I actually feel kinda silly writing this blog because the answer to the subject question seems so obvious. But even among seasoned cybersecurity professionals, the question of the CISO’s reporting structure has taken on a life of its own. I cannot imagine a more pointless debate.
But, for the sake of argument – and to keep this blog short – let’s assume there are only 2 types of ‘reporting’:
- To a direct line manager (Administrative Reporting); and
- To the recipients of the CISO’s functional output (Functional Reporting).
The most appropriate example for this – due to it’s many similarities – is Internal Audit (IA). I’ve never seen these folks administratively report to a manager who is not either the Chief Financial Officer (CFO) or the Chief Legal Officer (CLO)/General Counsel (GC). Nor would I ever expect to, as what they do is so well established that no-one questions their hierarchy.
Why is cybersecurity more complicated?
The very concept of IA dictates that their administrative management cannot influence their output in any way. I believe such conflict of interest actually goes against some regulations/legislations. Not only must they have this complete autonomy in the creation of their output, they must have total immunity from any backlash related to its content. Especially from their direct line managers, in whose hands the auditor’s career rests.
Same for the CISO.
For IA, the recipients of the functional output just happen to be their protectors as well; The Board of Directors (or CEO if the BoD does not exist). This ‘dotted-line’ reporting structure allows the auditor’s to report the whole truth to the ultimate decision makers without fear of retribution.
Same for the CISO.
So why is the CISO role so different? Does it really matter to whom they report administratively as long as they have both access to, and the protection of the BoD? Just like IA, the only thing a CISO should have to worry about is their own ability/competence to perform the function. And if, as I HIGHLY recommend, make the CISO role a Board appointment (or don’t bother having one), both the BoD and CISO are fully aware of each other’s responsibilities in this regard.
So if you accept that it’s really only the BoD dotted-line that matters, to whom should the CISO report administratively to help avoid the inevitable politics?
Common CISO Administrative Reporting Structures
- Direct to the CEO – This is the ideal of course, as you can usually assume that to have this hands-on approach the CEO takes security seriously. Seriously enough anyway. That said, in this configuration the BoD must take a more active role in order to ensure full CISO independence;
- To the CSO – A true CSO will generally have more than just data security as their remit, but CISO and CSO are very often used interchangeably. So depending on what the CSO actually does, this can be a good fit if s/he does not interfere with the CISO’s access to the BoD;
- To the CTO – To me this is almost the definition of conflict of interest, this never works even if the BoD dotted-line is in full effect;
- Any other member of the C-Level – At this point, the duties of the CISO are so far removed from the knowledge/skill-set of their manager that it almost doesn’t matter which one you choose. This will be ‘administrative-only’ reporting to the nth degree. But as long as the CISO’s relationship with the BoD is healthy, this should not detract from the CISO’s ability to get the job done; and/or
- Below C-Level – If the CISO role is more than 2 layers beneath the CEO, don’t bother having one, it’s clear neither the CEO or the BoD gives a damn.
Frankly, the CISO’s reporting structure is irrelevant if you haven’t chosen the right CISO for the right reasons. And AS a CISO, if you had no input to your reporting structure why did you take the job in the first place?
I am reminded of the eternal classic “The Hitchhiker’s Guide to the Galaxy” by Douglas Adams:
“Forty-two!” yelled Loonquawl. “Is that all you’ve got to show for seven and a half million years’ work?”
“I checked it very thoroughly,” said the computer, “and that quite definitely is the answer. I think the problem, to be quite honest with you, is that you’ve never actually known what the question is.”
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