AESO / NERC CIP Compliance Through XQ Data Centric Governance
XQ aligns with AESO-adopted NERC CIP requirements by enforcing data-centric Zero Trust controls that operate independently of network location, cloud provider, or application layer. Below is how XQ maps to core CIP obligations relevant to AESO-regulated entities.
Data Protection (CIP-005, CIP-007, CIP-011)
Data-level encryption with customer-controlled keys ensures BES Cyber System Information (BCSI) remains protected at rest, in use, and in transit.
External key management / HSM integration prevents cloud providers, SaaS vendors, or administrators from accessing plaintext data.
Cryptographic separation ensures that even if perimeter or system controls are bypassed, data remains inaccessible.
Identity, Access Control, and Least Privilege (CIP-004, CIP-007)
Policy-based access enforcement (RBAC/ABAC) ties data access to identity, role, attributes, and context (e.g., geography, device posture).
Zero Trust access decisions are made at the data layer, not just at the network or application layer.
Supports privileged access restrictions required for BCSI and critical operational data.
Information Protection & Governance (CIP-011)
Granular data labeling and governance policies allow utilities to explicitly define how BES data may be accessed, shared, or exported.
Persistent controls follow the data, including backups, replicas, analytics environments, and third-party integrations.
Enables enforcement of data retention, sovereignty, and controlled disclosure requirements.
Monitoring, Audit, and Incident Response (CIP-008, CIP-010)
Cryptographic access logs provide immutable audit trails showing who accessed which data, when, and under what policy.
Enables rapid containment by revoking keys or policies without system shutdowns or infrastructure reconfiguration.
Supports forensic and compliance reporting required by AESO audits.
Cloud and Third-Party Risk (CIP-013)
XQ reduces supply-chain and vendor risk by ensuring third parties never have implicit trust or data visibility, even when systems are integrated.
Allows AESO-regulated entities to use cloud and SaaS platforms without ceding control of regulated data.
| CIP Standard | Requirement | AESO / NERC Expectation | XQ Control | Audit Evidence Produced |
|---|---|---|---|---|
| CIP-004-6 | R2 – Personnel Risk Assessment | Access to BES Cyber System Information limited to authorized individuals | Data access enforced via cryptographic policy bound to identity, role, and attributes (RBAC/ABAC); access revocable at key level | Access policy definitions; identity-to-policy mappings; key revocation logs |
| CIP-004-6 | R3 – Access Management | Provisioning/deprovisioning of access to BES systems and data | Immediate access revocation via policy or key invalidation without system changes | Deprovisioning event logs; key lifecycle records |
| CIP-005-7 | R1 – Electronic Security Perimeter | Controlled access to BES Cyber Systems | Data remains encrypted and inaccessible outside policy regardless of network boundary | Encryption policy artifacts; access attempt logs |
| CIP-007-6 | R5 – System Access Controls | Enforce least privilege | Fine-grained, data-level access controls independent of OS or application permissions | Policy evaluation records; denied-access logs |
| CIP-007-6 | R6 – Monitoring & Logging | Detect unauthorized access attempts | Cryptographically enforced access logging at data layer | Immutable access logs; SIEM export |
| CIP-008-6 | R1 – Incident Response Plan | Ability to contain and respond to cyber incidents | Rapid containment by revoking data access keys or policies without shutting down systems | Incident response playbooks; revocation timestamps |
| CIP-010-4 | R1 – Configuration Change Management | Prevent unauthorized changes to BES systems or data controls | Policies and key changes are versioned, logged, and auditable | Policy version history; change approvals |
| CIP-010-4 | R4 – Vulnerability Assessments | Minimize exploitable attack surface | Cryptographic data isolation reduces impact of system compromise | Architecture diagrams; threat model documentation |
| CIP-011-3 | R1 – Information Protection | Protect BES Cyber System Information from unauthorized disclosure | Persistent encryption and policy enforcement follow data across environments | Data classification rules; encryption enforcement reports |
| CIP-011-3 | R2 – Information Disposal | Secure handling and disposal of BCSI | Cryptographic erasure via key destruction renders data unreadable | Key destruction logs; retention policies |
| CIP-013-2 | R1 – Supply Chain Risk Management | Manage third-party access to BES data | Vendors never receive plaintext access; no implicit trust | Third-party access policies; vendor isolation proofs |
| CIP-013-2 | R2 – Vendor Risk Controls | Control vendor-initiated access | Time-bound, policy-based access enforced at data layer | Temporary access records; expiration logs |
Practical Outcome for AESO-Regulated Utilities
XQ provides a defense-in-depth control at the data layer, complementing existing CIP network, system, and procedural controls. This helps utilities:
Meet AESO CIP expectations for BCSI protection
Safely adopt cloud and analytics platforms
Reduce audit scope and blast radius
Demonstrate enforceable, provable Zero Trust compliance
Auditor-Relevant Positioning (AESO Context)
XQ does not replace required CIP network, system, or procedural controls.
XQ provides a compensating and complementary data-layer control, reducing blast radius and audit scope.
Controls remain effective in cloud, hybrid, SaaS, backup, and analytics environments, which AESO increasingly scrutinizes.
How Utilities Typically Present XQ in AESO Audits
Mapped as a preventive and detective control for CIP-011, CIP-004, CIP-007, and CIP-013
Used to demonstrate defense-in-depth beyond perimeter security
Supports objective evidence requirements through cryptographic logs and policy artifacts
