BSI C5:2020·Criterion BCM-02·high·Component: Business Continuity Management

What this control requires

Documents impact analysis policies per SP-01, identifying critical services, threats, and RTO/RPO targets based on risk analysis. Ensures planning for disruptions, protecting cloud customer data availability and service continuity effectively.
— BSI C5:2020, Criterion BCM-02

In plain English

Documents impact analysis policies per SP-01, identifying critical services, threats, and RTO/RPO targets based on risk analysis. In practice, this means you can prove you risk cloud customer data-level controls on a defined cadence.

Why it matters

BSI C5 is the default cloud-security baseline German public-sector buyers and many DAX-listed enterprises expect; gaps here directly block procurement in the DACH region and frequently appear as must-have items in EU public-tender documents.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A C5 attesting auditor (under ISAE 3000 / IDW PS 860) tests both the design and — for a Type 2 — the operating effectiveness over the attestation period. For each criterion they look for both the Basic and any in-scope Additional objectives.

Within Business Continuity Management, the assessor will trace your implementation back to the catalogue reference (Criterion BCM-02) and look for objective evidence on the latest two assessment cycles.

How to implement

Business Continuity

BC/DR. Define RTO/RPO per service, test backup restoration quarterly, and run a tabletop of full-region failover annually.

Backups. Immutable backups (S3 Object Lock / Azure immutable storage / GCS bucket lock) plus an air-gapped copy for ransomware resilience.

Cloud Posture

CSPM. Run Wiz / Prisma / Defender for Cloud / Security Command Center over every account; auto-ticket findings above your accepted-risk threshold.

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

  • Risk. Document the trigger, the owner and the cadence.
  • Data. Document the trigger, the owner and the cadence.
  • Policy. Document the trigger, the owner and the cadence.
  • Business. Document the trigger, the owner and the cadence.
  • Scope: cloud customer data, business continuity, management.

Evidence to collect

  • Policy Document. A signed and version-controlled policy / standard / procedure document.
  • Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Signed policy or standard documents the safeguard. Focus: Business impact analysis policies and instructions.

Common pitfalls

  • DR plans that have never been tested in earnest, or that depend on an MFA token only one person can produce.
  • Treating CSPM findings as a backlog instead of a hot queue: findings older than the policy SLA accumulate until the auditor asks why.
  • Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

Related controls in BSI C5:2020

References

Topics: governance riskbusiness continuitycloud posturepolicy management