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BCM-004 Backup Policy and Implementation

Tier 1+ProviderDeployerGPAI Model ProviderManaged Service Provider

Description

Data and system backups are performed at a frequency that satisfies the defined RPO. Backups include application data, system state, and configuration. Backup copies are stored off-site or in a geographically separate cloud region. Backup data is encrypted at rest. Access to backups is restricted to authorised personnel.

Rationale

Backups are the technical mechanism that makes RPO commitments achievable. Encryption and off-site storage protect backup integrity and ensure usability after a primary-site failure.

Applicability (9 profiles)

SaaS AI Providerstablerequiredcore
Enterprise AI Deployerstablerequiredcore
GPAI Model Providerstablerequiredcore
High-Risk Provider (EU)stablerequiredcore
Public Body Deployer (EU)stablerequiredcore
DORA ICT Provider (EU)stablerequiredcore
HIPAA Business Associate (US)stablerequiredrole duty

164.308(a)(7)(ii)(A) makes retrievable exact copies a required specification, and 164.310(d)(2)(iv) adds the pre-movement copy, which continuous backup at the defined RPO satisfies.

NIS2 Cloud Provider (EU)stablerequiredcore

Framework Mappings (12)

BCR-08Backupfull
HIPAA-164.308.a.7.ii.AData Backup Planfull
HIPAA-164.310.d.2.ivData Backup and Storagefull
8.13Information backupfull
NIS2-Art.21.2.cBusiness Continuity and Crisis Managementinformative
NIS2-CIR-4.2Backup and Redundancy Managementpartial
CP-6Alternate Storage Sitefull
CP-9System Backupfull
CP-9(8)System Backup | Cryptographic Protectionfull
GV-6.2-005Third-Party Failure Contingency Processes | GV-6.2-005full
A1.2Environmental Protections, Software, Data Back-Up Processes, and Recovery Infrastructurepartial

Evidence (2)

configurationtechnicalautomated

Backup system configuration showing backup frequency, scope, encryption at rest, off-site or cross-region storage, and access restrictions for production data and systems.

Example: AWS Backup plan configuration export or Veeam/equivalent backup policy screenshot showing backup frequency, retention settings, encryption (KMS key or equivalent), storage location (cross-region bucket or off-site), and IAM access policy for backup storage

Test: Review the backup system configuration. Verify: (1) backup frequency meets or exceeds the RPO for each covered service; (2) backup scope includes application data, system state, and configuration; (3) backups are stored in a geographically separate region or off-site location; (4) backup data is encrypted at rest using an approved key; (5) access to backup storage is restricted to named authorised roles.

logtechnicalautomated

Backup job completion logs showing successful backup execution at the defined frequency for all critical systems.

Example: AWS Backup job history export, or equivalent backup tool job log, for the past 30 days, showing job name, target resource, start time, completion status, and size

Test: Review backup job logs for the last 30 days. Verify: (1) backup jobs ran at or above the defined frequency for all critical systems; (2) all jobs completed with a success status; (3) any failed backup jobs have a corresponding incident or remediation record; (4) no critical system has a gap in backup coverage exceeding the RPO window.

Questions (2)

boolean

Are data and system backups performed at a frequency that satisfies the defined recovery point objective?

Backups should cover application data, system state, and configuration. Encryption using a managed KMS key and IAM-restricted access to backup storage are expected.

multi

Which of the following characteristics apply to your production backup implementation?

Backups run at a frequency meeting or exceeding the defined RPOBackups stored in a geographically separate region or off-site locationBackup data encrypted at rest using an approved keyAccess to backup storage restricted to a named authorised roleBackup scope includes application data, system state, and infrastructure configurationAutomated backup job monitoring with alerts on failureNone of the above

All six characteristics are expected for a production backup implementation that satisfies RPO commitments and audit requirements.