sbd.govassure.uk

Statement of Applicability (SoA) Generator

Identify the Secure by Design controls and associated risks that apply to your project, based on the data you handle, the people you serve and the technologies you use.

Project details

Capture the metadata that will appear on the front page of your Statement of Applicability.

Per the Government Security Classifications Policy 2023.

How to use this tool

  1. 1. Enter project details.
  2. 2. Select the data types your service handles.
  3. 3. Identify your stakeholders.
  4. 4. Identify the technologies in scope.
  5. 5. Review the recommended controls, set priority and capture risks.
  6. 6. Export to Word, PDF or CSV.

All data is held in your browser. Nothing is sent to a server.

Data types in scope

Tick every data category your service will create, process, store or share. Each selection drives the list of applicable controls and the legislation that applies.

Stakeholders

Tick every group that will interact with the service or whose data is processed by it.

Technologies and architecture

Tick every technology component or pattern that is part of the design.

Applicable controls and risk register

Each control below has been identified as applicable to your selected data, stakeholders and technologies. Open a control to see its mapping to Secure by Design, NCSC CAF v4.0 and the NIST SP 800-53, and capture inherent and residual risk.

873Controls in this view
56Included
817Excluded
13Critical priority
0Risks assessed
0Evidence recorded
12Laws / standards in scope
Tier 1 - Foundationalcomputed from your scope
56 of 78 relevant baseline controls included

Lower-sensitivity service. The baseline is limited to controls required of every service regardless of context.

T1 56›T2 75›T3 77›T4 78
How this tier was reached
DriverHighest-rated selectionWeight
Nothing selected yet - the baseline is at its minimum.
Peak 0 + breadth 0 + classification 0score 0

Scoring uses the highest-sensitivity selection in each dimension rather than a total, so one category of highly sensitive data raises the tier regardless of how much routine data sits beside it. Breadth adds 1 for each dimension scoring 4 or more.

Professional judgement beats the formula. An override is recorded in the Statement of Applicability.
The "Applicable" view filters the full control library by your data, stakeholder and technology selections. Switch to "All" to browse the complete framework, or to "Baseline" for the curated minimum.
Show

11 controls match

By default the recommended baseline is included and all other controls are excluded. Use these actions to bulk-include or reset.
LOCAL-AU-02 · Audit and AccountabilityBASELINETier 1+

Event Logging

SbD-5 Build in detect and respond securitySbD-9 Embed continuous assuranceCAF C1.aCAF mapping: strongNIST AU-2NIST CSF: Detect

Decide deliberately what to log, driven by what you would need to answer during an investigation. Logging is the evidence base every other assurance claim rests on, which is why it sits at tier 1.

Assessment objective (6 determination statements)
  • [event types] that the system is capable of logging are identified in support of the audit logging function
  • The event logging function is coordinated with other organisational entities requiring audit-related information to guide and inform the selection criteria for events to be logged
  • [event types (subset of AU-02_ODP[01])] are specified for logging within the system
  • The specified event types are logged within the system [frequency or situation]
  • A rationale is provided for why the event types selected for logging are deemed to be adequate to support after-the-fact investigations of incidents
  • The event types selected for logging are reviewed and updated [frequency]
Secure by Design
SbD-5 – Build in detect and respond security; SbD-9 – Embed continuous assurance
NCSC CAF v4.0
C1.a Sources and Tools for Logging and Monitoring
Mapping confidence
Strong
CAF outcomes
C1.a
NIST reference
AU-2 – Audit and Accountability
NIST baseline
LOW
Significance weighting
10
NIST CSF function
Detect
Legislation / policy
NCSC Cyber Assessment Framework v4.0; UK GDPR
Example threats
An incident cannot be reconstructed because the relevant events were never logged; Access to personal data is not logged, so misuse is undetectable
MITRE techniques
T1685.005 Disable or Modify Tools: Clear Windows Event Logs; T1530 Data from Cloud Storage

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location
LOCAL-CA-02 · Assessment, Authorization, and MonitoringBASELINETier 1+

Control Assessments

SbD-9 Embed continuous assuranceCAF A2.cCAF mapping: strongNIST CA-2NIST CSF: Identify

Independent assessment of whether the controls actually work, distinct from the team's own view. CAF v4.0 moved assurance to A2.c specifically to stop it being answered with 'we have a policy'.

Assessment objective (9 determination statements)
  • An appropriate assessor or assessment team is selected for the type of assessment to be conducted
  • A control assessment plan is developed that describes the scope of the assessment, including controls and control enhancements under assessment
  • A control assessment plan is developed that describes the scope of the assessment, including assessment procedures to be used to determine control effectiveness
  • A control assessment plan is developed that describes the scope of the assessment, including the assessment environment
  • A control assessment plan is developed that describes the scope of the assessment, including the assessment team
  • A control assessment plan is developed that describes the scope of the assessment, including assessment roles and responsibilities
  • The control assessment plan is reviewed and approved by the authorising official or designated representative prior to conducting the assessment
  • Controls are assessed in the system and its environment of operation [assessment frequency] to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting established security requirements
  • …and 3 further determination statements in SP 800-53A.
Secure by Design
SbD-9 – Embed continuous assurance
NCSC CAF v4.0
A2.c Assurance
Mapping confidence
Strong
CAF outcomes
A2.c
NIST reference
CA-2 – Assessment, Authorization, and Monitoring
NIST baseline
LOW
Significance weighting
10
NIST CSF function
Identify
Legislation / policy
NCSC Cyber Assessment Framework v4.0; GDS Service Standard
Example threats
Assurance is self-asserted by the team that built the service

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location
LOCAL-CA-05 · Assessment, Authorization, and MonitoringBASELINETier 1+

Plan of Action and Milestones

SbD-9 Embed continuous assuranceSbD-10 Make changes securelyCAF A2.cCAF mapping: strongNIST CA-5NIST CSF: Identify

A plan of action with milestones for every weakness not yet fixed, so that known gaps are managed rather than forgotten.

Assessment objective (2 determination statements)
  • A plan of action and milestones for the system is developed to document the planned remediation actions of the organisation to correct weaknesses or deficiencies noted during the assessment of the controls and to reduce or eliminate known vulnerabilities in the system
  • Existing plan of action and milestones are updated [frequency] based on the findings from control assessments, independent audits or reviews, and continuous monitoring activities
Secure by Design
SbD-9 – Embed continuous assurance; SbD-10 – Make changes securely
NCSC CAF v4.0
A2.c Assurance
Mapping confidence
Strong
CAF outcomes
A2.c
NIST reference
CA-5 – Assessment, Authorization, and Monitoring
NIST baseline
LOW
Significance weighting
10
NIST CSF function
Identify
Legislation / policy
NCSC Cyber Assessment Framework v4.0
Example threats
Accepted weaknesses have no expiry and quietly become permanent

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location
LOCAL-CA-07 · Assessment, Authorization, and MonitoringBASELINETier 1+

Continuous Monitoring

SbD-9 Embed continuous assuranceCAF A2.cCAF C1.aCAF mapping: strongNIST CA-7NIST CSF: Detect

Continuous monitoring of control effectiveness, so the risk owner has current evidence rather than an annual snapshot. This is the control that turns a Statement of Applicability from a statement of intent into an assurance argument.

Assessment objective (9 determination statements)
  • A system-level continuous monitoring strategy is developed
  • System-level continuous monitoring is implemented in accordance with the organisation-level continuous monitoring strategy
  • System-level continuous monitoring includes establishment of the following system-level metrics to be monitored: [system-level metrics]
  • System-level continuous monitoring includes established [frequencies] for monitoring
  • System-level continuous monitoring includes established [frequencies] for assessment of control effectiveness
  • System-level continuous monitoring includes ongoing control assessments in accordance with the continuous monitoring strategy
  • System-level continuous monitoring includes ongoing monitoring of system and organisation-defined metrics in accordance with the continuous monitoring strategy
  • System-level continuous monitoring includes correlation and analysis of information generated by control assessments and monitoring
  • …and 3 further determination statements in SP 800-53A.
Secure by Design
SbD-9 – Embed continuous assurance
NCSC CAF v4.0
A2.c Assurance; C1.a Sources and Tools for Logging and Monitoring
Mapping confidence
Strong
CAF outcomes
A2.c, C1.a
NIST reference
CA-7 – Assessment, Authorization, and Monitoring
NIST baseline
LOW
Significance weighting
10
NIST CSF function
Detect
Legislation / policy
NCSC Cyber Assessment Framework v4.0
Example threats
Controls degrade silently between annual assessments
MITRE techniques
T1078 Valid Accounts

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location
LOCAL-CA-08 · Assessment, Authorization, and MonitoringBASELINETier 3+

Penetration Testing

SbD-9 Embed continuous assuranceCAF A2.cCAF B4.dCAF mapping: strongNIST CA-8NIST CSF: Identify

Independent penetration testing before live and after significant change, with findings tracked to closure. An IT health check report with open highs is not evidence of assurance.

Assessment objective
  • Penetration testing is conducted [frequency] on [system(s) or system components]
Secure by Design
SbD-9 – Embed continuous assurance
NCSC CAF v4.0
A2.c Assurance; B4.d Vulnerability Management
Mapping confidence
Strong
CAF outcomes
A2.c, B4.d
NIST reference
CA-8 – Assessment, Authorization, and Monitoring
NIST baseline
HIGH
Significance weighting
6
NIST CSF function
Identify
Legislation / policy
NCSC Cyber Assessment Framework v4.0; GDS Service Standard
Example threats
Testing is scoped to exclude the components most likely to be vulnerable; Report is filed without a remediation plan
MITRE techniques
T1190 Exploit Public-Facing Application; T1213 Data from Information Repositories

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location
LOCAL-CP-04 · Contingency PlanningBASELINETier 1+

Contingency Plan Testing

SbD-6 Design flexible architecturesSbD-9 Embed continuous assuranceCAF B5.aCAF D1.cCAF mapping: strongNIST CP-4NIST CSF: Recover

Exercise the contingency plan on a schedule, and record what the exercise changed.

Assessment objective (5 determination statements)
  • The contingency plan for the system is tested [frequency]
  • [tests] are used to determine the effectiveness of the plan
  • [tests] are used to determine the readiness to execute the plan
  • The contingency plan test results are reviewed
  • Corrective actions are initiated, if needed
Secure by Design
SbD-6 – Design flexible architectures; SbD-9 – Embed continuous assurance
NCSC CAF v4.0
B5.a Resilience Preparation; D1.c Testing and Exercising
Mapping confidence
Strong
CAF outcomes
B5.a, D1.c
NIST reference
CP-4 – Contingency Planning
NIST baseline
LOW
Significance weighting
10
NIST CSF function
Recover
Legislation / policy
NCSC Cyber Assessment Framework v4.0
Example threats
Testing confirms the plan is followed rather than whether it works

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location
LOCAL-IR-03 · Incident ResponseBASELINETier 2+

Incident Response Testing

SbD-5 Build in detect and respond securitySbD-9 Embed continuous assuranceCAF D1.cCAF mapping: strongNIST IR-3NIST CSF: Respond

Test the response plan through exercises, including scenarios where the primary responders are unavailable.

Assessment objective
  • The effectiveness of the incident response capability for the system is tested [frequency] using [tests]
Secure by Design
SbD-5 – Build in detect and respond security; SbD-9 – Embed continuous assurance
NCSC CAF v4.0
D1.c Testing and Exercising
Mapping confidence
Strong
CAF outcomes
D1.c
NIST reference
IR-3 – Incident Response
NIST baseline
MODERATE
Significance weighting
8
NIST CSF function
Respond
Legislation / policy
NCSC Cyber Assessment Framework v4.0
Example threats
Plan has never been rehearsed and fails on first contact

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location
LOCAL-RA-05 · Risk AssessmentBASELINETier 1+

Vulnerability Monitoring and Scanning

SbD-9 Embed continuous assuranceSbD-5 Build in detect and respond securityCAF B4.dCAF C2.aCAF mapping: strongNIST RA-5NIST CSF: Detect

Regular vulnerability scanning with a defined remediation clock by severity. The clock matters more than the scan: an unactioned finding is not a control.

Assessment objective (9 determination statements)
  • Systems and hosted applications are monitored for vulnerabilities [frequency and/or randomly in accordance with…] and when new vulnerabilities potentially affecting the system are identified and reported
  • Systems and hosted applications are scanned for vulnerabilities [frequency and/or randomly in accordance with…] and when new vulnerabilities potentially affecting the system are identified and reported
  • Vulnerability monitoring tools and techniques are employed to automate parts of the vulnerability management process by using standards for enumerating platforms, software flaws, and improper configurations
  • Vulnerability monitoring tools and techniques are employed to facilitate interoperability among tools and to automate parts of the vulnerability management process by using standards for formatting checklists and test procedures
  • Vulnerability monitoring tools and techniques are employed to facilitate interoperability among tools and to automate parts of the vulnerability management process by using standards for measuring vulnerability impact
  • Vulnerability scan reports and results from vulnerability monitoring are analysed
  • Legitimate vulnerabilities are remediated [response times] in accordance with an organisational assessment of risk
  • Information obtained from the vulnerability monitoring process and control assessments is shared with [personnel or roles] to help eliminate similar vulnerabilities in other systems
  • …and 1 further determination statements in SP 800-53A.
Secure by Design
SbD-9 – Embed continuous assurance; SbD-5 – Build in detect and respond security
NCSC CAF v4.0
B4.d Vulnerability Management; C2.a Threat Hunting
Mapping confidence
Strong
CAF outcomes
B4.d, C2.a
NIST reference
RA-5 – Risk Assessment
NIST baseline
LOW
Significance weighting
10
NIST CSF function
Detect
Legislation / policy
NCSC Cyber Assessment Framework v4.0; UK GDPR
Example threats
Findings accumulate in a backlog with no owner and no deadline; Scanning covers infrastructure but not application dependencies
MITRE techniques
T1595 Active Scanning; T1190 Exploit Public-Facing Application

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location
LOCAL-SA-11 · System and Services AcquisitionBASELINETier 2+

Developer Testing and Evaluation

SbD-9 Embed continuous assuranceSbD-10 Make changes securelyCAF A4.bCAF B4.dCAF mapping: strongNIST SA-11NIST CSF: Identify

Security testing within development, automated in the pipeline so that it runs on every change rather than at a milestone.

Assessment objective (9 determination statements)
  • The developer of the system, system component, or system service is required at all post-design stages of the system development life cycle to develop a plan for ongoing security assessments
  • The developer of the system, system component, or system service is required at all post-design stages of the system development life cycle to implement a plan for ongoing security assessments
  • The developer of the system, system component, or system service is required at all post-design stages of the system development life cycle to develop a plan for privacy assessments
  • The developer of the system, system component, or system service is required at all post-design stages of the system development life cycle to implement a plan for ongoing privacy assessments
  • The developer of the system, system component, or system service is required at all post-design stages of the system development life cycle to perform [unit, integration, system or regression] testing/evaluation [frequency to conduct] at [depth and coverage]
  • The developer of the system, system component, or system service is required at all post-design stages of the system development life cycle to produce evidence of the execution of the assessment plan
  • The developer of the system, system component, or system service is required at all post-design stages of the system development life cycle to produce the results of the testing and evaluation
  • The developer of the system, system component, or system service is required at all post-design stages of the system development life cycle to implement a verifiable flaw remediation process
  • …and 1 further determination statements in SP 800-53A.
Secure by Design
SbD-9 – Embed continuous assurance; SbD-10 – Make changes securely
NCSC CAF v4.0
A4.b Secure Software Development and Support; B4.d Vulnerability Management
Mapping confidence
Strong
CAF outcomes
A4.b, B4.d
NIST reference
SA-11 – System and Services Acquisition
NIST baseline
MODERATE
Significance weighting
8
NIST CSF function
Identify
Legislation / policy
NCSC Cyber Assessment Framework v4.0
Example threats
Testing is a pre-release activity, so defects are found when they are most expensive
MITRE techniques
T1190 Exploit Public-Facing Application; T1059.007 Command and Scripting Interpreter: JavaScript

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location
LOCAL-SI-02 · System and Information IntegrityBASELINETier 1+

Flaw Remediation

SbD-10 Make changes securelySbD-9 Embed continuous assuranceCAF B4.dCAF mapping: strongNIST SI-2NIST CSF: Protect

Remediate flaws on a defined clock, with an emergency path for actively exploited vulnerabilities.

Assessment objective (9 determination statements)
  • System flaws are identified
  • System flaws are reported
  • System flaws are corrected
  • Software updates related to flaw remediation are tested for effectiveness before installation
  • Software updates related to flaw remediation are tested for potential side effects before installation
  • Firmware updates related to flaw remediation are tested for effectiveness before installation
  • Firmware updates related to flaw remediation are tested for potential side effects before installation
  • Security-relevant software updates are installed within [time period] of the release of the updates
  • …and 2 further determination statements in SP 800-53A.
Secure by Design
SbD-10 – Make changes securely; SbD-9 – Embed continuous assurance
NCSC CAF v4.0
B4.d Vulnerability Management
Mapping confidence
Strong
CAF outcomes
B4.d
NIST reference
SI-2 – System and Information Integrity
NIST baseline
LOW
Significance weighting
10
NIST CSF function
Protect
Legislation / policy
NCSC Cyber Assessment Framework v4.0; UK GDPR
Example threats
A known exploited vulnerability waits for the next monthly release window
MITRE techniques
T1190 Exploit Public-Facing Application; T1210 Exploitation of Remote Services

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location
LOCAL-SR-04 · Supply Chain Risk ManagementBASELINETier 2+

Provenance

SbD-2 Source secure technology productsSbD-9 Embed continuous assuranceCAF A4.aCAF A4.bCAF mapping: strongNIST SR-4NIST CSF: Identify

Provenance for the components in the service, in practice a software bill of materials kept current. Without one, responding to a newly disclosed dependency vulnerability starts with days of discovery.

Assessment objective (3 determination statements)
  • Valid provenance is documented for [systems, system components, and associated d…]
  • Valid provenance is monitored for [systems, system components, and associated d…]
  • Valid provenance is maintained for [systems, system components, and associated d…]
Secure by Design
SbD-2 – Source secure technology products; SbD-9 – Embed continuous assurance
NCSC CAF v4.0
A4.a Supply Chain; A4.b Secure Software Development and Support
Mapping confidence
Strong
CAF outcomes
A4.a, A4.b
NIST reference
SR-4 – Supply Chain Risk Management
Significance weighting
3
NIST CSF function
Identify
Legislation / policy
NCSC Cyber Assessment Framework v4.0
Example threats
A critical dependency vulnerability is disclosed and no-one can say whether it is in use
MITRE techniques
T1195.001 Supply Chain Compromise: Compromise Software Dependencies and Development Tools; T1588.006 Obtain Capabilities: Vulnerabilities

Risk assessment

Example risk scenarios — select one to use as your starting pointMITRE ATT&CK v19.1

Each scenario states the asset at stake, the threat event, the vulnerability it exploits and the direct consequence. Adapt the wording to this service before relying on it.

Assurance and evidence

How a risk owner would know this control is working. Required to demonstrate Secure by Design principle 9.

The team or role that operates it, not the risk owner
How anyone would confirm it works
What the check produces
Where an assessor would find it - a repository path, Confluence page, ticket reference or shared drive location

Review and export

Statement of Applicability ready

Generate your document below.
Controls how much detail appears in the on-screen preview, Word export and printed PDF. The CSV register always contains every control regardless of this setting.

Export options

Generate a printable Statement of Applicability or a data file that can be imported into a project risk register.


Document preview

Configuration map

A traceability matrix of how scope becomes controls. Read across a row to see what a selection brings in; read down a column to see what put a control there. Generated live from the same gate, tier and weighting tables the tool uses to set defaults.

Scope selection → control

 
Cell: selection opens this gate universal, no gate Control: included held by tier out of scope Weight: 5 4 3 2 1

Secure by Design

What this tool maps to, what it does not cover, and where it fits in Secure by Design delivery.

Secure by Design is mandatory for government departments and arm’s length bodies. This tool produces one of the artefacts it asks for — an agreed, justified control set. It is not, on its own, evidence of Secure by Design compliance.