Babel Fish

Risk Register: The Only Way to Talk to the Board

Ever wondered how really effective cybersecurity professionals not only get direct access to the CEO / Board of Directors (BoD), but actually manage to get a budget out of them? Better even than that, they get the entire C-Suite to evangelise the organisation’s security program on their behalf!

It’s quite easy actually, they speak the same language as the CEO / BoD. This is not the language of security, it’s the language of business goals. Or to put it crassly, it’s the language of money.

For example, if you are a CSO / CISO and have reported to your Board how many malware attacks your controls blocked, or how well your firewall is working I’m surprised you still have a job. The vast majority of Board members care nothing for the detail, and frankly, nor should they. As much as I have preached about how the CEO /BoD should care about security, what I’m really saying is that they should at least appear to care.

The only ones who actually care about cybersecurity [for its own sake] are those with a vested interest. Practitioners, consultants, and especially product vendors, all say they are passionate about security. They may well be, but as an analogy, are you ever passionate about your car insurance? No, of course not, quite the opposite, you just know you have to have it.

Security is no different to insurance in this respect, it’s not like sales or marketing where there is an obvious correlation between the effort and result. With security, the effects are invariably seen only when things have gone horribly wrong. Even then, the Board don’t care about security itself, they care about how the failure of security affected the bottom line. Coincidently, this is often when they start asking all the wrong questions and throw money at the symptoms not the root cause. Like hiring a CISO for example.

Even as one of those with a direct vested interest in security, I am absolutely fine with this. I know my place, which is to provide a direct link from the individual IT assets to the business’s goals. If I can’t show how a risk to the assets at my level can affect an entire business at theirs, how can I possible expect them to understand what I’m talking about? And to be clear, it’s my job to perform this translation, not theirs.

The Babel Fish that performs this modern day miracle? The Risk Register.

I’d say about 75% of organisations I’ve helped over the years have no risk register at all, 20% have only a business risk register, and the remaining 5% have separate business and IT registers. Not one has a single register that maps the IT risks to the business goals. Not one. Worse is the fact that all of these risk registers were very poorly conceived and resulting in nothing but poor decision-making.

The single risk register I’m talking about is the one where anyone can view their part of it and determine exactly how their actions can affect the whole. Does this mythical creature even exist!?

So how DO you map assets to business goals?

Like everything else in security, it’s actually simple. Bloody difficult, but simple.

Step 1: Do Asset Management Properly – I can already exclude every organisation I worked with, and I’ve only heard rumours of this being done well. Basically, if you don’t know what you’ve got, you can’t manage it, let alone perform any step that follows;

Step 2: Map Your Assets to Your Business Processes – I am often amazed that asset dependencies are not fully mapped. How do you perform change control properly if you have no idea how you’re impacting the business process that the changing assets support? How can you prioritise assets? Dependencies, inter-dependencies and data flows must be fully defined;

Step 3: Perform a Business Impact Analysis on Every Business Processes – If you can’t even take a stab at valuing each of your business processes, how can you prioritise them? Whether you can directly quantify them (e.g. revenue) or only qualify them (e.g. HR) you have to know what they are worth to you;

Step 4: Map Your Business Processes to Your Business Goals – This can be tricky as you’re going from the 100% technical to the 100% business. But if you have no idea whether or not your goals are achievable with your current assets, they aren’t very good goals, are they?

In theory and for example, you now know that if a certain database is lost; a) the business process that will fail, b) the potential losses, and c) the goals that may now become unachievable. Not every goal obviously (e.g. M&A), but definitely the ones that got you this far.

So, when you next talk to the BoD, you can show them the possible impact of not spending money on database redundancy where it hurts the most

Their pockets.

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Ignorance

How to Run a GDPR Project

First: If you think that as a cybersecurity ‘expert’ I know how to run a GDPR project a) you can’t be that familiar with GDPR, and b) you have not read any of my previous blogs.

Second: If you have read my previous blogs and clicked into this blog hoping to get advice on how to run a GDPR project, you weren’t ‘listening’. At most I am a first conversation and a pointer to your next.

Then again, would you be reading this right now if the title was; “GDPR: No Idea What I’m Doing, But Here’s Yet Another Opinion.”?

So like everyone else on this little regulatory bandwagon – with the possible exception of privacy lawyers – all I have are opinions, and what I hope is a little common sense. Here in the UK for example, the GDPR is just an expansion of the Data Protection Act of 1998, which in turn was a consolidation of previous acts, some dating back to 1984. And if that’s not enough, ‘The Guidelines on the Protection of Privacy and Transborder Flows of Personal Data‘ published in 1980 by the Organisation for Economic Co-operation & Development (OECD) contained many of the basic tenets upon which the GDPR is predicated:

  1. Collection Limitation Principle;
  2. Data Quality Principle;
  3. Purpose Specification Principle;
  4. Use Limitation Principle;
  5. Security Safeguards Principle …and so on.

That means privacy lawyers have had 37 years to get good at this stuff and pass it on to all fledgling privacy lawyers. The rest of us may have some knowledge, but this will only ever be enough to overlap with the legal profession. This overlap will then hopefully enable us to translate the lawyer’s legalese into a language relevant to our respective departments. This is actually critical to GDPR implementation as lawyers do NOT have the final say, it will always be a negotiation.

Why is this not enough? Why would any non-lawyer even want the task of applying GDPR’s Recitals and Articles into a business’s specific context? Do you think you’ll make enough money to retire before you’re discovered as an incompetent? I have never seen a clearer case for a team effort.

The GDPR Implementation Team

  1. The Lawyer – For some reason everyone assumes that when I say lawyers should lead the effort, they come back with expressions of horror. “Lawyers can’t project manage!”, “Lawyers can’t operationalise GDPR!” and so on. By lead, I mean setting the goals and objectives. You know, leading, not managing. Only lawyers are truly qualified to provide proper context, so they should make their case first.
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  2. The Salesman – Like it or not, GDPR will have an impact on your business. Leave the sales team out and you have ruined any chance you have of making that impact a positive one.
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  3. The Marketer – As with the salesman, there is no reason that ‘compliance’ with GDPR can’t have a positive impact on an organisation, even its bottom line. The marketing / PR spin is the face of your efforts.
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  4. The People Person – Sounds better than the HR person, but I have never understood why these folks have so little part in projects like this. They are the Keepers of the Culture, use them.
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  5. The Technologist – While there is very little directly related to technology in the GDPR, it’s clear that technology has a huge role to play in its implementation. There is not compliance without the IT team.
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  6. The Project Manager – This one needs no explanation
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  7. The Cyber-Peep – Where there is data and technology, there is a need for security wrappers, but this role is no more critical than the others. That’s like saying the wheels are the most important part of a car.

And yes, if there are other departments they should be included too. Privacy cannot be siloed.

What’s missing is something to bring it all together. If only there was an organisational function that took the input from all of these departments and stakeholders and formulated a plan to accomplish the business’s goals! Wait, sounds a lot like Governance, doesn’t it?

It’s already far too late to be proactive, but you have until the 25th of May, 2018 to appear to be proactive. Get your team together and don’t waste this opportunity.

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CISO Lifespan

Why CSOs / CISOs Only Have a 2 Year Lifespan

In previous blogs I expanded upon two main reasons why CISOs seem to have such a limited lifespan, and why the role is currently one of the most difficult senior leadership roles to both fulfil, and stay in long-term.

In Make the CSO Role a Board Appointment, or Don’t Bother Having One I touched upon the fact that so few CSOs; 1) are hired by the right people or for the right reasons, 2) report to the correct hierarchy, and 3) have the necessary support from the people from whom they need it most.

In The 3 Types of CISO: Know Which You Need I tried to explain why there is effectively no such thing as an ‘all-rounder’ CISO, so expectations are already completely out of line with reality.

I’ve now come up with a 3rd; Expecting the CISO alone to fix everything.

While this may be a byproduct of the first two, it is nevertheless important enough to be addressed by itself. And for once, I can’t actually blame the CEO entirely for this issue, the CISO is every bit as culpable.

Consider this scenario; An organisation, for whatever reason, decides it needs a security expert in senior management. Even if the BoD does get involved from the beginning, the organisation will end up writing a job description of some sort. This is no different from going to the Doctor’s, diagnosing yourself, and writing your own prescription.

This description will then be advertised in some fashion, guaranteeing that the only people who respond are the ones wholly unqualified to fill it. In the same way that anyone who wants to be in politics should be stopped from doing so, anyone who responds to a CISO role that they didn’t draft themselves has no idea what they are doing.

There is only one exception to this, and that’s if the organisation has already put the basics of a security program in place and need someone to optimise it. Everything before this is a series of consulting gigs, the aim of which is to prepare the organisation’s security program to the point a CISO can come in and run with it.

So, whether you’re an organisation looking for a long-term CISO, or a CISO looking for a long-term gig, what do you do?

A Security Program in 10 Difficult-as-Hell Steps

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Clearly there are many steps in between these, as none of this appropriately addresses two of the most important aspects of any security program; 1) Senior Leadership’s role in changing the corporate culture, and 2) a Knowledge Management program personified by documented processes and procedures.

But in no way do I wish to downplay the CISO role to one of a babysitter, it is still one of the most difficult roles imaginable. However, I have never met a CISO who joined an organisation at Step 1, and was still the CISO a year or so later. Because the CISO role is perceived by many security professionals as the pinnacle of their career, too few ask the hard questions before committing;

  1. Has the organisation followed the 10 steps? – If no, where are they in the process?. If yes;
  2. Am I right for the job? – If no, can I help them find someone who is. If yes;
  3. Do I really want the job? – Go in with your eyes wide open, or again, walk away.

As long as both the organisation and the prospective CISO are fully aware of these issues, there is no reason a CISO can’t go the distance. That said, there is no reason a security program can’t be put on track without one…

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Can Governance Replace the CISO?

Perform research on IT Governance models and you’ll eventually come across the concept of People, Process, & Technology (The Golden Triangle). Yet another concept whose origination has been lost in time (it was not Bruce Schneirer), but one whose evolution has polarised the security industry.

On the one side you have the technology-first advocates. Even a security icon like Bruce Schneier says; “We rely far too much on policy and people, neither of which are reliable, especially when dealing with fast-changing, large scale infrastructures.“. Oddly enough you’ll find most of the security product vendors in this camp too. I know, weird huh?

Then you have the side that I’m on, that says all the technology in the world can’t fix stupid. The enormous benefits that can be derived from technology are only achievable if the people put the processes in place to make the technologies effective.

In cybersecurity, technology can only enhance, it cannot fix.

Yes, of course technology is critical, why do you think I rage against PCI’s ‘daily review’ of logfiles so much? No, I do not believe that an organisation can ever achieve good security without the automation that only technology can bring, but putting technology first is the definitive cart before the horse.

In cybersecurity, technology can only enhance something that already works, it cannot replace it entirely.

So, to me, the job of the CISO is to get the three aspect of the golden triangle into line with the only things that matters; the business goals. In the digital age, technology is the ultimate enabler, and the CSO/CISOs the ultimate facilitators of that technology. The IT security function gets involved in everything from M&A to compliance, from incident response to internal audit, it’s the CISO’s role to bring it all together into a sustainable program. One that that is only ever appropriate to the business’s needs and no more.

But none of this is possible without Governance. The CISO, as a facilitator, is only a bridge between the business goals and the means to get there. It’s the Governance function that gets the job done.

Also, not every organisation can afford a CISO, and frankly nor should they even contemplate one if there is no discernible return on investment. This is where the Virtual CISO can come into play, and from my perspective, the only reason to consider one. It’s the v-CISO’s job to train the governance committee (or whatever it’s called) to do what CISOs do.

Too many organisations are instantly turned off by the word ‘Governance’. At best it’s seen as unnecessary bureaucracy, at worst it’s perceived as some kind of dystopian ‘Big Brother’. Nothing could be further from the truth; it’s not a department, it’s not an institution, it’s a function, one designed to help keep a business IN business.

EVERY organisation needs governance, regardless of size, region, or industry sector. The governance charter, membership, responsibilities, and operation will vary considerably, but all need to be appropriate, and of measurable benefit.

Only someone with the skill-set of a true CISO can put this in place in such a way as to be sustainable without them. But only a Governance function can keep it going.

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Want to Stay Compliant, Work WITH Internal Audit

Internal Audit.

It’s right up there with Traffic Wardens, Used Car Salesman, and Lawyers, isn’t it? You get a phone call from Internal Audit (IA) and it feels like you’ve just been sent to the Head Master’s office!

But why? If you have been doing everything right, following appropriate policies and procedures, have ACTUALLY read the Acceptable Use / Code of Conduct, why would this be any different? I mean, even SECURITY winces at IA, and we’re total pariahs ourselves!

This is unfortunate, because like it or not, every department needs someone to provide checks and balances. Someone who can look at everything with a fresh and objective pair of eyes, someone not answerable to YOUR boss so can tell them how it is without repercussions, someone who can suggest changes that you know should happen, but fear / politics prevents you from saying anything.

Take your pick, regardless of how you view IA, they, like InfoSec, are an necessary evil in a world where both the threat and regulatory landscapes are spinning out of control.

Best practice frameworks like ISO 27001 call for Internal Audit by name, and an ever increasing number of regulators are requiring  evidence FROM IA processes so that organizations demonstrate that they are actually complying with their own policies. This should not be a hardship, if your corporate security culture was adequate, this would not be an issue. Look to the senior leadership, it they don’t care, no-one else will.

I have stated over and over again that if you were doing security properly, EVERY compliance regulation on the planet would fall out the back-end (plus or minus some customised reporting). Not one has ever, and likely WILL never go above industry accepted best practices, as no-one is looking for perfection, just risk-reduction enough.

It makes perfect sense to me therefore that you would put a watcher on the watchers. Security have their fingers in almost every business pie, just to make sure that proper security controls are built in from the beginning. Like Legal, security is there to save the business from itself, and done properly, it should NEVER get in the way.

This can lead to a certain complaisance, or blinkered view of the world, IA can provide the necessary perspective to continually test processes that that could potentially stagnate if not seen through an objective lens. And who knows, because IA generally have direct (if dotted line) access senior leadership, there is a very good chance your requests for budget/resources will be looked on favorably if supported by an entity mostly immune from repercussions.

In this context therefore, Internal Audit is the conscience of Security; Are the controls enough?; Are they too much?; Are they easily measured?; are they flexible enough to adapt to business goals?; etc…

From the very first policy draft, to the almost ubiquitous Plan, Do, Check, Act of ISO 2700X, security professionals need to look to IA for support and guidance, but the opposite is equally true. IA can tend to rely on their unassailable positions to hide behind lack of expertise in security subject matter, they need to work just as closely with security to make sure they are up to the task.