Skip to main content

Periodic Review Checklist - Governance and Contracting

This checklist applies to projects, applications or contracts with a technical impact and aims to validate the practical application of the practices prescribed in Chapter 14 - Governance and Contracting (GOV-001 to GOV-012).

📌 It must be used in formal reviews, internal audits, project milestones or technical revalidation cycles.


📋 Verification Items​

ItemVerified?
Is there a formal security governance model approved by management and reviewed within ≤12 months? (GOV-001)☐
Does the application or project have a formally designated and registered security owner? (GOV-002)☐
Is the criticality level (L1–L3) documented and justified?☐
Are the approval authorities per risk level documented and known to the decision-makers, with traceable escalation? (GOV-003)☐
Are the risk-proportional minimum requirements identified and applied?☐
Is there a formal exception management process, recording each exception with owner, compensating measure, referenceable evidence, expiry date (TTL of Policy 05 §7) and a revalidation alert 15 days before (or at the midpoint of the TTL, if shorter than 30 days)? (GOV-004/GOV-005)☐
Do contracts with third parties include risk-proportional security clauses? (GOV-006)☐
Have suppliers with technical access been validated (questionnaire/checklist; L3: SBOM, incident SLA, right to audit) before onboarding? (GOV-007)☐
Is there organisational traceability per application linking risk → requirements → exceptions → suppliers → owner? (GOV-008)☐
Is the chain of authority of each risk decision (who requested, assessed, approved) verifiable, with referenceable and retained evidence? (GOV-009)☐
Is there a periodic compliance review cycle by asset type (L3 quarterly, L2 half-yearly, L1 annual; suppliers annual, half-yearly at L3), with corrective actions (owner and deadline)? (GOV-010)☐
Are there governance KPIs defined, collected and reported to management, with thresholds that trigger corrective action? (GOV-011)☐
Is there an active maturity assessment (SAMM/DSOMM or equivalent) within ≤12 months, with an evolution plan (L3)? (GOV-012)☐
Is the application included in the control matrix of SbD-ToE practices, and are the relevant organisational policies formally approved and audited?☐
Do contracts with AI model providers include data retention, training opt-out, GDPR localisation (Art. 44–49), audit rights, a change-notification SLA and compliance with AI Act Article 53 (and Article 55, if the model has systemic risk) when GPAI, with the provider on the approved list (DEP-014)?☐
Is there a formal secure offboarding process (access revocation, asset recovery, secret rotation), and do the decision-makers have valid SbD training within the last 12 months (Ch. 13)?☐
Do third parties complete technical onboarding and mandatory training (by profile, with quiz and sandbox) with a recorded sign-off before access to systems, with the record traceable and retained as required by regulation (GOV-013)?☐
Is the access of active contractors reviewed periodically (half-yearly L1 / quarterly L2–L3) with validation of need, same-day removal of excessive access, a signed review and changes in the audit trail (GOV-014)?☐

🔄 Operational Integration​

  • It may be used as a recurring review template in Jira, Confluence, SharePoint or Forms;
  • It must have joint validation by AppSec, GRC and product management;
  • Each item requires traceable and versioned evidence, in accordance with the practices of Ch. 14.

🎯 Compliance and Indicators​

  • Positive validation of this checklist makes it possible to declare compliance with Chapter 14 - Governance and Contracting.
  • The results may be integrated into dashboards, audit cycles and maturity metrics.
  • It makes it possible to derive objective KPIs such as:
    • % of applications with formally approved exceptions;
    • % of validated suppliers;
    • % of contracts with security clauses;
    • % of projects with an up-to-date SbD-ToE control matrix.

🔗 Cross-links​

  • Ch. 01 - Risk classification (basis for proportional application)
  • Ch. 02 - Security requirements (target of exceptions, traceability)
  • Ch. 05 - Dependencies and SBOM (contractual clauses and validations)
  • Ch. 10 - Security testing (practical validation of controls)
  • Ch. 13 - Training (mandatory validation of critical functions)
  • Ch. 14 addon/11-controlos-praticas-sbd - Consolidated control of SbD-ToE practices

✅ This checklist is a central mechanism for the continuous, proportional and traceable control of the adoption of the SbD-ToE model in real governance and contracting contexts.