Safeguard 11.1: Establish and Maintain a Data Recovery Process

Safeguard 11.1 requires you to define, document, and run a repeatable data recovery process so you can restore business data after ransomware, accidental deletion, system failure, or third-party outages. To operationalize it fast, scope the “recoverable data,” set recovery objectives, standardize backup/restore workflows, test restores, and retain evidence that the process runs as designed. ¹

Key takeaways:

• Write a recovery process that names systems, owners, recovery targets, and approved restore methods. ²
• Prove operability with restore tests, logs, tickets, and after-action notes, not just a policy. ¹
• Treat third parties (SaaS, MSPs, cloud) as part of the recovery chain and collect contractual and technical recovery evidence. ²

“Safeguard 11.1: establish and maintain a data recovery process requirement” is easy to misunderstand as “we have backups.” Auditors and incident responders will look for more: a defined method to recover the right data, within a time window the business can tolerate, using steps that work under pressure. CIS v8 frames this as an implementation expectation under the Data Recovery control family: you document the process, keep it current, and run it in a way that can be verified. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat 11.1 as an operational control with clear scope, roles, runbooks, and recurring evidence capture. Your goal is twofold: (1) reduce downtime and data loss risk from common failure modes (ransomware, operator error, cloud misconfigurations, third-party disruptions), and (2) demonstrate control design and operating effectiveness during internal audit, customer due diligence, or external assessments mapped to CIS. ²

This page gives requirement-level guidance you can hand to IT, Security Operations, Infrastructure, and application owners, then track through a control owner workflow (including evidence) in Daydream.

Regulatory text

Excerpt (as provided): “CIS Controls v8 safeguard 11.1 implementation expectation (Establish and Maintain a Data Recovery Process).” ¹

What the operator must do (plain meaning):

• Establish: Define a documented, repeatable process for restoring data that the organization depends on. The process must cover what gets recovered, from where, by whom, and under what conditions. ²
• Maintain: Keep the process accurate as systems, storage locations, SaaS providers, and architectures change. “Last year’s runbook” is a common failure point. ¹
• Make it provable: CIS safeguards are assessed on whether they’re implemented. You need operational evidence that the recovery process runs and works. ²

Plain-English interpretation (what 11.1 is really asking)

You must be able to answer, quickly and consistently:

1. What data do we need back to operate?
2. Where is it backed up or otherwise recoverable?
3. How do we restore it (step-by-step), including access and approvals?
4. How do we know restores work (testing), and how do we prove it (evidence)?

Backups are only one input. A “data recovery process” also covers restore permissions, key management (if encrypted), dependencies (identity, DNS, networking), and third-party recovery steps for SaaS and managed platforms. ²

Who it applies to

Entity types: enterprises and technology organizations using CIS Controls v8 as a security baseline. ¹

Operational contexts where 11.1 becomes high-friction:

• Hybrid environments (on-prem + cloud) where backups span multiple tools and owners.
• SaaS-heavy stacks where “backup” may mean exports, replication, or provider-native retention.
• Ransomware risk where restore integrity and administrative separation matter.
• Third-party dependencies (MSPs, hosting, payroll, CRM) where your recovery ability depends on a contract and the provider’s operational maturity.

What you actually need to do (step-by-step)

Step 1: Set scope and control ownership

• Assign a control owner (usually Infrastructure/IT Ops) and a GRC owner responsible for evidence and reviews. ²
• Define in-scope data domains: production databases, file shares, endpoint user data (if required), cloud object storage, SaaS tenant data, and configuration data that must be restored to access the data (for example IAM configuration exports). Keep it in a simple inventory table.

Practical output: “Data Recovery Scope Register” with system name, data type, source of truth, backup/recovery method, owner, and restore runbook link.

Step 2: Define recovery objectives the business will sign

Even in CIS-only programs, you need recovery targets to make the process actionable.

• Work with business owners to define recovery time objective (RTO) and recovery point objective (RPO) per tier (mission-critical, important, supporting).
• Document assumptions (dependencies, third-party SLAs, required credentials).

Exam reality: auditors often accept “tiered” objectives when they are approved, consistent, and mapped to systems, even if you cannot prove perfection across every app.

Step 3: Document the recovery process as runnable runbooks

Create short, operational runbooks. Avoid policy prose. Minimum content per runbook:

• Trigger conditions (ransomware suspected, accidental deletion, corruption, outage)
• Roles: incident commander, restore operator, approver, app owner validator
• Restore source: backup vault/bucket, snapshot, replica, SaaS export
• Steps (command-level where needed)
• Validation checks (data integrity checks, app smoke test, user acceptance)
• Rollback steps if restore introduces corruption
• Communication steps and required tickets

Store runbooks in a controlled repository with version history.

Step 4: Build restore access and approvals that work during incidents

Common failure mode: nobody can access backup consoles during a real outage.

• Pre-stage break-glass access or emergency access procedures for restore tooling.
• Ensure restore actions are logged (central logging or tool-native audit logs).
• Define approval rules: who can authorize destructive restores, who can access sensitive backups.

Step 5: Test restores and capture evidence

A “successful backup job” does not prove recoverability.

• Run restore tests for representative systems in each tier.
• Include at least one test path for SaaS recovery (export/import, provider restore request, or documented provider procedure).
• Record outcomes, issues, and corrective actions.

Evidence tip: a restore test that finds issues can still support compliance if you track remediation to closure and re-test.

Step 6: Integrate third parties into the recovery chain

For critical third parties:

• Confirm the provider’s recovery method (tenant-level restore, snapshots, exports).
• Collect contractual commitments where available (support responsiveness, retention, restoration responsibilities).
• Document your side of the process: who opens the ticket, what information is required, and how restored data is validated internally.

Step 7: Operationalize maintenance (keep it current)

• Add a change trigger: new systems, major releases, data store migrations, backup tool changes, and onboarding/offboarding of key third parties.
• Schedule recurring reviews of runbooks and the scope register.
• Track exceptions explicitly (systems without feasible backups, legacy constraints) with compensating controls and an end date.

Where Daydream fits (earned, practical)

Use Daydream to map Safeguard 11.1 to a named control owner, attach runbooks and restore test evidence on a recurring cadence, and keep a single audit-ready record that shows design (process) and operation (tests, tickets, logs). This directly addresses the common risk factor for 11.1: missing implementation evidence. ¹

Required evidence and artifacts to retain

Use this as your evidence checklist (keep it tight and reviewable):

Artifact	What it proves	Good enough for audit
Data Recovery Policy/Standard (1–3 pages)	Governance and expectations	Approved, versioned, current
Data Recovery Scope Register	What data/systems are covered	Mapped to owners and methods
System-level runbooks	Steps are executable	Stored with version history
Backup/restore configuration exports or screenshots	Tooling is configured	Dated and tied to scope items
Restore test records	Recoverability, not just backups	Ticket + result + validation notes
Incident tickets referencing restores	Process runs in real life	Links to logs, approvals, outcomes
Access control evidence for restore tooling	Only authorized restores	Role mappings + audit logs
Third-party recovery documentation	SaaS/outsourced recovery is addressed	Provider procedure + your internal steps

Common exam/audit questions and hangups

1. “Show me a restore, not a backup report.” Provide restore test tickets and validation notes tied to the system inventory.
2. “Which systems are in scope?” If you cannot answer consistently, your program will look ad hoc.
3. “Who can restore production data?” Auditors expect defined roles, approvals, and traceable logs.
4. “How do you know runbooks are current?” Show review history, change triggers, and last tested dates.
5. “What about SaaS?” “The provider handles it” is rarely accepted without documented steps and evidence you can execute them.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Confusing retention with recovery. Long retention does not prove you can restore quickly. Fix: require restore tests and validation results for key systems. ²
• Mistake: No owner per system. “IT owns backups” fails when apps are distributed. Fix: assign an app owner validator for each tier-1 system.
• Mistake: Runbooks that assume perfect conditions. Real incidents include missing credentials, MFA changes, and broken dependencies. Fix: document emergency access steps and dependencies explicitly.
• Mistake: Ignoring third-party recovery. SaaS is still your operational risk. Fix: build provider steps into runbooks and collect proof you can initiate restores.
• Mistake: Evidence scattered across tools. Fix: centralize evidence capture in Daydream (runbook link, test ticket, logs) with a recurring schedule. ¹

Risk implications (why CIS cares)

A weak or untested recovery process increases:

• Operational outage risk (extended downtime due to unclear steps or missing access)
• Data integrity risk (restoring corrupted or incomplete data)
• Ransomware impact (inability to recover without paying, or restoring reinfected data)
• Audit and customer trust risk (you cannot demonstrate recoverability even if backups exist)

CIS v8 treats recoverability as a practical security outcome, not a documentation exercise. ²

Practical 30/60/90-day execution plan

First 30 days (stabilize and scope)

• Name control owner(s) and set an evidence folder structure in Daydream.
• Build the Data Recovery Scope Register for critical systems and key SaaS.
• Collect existing runbooks and backup diagrams; identify gaps (no restore path, no owner, no access).

Days 31–60 (make it runnable)

• Write or rewrite runbooks for the highest-impact systems.
• Define restore approvals and emergency access procedures.
• Schedule and run restore tests for representative systems per tier; open remediation tickets for failures.

Days 61–90 (make it provable and maintainable)

• Implement a recurring restore test cadence aligned to your risk tiers.
• Add change triggers to your change management process so runbooks update when systems change.
• Produce an audit packet: scope register, runbooks, latest restore tests, remediation closure, and third-party recovery procedures.

(These timeboxes are an execution pattern, not a claim about how long your organization will take.)

Frequently Asked Questions

Does Safeguard 11.1 require offline backups or immutable storage?

11.1 requires a data recovery process, not a specific backup architecture. If ransomware is in your threat model, design your recovery process to include backup protection mechanisms and prove restores work under constrained access. ²

What counts as “data” for recovery: just databases, or also configurations?

Treat both as in scope if losing the configuration prevents access to the data. Common examples include IAM configuration exports, encryption key procedures, and infrastructure configuration needed to mount storage. ²

We’re SaaS-first. How do we meet 11.1 if we can’t run backups ourselves?

Document the provider recovery mechanism (exports, provider restores, retention) and your internal steps to request, validate, and re-enable access. Retain evidence from test restores or tabletop exercises that walk through the provider workflow. ²

How detailed do runbooks need to be for auditors?

Detailed enough that a qualified operator can execute them without guessing during an incident. Auditors usually focus on clarity of roles, prerequisites, restore steps, and proof of testing tied to in-scope systems. ²

What evidence is most persuasive in an assessment?

Restore test tickets with timestamps, logs, validation results, and follow-up remediation records. Pair that with a scope register that shows you know which systems are covered and who owns them. ¹

How do we handle systems that can’t be backed up (legacy or vendor-managed)?

Track them as explicit exceptions with a documented rationale, compensating measures, and an owner-approved remediation plan. Auditors react poorly to “we didn’t know” but often accept “we know, and here is the plan.” ²

Footnotes

1. CIS Controls v8; CIS Controls Navigator v8

2. CIS Controls v8