Skip to main content

Applying Governance and Contracting Throughout the Lifecycle

🧭 When to apply​

Phase / EventExpected actionEvidence
PlanningDefine contractual clauses and metricsApproved documents
ExecutionRecord exceptions, apply clauses to suppliersGRC record
ValidationSupplier audits, exception reviewsAudit reports
OperationsContinuous KPI reportingDashboards
AuditOrganisational reviewConsolidated report

👥 Who carries out each action​

RoleResponsibility
DeveloperRecord exceptions and comply with policies
AppSec EngineerValidate exceptions, oversee traceability
DevOps / SREEnsure technical execution in line with the clauses
Executive ManagementApprove residual risk
Legal + ProcurementIntegrate security clauses into contracts
GRC / ComplianceConsolidate metrics and audit suppliers

📖 Normalised User Stories​

US-01 - Formal exception process with approval authorities by risk level​

Context. Without formal exceptions, practices are ignored without transparency. Without clear approval authorities by risk level, decisions are inconsistent and responsibility is dispersed.

User Story

Story.
As Developer + AppSec Engineer, I want to submit security exceptions through a formal flow with automatic routing by risk level (L1→app manager, L2→AppSec+manager, L3→CISO+AppSec+senior management), so that transparency, risk-proportionate approval and periodic revalidation are ensured.

Acceptance criteria (BDD).

  • Given that a control cannot be met in an application classified as L1, L2 or L3
    When I submit an exception with technical justification and compensation
    Then it is routed to the appropriate approval authority, assessed, and approved or rejected
  • And revalidation is automatically scheduled for the expiry date, within the TTL of Policy 05 §7

Acceptance criteria (DoD).

  • Exception recorded in a GRC tool with mandatory fields: application, risk (L1–L3), missing control, justification, compensation, owner
  • Approval authority determined automatically by risk level
  • Formal approval received (digital signature or timestamp record)
  • Revalidation schedule created and owner notified (15 days before expiry, or at the midpoint of the TTL if it is shorter than 30 days)
  • Mitigation issue created in the security backlog for the next release
  • Automatic notification sent to the owner if the exception is approaching expiry

Artefacts & evidence. Versioned exception register, Formalised decision with approval authority, Revalidation schedule, Backlog issue, Automatic notifications

Proportionality.

L1L2L3
Mandatory (formal record; approval by the application manager)MandatoryMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
ExecutionWhenever there is a deviationDeveloper (submission) + AppSec Engineer (validation) + Executive Management / CISO (approval according to level)Approval within 5 days (L1–L2), 3 days (L3); Revalidation notification 30 days before expiry

US-02 - Security contractual clauses​

Context. Suppliers without clauses can compromise the entire chain.

User Story

Story.
As Legal + Procurement, I want to include SbD-ToE clauses in contracts, so that supplier compliance is guaranteed.

Acceptance criteria (BDD).

  • Given a new contract
    When clauses are applied
    Then the supplier commits to complying with security practices

Acceptance criteria (DoD).

  • Clauses published in a contract template
  • Contracts legally validated
  • Compliance monitoring

Artefacts & evidence. Contracts, clauses

Proportionality.

L1L2L3
Mandatory (minimum clauses)MandatoryMandatory + audits

Integration into the SDLC.

PhaseTriggerResponsibleSLA
PlanningNew contractLegal + ProcurementAccording to the US cycle

US-03 - Continuous supplier validation​

Context. Compromised suppliers propagate risk.

User Story

Story.
As GRC / Compliance, I want to validate suppliers continuously, so that compliance and contractual security are ensured.

Acceptance criteria (BDD).

  • Given an active supplier
    When an audit takes place
    Then the report documents compliance

Acceptance criteria (DoD).

  • Annual audit
  • Report published
  • Findings recorded

Artefacts & evidence. Audit reports

Proportionality.

L1L2L3
OptionalMandatory (annual)Mandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
ValidationAudit of an active supplierGRC / ComplianceAnnual audit

US-04 - Organisational traceability​

Context. Without traceability, management has no real visibility.

User Story

Story.
As an AppSec Engineer, I want to aggregate security practices by project into an organisational dashboard, so that visibility is provided and adoption is measured.

Acceptance criteria (BDD).

  • Given active projects
    When metrics are collected
    Then the dashboard shows the overall status

Acceptance criteria (DoD).

  • Dashboard configured
  • Metrics per chapter collected
  • Reports delivered to senior management

Artefacts & evidence. Dashboard, reports

Proportionality.

L1L2L3
BasicMandatoryMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
OperationCollection of metrics from active projectsAppSec Engineer + GRC / ComplianceAccording to the US cycle

📊 Global Traceability Matrix​

The following table consolidates the traceability practices applied in each chapter, showing the focal point for audit and governance:

ChapterUSContextMain artefactResponsible
Ch. 02US-07Requirements with SEC-Lx-* tagsBacklog with traceabilityQA / Product Owner
Ch. 07US-03Logs and commit-build-release correlationCI/CD reports + audit trailDevOps / SRE
Ch. 08US-02Versioned and traceable modulesIaC module historyDevOps / SRE
Ch. 09US-06SBOM with provenance per imagesbom.json + metadataDevOps / SRE
Ch. 11US-02End-to-end traceability (build → deploy → runtime)Attestations + deploy logsDevOps / SRE
Ch. 12US-01Correlated security eventsEvents + SIEM logsOperations (Ops) / AppSec Engineer
Ch. 14US-04Organisational metrics dashboardDashboard + quarterly reportsAppSec Engineer + GRC / Compliance

Notes:

  • Each chapter has a traceability focal point that is integrated into the organisational matrix
  • Ch. 14 - US-04 aggregates data from all chapters for executive visibility
  • All artefacts must be versioned and auditable according to level L1–L3
  • Minimum SLA: Monthly (L1), fortnightly (L2), continuous (L3) reports

US-05 - Governance KPIs​

Context. Without metrics, there is no continuous improvement.

User Story

Story.
As Executive Management, I want to define and monitor governance KPIs, so that the effectiveness of the SbD-ToE programme is assessed.

Acceptance criteria (BDD).

  • Given a quarterly cycle
    When KPIs are measured
    Then a report is shared with senior management

Acceptance criteria (DoD).

  • KPIs defined (e.g. exceptions, audited suppliers)
  • Metrics collected
  • Report shared

Artefacts & evidence. KPI reports

Proportionality.

L1L2L3
BasicMandatoryMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
AuditQuarterly KPI measurement cycleExecutive Management + GRC / ComplianceAccording to the US cycle

US-06 - Execution of a formal supplier validation flow​

Context. Unvalidated suppliers introduce untraceable risk into the supply chain.

User Story

Story.
As a Procurement Officer, I want to execute the formal supplier validation flow (questionnaire → AppSec analysis → approval), so that new suppliers are guaranteed to meet minimum requirements before onboarding.

Acceptance criteria (BDD).

  • Given a new supplier with access to data, code or pipelines
    When the validation flow is initiated
    Then the questionnaire is sent, analysed by AppSec, and the approval/exception is recorded

Acceptance criteria (DoD).

  • Validation checklist completed (questionnaire, clauses, evidence)
  • Technical analysis by the AppSec Engineer documented
  • Formalised decision (Approval / Rejection / Exception) recorded in GRC
  • Supplier Owner designated and notified

Artefacts & evidence. Questionnaire form, AppSec analysis report, GRC record

Proportionality.

L1L2L3
Mandatory (questionnaire or checklist)MandatoryMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
PlanningNew supplier with access to data, code or pipelines; start of the validation flowAppSec Engineer + Procurement Officer2 weeks (L1 and L2), 1 week (L3)

Useful links.


US-07 - Continuous cycle of exception review and reassessment​

Context. Forgotten exceptions become permanent unmitigated risk.

User Story

Story.
As an AppSec Engineer, I want to review and reassess exceptions and compensations periodically, so that residual risk is guaranteed to remain mitigated and compensations remain effective.

Acceptance criteria (BDD).

  • Given an active exception or compensation with a review deadline
    When the scheduled review date arrives (or a critical event occurs)
    Then it is reassessed, revalidated, extended or closed

Acceptance criteria (DoD).

  • Review schedule defined by criticality (L3 quarterly, L2 half-yearly)
  • Exception register updated with the new review date
  • Reassessment documented (maintained, extended, closed)
  • Security Owner notified and decision approved

Artefacts & evidence. Exception table with deadlines, Reassessment report, Notification to owner

Proportionality.

L1L2L3
BasicMandatoryMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
OperationSchedule (quarterly/half-yearly), Critical incident, Architecture changeAppSec Engineer + GRC / ComplianceReassessment within 5 working days
ValidationSchedule (quarterly/half-yearly), Critical incident, Architecture changeAppSec Engineer + GRC / ComplianceReassessment within 5 working days

Useful links.


US-08 - Compliance repository per application (systematic control)​

Context. Without a centralised repository, the security status remains invisible to auditors and management.

User Story

Story.
As AppSec Engineer + Scrum Master / Team Lead, I want to maintain a structured compliance repository for each application, so that the status of all SbD-ToE practices is consolidated and internal and external audits are facilitated.

Acceptance criteria (BDD).

  • Given an application classified as L1, L2 or L3
    When the repository is created or updated
    Then it reflects the status of all chapters (2–13) in a structured checklist

Acceptance criteria (DoD).

  • Repository created (YAML file, versioned MD or GRC dashboard)
  • Checklist per chapter (02–13) included with binary status (Yes/No/Exception)
  • Validation evidence linked (links to reports, tests, scans, audits)
  • Change history maintained and auditable
  • Updated per relevant release or critical event

Artefacts & evidence. Compliance file (YAML/MD), Links to validation reports, Version history

Proportionality.

L1L2L3
BasicMandatoryMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
PlanningCreation or update of the repository; relevant release or critical eventAppSec Engineer + Scrum Master / Team Lead + GRC / ComplianceUpdate per release or 5 days after a critical event
ExecutionCreation or update of the repository; relevant release or critical eventAppSec Engineer + Scrum Master / Team Lead + GRC / ComplianceUpdate per release or 5 days after a critical event
ValidationCreation or update of the repository; relevant release or critical eventAppSec Engineer + Scrum Master / Team Lead + GRC / ComplianceUpdate per release or 5 days after a critical event

Useful links.


US-09 - Formal designation of security owners per application​

Context. Without a clear owner, dispersed responsibility results in neglect of exceptions and validations.

User Story

Story.
As Executive Management, I want to formally designate a security owner (for example, the Security Champion) for each application, so that clear accountability, continuity of security decisions and risk communication are guaranteed.

Acceptance criteria (BDD).

  • Given an application classified as L1, L2 or L3
    When the security owner is designated
    Then they are responsible for submitting exceptions, validations, risk communication and policy compliance

Acceptance criteria (DoD).

  • Security owner designated in writing (official e-mail, document, HR system)
  • Responsibilities documented (exceptions, validation, communication, traceability)
  • Mandatory SbD-ToE training completed (Ch. 13 - Training and Onboarding)
  • Centralised register maintained (Git, Confluence, SharePoint)
  • Formal notification to the previous owner (if there is rotation)

Artefacts & evidence. Designation document, Proof of training, Centralised register of owners

Proportionality.

L1L2L3
MandatoryMandatoryMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
PlanningL1–L3 application; project kick-off or owner rotationExecutive Management + Security Champion + AppSec EngineerDesignation at project kick-off or change of owner

Useful links.


US-10 - Periodic validation of applications (compliance cycle)​

Context. Without recurring validations, deviations are not detected until an audit or incident.

User Story

Story.
As AppSec Engineer + GRC / Compliance, I want to execute periodic compliance validations against SbD-ToE on each application, so that requirements are ensured to remain applied and effective, deviations are detected early, and evidence is kept up to date.

Acceptance criteria (BDD).

  • Given a review schedule defined by criticality (L3 quarterly, L2 half-yearly)
    When the review cycle arrives
    Then the application is reassessed, evidence collected, and status updated in the repository

Acceptance criteria (DoD).

  • Review schedule defined and communicated to the Scrum Master / Team Lead
  • Validation checklist per chapter executed
  • Evidence collected (tests, scans, reviews, external audits)
  • Compliance report generated with clear status
  • Findings and deviations recorded in a tracking system (Jira, etc.)
  • Action plan created for critical non-conformities

Artefacts & evidence. Validation report per cycle, Completed checklist, Action plan for findings, Cycle history

Proportionality.

L1L2L3
AnnualHalf-yearlyQuarterly

Integration into the SDLC.

PhaseTriggerResponsibleSLA
ValidationCyclical schedule, Relevant release, Critical incidentAppSec Engineer + GRC / Compliance + Scrum Master / Team LeadCycle completed within 2 weeks of the trigger
AuditCyclical schedule, Relevant release, Critical incidentAppSec Engineer + GRC / Compliance + Scrum Master / Team LeadCycle completed within 2 weeks of the trigger

Useful links.


US-11 - Consolidation of governance and maturity KPIs​

Context. Without consolidated metrics, executive decisions on the effectiveness of SbD-ToE lack an empirical basis.

User Story

Story.
As CISO + Executive Management, I want to consolidate and report governance KPIs (exceptions, audited suppliers, compliance per chapter, maturity), so that the organisation's security maturity is assessed objectively and strategic decisions are taken.

Acceptance criteria (BDD).

  • Given compliance and exception data per application
    When the reporting cycle arrives (quarterly/half-yearly)
    Then KPIs are calculated, visualised and reported to senior management

Acceptance criteria (DoD).

  • KPIs defined (e.g. % applications with traceability, % exceptions resolved, % suppliers audited, SAMM/SSDF maturity level)
  • Dashboard configured with metrics per chapter and per application
  • Data aggregated from all projects, teams and suppliers
  • Consolidated report delivered to Executive Management, CISO and GRC
  • Trends identified and recommendations included
  • History maintained for trend analysis

Artefacts & evidence. KPI dashboard, Quarterly/half-yearly consolidated report, Trend history, Executive analysis

Proportionality.

L1L2L3
BasicMandatoryMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
AuditIn line with Policy 35: annual (L1), half-yearly (L2), quarterly (L3)GRC / Compliance + AppSec Engineer + CISOReport published 5 days after the end of the period
OperationIn line with Policy 35: annual (L1), half-yearly (L2), quarterly (L3)GRC / Compliance + AppSec Engineer + CISOReport published 5 days after the end of the period

Useful links.


US-12 - Formalisation of a governance model by risk level​

Context. Without a documented formal model, security decisions are scattered across AppSec, Management and Legal. The lack of explicit criteria for approval by level results in inconsistency, untraceable risk, and stakeholder mistrust.

User Story

Story.
As CISO + AppSec Engineer, I want to formalise and document the governance model with explicit approval authority levels and clear roles and responsibilities, so that security decisions are guaranteed to be taken with appropriate authority, consistency, and full traceability.

Acceptance criteria (BDD).

  • Given that the organisation adopts SbD-ToE
    When a new governance model is defined or revised
    Then it is documented with approval authorities per L1–L3, approved by senior management, and communicated to all stakeholders

Acceptance criteria (DoD).

  • Formal "SbD-ToE Security Governance Policy" document approved by senior management
  • Approval authority levels explicitly defined: L1 (Application Manager), L2 (AppSec + Manager), L3 (CISO + AppSec + Senior Management)
  • Roles and responsibilities mapped by function (Dev, AppSec, Management, Legal, GRC, CISO)
  • Decision record template created (Jira / SharePoint / Git) with mandatory fields
  • Escalation flow documented with SLAs per level
  • Training delivered to all approvers (Ch. 13 - Governance Training Track)
  • Official communication published on corporate channels

Artefacts & evidence. Policy document, Decision template, Repository of recorded decisions, Proof of approver training, Communication e-mail

Proportionality.

L1L2L3
Mandatory (model approved by senior management)Mandatory (+ approval authorities per level)Mandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
PlanningSbD-ToE kick-off, annual review, organisational changeCISO + AppSec Engineer + GRC / Compliance + LegalPublication within 2 weeks
ExecutionSbD-ToE kick-off, annual review, organisational changeCISO + AppSec Engineer + GRC / Compliance + LegalPublication within 2 weeks

Useful links.


US-13 - Systematic and periodic control per SbD-ToE chapter​

Context. Without a centralised compliance checklist, an application's compliance status with Ch. 2–13 remains invisible. Deviations are not detected until an audit or critical incident. Management has no visibility of progress.

User Story

Story.
As AppSec Engineer + Scrum Master / Team Lead, I want to maintain a centralised, versioned and auditable checklist of compliance with all SbD-ToE chapters (2–13), with periodic verification per release or critical event, so that the real status of all practices is consolidated and audits, risk decisions, and demonstration of regulatory compliance are facilitated.

Acceptance criteria (BDD).

  • Given an application classified as L1, L2 or L3
    When a validation cycle is triggered (per release, quarterly for L3, half-yearly for L2, or critical event)
    Then the checklist is completed with status, evidence is linked, and a report is generated

Acceptance criteria (DoD).

  • Versioned checklist file created in a repository (YAML, MD or GRC dashboard) with the structure: Chapter | Practice | Status (Yes/No/Exception/N/A) | Evidence (link/reference) | Owner | Validation date
  • Integration with the version control system (Git) or GRC with auditable history
  • Triggers defined and automated: relevant release, critical event (incident, CVE), scheduled cycle (L3 quarterly, L2 half-yearly, L1 annual)
  • History maintained with dated changes and those responsible (audit trail)
  • Consolidated report generated per cycle with % compliance, critical findings, and action plan
  • Evidence artefacts linked or referenced in the checklist (links to tests, scans, reports, audits)
  • Automatic notification sent to the Scrum Master / Team Lead and AppSec Engineer when a cycle is triggered

Artefacts & evidence. Versioned checklist file (YAML/MD), Git history or GRC dashboard, Reports per cycle, Links to validation artefacts, Action plan for non-conformities, Version history

Proportionality.

L1L2L3
BasicMandatoryMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
PlanningRelevant release, critical event, scheduled cycle (quarterly/half-yearly/annual)AppSec Engineer (validation) + Scrum Master / Team Lead (completion) + GRC / Compliance (consolidation)Update within 5 working days of the trigger
ExecutionRelevant release, critical event, scheduled cycle (quarterly/half-yearly/annual)AppSec Engineer (validation) + Scrum Master / Team Lead (completion) + GRC / Compliance (consolidation)Update within 5 working days of the trigger
ValidationRelevant release, critical event, scheduled cycle (quarterly/half-yearly/annual)AppSec Engineer (validation) + Scrum Master / Team Lead (completion) + GRC / Compliance (consolidation)Update within 5 working days of the trigger
AuditRelevant release, critical event, scheduled cycle (quarterly/half-yearly/annual)AppSec Engineer (validation) + Scrum Master / Team Lead (completion) + GRC / Compliance (consolidation)Update within 5 working days of the trigger

Useful links.


US-14 - Continuous reassessment and rotation of suppliers post-onboarding​

Context. Suppliers are validated at onboarding, but without periodic review, deviations emerge over time (new unmitigated CVEs, SLA not met, changes of ownership, evolution of risk). Residual risk accumulates invisibly. Contracts expire without renewal of validation.

User Story

Story.
As Procurement Officer + AppSec Engineer, I want to reassess and re-approve suppliers periodically (annual for L1 and L2, half-yearly for L3, and upon a critical event), with updated technical validation, SLA compliance analysis, and escalation for a decision on penalty or replacement if necessary, so as to ensure that they continue to meet requirements and SLAs, that risk is mitigated, and that continuity decisions are evidence-based.

Acceptance criteria (BDD).

  • Given an active supplier with a contract in force
    When the scheduled review date arrives (calendar) or a critical event occurs (incident, critical CVE, SLA change)
    Then the supplier is reassessed with an updated questionnaire, validated technical evidence (SBOM, SLA compliance, changes) and the decision is formalised

Acceptance criteria (DoD).

  • Supplier review schedule defined and communicated (annual for L1 and L2, half-yearly for L3, or upon a critical event)
  • Updated questionnaire with security and SLA questions sent to the supplier
  • Technical analysis documented (AppSec): SBOM validated, CVEs analysed, SLA compliance verified, organisational/technical changes identified
  • Decision formalised and recorded in GRC: Approved / Exception created / Penalty proposed / Termination initiated
  • Owner formally notified by e-mail with the decision and next review date
  • Mitigation plan created if gaps are identified (deadline, AppSec owner, expected validation)
  • Register updated in the supplier repository with date, decision-maker, and history

Artefacts & evidence. Review schedule, Updated questionnaire + answers, Documented technical analysis, Decision recorded in GRC, Formal communication to the supplier, Mitigation plan if applicable, Decision history

Proportionality.

L1L2L3
AnnualAnnual / critical eventHalf-yearly / critical event

Integration into the SDLC.

PhaseTriggerResponsibleSLA
ValidationScheduled calendar (annual/half-yearly), Critical incident, Unmitigated critical CVE, Change of contract/ownership/SLAAppSec Engineer (technical analysis) + Procurement Officer (coordination) + GRC / Compliance (decision and record)Reassessment completed within 2 weeks of the trigger
OperationScheduled calendar (annual/half-yearly), Critical incident, Unmitigated critical CVE, Change of contract/ownership/SLAAppSec Engineer (technical analysis) + Procurement Officer (coordination) + GRC / Compliance (decision and record)Reassessment completed within 2 weeks of the trigger

Useful links.


US-15 - Technical Preparation and Validation of Contractors Before Access​

Context. Contractors gain access without understanding security policies, mandatory tools, or procedures. Risk of involuntary error (exposed credentials, unauthorised data access, insecure practices).

User Story

Story.
As Security Champion + HR / People Operations, I want to execute a structured technical preparation process for contractors (screening, mandatory training, comprehension test, sandbox environment) before they gain access to systems, so that they are guaranteed to be prepared, to have understood fundamental policies, and to be able to work securely.

Acceptance criteria (BDD).

  • Given a new contractor approved by Procurement (US-06) and a signed contract
    When the project start date arrives
    Then the preparation track is triggered: mandatory training, quiz, sandbox setup, NDA confirmation

Acceptance criteria (DoD).

  • Preparation checklist completed (skills screening, expected security level, required training defined)
  • Profile-based training track (Dev, DevOps, QA, etc.) started in the LMS or training platform
  • Security policy comprehension quiz completed (minimum score 80%)
  • Access to a sandbox environment provided for practice (e.g. private Git repository, demo application, security tools)
  • NDA and confidentiality agreement digitally signed with timestamp
  • Technical onboarding checklist completed and validated by the team (Security Champion + Tech Lead)
  • Real access to systems granted only after all approval steps
  • "Ready for access" record documented in GRC with date, validator, and reference to all validations

Artefacts & evidence. Completed preparation checklist, Confirmed LMS enrolment, Validated quiz score, Sandbox access credentials, Digitally signed agreements, Onboarding checklist, GRC "ready for access" record

Proportionality.

L1L2L3
BasicMandatoryMandatory + validated quiz

Integration into the SDLC.

PhaseTriggerResponsibleSLA
PlanningContract signed, project start dateHR / People Operations (coordination) + AppSec Engineer (validation) + Tech Lead (sandbox setup)Completion 2–3 working days before the start date; Notification: Contractor informed by e-mail about the track

Useful links.


US-16 - Mandatory Training Track Before Access (Contractors)​

Context. Contractors started without completing mandatory security training. Lack of clear integration between Ch. 13 (Training) and Ch. 14 (Governance): who approves, what the SLA is, how it is tracked.

User Story

Story.
As CISO + Training Manager, I want to define and execute a mandatory training track per contractor profile, with an explicit completion SLA before technical access, so that minimum security awareness, regulatory compliance (DORA, NIS2), and traceability of preparation are guaranteed.

Acceptance criteria (BDD).

  • Given a newly hired contractor
    When a training track is assigned in the LMS
    Then they must complete mandatory courses, pass a quiz, and have a consolidated record before real access

Acceptance criteria (DoD).

  • Training track defined per profile (Developer, DevOps, QA, Architecture, etc.) with estimated duration
  • Mandatory courses listed and mapped to SbD-ToE chapters:
    • [O1] General Security Awareness (2h) → Ch. 00 + 02 + 14
    • [O2] SbD-ToE Overview (1h) → Ch. 01–03 (risk, requirements, threat modelling)
    • [O3] Secure Coding & SAST (2h) → Ch. 06 (if developer)
    • [O4] CI/CD Security & Artefacts (1h) → Ch. 07 (if DevOps)
    • [O5] Incident Response Basics (1h) → Ch. 12
    • [O6] Supply Chain & Dependencies (1h) → Ch. 05 (if involved with builds)
  • Assessment quiz per course (minimum score 80%) completed
  • Centralised register updated (LMS or Confluence) with dates, scores, validator
  • Completion SLA communicated to the contractor: Maximum 5 working days before the start date
  • Automatic notification sent if the SLA is at risk (e.g. 2 days before the deadline)
  • "Training complete" sign-off provided to the AppSec Engineer (releases technical access)
  • History kept in line with Policy 33 (duration of the contract + 1 year at L1 and L2; duration of the contract + 3 years at L3)

Artefacts & evidence. Training track defined per profile, LMS enrolment, Quiz completion records, Completion sign-off, SLA compliance checklist, Notifications sent

Proportionality.

L1L2L3
Mandatory (onboarding equivalent to that of employees, completed before access)MandatoryMandatory + 80% score required

Integration into the SDLC.

PhaseTriggerResponsibleSLA
PlanningContractor approved (end of US-06/US-15)AppSec Engineer (completion validation) + Training Manager (track coordination; HR traceability)Training completed before real access; Notification: weekly if at risk, daily if <3 days
ExecutionContractor approved (end of US-06/US-15)AppSec Engineer (completion validation) + Training Manager (track coordination; HR traceability)Training completed before real access; Notification: weekly if at risk, daily if <3 days

Useful links.


US-17 - Secure Offboarding of Contractors and Supplier Termination​

Context. Contractors finish a project or contract without a formal process: access remains active, assets (code, credentials, documents) are not recovered. Risk of post-termination leakage, residual access, breach of confidentiality.

User Story

Story.
As Security Champion + HR / People Operations + DevOps / SRE, I want to execute a formal and automatic secure offboarding process when a contractor finishes or a supplier is terminated, so that access is guaranteed to be fully revoked, assets recovered, confidentiality maintained, and legal compliance ensured.

Acceptance criteria (BDD).

  • Given a contractor whose end date is known (or a supplier terminated with notice)
    When the offboarding date arrives
    Then access is revoked, assets recovered, and completion documented

Acceptance criteria (DoD).

  • Offboarding checklist prepared 2 weeks in advance (DevOps / SRE, HR / People Operations, AppSec Engineer, Tech Lead)
  • Formal notification sent to the contractor/supplier with the exact deactivation date
  • Access to systems revoked (on the same day as the end date; ≤ 2 h for unplanned departures; immediately for security reasons):
    • User accounts deactivated in Git, Jira, CI/CD
    • SSH keys and API tokens removed
    • VPN, cloud IAM access revoked
    • MFA removed
    • Corporate e-mail accounts deactivated (if applicable)
  • Assets recovered:
    • Code/repositories transferred or archived (if the contractor developed them)
    • Documentation delivered and versioned
    • Laptop/hardware returned, wiped, and certified clean
    • Secrets (API keys, passwords) rotated
  • Last backup of the contractor's work performed (e.g. clone of private repos)
  • Formal "offboarding complete" sign-off recorded in GRC with timestamp
  • Legal reminder sent to the contractor: Confidentiality obligations continue after termination (duration, consequences)
  • Offboarding report archived for 5 years (Policy 33)

Artefacts & evidence. Completed offboarding checklist, Confirmation of access deactivation, Backup certificate, Recovered assets (inventory), GRC sign-off, Legal notice, Archived report

Proportionality.

L1L2L3
BasicMandatoryMandatory + audit trail

Integration into the SDLC.

PhaseTriggerResponsibleSLA
OperationKnown end date (scheduled), Immediate termination (unscheduled)DevOps / SRE (technical access) + AppSec Engineer (validation) + HR / People Operations (timeline coordination; checkpoints)Offboarding completed within <24h of the end date; Notification: HR sends notice 2 weeks in advance
ValidationKnown end date (scheduled), Immediate termination (unscheduled)DevOps / SRE (technical access) + AppSec Engineer (validation) + HR / People Operations (timeline coordination; checkpoints)Offboarding completed within <24h of the end date; Notification: HR sends notice 2 weeks in advance

Useful links.


US-18 - Continuous Monitoring of Supplier Compliance (Alerts and Escalation)​

Context. Suppliers are assessed periodically (US-14), but risk between cycles is not detected. CVEs, critical incidents, SLA changes, or breaches are not monitored in real time.

User Story

Story.
As AppSec Engineer + Operations (Ops), I want to continuously monitor the compliance of critical suppliers (incidents, CVEs, SLA, organisational changes) and escalate automatically if gaps emerge, so that residual risk between formal assessment cycles is reduced and critical events are detected in real time.

Acceptance criteria (BDD).

  • Given a critical supplier (L2–L3) with a contract in force
    When an incident, critical CVE, SLA breach, or organisational change is reported
    Then an automatic alert is generated and escalated to AppSec and Procurement

Acceptance criteria (DoD).

  • Integration with the supplier's incident feed (status page, e-mail alerts, API)
  • Continuous monitoring of CVEs in the supplier's technical stack (via SBOM/SCA tool)
  • Automatic alert triggered if:
    • Critical CVE in a supplier dependency not mitigated within 72h (L3) or 7 days (L2)
    • Security incident reported by the supplier
    • SLA not met (e.g. uptime <99.5% for L3, <99% for L2)
    • Change of ownership, location, or subcontracting
  • Automatic escalation with priority:
    • P1 (exploited critical CVE, serious incident): immediate → AppSec Engineer + Procurement Officer + CISO
    • P2 (critical CVE with no known exploitation, significant incident): ≤ 1h → AppSec Engineer + Procurement Officer
    • P3 (high CVE, moderate incident): ≤ 4h → AppSec Engineer
    • Regulatory track (any severity): GRC/Compliance + DPO ≤ 1h after confirmation (Policy 32 §4.1)
  • Automatic trigger of a special out-of-cycle review (US-14) if there is a critical gap
  • Record of alert, escalation, and action documented in GRC (audit trail)
  • Real-time dashboard with the status of critical suppliers and active alerts (visible to the board)

Artefacts & evidence. Incident feed configured, Active CVE monitoring, Alerts documented with timestamps, Escalation records, Dashboard, GRC audit trail

Proportionality.

L1L2L3
NoRecommendedMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
OperationIncident, critical CVE, SLA breach, contractual changeAppSec Engineer (initial setup) + Operations (Ops) (24x7 operation)Triage ≤ 15 min after the alert; escalation by severity (P1 immediate; P2 ≤ 1h); GRC/Compliance + DPO ≤ 1h if there is a regulatory track

Useful links.


US-19 - Quarterly Review of Contractor Access (Least Privilege)​

Context. Contractors gain initial access, but permissions accumulate over time ("access creep"). Without periodic review, the principle of least privilege is violated.

User Story

Story.
As Security Champion + DevOps / SRE + Tech Lead, I want to review the access of active contractors quarterly, validating that they only have the access needed for the project, so that the principle of least privilege is maintained, the risk of excessive access is reduced, and obsolete access is removed.

Acceptance criteria (BDD).

  • Given active contractors with access to systems (repos, CI/CD, databases, cloud)
    When the quarterly review cycle arrives
    Then access is validated with the Tech Lead, and excessive access is removed on the same day

Acceptance criteria (DoD).

  • List of active contractors extracted from systems (Git orgs, Jira, VPN, Cloud IAM, databases)
  • For each contractor:
    • Access listed in detail (repositories, CI/CD pipelines, databases, cloud resources, etc.)
    • Tech Lead validates each access: Needed for the current project? (Yes/No/Modify)
    • If Not needed: access removed on the same day
    • If Modify: new scope configured, old one revoked
    • If Yes: maintained with dated confirmation
  • Review checklist completed and digitally signed by the Tech Lead + Security Champion
  • Notification sent to each contractor informing them of the review outcome
  • If access is removed: clear notification indicating the reason and completion date
  • Record of changes documented in the audit trail (Git logs, IAM change log, etc.)
  • Consolidated report (% of access maintained, % removed) delivered to the AppSec Engineer

Artefacts & evidence. List of contractors and access, Signed checklist, Notifications sent, Git/IAM change logs, Consolidated report, Sign-off

Proportionality.

L1L2L3
Half-yearlyQuarterlyQuarterly

Integration into the SDLC.

PhaseTriggerResponsibleSLA
ValidationSchedule (quarterly), Project change, IncidentSecurity Champion (coordination) + Tech Lead (validation of need) + DevOps / SRE (technical changes)Review started and completed within 1 week

Useful links.


US-20 - Post-Project Feedback and Contractor Rating​

Context. Contractors finish a project without feedback on their security performance. Without assessment data, it is impossible to take an informed decision on re-hire or referral.

User Story

Story.
As Security Champion + Tech Lead, I want to collect structured post-project feedback on contractors covering security understanding, incidents, and recommendations, so that re-hire decisions are informed, the preparation programme is improved, and an assessment database is created.

Acceptance criteria (BDD).

  • Given a contractor whose project is ending
    When offboarding is initiated (US-17)
    Then a feedback form is sent for the Tech Lead + AppSec Engineer to complete

Acceptance criteria (DoD).

  • Feedback form created with structured questions:
    • Security: Understanding of policies (scale 1–5), Best practices applied (Yes/No), Incidents during the project (Yes/No + desc)
    • Performance: Code quality (1–5), Testing (1–5), Documentation (1–5)
    • Compliance: Contractor followed mandatory procedures (Yes/No), Violations (Yes/No + desc)
    • Recommendations: Areas for improvement in training/preparation, Overall security rating (1–5 stars)
    • Decision: Re-hire recommended? (Yes/No/Maybe + justification)
  • Feedback collected from the Tech Lead + AppSec Engineer + Security Champion (consensus)
  • Result recorded in a centralised system (HR, Procurement, GRC) with date and reviewers
  • Rating (positive/neutral/negative) stored as a reference for future hiring
  • If there are multiple contractors from the same supplier: aggregated insights for supplier review (US-14)
  • Consolidated results published in a quarterly report of the contractor programme

Artefacts & evidence. Completed feedback form, Ratings recorded (HR/GRC system), Aggregation per supplier, Quarterly report, History of assessments

Proportionality.

L1L2L3
OptionalRecommendedMandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
OperationOffboarding initiated (US-17)Security Champion (coordination) + Tech Lead + AppSec Engineer (completion)Feedback completed within 3 working days after the end of the contract

Useful links.


US-21 - Contracting AI model providers​

Context. US-14 covers continuous reassessment of suppliers in general. When the supplier is an AI model provider (Anthropic, OpenAI, Google, Mistral, Cohere, HuggingFace, in-house self-hosted providers), clauses arise that traditional contracts did not cover: data retention, training opt-out, processing location (GDPR), audit rights over inference logs, SLA for notification of version changes, declared compliance with AI Act Art. 53/55 when the provider supplies GPAI. This US operationalises those contractual requirements before the provider enters the approved list (cross-link DEP-014).

User Story

Story. As GRC / Compliance + Procurement with support from Legal, I want each contract with an AI model provider to include minimum clauses covering data handling, location, audit rights, change notification and applicable regulatory compliance, so that operational use of the provider is legally and technically sustainable.

Acceptance criteria (BDD).

  • Given that a new AI provider is intended to be adopted for operational use When contractual due diligence begins Then the due diligence (cross-link Policy 33 §3) is extended with the AI-specific criteria: data retention, training opt-out, location (GDPR Art. 44–49), audit rights, notification SLA, AI Act Art. 53/55 when GPAI
  • Given that the contract is finalised When the provider is added to the approved list (DEP-014) Then the contract_ref references the contract in force and records critical clauses
  • Given that the provider changes its data model (e.g. a new training policy) or the model's major version When it is notified according to the contractual SLA Then a review runs (appsec + grc) before the cutover; without adequate notification, a proactive review is triggered

Checklist.

  • Data retention: declared (preference for zero retention for sensitive data); compatible with the classification of the data the system sends
  • Training opt-out: contracted when applicable; declared when "opt-out by default"
  • Processing location: documented; compliant with GDPR Art. 44–49 when there is personal data; clauses for international transfers when applicable
  • Audit rights: contracted access to inference logs or equivalent when required (typical at L3)
  • Prior notification SLA for changes that alter behaviour (major model version, data policy, discontinuation)
  • Availability SLA declared; architectural fallback in case of outage (cross-link Ch. 04 §AI/ML)
  • Declared compliance with AI Act Article 53 (and Article 55, if the model has systemic risk) when the provider supplies GPAI
  • Declared compliance with GDPR Article 28 (processors) when personal data are involved
  • Provider included in the approved list (DEP-014) with risk_classification
  • Critical clauses recorded in the provider's record sheet; review scheduled

🧾 Artefacts & evidence.

  • Contract signed with explicit clauses (referenced in contract_ref of the approved list)
  • Provider record sheet in the governance repository (governance/ai-providers/<provider>.md) with critical clauses
  • Record of notifications received from the provider + actions taken
  • Periodic review documented according to the risk level

⚖️ Proportionality.

LevelMandatory?Adjustments
L1RecommendedMinimum clauses: location + zero retention for sensitive data
L2YesDetailed clauses: retention, opt-out, location, SLA, basic audit rights
L3YesDetailed clauses + operational audit rights + AI Act Article 53 (and Article 55, if the model has systemic risk) when GPAI; Legal review mandatory

Integration into the SDLC.

PhaseTriggerResponsibleSLA
Pre-onboardingAdoption of a new AI providerGRC / Compliance + Procurement + LegalBefore operational use
OperationChange notification by the providerAppSec Engineer + GRC / ComplianceAccording to the contractual SLA; pre-cutover
Periodic reviewCadence by risk levelGRC / ComplianceL1 annual / L2 half-yearly / L3 quarterly
DiscontinuationProvider removed from the listGRC / Compliance + DevOps / SREMigration plan before operational removal

Useful links.


US-22 - Formal approval and periodic audit of organisational policies​

A policy not approved by senior management has no authority; a policy that is not audited loses adherence over time.

Context. The chapter prescribes a set of relevant organisational policies (exception management, secure contracting, organisational traceability, supplier audit, governance KPIs — see intro §Relevant Organisational Policies) and the canonical checklist requires them to be formally approved and audited. US-12 formalises the policy for the governance model, but the rest of the body of policies is left without a user story that operationalises its cycle of approval by senior management and periodic audit. Without this cycle, the policies exist as a document but not as a living control: no one confirms that they remain approved, up to date and complied with.

User Story

Story.
As GRC / Compliance with the support of CISO + Executive Management, I want to keep each organisational policy of the chapter in a formal cycle of approval by senior management and periodic adherence audit, so that the body of policies is guaranteed to have authority, be up to date and be effectively complied with and auditable.

Acceptance criteria (BDD).

  • Given a relevant organisational policy (exceptions, secure contracting, traceability, supplier audit, governance KPIs)
    When it is created or revised
    Then it is submitted for formal approval by senior management, with version, date and approver recorded before it comes into force
  • Given a policy in force
    When the defined audit cycle arrives (at most annual)
    Then practical adherence is audited, deviations are recorded and corrective action is generated with an owner and deadline

Checklist.

  • Inventory of the chapter's relevant organisational policies maintained and versioned, with status (Mandatory/Recommended), owner and date of last approval
  • Each policy has formal senior-management approval recorded (version, date, approver) before it comes into force; review at least annually or after significant organisational change
  • Periodic adherence audit executed per defined cycle, with deviations recorded and corrective actions (owner + deadline) tracked through to closure

Artefacts & evidence. Versioned inventory of policies with status and owner; record of formal approval by senior management (version/date/approver); adherence audit report per cycle; corrective action plan for deviations.

Proportionality L1–L3.

L1L2L3
Mandatory policies approved; informal annual auditFull set approved; formal annual audit with deviations recordedFull set approved; formal audit ≤ annual + review upon organisational change; corrective actions tracked through to closure

Integration into the SDLC.

PhaseTriggerResponsibleSLA
PlanningCreation or revision of a policyGRC / Compliance + CISO + Executive Management (approval)Approval before coming into force
AuditPeriodic cycle (≤ annual) or organisational changeGRC / Compliance + AppSec EngineerAudit completed within the cycle; corrective actions with a defined deadline

Useful links.


📦 Expected artefacts​

ArtefactEvidence
Exception register with approval authoritiesVersioned GRC tool, auditable decisions
Contracts with clausesLegally validated documents
Supplier reportsAudits and findings, technical analysis
Organisational dashboardMetrics per project and application
KPI reportsQuarterly/half-yearly consolidation
Supplier validation formCompleted questionnaire, AppSec analysis, GRC record
Exception table with revalidation scheduleTraceability with expiry dates
Compliance repository per appVersioned YAML/MD file, Auditable history
Owner designation documentCentralised register with validated training
Periodic validation reportsChecklist + Action plan, cycle history
KPI and maturity dashboardMetrics per chapter, Historical trends
SbD-ToE Governance PolicyApproved document, Approval authority levels, Decision template
Centralised compliance checklistVersioned file per app (YAML/MD), Git history
Supplier reassessment scheduleQuarterly/half-yearly/annual planning, Automatic notifications

⚖️ L1–L3 proportionality matrix​

PracticeL1L2L3
Formal exceptions with approval authoritiesMandatory (formal record; approval by the application manager)MandatoryMandatory
Contractual clausesMandatory (minimum clauses)MandatoryMandatory + audits
Continuous supplier validationOptionalMandatory (annual)Mandatory
Organisational traceabilityBasicMandatoryMandatory
Governance KPIsBasicMandatoryMandatory
Formal supplier validation flowMandatory (questionnaire or checklist)MandatoryMandatory
Continuous review of exceptionsBasicMandatoryMandatory
Compliance repository per appBasicMandatoryMandatory
Formal designation of security ownersMandatoryMandatoryMandatory
Periodic compliance validationAnnualHalf-yearlyQuarterly
Maturity KPIs and executive reportingBasicMandatoryMandatory
Formal governance modelMandatory (model approved by senior management)Mandatory (+ approval authorities per level)Mandatory
Centralised checklist per chapterBasicMandatoryMandatory
Post-onboarding supplier reassessmentAnnualAnnual / critical eventHalf-yearly / critical event
Technical preparation of contractorsBasicMandatoryMandatory + validated quiz
Pre-access training trackBasicMandatoryMandatory + 80% score
Secure offboardingBasicMandatoryMandatory + audit trail
Continuous supplier monitoringNoRecommendedMandatory
Quarterly access review (contractors)Half-yearlyQuarterlyQuarterly
Post-project feedbackOptionalRecommendedMandatory

🏁 Final recommendations​

  • Unrecorded exceptions = invisible risk. US-01 (with clear approval authorities) and US-07 should be operationalised to guarantee continuous traceability and automatic revalidation.
  • The formal model is the foundation. US-12 documents governance with explicit criteria, approval authorities per L1–L3, and mandatory training for approvers (Ch. 13).
  • Suppliers must be part of the SbD-ToE model. US-02, US-06, US-14 and US-18 serve contractual integration, initial validation, periodic reassessment, and continuous monitoring.
  • Contractors deserve a dedicated lifecycle. US-15 (technical preparation), US-16 (mandatory training), US-17 (offboarding) and US-19 (access review) ensure that contractors are prepared, maintain least privilege, and leave securely.
  • Clear designation of owners eliminates dispersed responsibility. US-09 guarantees continuity of security decisions with validated training.
  • A centralised compliance repository gives full visibility. US-08 and US-13 consolidate the status of all practices per application, chapter and cycle.
  • Periodic validations detect deviations early. US-10 integrates continuous review into the lifecycle; US-13 validates per chapter; US-14 reassesses suppliers; US-19 validates contractor access.
  • Governance KPIs are the objective measure of maturity. US-05 and US-11 enable evidence-based strategic decisions (% compliance, % exceptions resolved, % suppliers audited).
  • Organisational traceability gives transparency to management. US-04 aggregated with US-08, US-10, US-13, US-14 and US-20 creates visibility of risk at all levels.
  • Continuous preparation and feedback improve contractor quality. US-15, US-16 and US-20 create a continuous improvement cycle and an assessment database for re-hire.
  • This chapter is the "cement" that binds the remaining chapters 2–13: it makes practices visible, auditable, traceable and sustainable over time. Without formal governance (US-12), systematic control (US-13), a contractor lifecycle (US-15–17, 19–20), and continuous reassessment (US-01, US-07, US-14, US-18), SbD-ToE is limited to one-off technical practice.