cc3-4 Medium priority Security / Risk Assessment

Significant changes are assessed for security impact

Major changes to the organization, technology, or environment can invalidate existing controls or introduce new risks. Acquisitions, new product lines, significant infrastructure changes, key staff departures, and new regulatory requirements all have security implications. This control requires a process to identify significant changes, assess their risk impact, and update controls accordingly — rather than discovering the gap during an audit or an incident.

Complete first: cc3-2

Implementation steps

  1. 1

    Define what constitutes a significant change

    Document the types of changes that trigger a security impact assessment. Common examples: launching a new product or entering a new market, migrating to a new cloud provider or major infrastructure change, acquiring or being acquired, significant headcount changes (especially in IT or security), new regulatory requirements affecting your industry, major new customer or data type.

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  2. 2

    Build security review into change processes

    Add a security impact assessment step to your change management process for significant changes. The assessment should answer: Does this change introduce new risks? Does it require new controls? Does it invalidate existing controls? Who is the security owner for this change?

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  3. 3

    Update the risk register after significant changes

    When a significant change occurs, update the risk register to reflect any new or modified risks. This ensures your risk posture documentation stays current and demonstrates that the change assessment process actually resulted in action.

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Evidence required

Significant change definition and process

Documentation of what triggers a security impact assessment and how it is conducted.

  • - Change management policy with security assessment trigger criteria
  • - Security review checklist for significant changes
  • - Risk assessment policy with change triggers defined

Records of change-triggered assessments

Evidence that security impact assessments were conducted when significant changes occurred.

  • - Security review document for infrastructure migration
  • - Updated risk register entry following a major product launch
  • - Change advisory board minutes with security impact noted

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