CIP-003 — Security Management Controls

Description

CIP-003 defines foundational security-management controls. It addresses cybersecurity policies, senior management accountability, personnel and organizational responsibilities, information protection expectations, incident reporting coordination, and baseline controls for applicable low-impact BES Cyber Systems.

Implications

• Establishes governance, accountability, documented policies, and periodic review requirements.
• Requires management sponsorship and clear ownership of CIP responsibilities across operations, IT, OT, physical security, legal, procurement, and compliance.
• Low-impact systems still require defined baseline protections, even when the full medium- or high-impact control set does not apply.
• Weak governance can undermine otherwise effective technical controls and increase audit exposure.

Common Compensating Controls

• Board- or executive-approved cybersecurity and CIP policy suite with annual review and version control.
• Named CIP senior manager, system owners, control owners, and escalation authorities.
• Risk register, exception process, policy attestations, internal audits, and management reporting.
• Baseline controls for low-impact environments: documented electronic access controls, physical access controls, incident response, and security awareness.
• Periodic tabletop exercises and independent governance assessments.

Compensating controls should address the specific requirement and be documented with rationale and evidence.