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1. Information Security Governance: What Is It And How Can We Accomplish It ? Todd Fitzgerald, CISM, CISA, CISSP, ITILV3 ISO27000 Certified
National Government Services
Medicare Systems Security Officer
ISACA Kettle-Moraine Chapter Meeting
December 4, 2008 Milwaukee, WI
3. Today’s Objectives… To Discuss Security Governance Definition
Why We Need Security Governance
13 Questions
Leadership Core Competencies
Vehicles For Communication
Security Control Structures
Achieving Security Compliance
Effectively Working With Internal/External Auditors
4. Security Governance Defined “Information Security governance is a subset of enterprise governance that provides strategic direction, ensures objectives are achieved, manages risk appropriately, uses organizational resources responsibility, and monitors the success or failure of the enterprise security programme.”
- IT Governance Institute
5. And Wikipedia Says… Governance relates to decisions that define expectations, grant power, or verify performance. It consists either of a separate process or of a specific part of management or leadership processes. Sometimes people set up a government to administer these processes and systems.
In the case of a business or of a non-profit organization, governance relates to consistent management, cohesive policies, processes and decision-rights for a given area of responsibility. For example, managing at a corporate level might involve evolving policies on privacy, on internal investment, and on the use of data.
6. Governance Derived From Latin Origins To denote “Steering” Steering Vs “Power Over”
Defines expectations
Grants power
Verifies performance
Avoids undesirable consequences
Coordinates and controls activity
Provides processes to control an activity
7. Risks Are Increasing Cybercrime
Malware
Identity Theft
Lost Laptops
Targeted Financial Gain
Personal information Sharing
Slowing of security investment
Dissipation of security message
Competitive pressures
8. News Items Continue To Gain Attention of Board of Directors
9. A Who’s Who of Fortune 500 Companies.. And The List Is Growing
10. Leading Organizations Adhere To This Model
11. Leading Organizations Adhere To This Model
12. Information Security Strategy Must Align With Business Objectives Top-down process
Linkages to business process and strategy
Information in oral, paper, and electronic forms
Transcends physical boundaries
Establish acceptable practices, policies, and procedures
13. An Information Security Program With Governance Provides Increased Assurance Risk management
Resource management of critical skills and infrastructure
Performance measurement
Providing value-add in delivery of services and products
Specific Organizational accountability for security
14. Can Organizations Survive Without …?
15. Few Organizations Can Survive Without Customer Information
Knowledge of processes
Accounting and financial reporting information
16. However, Information Security Importance Varies Amongst Senior Executives
17. However, Information Security Importance Varies Amongst Senior Executives
18. However, Information Security Importance Varies Amongst Senior Executives
19. However, Information Security Importance Varies Amongst Senior Executives
20. However, Information Security Importance Varies Amongst Senior Executives
21. However, Information Security Importance Varies Amongst Senior Executives
22. Fear Uncertainty Doubt Gets Investment $$$
23. However, The Next Time The Event Happens
24. The Governance Answer…
25. Security Needs Involvement From The Board of Directors/Executive Management Strategic Oversight
Review alignment with organization strategy
Determine Risk profile for organization
Endorse security program
Require regular reporting on effectiveness
Review investment return
Potential new technologies to add value, reduce costs
26. “Techie” Core Competencies
27. Shift To Leadership Competencies
28. Security Officer Core Competencies
29. (The Detail)
30. (The Detail)
31. (The Detail)
32. (The Detail)
33. (The Detail)
34. (The Detail)
35. Now The C-Level People Understand The Security Guy Behind The Mask and The Security Team’s Role, But…
36. Multiple Groups Must Understand Security At The Appropriate Level Competitive Disadvantage
Fraud
Loss due to disclosure, destruction of information
Reputation/Public Confidence
Bad decisions
Business disruption
Legal Liability
Safety risks
Loss of productivity
Low Morale
Corporate Espionage, loss of contracts
37. Focus Different, Goals Ultimately The Same Increase shareholder value (stock price)
Increase revenue
Reduce administrative costs
Increase market share
Increase worker productivity
Provide innovative products
Provide quality products and customer service
Attract and retain talented workforce
Accept reasonable business risk
38. Ensure Communication Plan Delivers Targeted Security Message
39. Security Governance Depends Upon Clear Management Directives And Expected Outcomes
40. Security Governance Depends Upon Clear Management Directives And Expected Outcomes
41. Security Governance Depends Upon Clear Management Directives And Expected Outcomes
42. Security Governance Depends Upon Clear Management Directives And Expected Outcomes
43. Security Governance Depends Upon Clear Management Directives And Expected Outcomes
44. Multiple “Best Practice” Standards Have Been Created To Provide Guidance For Our “Security Cultures” Control Objectives for Information and related Technology (COBIT 4.1)
ISO27001/2 Information Security Management System (ISMS)
Payment Card Industry Data Security Standard
Graham-Leach-Bliley (GLBA)
European Union Privacy Directives
Recommended Controls For Federal Information Systems (NIST 800-53)
Federal Information System Controls Audit Manual (FISCAM)
DISA Security Technical Implementation Guides (STIGs)
HIPAA Final Security Rule
45. Each Control Framework/Set of Standards Has Their Governance Purpose COBIT
ISO27001/27002
NIST 800-53
PCI Data Standard
HIPAA
DISA STIGS
FISMA
46. NIST 800-53 Recommended Controls For Federal Information Systems Is Very Useful For All Environments
47. Attaining Compliance With These Regulations Is A Life Changing Event!
48. Achieving Security Compliance Assurance Requires Specific Due Diligence Designate individual responsible for compliance assurance oversight
Establish security management governing body
Select control frameworks and controls
Conduct awareness and training
Research and apply technical controls
Verify Compliance
Implement formal remediation process
Dedicate staff, automate compliance tasks
Report on compliance metrics
Enforce penalties for noncompliance to policy
Collaborate and network externally
49. Security Audits Necessary To Ensure Controls Are Functioning
50. Controls Must Be Tested To Provide Adequate Assurance of Compliance To Policies Quarterly vulnerability assessments
Annual penetration tests
External/Internal Audits
Random spot-checks
Informal testing with security awareness training
Security configuration reviews
SDLC walkthroughs
51. Let’s Agree On This Before We ‘Dump’ On The Auditors Auditors and Security Officers exist to ensure the business has:
Documented policies
Documented procedures/processes
Documented evidence of implementation these controls
Evidence of ongoing operations
Periodically tested the controls
52. What Do Security Officers LIKE about Auditors ? Internal Audit areas usually have organizational clout
Controls-oriented
Can identify previously unknown issues
Provide ammunition/urgency for fixing issues quickly
Provide knowledge of best practices and standards
Internal Auditors find issues prior to external audits
53. Adopting A “Reasonable” Approach To Auditing For Security Governance
54. Final Thoughts Security Governance requires Top-Down Responsibility Sharing
Ask the question – why am I involving this group? What is needed from them?
Governance provides visibility to the effectiveness of the security program, and is the pathway to future security investments
55. Further Reading “CISO Leadership: Essential Principles For Success”, 2008 Book by Todd Fitzgerald and Micki Krause, ISC2 Press/Auerbach Publications Available on Amazon.com, ISC2 Website
“Security Governance: Taming the Compliance Beast”,T.Fitzgerald, 2008 Information Security Handbook (Tipton, Krause)
“13 Questions the CISO, CEO, and CISO Should Ask Each Other”, T. Fitzgerald, ISC2 Journal, September/October 2007
“Security Governance”, 2007 Information Security Handbook , T.Fitzgerald (Tipton, Krause)
NIST 800 series special publications (www.csrc.nist.gov/publications)
IT Governance Institute, Information Security Governance: Guidance For Boards of Directors and Executive Management 2nd Edition, www.itgi.org