managed. It names the step it follows and starts when that step closes.
Action orderThe order MA-11 sets: practices on which a risk outside appetite or a recorded unmet obligation rests; then the lower level; then the larger domain gap; then domain and practice order.
Earliest Managed claimThe date [[6]] months after the practice was last shown at Defined: the end of fieldwork for a first step, or the re-assessment (or, before it, the due date) of the step it follows (MA-12).
EffortS Small, [[up to 5]] person-days; M Medium, [[6 to 20]] person-days; L Large, [[21 to 60]] person-days. The bands of the Target-State Maturity Roadmap.
As-at dateThe date every overdue flag, days-overdue figure and measure is worked out at.
Head of Information SecurityOwns the security programme being assessed, coordinates the evidence, proposes the improvement plan from the findings, and owns the tracker. Rates no practice they own or run.
Assessment leadThe person who plans the assessment, assigns assessors, decides each result and writes the report. Independent of the practices they rate.
Assessment sponsorThe member of management who commissions the assessment, approves its scope and targets, and receives the report.
(calc), (working)A column or cell the workbook calculates. Do not type or paste over it. Working columns hold intermediate values other formulas read.
MA-nn, MP-nn, DM-nn, MAM-nnThe rules, practices, domains and headline measures of the Security Maturity Model & Scoring Method. MF-nn are this cycle's actions; RS-nn the later steps of the Target-State Maturity Roadmap. PH-n and IT-n are the phases and independence triggers of the Internal Security Assessment Procedure.
EXAMPLEA worked example: a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders, after its first assessment, ASM-2026-1, as at 30 Sep 2026. Delete before use.

Framework References

Framework references

These references indicate relevance only and do not reproduce the text of any standard.

FrameworkReferenceSupported by
ISO/IEC 27001:2022Clause 10.1 — Continual improvementActions sheet: improvements planned from the assessment's findings, tracked to closure and checked
NIST CSF 2.0ID.IM-01 — “Improvements are identified from evaluations”Findings sheet: the improvements identified from this evaluation, in the order the rules set
NIS2 — Directive (EU) 2022/2555Article 21(4) — an entity that finds that it does not comply with the measures in paragraph 2 takes, “without undue delay, all necessary, appropriate and proportionate corrective measures”Actions sheet: each shortfall found turned into an action with an owner and a date, and tracked until a re-assessment shows it corrected. Where a shortfall concerns a measure of Article 21(2), the tracker is a record of the corrective measures taken
NIS2 — Implementing Regulation (EU) 2024/2690Article 1 — lays down the technical and methodological requirements of the Article 21(2) measures, and further specifies when an incident is significant, for DNS service providers, TLD name registries, cloud computing, data centre and content delivery network providers, managed service and managed security service providers, providers of online marketplaces, online search engines and social networking services platforms, and trust service providersApplies to the providers its Article 1 names. For them, the Annex point below; for others, a useful guide only
NIS2 — Implementing Regulation (EU) 2024/2690Annex, point 2.3.3 — the results of the independent reviews, including the results of compliance monitoring (point 2.2) and of monitoring and measurement (point 7), are reported to the management bodies; “Corrective actions shall be taken or residual risk accepted according to the relevant entities’ risk acceptance criteria.”Measures sheet: progress reported to management each quarter, and each finding either acted on or, where the approver decides to stop an action, the residual risk accepted by the entity's criteria. For the providers Article 1 names, the results can feed the independent review; the tracker is not that review
DORA — Regulation (EU) 2022/2554Article 6(5) — the ICT risk management framework is documented and reviewed at least once a year (periodically for microenterprises), upon major ICT-related incidents, and following supervisory instructions or conclusions from digital operational resilience testing or audit processes; “It shall be continuously improved on the basis of lessons derived from implementation and monitoring.” A report on the review is submitted to the competent authority on requestActions and Measures sheets, for financial entities: improvements drawn from an assessment and followed through, which can inform the yearly review of the ICT risk management framework
DORA — Regulation (EU) 2022/2554Article 6(7) — “Based on the conclusions from the internal audit review, financial entities shall establish a formal follow-up process, including rules for the timely verification and remediation of critical ICT audit findings.”Actions sheet, for financial entities: the same follow-up discipline (owner, date, verification by someone else) as a formal follow-up process. It does not replace the follow-up of internal audit findings, which the audit's own process governs
DORA — Delegated Regulation (EU) 2024/1774Article 28(6) — “Based on the outcome of the audit referred to in paragraph 5, the financial entities referred to in paragraph 1 shall ensure the timely verification and remediation of critical ICT audit findings.”Actions sheet, for entities under the simplified framework: closure only on verification. The audit's critical findings are followed up under the audit's own rules
GDPR — Regulation (EU) 2016/679Article 24(1) — the controller implements appropriate technical and organisational measures to ensure, and to be able to demonstrate, that processing is performed in accordance with the Regulation; “Those measures shall be reviewed and updated where necessary.”Actions sheet: measures reviewed and updated where the assessment found them wanting, with a record that shows it
GDPR — Regulation (EU) 2016/679Article 32(1)(d) — the security measures include, as appropriate, “a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing”Findings and Actions sheets: the results of assessing the effectiveness of security measures, and what was done about them

Editions referenced: ISO/IEC 27001:2022 incl. Amd 1:2024; NIST CSF 2.0; Directive (EU) 2022/2555 (NIS2) and Implementing Regulation (EU) 2024/2690; Regulation (EU) 2022/2554 (DORA); Regulation (EU) 2016/679 (GDPR)

ISO/IEC 27001 references name the clause or control this document relates to. They do not say that meeting it meets any other framework's requirement.

These references show where this document supports an external framework. They indicate relevance only and do not reproduce the text of any standard.

Prepared by Zero One Cybersecurity · Published by CISO Times

CISO Times Resource Licence — Internal Use