Requirement
Essential Cybersecurity Controls (ECC – 2 : 2024) - Control - 2-9-4 – The cybersecurity requirements for backup and recovery management must be reviewed periodically.
Understanding the Requirement
This control from Essential Cybersecurity Controls (ECC – 2 : 2024) requires organizations to perform regular, documented reviews of the cybersecurity requirements that govern backup and recovery processes. At its core the control demands a recurring assessment according to an approved review plan and interval (for example, quarterly), coordination between the cybersecurity function and relevant teams such as IT, use of defined review channels or tools, and formal documentation and approval of any requirement changes.
Technical Implementation
- Create a documented Backup & Recovery Requirements Review Plan that defines scope, roles, frequency (e.g., quarterly), acceptance criteria, and escalation paths. Include who will own the review (typically the Cybersecurity lead) and which departments must participate (IT, Applications, Legal/Compliance).
- Conduct periodic assessments using a checklist that maps current backup configurations, retention settings, encryption, access controls, and recovery time/objective targets (RTO/RPO) against the documented requirements. Include technical verification steps such as listing scheduled jobs, checking encryption keys, and verifying permissions on backup storage.
- Use a compliance management system or a structured channel (e.g., scripted email workflow with templates) to run reviews and collect evidence. Attach artifacts such as backup job logs, test restore reports, change requests, and dated review minutes to the record for auditability.
- Run periodic restore tests (at least once per review cycle) on representative datasets to validate recovery procedures and RTO/RPO. Document test scenarios, results, lessons learned, and remediation actions. Treat failed tests as triggers for immediate requirement updates.
- Maintain a change-control process: when laws, regulations, vendor capabilities, or business needs change, update the backup and recovery requirements and route those changes for formal approval by the head of the organization or a delegated deputy. Record approver name, date, and version history.
- Keep a simple living register of backup assets, requirements versions, review dates, and assigned owners. Automate reminders for upcoming reviews and link review artifacts to corresponding backup systems to reduce manual overhead for SMB teams.
Example in a Small or Medium Business
AcmeCo, a 60-person services firm, adopted a quarterly Backup & Recovery Requirements Review Plan owned by the cybersecurity manager. The review checklist covers backup schedules for file servers, database snapshots, cloud storage encryption, access roles to backup repositories, and target RTO/RPO for critical services. The cybersecurity manager runs the review with IT and an applications lead, gathers evidence (backup logs and a recent restore test video), and documents findings in the compliance system. During one quarter the team finds that a third-party SaaS vendor changed its retention policy; they updated the internal requirement to extend the export schedule, recorded the change, and submitted it to the COO for approval. The team also ran a test restore of the customer database, documented the 45-minute recovery time, and adjusted the RTO expectation to match operational reality. All artifacts and the approval record are retained for audits and the next review cycle. This approach keeps backup posture aligned with business needs and regulatory shifts while remaining lightweight enough for an SMB to manage.
Summary
Periodic review of backup and recovery cybersecurity requirements combines simple policy controls—documented review plans, approval gates, and version history—with technical measures—checklists, restore testing, configuration verification, and evidence collection. For SMBs, implementing a regular cadence (for example, quarterly), involving cybersecurity and IT, using a modest compliance tool or structured workflow, and maintaining clear records ensures backup requirements stay current, recoveries are reliable, and changes are approved and auditable.
