DRAFT: Remove critical system tier requirement to scope GCF control requirements

Why is this change being made?

The scope for system audits on the Security Compliance audit schedule has historically been based on the critical system tier of the system. The critical system tier had a baseline set of identified controls that are then tested for each system. However, not all systems require the same subset of controls to be tested each quarter. Systems that have existed on the audit schedule through at a minimum of two quarters often have controls that are not applicable to that system yet are required to be "tested" as part of the tiering structure.

This change would remove the system tiering requirement and subsequent required set of GCF controls.

The following adjustments would be made:

1. If the system is net new (ie. new to GitLab, has never been tested on the Security Compliance audit schedule) and high risk: The critical system tier would be reviewed and a baseline set of controls for that tier would be evaluated
2. If the system has had previous testing performed within that fiscal year and high risk: The set of GCF controls tested would be limited to high risk controls and/or controls that had findings (observations) identified
   • controls that were determined to be not applicable, or low risk would move to an annual cadence
3. If the system is net new (ie. new to GitLab, has never been tested on the Security Compliance audit schedule) and low risk: The critical system tier would be reviewed and a baseline set of controls for that tier would be evaluated by the system/business owner through a self assessment (process to be determined)
4. If the system has had previous testing performed within that fiscal year and low risk: The GCF controls tested would be based on critical system tier and reviewed on a 2 year cadence

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