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2.4 Security Governance Approach

Effective security governance requires the development and clear documentation of a framework, which is a structured approach for overseeing and managing risk for an enterprise. The implementation and ongoing use of the governance framework enables the organization’s governing body to set clear direction for and demonstrate their commitment to information security and risk management.

Security Governance Framework

The definition, monitoring, and maintenance of a security governance framework entails a number of tasks:

  • Appoint a single executive to be ultimately responsible for security governance, whose duties including implementing the framework and developing and monitoring an information security strategy and security assurance program. The framework needs to encompass all of the elements discussed in Section 2.3.

  • Decide and communicate to top executives the objectives of the security governance framework, including ensuring alignment with overall organization policies and goals, enhancing business value, and adequately managing risk.

  • Ensure integration of the security architecture with the enterprise architecture, as discussed in Section 2.3.

  • Include a process that enables the governing body to evaluate the operation of the information security strategy to ensure that it aligns with business needs the organization’s current risk appetite.

  • Regularly review the organization’s risk appetite to ensure that it is appropriate for the current environment in which the organization operates.

  • Formally approve the information security strategy, policy, and architecture.

Security Direction

A governing body is responsible for ensuring that there is effective security direction. Typically, the governing body consists of those individuals ultimately responsible for what the organization does. In a publicly held company, for example, this is the board of directors, supplemented by executive managers who have operational responsibility for various business units.

The Information Security Forum’s (ISF’s) Standard of Good Practice for Information Security (SGP) recommends that effective security direction be provided by a combination of a single individual responsible for information security supported by a governing body. The single individual is a CISO or equivalent executive. This individual’s responsibilities include implementing the organization’s overall approach and ensuring that a security mind-set permeates the organization. This latter requirement entails coordination and collaboration with executives, managers, and operations personnel.

The SGP also recommends that the governing body include the CISO and have a mission to support the CISO as well as review the activities that are under the CISO’s direction. Other members of the governing body could include the CIO, key department heads, and heads of business support functions such as human resources. The governing body assists in the coordination of security activities and ensuring that the CISO has the resources and authority required to effect needed changes. In addition, the governing body reports security status and plans to the stakeholders.

COBIT 5 provides a more elaborate governing body structure than the SGP suggests, and it is worthwhile for larger organizations. COBIT 5 distinguishes five distinct roles/structures:

  • Chief information security officer (CISO): The CISO has overall responsibility for the enterprise information security program. The CISO is the liaison between executive management and the information security program. The CISO should also work with key business stakeholders to address information protection needs. The CISO is responsible for:

    • Establishing and maintaining an ISMS

    • Defining and managing an information security risk treatment plan

    • Monitoring and reviewing the ISMS

  • Information security steering (ISS) committee: This committee ensures, through monitoring and review, that good practices in information security are applied effectively and consistently throughout the enterprise. The ISS committee is responsible for enterprisewide information security decision making in support of strategic decisions made by the enterprise risk management committee.

  • Information security manager (ISM): The ISM has overall responsibility for the management of information security efforts, including application security, infrastructure security, access management, threat and incident management, risk management, awareness program, metrics, and vendor assessments.

  • Enterprise risk management (ERM) committee: This committee is responsible for the decision making of the enterprise to assess, control, optimize, finance, and monitor risk from all sources for the purpose of increasing the enterprise’s short- and long-term value to its stakeholders.

  • Information custodians/business owners: These individuals serve as liaisons between the business and information security functions. They are associated with types of information, specific applications, or business units in an enterprise. They serve as trusted advisors and monitoring agents regarding information within the business.

COBIT 5 makes a distinction between the CISO and the ISM, with the CISO being a C-level position with oversight of an ISM, who has operational management responsibilities [ISAC08]. Other organizations combine the roles of CISO and ISM and may dispense with the CISO title.

Also, many organizations have a single security governing body, but COBIT 5 recommends a split into two committees for larger organizations. The ISS committee focuses on ensuring that security policies and practices are effectively implemented and monitored, and the ERM committee focuses on risk assessment. The suggested composition of the ISS committee is as follows:

  • CISO: Serves as ISS committee chair and liaison to the ERM committee.

  • ISM: Communicates design, implementation, and monitoring of practices.

  • Information custodians/business owners: Are in charge of certain processes or business applications; responsible for communicating business initiatives that may impact information security and information security practices that may impact the user community.

  • IT manager: Reports on the status of IT-related information security initiatives.

  • Representatives of specialist functions: May include, permanently or as needed, representatives from internal audit, human resources, and legal departments.

The suggested composition of the ERM committee is as follows:

  • CISO: Provides the committee with advice on specific information risks.

  • CEO, COO, CFO, etc.: One or more representatives of senior executive management.

  • Information custodians/business owner: Are in charge of certain processes or business applications; responsible for communicating business initiatives that may impact information security and information security practices that may impact the user community.

  • Audit/compliance representative: Advises committee on compliance risk.

  • Legal representative: Provides legal input.

  • CRO: Advises on risk from strategic, financial, operational, reputational, and compliance perspectives.

Responsible, Accountable, Consulted, and Informed (RACI) Charts

COBIT addresses the responsibility of all roles played by employees involved in IT governance actions. The COBIT responsibility model is formalized through a RACI chart matrix attached to all 34 COBIT processes. RACI explains what the responsibilities of all employees are regarding the key activities performance:

  • Responsible: A person doing an activity and expected to deliver or submit the assigned work portion within the given deadlines. For example, in the case of software development project, developers are responsible.

  • Accountable: A person with decision-making authority and who is expected to ensure the successful completion of project work. For example, a team leader or a project coordinator is accountable.

  • Consulted: A stakeholder who should be included in any decision making or work activity by being consulted prior to the decision or action. This may a person whose area of responsibility would be affected by the activity, such as a business unit manager, or a person whose expertise should be consulted, such as a technical professional.

  • Informed: A person who needs to know of decision making or actions after they occur. Such a person may have a direct concern in the outcome and progress of the work.

RACI charting helps avoid the following problems:

  • Unclear accountability between individuals or departments

  • Redundancies or work not being accomplished

  • Delayed or incomplete work

  • Inadequate communication and/or coordination

  • Unclear approval/decision-making processes

Table 2.4 shows a portion of the RACI chart for security governance. The table indicates which entity is accountable for each activity, and which entity or entities are responsible for that activity.

TABLE 2.4 Partial COBIT 5 RACI Chart for Organizational Structures

Activity

CISO

ISS

ISM

ERM

IC/BO

Identify and communicate information security threats, desirable behaviors, and changes needed to address these points.

A

 

R

 

 

Ensure that environmental and facilities management adheres to information security requirements.

A

 

R

 

 

Provide ways to improve efficiency and effectiveness of the information security function (for example, through training of information security staff; documentation of processes, technology, and applications; and standardization and automation of the process).

A

 

R

 

 

Define and communicate an information security strategy that is in line with the business strategy.

R

A

 

 

 

Research, define, and document information security requirements.

R

A

 

 

 

Validate information security requirements with stakeholders, business sponsors, and technical implementation personnel.

R

A

 

 

 

Develop information security policies and procedures.

R

A

 

 

 

Define and implement risk evaluation and response strategies and cooperate with the risk office to manage the information risk.

R

 

 

A

 

Ensure that the potential impact of changes is assessed.

R

A

 

 

 

Collect and analyze performance and compliance data related to information security and information risk management.

R

 

R

 

 

Raise the profile of the information security function within the enterprise and potentially outside the enterprise.

 

R

 

 

R

A = accountable

R = responsible

IC/BO = Information custodians/business owners

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