Policy governance

Kaspersky blogged about security policies in the context of human factors making organizations vulnerable to malware:
"In many cases, policies are written in such a difficult way that they simply cannot be effectively absorbed by employees. Instead of communicating risks, dangers and good practices in clear and comprehensive instructions, businesses often give employees multipage documents that everyone signs but very few read – and even less understand."
That is just the tip of an iceberg. Lack of readability is just one of at least six reasons why corporate security policies are so often found lacking in practice:
  • Lack of scope: ‘security policies’ are typically restricted to IT/cyber security matters, leaving substantial gaps, especially in the wider aspects of information risk and security such as human factors, fraud, privacy, intellectual property and business continuity.

  • Lack of consistency: policies that were drafted by various people at various times for various reasons, and may have been updated later by others, tend to drift apart and become disjointed. It is not uncommon to find bald contradictions, gross discrepancies or conflicts. Security-related obligations or expectations are often scattered liberally across the organization, partly on the corporate intranet, partly embedded in employment contracts, employee handbooks, union rulebooks, printed on the back of staff/visitor passes and so on. 

  • Lack of awareness: policies are passive, formal and hence rather boring written documents - dust-magnets. They take some effort to find, read and understand. Unless they are accompanied by suitable standards, procedures, guidelines and other awareness materials, and supported by structured training, awareness and compliance activities to promote and bring them to life, employees can legitimately claim that they didn’t even know of their existence - which indeed they often do when facing disciplinary action. 

  • Lack of accountability: if it is unclear who owns the policies and to whom they apply, noncompliance is the almost inevitable outcome. This, in turn, makes it risky for the organization to discipline, sack or prosecute people for noncompliance, even if the awareness, compliance and enforcement mechanisms are in place. Do your policies have specific owners and explicit responsibilities, including their promotion through awareness and training? Are people - including managers - actually held to account for compliance failures and incidents?

  • Lack of compliance: policy compliance and enforcement activities tend to be minimalist, often little more than sporadic reviews and the occasional ticking-off. Circulating a curt reminder to staff shortly before the auditors arrive, or shortly after a security incident, is not uncommon. Policies that are simply not enforced for some reason are merely worthless, whereas those that are literally unenforceable (including those where strict compliance would be physically impossible or illegal) can be a liability: management believes they have the information risks covered while in reality they do not. Badly-written, disjointed and inconsistent security policies are literally worse than useless.
Many of these issues can be traced back to lacking or inconsistent policy management processes. Policy ownership and purpose are often unclear. Even simple housekeeping activities such as version control and reviews are beyond many organizations, while policies generally lag well behind emerging issues.

That litany of issues and dysfunctional organizational practices stems from poor governance ... which intrigues me to the extent that I'm planning to write an article about it in conjunction with a colleague. He has similar views to me but brings a different perspective from working in the US healthcare industry. I'm looking forward to it.

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