Question: Are key security and privacy roles (CISO, DPO, Risk Officer) appointed with written mandates and independence?
Objective — Why This Matters
Named, empowered roles avoid conflicts and speed decisions, especially for incidents and regulator interactions. Independence protects objectivity.
Maturity Levels (0–5)
0 — Unaware
No formal role owners.
No formal role owners.
1 — Ad Hoc
People “wear the hat” informally.
People “wear the hat” informally.
2 — Defined
Appointment letters and ToR exist; reporting lines clear.
Appointment letters and ToR exist; reporting lines clear.
3 — Managed
Mandates include decision authority and escalation.
Mandates include decision authority and escalation.
4 — Integrated
Independence safeguards (no conflicting KPIs); periodic board access.
Independence safeguards (no conflicting KPIs); periodic board access.
5 — Optimized
Succession and backup roles defined; performance linked to outcomes.
Succession and backup roles defined; performance linked to outcomes.
How to Level Up
| From → To | Actions |
|---|---|
| 0 → 1 | Nominate role owners and draft ToR with duties. |
| 1 → 2 | Issue appointment letters; publish org chart with reporting. |
| 2 → 3 | Define decision rights and escalation time limits. |
| 3 → 4 | Document independence (no product P&L conflicts); board access policy. |
| 4 → 5 | Create deputies; set outcome KPIs (e.g., audit closure time). |
People / Process / Technology Enablers
- People: CISO (part-time acceptable), Privacy/DPO, Risk lead.
- Process: ToR templates; conflict-of-interest statement.
- Technology: HRIS role records; org chart tool.
Evidence Required
- Appointment letters/ToR.
- Updated org chart with lines of reporting.
- Conflict-of-interest/independence note.
Metrics / KPIs
- Number of escalations resolved within SLA.
- % policies owned and reviewed on time.
- Audit finding age (by role).
Low-Cost / Open-Source Options (MSME)
| Purpose | Tool | Notes |
|---|---|---|
| Org charts | draw.io | Simple export to PDF/PNG. |
| ToR templates | Markdown repo | Versioned in git. |
| Role visibility | Intranet page | Who to contact, when, how. |
Common Pitfalls
- Combining security with conflicting delivery KPIs.
- Roles named but no authority/time.
- No backups; decisions stall during leave.
Compliance Mapping
| Standard | Clauses / Notes |
|---|---|
| ISO/IEC 27001:2022 | 5.3 roles/responsibilities |
| DPDP Act 2023 | Sec 10(1) DPO/lead |
| NIRMATA Scoring | GL-Q05 expects formal mandate + independence proof. |