The Matrix, policy edition

Inspired by an insightful comment on LinkeDin from an SC 27 colleague on the other side of the world (thanks Lars!), I spent most of last week updating the SecAware security policy templates and ISO27k ISMS materials.

The main change was to distinguish conformity from compliance - two similar terms that I admit I had been using loosely and often incorrectly for far too long. As I now understand them:

  • Compliance refers to fulfilling binding (mandatory) legal, regulatory and contractual obligations;
  • Conformity concerns fulfilling optional (discretionary) requirements in standards, agreements, codes of ethics etc. 

It's a fine distinction with implications for the associated information risks, given differing impacts:

  • Noncompliance may lead to legal enforcement action (fines/penalties), other costly sanctions (such as more intrusive monitoring by the authorities and perhaps revocation of operating licenses) and business issues (such as reputational damage and brand devaluation, plus the costs of defending legal action). 
  • The consequences of nonconformity may be trivial or nothing at all if nobody even cares, but can also involve business issues such as inefficiencies, excess costs and so on, particularly if customers, business partners, the authorities or other stakeholders are seriously concerned at management's apparent disregard for good security practices.
Certification of an organisation's ISMS, then, demonstrates its conformity with, not compliance to, ISO/IEC 27001 - well in most cases anyway, where management voluntarily chooses to adopt and conform to the standard. If they are obliged by some mandatory, legally-binding requirement (an applicable law or regulation, or perhaps terms in a formal contract with a supplier or customer, perhaps due to a law or regulation that pplies to them), I guess they must comply.
 
Putting that another way, nonconformity is an option. Noncompliance isn't.

Anyway, having adjusted the terminology and tweaked the SecAware materials, I took the opportunity to prepare two new 'bulk deal' packages - a comprehensive suite of information security policy templates, and a full set of ISO27k ISMS materials. I'm hoping to persuade customers to spend invest a little more for greater returns. 

The SecAware policies, for instance, are explicitly designed to work best as a whole, an integrated and coherent suite as opposed to an eclectic collection of policies on various discrete topics. In recent years, I have developed a spreadsheet to track the mesh of relationships between policies:


Yellow blobs on the matrix indicate touch-points between policies, issues of common concern. For example, blobs in the access control policy column mean the policy is related in some way to policies on business relationships, clear desk and screen, cryptography, database security and so on. 

If, say, a organisation has an access control policy but currently lacks a policy on the information risk and security aspects of business relationships (e.g. with its Internet and cloud service providers), that may represent a gap in its policy framework unless the access control policy happens to cover business relationship security as well. Likewise with all the other related aspects. While technically it would be possible for the access control policy to cover the lot, in practice that would be 'suboptimal', resulting in an unfocused, unweildy, convoluted and confusing policy, especially if each policy went into detail on related topics.

[Trust me, I know. BTDT. Years back I developed an 'Information security policy manual' as a single document. It was a headache to maintain and having grown to about 150 pages, a nightmare to read and understand. The 'policy suite' approach with a collection of topic-specific policies works better for me and our clients.]

The relationships are bidirectional, by the way: access control is relevant to business relationship security, and vice versa. That markedly simplifies the matrix since blobs to the right of the black diagonal would be a mirror image of those to the left.

The matrix is a surprisingly useful policy management tool, a simple, visual way to maintain the complex relationships between policies in the suite. A few days ago, for instance, I added entries for three new policies on responsible disclosure, threat intelligence and data masking/redaction. Updating the matrix involves determining, for each policy, which related areas are significant enough to merit blobs. It's worth checking that the linked policies don't both cover the same issues, at least not in any detail and especially not in conflicting terms - although, having personally written and regularly maintained these policies for decades, I already have a pretty good idea about what the related policies do and don't say. It's getting harder, though, as the suite approaches 80 topic-specific policies (!) plus 8 Acceptable Use Policies and an overarching Corporate Information Security Policy and, frankly, I'm getting on a bit.

The security architectural objective is to ensure that all relevant policy matters are covered clearly and unambiguously, leaving no significant gaps or overlaps. The policies need to interlock, supporting each other and strengthening the entire control construct. That's important from a governance perspective since policies are a primary mechanism for exerting management direction and control over the organisation.

So, there you have it, a Hinson tip for managing a complex mesh of information security or indeed other policies, something worth contemplating at least. I commend it to the house.

Popular posts from this blog

Pragmatic ISMS implementation guide (FREE!)

Image
Early this morning ( very  early!) I remotely attended an ISO/IEC JTC 1/SC 27/WG 1 editing meeting in London discussing the planned revision of ISO/IEC 27003:2017 . Overall, the meeting was very productive in that we got through a  long  list of expert comments on the preliminary draft standard, debated the objectives of the project and the standard and reached consensus on most points. In summary: 27003 is to be revised to align with the current 2022 releases of ISO/IEC 27001 , 27002 and 27005 : These changes are  mostly  minor aside from the new section 6.3 on ISMS changes.
Read more

Two dozen information risks that ISO forgot

Image
Selecting the wrong controls - controls that are inappropriate, ineffective, too costly, impracticable, fragile, unnecessary, counterproductive or whatever, often as a result of blind faith in fads and fashions of the day and FOMO e.g. MFA, AI, cyber Failing to select the right controls - controls that are ideal for the particular situation, both now and in perpetuity, for whatever reason - mostly ignorance and prejudice Selecting and implementing controls at the wrong time or in the wrong way (where 'wrong' includes ineffective, inappropriate, sub-optimal e.g. bolting on controls rather than designing and building them in) Inept and inaccurate identification, analysis and quantification of risk, including reliance on p oor quality (incomplete, inaccurate, out of date, misleading, unreliable ...) information about actual risks, particularly subtle and emerging risks plus those involving deliberate concealment and misdirection e.g. fraud, misinformation, disinformation, propagan
Read more

Philosophical phriday - compliance risk

Image
According to a vendor's promotional video interview I saw recently, the 'cybersecurity compliance burden' has allegedly become so significant that [customer] organisations are eagerly buying [their] software tools and services to help them manage and fulfil their obligations. The vendor's argument goes that, instead of accumulating a ragtag bunch of policies and other controls relating to user Identification and Authentication (I&A), for instance, it makes sense to:  Identify all the cybersecurity-related laws, regulations and standards that apply to the organisation; Examine them for any security control requirements relating to, say, I&A; Rationalise the I&A controls down to the smallest set that satisfies all the requirements - the lowest common denominator; Design, implement, use, manage and maintain those I&A controls; Have the I&A controls checked or audited to gain assurance that the compliance requirements are met.  OK so far? Sounds reasonab
Read more

ISMS internal audit priorities

Image
A thread on the ISO27k Forum sparked my imagination over coffee this morning. Hope had previously asked for assistance with an ISO/IEC 27001:2022 audit plan.  Bhushan offered a lengthy and generally sound response explaining how to use a spreadsheet with tabs to plan and record the audit work performed on 100% of the main body clauses and 50% of the 93 Annex A controls, day-by-day. That's OK ... except it wasn't entirely clear that he was interpreting and elaborating on the standard's actual requirements. ISO/IEC 27001 does not explicitly require, for example, that (as Bhushan stated) "ALL the management system clauses from 4 to 10 AND their sub-clauses need to be listed and audited" in an ISMS internal audit, although evidently he interprets it in that way. In clause 9.2.1, the standard states a requirement for internal audits to provide information on whether the ISMS conforms to the organization’s own requirements for the ISMS plus the requirements of the stan
Read more

Reading between the lines of ISO27001 [L O N G]

Image
ISO/IEC 27001 is a succinct, formally-worded standard for two key reasons: It is deliberately generic, being applicable to all manner of organisations regardless of difference in location/s, size, industry, maturity, structure, information risk and security status ... and so on. In effect, it specifies the lowest common denominator - the things that ALL organisations should be doing to manage their information security controls, as a minimum. The hurdle is set low enough that every organisation ought to find value in designing, implementing and operating an I nformation S ecurity M anagement S ystem as laid out in the standard. It is a certifiable standard, explicitly specifying the characteristics that every certified organisation's ISMS is expected to have. Again, it is a minimal specification with no concept of typical, average or maximum security: that is entirely down to the organisations themselves to determine, following the information risk management processes minimally de
Read more

Passionate dispassion

Image
Someone who is actively involved in, or is managing, an activity is patently not independent of it. They may well make a conscious, rational and determined effort to be objective, dispassionately reviewing evidence etc ., but their subconscious/emotional biases/prejudices and beliefs/value-systems will inevitably influence what they do. With the best will in the world, they will struggle to challenge and assess their past decisions and activities, especially if they were "certain" or "determined" or genuinely believed they were "doing the right thing". Furthermore, it is very hard for anyone to review the things they did not do, decisions they did not make or options they did not even consider. Mostly, they remain out of sight or out of the question.
Read more

45 ISO Management Systems Standards

Image
The ISO website  currently lists 45 published M anagement S ystems S tandards: 1. ISO 7101:2023 Healthcare organization management — Management systems for quality in healthcare organizations — Requirements 2. ISO 9001:2015 Quality management systems — Requirements 3. ISO 10012:2003 Measurement management systems — Requirements for measurement processes and measuring equipment 4. ISO 13485:2016 Medical devices — Quality management systems — Requirements for regulatory purposes 5. ISO 14001:2015 Environmental management systems — Requirements with guidance for use 6. ISO 14298:2021 Graphic technology — Management of security printing processes
Read more

Philosophical phriday - a noncompliance ramble

Image
In a previous philosophical phriday post , I moaned about vendors of security compliance support/management tools and services over-promising and under-delivering - an admittedly biased, even cynical opinion piece about the compliance imperative . A recent article in Corporate Compliance Insights notes that "CISOs are not just defenders against cyber threats but also champions of compliance and operational resilience". Hmmm, are CISOs 'compliance champs', really? Today, I'm discussing alternatives to being compliance-driven. How else can organisations drive their information risk, security and related concerns in a positive direction?
Read more

Adaptive SME security Crowdstrike special

Image
As if on cue, along comes a golden opportunity to consider what the Adaptive SME security  approach has to say regarding the Crowdstrike incident: That's not 20/20 hindsight but foresight: I've picked out the most relevant rows from the security controls table published in the guide 24 hours before the incident.  Although Crowdstrike primarily supplies much larger enterprises than SMEs, the incident could equally have afflicted other security software, or indeed operating systems such as Windows and assorted cloud apps commonly used by SMEs. Regardless of the details, it is a wake-up call, an opportunity to consider and respond to the information risks ... and to adapt , accordingly.
Read more