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GOV-019 Information Security in Project Management

Tier 2+ProviderDeployerGPAI Model ProviderManaged Service Provider

Description

Information security requirements are recorded in the project artefacts of every project that creates or materially changes a system, a service or a process, whatever the delivery method. A security review record exists at each project gate the delivery process defines. The go-live record for each project shows every security finding either resolved or accepted as a risk by a named approver holding the authority to accept it, dated before deployment.

Rationale

Security designed in at the point requirements are written costs a fraction of security retrofitted after go-live. The go-live gate is the last point at which a finding can still change the design. This control reaches every project, including the procurements, migrations and process changes that never touch the software pipeline; the in-pipeline controls for code are APP-002 and APP-003. The privacy gate is DAT-012.

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
NIS2 Cloud Provider (EU)stablerequiredcore

Framework Mappings (3)

5.8Information security in project managementfull
PL-2System Security and Privacy Planspartial
CC5.1COSO Principle 10: Selects and Develops Control Activitiespartial

Evidence (2)

policydocumentmanual

Information security in project management procedure defining mandatory security gates, review points, and sign-off requirements throughout the project lifecycle.

Example: Secure SDLC or Project Security Requirements Procedure (Confluence), listing: project types in scope, required security activities per phase (e.g. security requirements at design, threat modelling before build, security review before go-live), and the named role responsible for sign-off.

Test: Request the project security procedure. Verify: (1) security activities are defined for each project phase, (2) a mandatory pre-launch security review or sign-off is required, (3) the procedure specifies how findings must be resolved before deployment, (4) the document has an approval date within the last 12 months.

recorddocumentmanual

Pre-launch security review records for recent projects confirming security gates were completed before go-live.

Example: Jira tickets or Confluence sign-off pages for the last two to three project launches, showing: security review checklist completion, named reviewer, findings list, disposition of each finding, and go-live approval.

Test: Select two recent project launches. Request the security review records for each. Verify: (1) a security review was conducted prior to go-live, (2) all findings are documented with severity ratings, (3) each finding is either resolved or has a documented risk-acceptance from a named approver, (4) a named security reviewer signed off the deployment.

Questions (2)

boolean

Does your organisation have a documented process for integrating information security requirements throughout the project lifecycle, including mandatory security reviews before go-live?

The process should define required security activities per project phase and require that findings are resolved or risk-accepted before deployment.

multi

At which stages of a project are security activities formally required?

Security requirements defined at project initiation / designThreat modelling conducted before build beginsSecurity review or penetration test before go-liveRisk acceptance from a named approver required before deploymentPost-launch security retrospective or reviewNone of the above

Pre-launch security sign-off is the minimum. Look for completed review checklists with a named security reviewer and documented disposition of findings.