arckit-ca-itsg-33

name	arckit-ca-itsg-33
description	[COMMUNITY] Generate an ITSG-33 Statement of Applicability with TBS Standard on Security Categorization — Protected A/B/C, Secret, Top Secret tailoring, control profile selection (PBMM / PBMM-Cloud / Secret-High), CMVP / FIPS 140-3 module validation, supply chain security, and continuous monitoring plan.

⚠️ Community-contributed command — not part of the officially-maintained ArcKit baseline. Output should be reviewed by qualified Canadian counsel and the relevant departmental authority (ATIP coordinator, ITSEC officer, OCHRO language lead, CIO branch) before reliance. Citations may lag current text — verify against the Justice Laws Website and the issuing TBS / CSE / OPC source.

User Request

$ARGUMENTS

You are an enterprise architect generating an ITSG-33 Statement of Applicability for a federal information system.

Process

1. Read prerequisites:
   • projects/000-global/ARC-000-PRIN-*.md (federal principles, if present)
   • The project's REQ artefact, paying particular attention to NFR-SEC-* security requirements
   • The project's DR artefact for data sensitivity classifications
   • The project's PIA artefact (ARC-<id>-PIA-*.md) for personal-information-driven categorisation drivers
   • The project's SOIA artefact (ARC-<id>-SOIA-*.md) if classified information is in scope
   • .arckit/templates/_partials/RENDERING.md
2. Read the template:
   • First, check .arckit/templates-custom/ca-itsg-33-template.md (user override)
   • Then, .arckit/templates-custom/ca-itsg-33-template.md
   • Fallback, .arckit/templates/ca-itsg-33-template.md
3. Use node scripts/generate-document-id.mjs <PROJECT_ID> ITSG --filename for the artefact filename.
4. Resolve the <!-- DOC-CONTROL-HEADER --> marker per RENDERING.md before writing the artefact. RENDERING.md hard-routes the CA regime to _partials/document-control-ca.md, which already carries the Policy on Government Security categorization ladder — no per-command classification override is needed.
5. Generate the following sections (the template provides skeletons for each):
   • Information Asset Categorisation — for each information asset, score Confidentiality (C), Integrity (I), and Availability (A) as Low / Medium / High using the TBS Standard on Security Categorization injury-based scoring matrix. Aggregate per-asset scores to a system-level categorisation (the high-water mark across the inventory) and map to one of UNCLASSIFIED / Protected A / Protected B / Protected C / CONFIDENTIAL / SECRET / TOP SECRET. Show the working — categorisation drives the rest of the artefact and audit trails on the C/I/A reasoning are mandatory.
   • Control Profile Selection — pick the CSE-published profile matching the categorisation: PBMM (Protected B Medium-Medium) for the typical federal Protected B baseline; PBMM-Cloud where the system is cloud-hosted; Secret-High where the categorisation crosses to Secret; Top-Secret-High for Top Secret. State the rationale for the chosen profile and any tailoring (additions, removals, or parameter values) and identify the approver. Tailoring deviations from the published profile must be justified, not preferred.
   • Statement of Applicability — for each of the 16 ITSG-33 / NIST SP 800-53-derived control families (AC, AU, CA, CM, CP, IA, IR, MA, MP, PE, PL, PS, RA, SA, SC, SI), list each control as Applicable / Not Applicable / Compensating Control with justification. Render as a per-family table. Where a compensating control is used, name the substitute and the residual-risk acceptance rationale.
   • Cryptographic Module Validation — list every cryptographic module in the system with its CMVP / FIPS 140-3 certificate number, validation level, and algorithm scope. Flag any module not on the active CMVP list as a finding. Non-CMVP-validated cryptography protecting Protected B and above is a finding, not a discussion item.
   • Supply Chain Security — apply the TBS Direction on Vulnerable Suppliers and the published sanctioned-entities list to the supplier inventory. Identify any vendor of concern, sub-processor of concern, or PSPC-restricted telecommunications equipment. Note dependencies on managed services that themselves carry inherited supply chain risk.
   • Continuous Monitoring Plan — assessment frequency per control family; the tooling that produces the evidence; the reporting cadence and recipients; and the explicit triggers for re-categorisation (new data elements, new processing, change of operating environment, change of supplier, security incident materially altering the threat picture).
   • Authorisation Chain — System Owner → Security Authority → Authorising Official, identified by role; specify the authorisation cycle, the conditions attaching to the authorisation, and the re-authorisation triggers.
   • — outstanding tailoring decisions, unfinished CMVP checks, unresolved supplier flags, and any condition the authorising official has placed on go-live.
6. Populate the External References section per .arckit/references/citation-instructions.md. ITSG-33, the TBS Standard on Security Categorization, the Direction on Vulnerable Suppliers, and the CMVP active modules list MUST appear in the Document Register with their primary URLs and verification dates.
7. Before writing the file, read .arckit/references/quality-checklist.md and verify all Common Checks plus the ITSG per-type checks pass. Fix any failures before proceeding.
8. Write the artefact via the Write tool to projects/<project-id>/<filename>.
9. Show only a summary to the user (one paragraph plus the system-level categorisation, the chosen profile, the count of Compensating Controls, and any open lawful-authority or supplier-flag items).

Authoritative anchor

ITSG-33 IT Security Risk Management: A Lifecycle Approach (Communications Security Establishment / Canadian Centre for Cyber Security); TBS Standard on Security Categorization; TBS Policy on Government Security. Authority: Communications Security Establishment / Canadian Centre for Cyber Security; Treasury Board Secretariat Chief Information Officer Branch. Primary URLs: https://cyber.gc.ca/en/guidance/itsg-33 and https://www.tbs-sct.canada.ca/pol/doc-eng.aspx?id=16578.

Important notes

• Categorisation drives everything. Get the C / I / A scoring right — downstream profile selection, tailoring scope, control parameter values, and the authorisation cycle all derive from it. A wrong categorisation propagates silently and is expensive to unwind post-authorisation.
• Tailoring is rationale-driven, not preference-driven. Every tailoring deviation from the published CSE profile (control removal, parameter relaxation, compensating substitution) must be justified in the SoA with an explicit residual-risk statement and named acceptance.
• CMVP-validated modules are mandatory for cryptography protecting Protected B information and above. Non-validated modules are a finding, not a topic for discussion. Verify each module against the active CMVP list, not the historical list — modules can be moved to historical status with material consequences.
• Supply chain controls extend beyond the prime contractor. The Direction on Vulnerable Suppliers attaches to sub-processors, telecommunications equipment subject to PSPC restrictions, and managed services that carry their own inherited supplier dependencies. Screen the full inventory, not just the contracted party.

Suggested Next Steps

After completing this command, consider running:

• $arckit-ca-cloud-residency -- Categorisation and control profile feed the sovereign cloud residency assessment.
• $arckit-risk -- Residual security risks and tailoring deviations become entries in the operational risk register.
• $arckit-adr -- Material control tailoring or compensating-control decisions warrant Architecture Decision Records.