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I spy with my beady eye ...

24 Apr 2021

Pre-shocks and after-shocks



Just a brief note today: it's a lovely sunny Saturday morning down here and I have Things To Do.

I'm currently enjoying another book by one of my favourite tech authors: Yossi Sheffi's The Resilient Enterprise*. As always, Yossi spins a good yarn, illustrating a strong and convincing argument with interesting, relevant examples leading to sound advice.

Specifically, I'm intrigued by the notion that major incidents/disasters leading to severe business disruption don't always come "out of the blue". Sometimes (often?), there are little warning signs, hints ahead of time about the impending crisis, little chances to look up from the daily grind and perhaps brace for impact. It ought to be possible to spot fragile supply chains, processes, systems and people, provided we are looking out for them ...   

Here in NZ at the moment, we are being treated to a public safety campaign using the analogy of meerkats, encouraging Kiwis to be constantly on the alert for signs of danger, thinking ahead and hopefully avoiding accidents rather than taking silly chances.  It makes sense. 

So I'm thinking perhaps we should update our template policies on incident reporting and/or incident management to encourage workers to report early warning signs, troubling concerns or situations early, before they turn into actual incidents (which also need to be reported, of course). It's a nice example of the value of security awareness.

* Less than ten bucks from Amazon in hardback, I see today. Even at full price, this book is a bargain, well worth it: now it's a steal! Grab it while it's hot!   

23 Apr 2021

KISS or optimise your ISO27k ISMS?

From time to time as we chat about scoping and designing Information Security Management Systems on the ISO27k Forum, someone naively suggests that we should Keep It Simple Stupid. After all, an ISO27k ISMS is, essentially, simply a structured, systematic approach for information risk management, isn't it?

At face value, then, KISS makes sense.

In practice, however, factors that complicate matters for organizations designing, implementing and using their ISMSs include different:

  • Business contexts – different organization sizes, structures, maturities, resources, experiences, resilience, adaptability, industries etc.;
  • Types and significances of risks – different threats, vulnerabilities and impacts, different potential incidents of concern;
  • Understandings of ‘information’, ‘risk’ and ‘management’ etc. – different goals/objectives, constraints and opportunities, even within a given organization/management team (and sometimes even within someone’s head!);
  • Perspectives: the bungee jumper, bungee supplier and onlookers have markedly different appreciations of the same risks;
  • Ways of structuring things within the specifications of ‘27001, since individual managers and management teams have the latitude to approach things differently, making unique decisions based on their understandings, prejudices, objectives and priorities, choosing between approaches according to what they believe is best for the organization (and themselves?) at each point;
  • Pressures, expectations and assumptions by third parties … including suppliers, partners and customers, certification auditors and specialists just like us … as well as by insiders;
  • Dynamics: we are all on constantly shifting sands, experiencing/coping with and hopefully learning from situations, near-misses and incidents, adapting and coping with change, doing our best to predict and prepare for uncertain futures.

As with computer applications and many other things, simplicity obviously has a number of benefits, whereas complexity has a number of costs. Not so obviously, the opposite also applies: things can be over simplified or overly complicated:

  • An over-simplified ISMS, if certifiable, will typically be scoped narrowly to manage a small subset of the organization's information risks (typically just its "cyber" risks, whatever that actually means), missing out on the added value that might be gained by managing a wider array of information risks in the same structured and systematic manner. A minimalist ISMS is likely to be relatively crude, perhaps little more than a paper tiger implemented purely for the sake of the compliance certificate rather than as a mechanism to manage information risks (an integrity failure?). Third parties who take an interest in the scope and other details of the ISMS may doubt the organization's commitment to information risk management, information security, governance, compliance etc., increasing their risks of relying on the certificate. There's more to this than ticking-the-box due diligence - accountability and compliance, for instance.
  • Conversely, an over-complicated ISMS may also be a paper tiger, this time a bureaucratic nightmare that bogs down the organization's recognition and response to information risks and incidents. It may take "forever" to get decisions made and implemented, outpaced by the ever-changing landscape of security threats and vulnerabilities, plus changes in the way the organization uses and depends on information. The ISMS is likely to be quite rigid and unresponsive - hardly a resilient, flexible or nimble approach. If the actual or perceived costs of operating the ISMS even vaguely approach the alleged benefits, guess what: managers are unlikely to support it fully, and will be looking hard for opportunities to cut funding, avoid further investment and generally bypass or undermine the red tape.

So, despite its superficial attraction, KISS involves either: ;

  • Addressing these and other complicating factors, which implies actively managing them in the course of designing, using and maintaining the ISMS, and accepting that simplicity per se may not be a sensible design goal; or
  • Ignoring them, pretending they don't exist or don't matter, turning a blind ear to them and hoping for the best.
Paradoxically, it is quite complicated and difficult to keep things simple! There are clearly several aspects to this, some that are very tough to ‘manage’ or ‘control’ and many that are interrelated.

I'm hinting at information risks associated with the governance, design and operation of an ISMS - information risks that can be addressed in the conventional manner, meaning whatever convention/s you prefer, perhaps the ISO27k approach, so (using this situation as a worked example) what does that entail?

  1. Establish context: for the purposes of the blog, the scope of this illustrative risk assessment is the design and governance of an ISMS, in the context of any organization setting out to apply ISO/IEC 27001 from scratch or reconsidering its approach for some reason (perhaps having just read something provocative on a blog ...).

  2. Identify viable information risks: I've given you a head start on that, above. With sufficient head-scratching, you can probably think of others, either variants/refinements of those I have noted or risks I have missed altogether. To get the most out of this exercise, don't skip this step. It's a chance to practice one of the trickier parts of information risk management.

  3. Analyze the risks: this step involves exploring the identified risks in more depth to gain a better understanding/appreciation of them. I've been 'analyzing' the risks informally as I identified and named them ... but you might like to think about them, perhaps consider the threats, vulnerabilities, potential incidents and the associated impacts. For example, what are the practical implications of an over-simplified or over-complicated ISMS? What are the advantages of getting it just right? How much latitude is there in that? Which are the most important aspects, the bits that must be done well, as opposed to those that don't really matter as much?
  4. Evaluate the risks: my personal preference is to draw up a PIG - a Probability vs. Impact Graph - then place each of the risks on the chart area according to your analysis and understanding of them on those two scales, relative to each other. Alternatively, I might just rank them linearly. If you prefer some other means of evaluating them, fine, go ahead. The real point is to get a handle on the risks, ideally quantifying them to help decide what, if anything, needs to be done about them, and how soon it ought to be done (i.e. priorities).

  5. Treat the risks has at least two distinct steps: (5a) decide what to do, then (5b) do it. Supplementary activities may include justifying, planning, gaining authorization for and seeking resources to undertake the risk treatments, plus various management, monitoring and assurance activities to make sure things go to plan - and these extras are, themselves, risk-related. "Critical" controls typically deserve more focus and attention than relatively minor ones, for instance. Gaining sufficient assurance that critical controls are, in fact, working properly, and remain effective, is an oft-neglected step, in my experience.

  6. Communicate: the written and spoken words, notes, diagrams, PIGs, priority lists, control proposals, plans etc. produced in the course of this effort are handy for explaining what was done, what the thinking behind it was, and what was the outcome. It's worth a moment to figure out who needs to know about this stuff, what are the key messages, and where appropriate how to gain engagement or involvement with the ISMS work. There are yet more information risks in this area, too e.g. providing inaccurate, misleading or out of date information, communicating ineptly with the wrong people, and perhaps disclosing sensitive matters inappropriately.

  7. Monitor and review the risks, risk treatments etc. is (or rather, should be!) an integral part of managing the ISMS design and implementation project, and a routine part of governance and management once the ISMS is operational. The ISMS management reviews, internal audits and external/certification audits are clear examples of techniques to monitor and review, with the the aim of identifying and dealing with any issues that arise, exploiting opportunities to improve and mature, and generally driving out the business value achieved by the ISMS. For me, ISMS metrics are an important part of this, and once more there are risks relating to measuring the wrong things, or measuring things wrong.
So, there we have it. You may still feel that KISS is the obvious way to go, and good luck if you do. Personally, I believe I can improve on KISS to design an optimal ISMS that best satisfies the organization's business objectives, generating greater value. Would you like to put me to the test? Do get in touch: I'm sure I'll enjoy advising you ... at my usual bargain rate!

19 Apr 2021

Policy development process: phase 2

Today we completed and published a new "topic-specific" information security policy template on clear desk and screen.

Having previously considered information risks within the policy scope, writing the policy involved determining how to treat the risks and hence what information security or other controls are most appropriate.  

Here we drew on guidance from the ISO27k standards, plus other standards, advisories and good practices that we've picked up in the course of ~30 years in the field, working with a variety of industries and organizations - and that's an interesting part of the challenge of developing generic policy templates. Different organizations - even different business units, departments, offices or teams within a given organization - can take markedly different attitudes towards clear desk and screen. The most paranoid are obsessive about it, mandating controls that would be excessive and inappropriate for most others. Conversely, some are decidedly lax, to the point that information is (to my mind) distinctly and unnecessarily vulnerable to deliberate and accidental threats. We've picked out controls that we feel are commonplace, cost-effective and hence sensible for most organizations.

COVID19 raises another concern, namely how the risks and controls in this area vary between home offices or other non-corporate 'working from home' workplaces, compared to typical corporate offices and other workplaces. The variety of situations makes it tricky to develop a brief, general policy without delving into all the possibilities and specifics. The approach we've taken is to mention this aspect and recommend just a few key controls, hoping that workers will get the point. Customers can always customise the policy templates, for example adding explicit restrictions for particular types of information, relaxing things under certain conditions, or beefing-up the monitoring, oversight and compliance controls that accompany the policies - which is yet another complicating factor: the business context for information security policies goes beyond the written words into how they are used and mandated in practice.

Doing all of this in a way that condenses the topic to just a few pages of good practice guidance, well-written in a motivational yet generic manner, and forms a valuable part of the SecAware policy suite, explains the hours we've sunk into the research and writing. Let's hope it's a best seller!

   


 

13 Apr 2021

Policy development process: phase 1

On Sunday I blogged about preparing four new 'topic-specific' information security policy templates for SecAware. Today I'm writing about the process of preparing a policy template.

First of all, the fact that I have four titles means I already have a rough idea of what the policies are going to cover (yes, there's a phase zero). 'Capacity and performance management', for instance, is one requested by a customer - and fair enough. As I said on Sunday, this is a legitimate information risk and security issue with implications for confidentiality and integrity as well as the obvious availability of information. In my professional opinion, the issue is sufficiently significant to justify senior management's concern, engagement and consideration (at least). Formulating and drafting a policy is one way to crystallise the topic in a form that can be discussed by management, hopefully leading to decisions about what the organisation should do. It's a prompt to action.

At this phase in the drafting process, I am focused on explaining things to senior management in such a way that they understand the topic area, take an interest, think about it, and accept that it is worth determining rules in this area. The most direct way I know of gaining their understanding and interest is to describe the matter 'in business terms'. Why does 'capacity and performance management' matter to the business? What are the strategic and operational implications? More specifically, what are the associated information risks? What kinds of incident involving inadequate capacity and performance can adversely affect the organization?

Answering such questions is quite tough for generic policy templates lacking the specific business context of a given organisation or industry, so we encourage customers to customise the policy materials to suit their situations. For instance:

  • An IT/cloud service company would probably emphasise the need to maintain adequate IT capacity and performance for its clients and for its own business operations, elaborating on the associated IT/cyber risks.
  • A healthcare company could mention health-related risk examples where delays in furnishing critical information to the workers who need it could jeopardise treatments and critical care.
  • A small business might point out the risks to availability of its key workers, and the business implications of losing its people (and their invaluable knowledge and experience i.e. information assets) due to illness/disease, resignation or retirement. COVID is a very topical illustration.
  • An accountancy or law firm could focus on avoiding issues caused by late or incomplete information - perhaps even discussing the delicate balance between those two aspects (e.g. there are business situations where timeliness trumps accuracy, and vice versa).

The policy templates briefly discuss general risks and fundamental principles in order to orient customers in the conceptual space, stimulating them (we hope) to think of situations or scenarios that are relevant to their organisations, their businesses or industries, and hence to their management.

'Briefly' is an important point: the discussion in this blog piece is already lengthier and more involved than would be appropriate for the background or introductory section of a typical policy template. It's easy for someone as passionate and opinionated as me to waffle-on around the policy topic area, not so easy to write succinctly and remain focused ... which makes policy development a surprisingly slow, laborious and hence costly process, given that the finished article may be only 3 or 4 pages. It's not simply a matter of wordsmithing: distilling any topic down to its essentials takes research and consideration. What must be included, and what can we afford to leave out? Which specific angles will stimulate senior managers to understand and accept the premise that 'something must be done'?

OK, that's it for today. Must press on - policy templates to write! I'll expand on the next phase of the policy development process soon - namely, how we flesh out the 'something that must be done' into explicit policy statements.


11 Apr 2021

Infosec policy development

We're currently preparing some new information risk and security policies for SecAware.com.  It's hard to find gaps in the suite of ~80 policy templates already on sale (!) but we're working on these four additions:

  1. Capacity and performance management: usually, an organization's capacity for information processing is managed by specialists in IT and HR.  They help general management optimise and stay on top of information processing performance too.  If capacity is insufficient and/or performance drops, that obviously affects the availability of information ... but it can harm the quality/integrity and may lead to changes that compromise confidentiality, making this an information security issue.  The controls in this policy will include engineering, performance monitoring, analysis/projection and flexibility, with the aim of increasing the organisation's resilience. It's not quite as simple as 'moving to the cloud', although that may be part of the approach.

  2. Information transfer: disclosing/sharing information with, and obtaining information from, third party organisations and individuals is so commonplace, so routine, that we rarely even think about it.  This policy will outline the associated information risks, mitigating controls and other relevant approaches.

  3. Vulnerability disclosure: what should the organisation do if someone notifies it of vulnerabilities or other issues in its information systems, websites, apps and processes? Should there be mechanisms in place to facilitate, even encourage notification? How should issues be addressed?  How does this relate to penetration testing, incident management and assurance?  Lots of questions to get our teeth into!

  4. Clear desks and screens: this is such a basic, self-evident information security issue that it hardly seems worth formulating a policy. However, in the absence of policy and with no 'official' guidance, some workers may not appreciate the issue or may be too lazy/careless to do the right thing. These days, with so many people working from home, the management oversight and peer pressure typical in corporate office settings are weak or non-existent, so maybe it is worth strengthening the controls by reminding workers to tidy up their workplaces and log off.  It's banale, not hard! 
The next release of ISO/IEC 27002 will call these "topic-specific information security policies" focusing on particular issues and/or groups of people in some detail, whereas the organisation's "information security policy" is an overarching, general, high-level framework laying out (among other things) the fundamental principles. Our corporate information security policy template is a mature product that already includes a set of principles, so it may not need changes to comply with the updated ISO/IEC 27002 when published later this year or early next ... but we'll seize the opportunity to review it anyway.