Since ISO27k is [information]
risk-driven, poor quality risk management is a practical as well as a
theoretical problem.
In practical terms,
misunderstanding the nature of [information] risk, particularly the ‘vulnerability’
aspect, leads to errors and omissions in the identification, analysis and hence
treatment of [information] risks. The most common issue I see is people
equating ‘lack of a control’ with ‘vulnerability’. To me, the
presence or absence of a control is quite distinct from the vulnerability, in
that vulnerability is an inherent weakness or flaw in something (e.g. an
IT system, an app, a process, a relationship, contract or whatever. Even
a control has vulnerabilities, yet we tend to forget or discount or simply
ignore the fact that controls aren’t perfect: they can and do fail in practice,
with several information risk management implications). Think about it:
when was the last time you seriously considered the possibility that a control
might fail? Did you identify, evaluate and treat that secondary risk, in
a systematic and formal manner … or did you simply get on with things
informally? Have you ever done a risk analysis on your “key controls”? Do you actually know which of your organization’s controls are “key”, and
why? That's a bigger ask than you may think. Try it and you'll soon find out, especially if you ask your colleagues for their inputs.
In theoretical terms, risk is
all about possibilities and uncertainties i.e. probability. Using
simplified models with defined values, it may be technically possible to
calculate a precise probability for a given situation under laboratory
conditions, but that doesn’t work so well in the real world which is more
complex and variable, involving factors that are partially unknown and
uncontrolled. We have the capability to model groups of events,
populations of threat actors, types of incident etc. but accurately predicting
specific events and individual items is much harder, verging on impossible in
practice. So even extremely careful, painstaking risk analysis still
doesn’t generate absolute certainty. It reduces the problem space to a
smaller area (which is good!), but not to a pinpoint dot (such precision that
we would know what we are dealing with, hence we can do precisely the
right things). What’s more, ‘extremely careful’ and ‘painstaking’ implies
slow and costly, hence the approach is generally infeasible for the kinds of
real-world situations that concern us. Our risk management resources are
finite, while the problem space is large and unbounded. The sky is awash
with risk clouds, and they are all moving!
Complicating things still
further, we are generally talking about ‘systems’ involving human beings
(individuals and organizations, teams, gangs, cabals and so on), not [just]
robots and deterministic machines. Worse, some of the humans are actively
looking to find and exploit vulnerabilities, to break or bypass our lovely
controls, to increase rather than decrease our risk. The real-world
environment or situation within which information risks exist is not just
inherently uncertain but, in part, hostile.
So, in the face of all that
complexity, there is obviously a desire/need to simplify things, to take short
cuts, to make assumptions and guesses, to do the best we can with the
information, time, tools and other resources at our disposal. We are
forced to deal with priorities and pressures, some self-imposed and some
imposed upon us. ISO27k attempts to deal with that by offering ‘good
practices’ and ‘suggested controls’. One of the ‘good practices’ is to
identify, evaluate and treat [information] risks systematically within
the real-world context of an organization that has business objectives,
priorities and constraints. We do the best we can, measure how well we’re
doing, and seek to improve over time.
At the same time, despite the
flaws, I believe risk management is better than specified lists of
controls. The idea of a [cut down] list of information security controls
for SMEs is not new e.g. “key controls” were specifically identified with
little key icons in the initial version of BS7799 I think, or possibly the code
of practice that preceded it. That approach was soon dropped because what
is key to one organization may not be key to another, so instead today’s ISO27k
standards promote the idea of each organization managing its own [information]
risks. The same concerns apply to other lists of ‘recommended’
controls such as those produced by CIS, SANS, CSA and others, plus those
required by PCI-DSS, privacy laws and other laws, regs and rulesets including
various contracts and agreements. They are all (including ISO27k)
well-meaning but inherently flawed. Better than nothing, but
imperfect. Good practice, not best practice.
The difference is that ISO27k
provides a sound governance framework to address the flaws systematically. It’s context-dependent, an adaptive rather than fixed model. I value that flexibility.