Implementing an effective information security governance framework with the right leadership structure is not an easy task, but failing to do so could mean the difference between a contained crisis and a devastating catastrophe when things go wrong.
Businesses live with risk. Risk is an opportunity and a threat that business leaders regularly assess to determine what they can live with and what they feel they must mitigate. But while some risks and their impacts are well understood, information security risks — and the severity and suddenness of their impact — remain tough to conceptualise for many. Business leaders often only understand the true scale of information security risk when a major incident spells it out — with unimagined consequences.
US retailer Target might be the (reluctant) poster child for a security breach at the moment, but it's not alone. Organisations face and can suffer from a diversity of security risks and impacts: Cybercriminals, insider threats, "hacktivists", denial-of-service attacks, and even offensive foreign government acts.
Do boards really understand the IT security risks for their organisation?
A telling question about the security governance framework in place at any organisation that's suffered a major breach is whether the board discussed cybersecurity before the incident. Did it understand the risk, the probability of its occurrence, and its impact? If it was surprised by the incident, chances are the risks and their impact weren't discussed.
Information security governance isn't about the technical aspects of IT security. It's about defining responsibility and accountability, and structuring policies to ensure that decisions are made in such a way that they help an organisation achieve an accepted level of risk.
The US National Institute of Standards and Technology (PDF) defines it for US government departments as "the process of establishing and maintaining a framework and supporting management structure and processes to provide assurance that information security strategies are aligned with and support business objectives".
The framework would also ensure that such strategies are "consistent with applicable laws and regulations through adherence to policies and internal controls, and provide assignment of responsibility".
Designing and implementing an information security governance framework will help manage risk, but it could also jar with an organisation's culture, particularly when it comes to who's calling the shots.
For example, should the chief information security officer (CISO) have a direct line to the board or CEO? Or perhaps the power to veto a business project that involves an unacceptable security risk? Or should the CISO do everything possible to align security objectives with business goals, perhaps to the detriment of sound IT security risk management?
Are suppliers and contractors to be included in the governance framework? Is there a role for cybersecurity insurance in offsetting risk — and at what expense? And how should organisations define where the information risks lie? Is it just in vulnerable IT systems? Or paper, too?
Governance structure is going to be critical to the overall framework, and one common sign that a board of directors probably doesn't have a grip on the information risks it faces is when information security leadership is tucked away behind the general rubric of IT.
Who should the CISO report to?
"The CISO should not report to the CIO," said Jeff Spivey, international vice president of the Information Systems Audit and Control Association (ISACA). "It's very difficult to bring up issues to a management level that needs to resolve them. That needs to be offset somewhere else so it's not an incestuous relationship."
David Lacey, a UK-based strategic advisor to security firm IOActive and the original author of the British Security Standard BS7799 — a predecessor to today's ISO 27000 series of cybersecurity standards — agrees. He added that putting the CISO on a leash leaves an organisation poorly prepared to deal with the blistering speed of today's attackers.
"In today's environment, major security vulnerabilities need to be fixed immediately. CISOs should be trusted to make the call. There's no time to argue or make a business case. And very few security business cases meet investment appraisal criteria," said Lacey. If that means the majority are declined, surely the board and shareholders have a right to know?
Lacey, previously an information security manager for Royal Mail Group, Royal Dutch-Shell Group, and the UK Foreign & Commonwealth Office, believes traditional security governance — and the standards used to build them — need to be abandoned. Instead of security leaders thinking like widget makers, they need to act with a fighter pilot's sense of peril.
"Cybersecurity increasingly needs to operate like a strategic crisis team. In a crisis, a team takes over decision making from the business. Speed and empowerment are crucial."
The problem, according to Lacey, is that security leaders are often too afraid of losing their jobs to stick their necks out when it's needed.
"There's always resistance to security because it costs money and slows down projects. The main risk to a business manager is always his bonus. It's never security. CISOs won't stand up to the business because they want a career. That's the reason we have compliance. But compliance does not result in effective security." Maybe business managers' bonus objectives should include a security measure?
How does an information governance policy work?
Policy documents aren't the most thrilling reading material, and are often not treated with the importance they deserve — sometimes because they've been poorly fitted to the organisation. However, in complex and dynamic environments with multiple stakeholders, well-defined policies can be critical to managing information risks as decisions are made.
The trick to ensuring that policies don't get ignored is to avoid seeing them as an audit checklist, which of course requires effort that some companies aren't prepared to expend.
"Too often, I see companies use policy templates downloaded from the internet, or the policies do not reflect how the business operates," said Brian Honan, principal of UK security consulting firm BH Consulting.
"This results in policies being ignored by staff and management, and the policies left to gather dust on a shelf somewhere. Their only function is to satisfy an audit requirement, which even then they may not achieve."
Honan added that they should be treated as "living documents" that are updated regularly and easy to access.
Well-designed risk management policies offer a base from which to take a calculated approach to information risks that will also shine the light on opportunities.
"It is quite ironic that security professionals often discuss risks without considering the opportunities," said Dr Steve Purser, who heads up the technical department of the European Union's official security think tank, the European Network and Information Security Agency (ENISA).
"Most of us do not take risks unless there is a clear reason for doing so, so it's important to understand the business motivation for doing something when considering the risk. In other words, a good risk management framework will enable the management to take account of both opportunity and risk."
Once they've been worked out, the organisation is able to inspect what risks can be mitigated and those that remain.
It's also a fallback document for when business managers overstep the limits of their decision-making powers. It ultimately clarifies where accountability for decisions lie, and ideally removes assumptions and ambiguity about who has the authority to make them.
"When these limits are reached, the governance policy explains the mechanisms and procedures that must be followed in order to control the risks in an appropriate fashion," explained Dr Purser.
Besides keeping the organisation clear of wayward decisions, the policies can also help shape cultural attitudes toward risk and security, which may ultimately improve the response to a security incident when one occurs.
"Used correctly, they can also be useful tools in educating staff on what the organisation regards as being a reasonable level of risk and what is intolerable, which in turn helps organisations to be prepared for security incidents and other unusual events."
Building and implementing the right policy and framework
Building an information security governance framework is all about understanding the business, the unique risks each unit faces, and working with each to achieve an optimal risk profile.
However, it's also a balancing act between different priorities, since risks seen through the eyes of an IT security professional will be different to a business executive's. Neither should be overruled without consideration for the overall organisation.
Ultimately, building the framework will require input and support from every level of the organisation, from the board to those executing the policy on a daily basis.
"A common issue with implementing information security governance is failure to get the buy-in of those that have to implement the framework," said ENISA's Dr Purser.
At a practical level, Honan pointed out, this means engaging business, to ensure that the policies align with their goals, and end-user representatives, to ensure that they're understood by those who will use them.
"The language used in the policies should be simple and straightforward, and it may be worthwhile having someone act as a 'policy translator' to ensure the language used is appropriate," advised Honan.
This type of engagement will also help refine where the organisation invests in security.
One example, said ISACA's Spivey, is where a unit knows that the impact of a disruption or outage to a particular system would knockout manufacturing for a day with a cost of $3 million.
"The cybersecurity group tells me what it takes to lower that risk for my business unit. It's a discussion about where's the value in each business unit, and how can those units be affected by these risks that cybersecurity group sees. Impact is important," he said.
"A lot of times in IT security, we think our risks are the most significant risks for the entire company," said Spivey. "The enterprise risk management responsibilities have to first understand what those risks are from a cybersecurity point, and then weigh the impact of those risks to other risks the company faces. And then apply the resources to ensure that risk is within [what] the board agrees is acceptable."
Governance structures at a leadership level may also require organisations to take an information-centric view of security. Spivey pointed to the emergence in banks of "information risk officers".
"My argument would be that person needs to be involved in information, no matter where it resides. It could be on paper, data in a computer, public speeches. It could be a number of different ways that information may not be controlled, limited, and protected as an enterprise secret," said Spivey.
Standards and compliance: Pitfall or helper?
Information security standards can help guide the process, and legal and regulatory compliance may kick-start a program. However, they definitely shouldn't be the cornerstone to an information security governance framework.
Some commonly referenced standards include ISO 27001 and 27002, ITIL, ISACA's COBIT 5 framework, and others such as the card scheme-backed PCI DSS. Then there are regulations impacting information handling in certain sectors, such as HIPAA for US healthcare, and more generally applied regulations like Sarbanes Oxley that place obligations on US businesses and their overseas entities.
While each standard attracts its own critics, they're not bibles. They can be used as a solid starting point to implement a good security framework, said Mark Jones, principal of Australia-based Enex Test Labs' security testing division.
"All the standards form a baseline, but for nothing else [than] they give someone that's trying to implement governance something to work towards, otherwise you'd be winging it and you'd probably miss something," said Jones, pointing out that most organisations do base their governance frameworks on one of them.
Standards and compliance may help to establish baseline security measures and could be a vital part of a governance framework; however, the organisation shouldn't implement a standard with a view only to passing an audit. That approach is a mistake, according to ENISA's Dr Purser, who said it could lead to a mess of security controls that aren't fitted to the organisation's needs.
"Compliance-based approaches can quickly become liability control mechanisms, and can lead the organisation into a false sense of security. It takes a lot of consistent effort to implement effective security controls, and even more effort to make sure that they remain current," said Purser.
That false sense of security may also stem from the lag between standards and the current threats that businesses face.
"Standards don't work because they take decades to become accepted," said Lacey. "Today's security standards are not good enough to defend against advanced persistent threats. The concept of collecting generally accepted practices is flawed. You can't defend against today's threats with yesterday's practices."
The bottom line is each business must go past the adoption of commonly accepted risk management standards and policy. Boards need to be aware of and educated regularly on the true risks of IT security breaches specific to their business, and on appropriate measures and budgets to mitigate risks. Boards need to get wiser to IT security risks, and IT security specialists (CISOs and their ilk) need to have the authority, business knowledge, and communications skills to influence the board. That's the quick way to close the IT security governance gap.