The title should be; Why YOUR Information Security Policies (ISP) are Pointless, but I figured this title was far more contentious/click-worthy.
If you’ve come this far, you’re in one of two groups:
- You’re horrified at my ignorance and want to rip me a new one (good for you by the way); or
- You’re thinking the equivalent of “I knew it!”, in which case you need this more than anyone.
When I say that your ISPs are pointless, it’s because in all likelihood they are. Assuming you even have a policy set (policies, standards and procedures), ~20 years of consulting experience has shown that they invariably:
- are not sponsored/supported/signed-off by the highest levels within and organisation – does anyone really care about something their bosses don’t visibly to care about?;
- are not managed by a governance function to ensure adherence to business goals / regulatory compliance / corporate responsibility etc – who else is going to do this? The CEO? A CXO by him/herself?;
- include no overarching framework policy that 1) spells out a commitment to security, 2) breaks down the responsibilities for everyone from the CEO to the interns, or 3) details the consequences for non-conformance – how well do buildings stand up without foundations?;
- are generic templates with zero attempt to fit them to the prevailing culture – sometimes the phrase “That’s not how we do things here!” is perfectly acceptable;
- are non-aspirational – it’s actually a good practice to set your policies above your current security capability, IF you have a comprehensive exception/variance process linked to a risk register / risk treatment plan as part of the framework;
- are not DIRECTLY linked to robust risk management processes to ensure full policy coverage and continuing suitability to the business – how do you know they’re right?, now and in the event of significant change?;
- are not part of an [annual] internal audit process to measure adherence – few companies even have an internal audit function, let alone one capable of assessing IT/IS policies;
- are not part of employee on-boarding and ongoing security awareness training programs – every role should have relevant policies assigned to it, and appropriate training should be continuous;
- are not maintained appropriately/consistently – you don’t need a librarian to do document management well, you just have to be organised; and
- are not distributed or made available to everyone whom they impact – “Policies, what policies?”
Bottom line is that I have never seen a policy set done well, and it’s not a coincidence that I’ve never seen security done well either. These two things go hand-in-hand and you absolutely cannot have one without the other.
Yes a decent policy set is ‘paperwork’, yes it’s bloody difficult and time consuming, and no, it’s not even remotely sexy, but don’t bother trying to get a security program in place without them. Seriously, don’t even bother, because it will fail.
Lego don’t send out a 4,000+ piece Death Star set without detailed build instructions, and that’s exactly what your policies, standards and procedures are; instructions on how to do security appropriately within your organisation.
So why don’t all security folks take this more seriously? Two main reasons; 1) they are so focused on technology that the processes fall to the wayside, and 2) they have tried over and over and finally gave up, electing to do what they can, knowing full well it will never be enough.
Security is about People, Process and Technology, in that order, because without a policy set you will have:
- no understanding of the technology[ies] you will need – risk assessment;
- no processes to run the technology properly – procedures;
- no way to sustain the technologies moving forward – vulnerability management;
- no understanding of what to do with technology output – incident response;
- no-one who could perform the incident response even if you did – security awareness training.
A decent set of information security policies ties all of this together into a sustainable program, and if you still don’t think they are that important, you are simply not paying attention.
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