NIST RMF vs Adaptive SME Security

NIST has just released SP 1314 Risk Management Framework (RMF) Small Enterprise Quick Start Guide as a lightweight form/introduction to the full RMF.


... and, despite having said the steps are not necessarily sequential ...




It's interesting to compare and contrast the NIST RMF against the Adaptive SME Security approach we released just last week: 




Relative to the Adaptive approach, RMF places more emphasis on assurance and authorisation, reflecting NIST's classical approach for the sprawling US defence industry, where the substantial risks of infiltration and compromise of supply chains by "forrners" (spies and spooks) implies the need for strong controls and governance.

As a former (reformed!) auditor, I certainly appreciate the value of assurance and management information in general, so maybe the Adaptive approach should offer stronger guidance in that area. However, I'm not entirely convinced of the value of stronger assurance for SMEs, especially for micro-SMEs. For example, the costs relating to, say, penetration testing or '27001 certification audits can be disproportionately high for micro-SMEs compared to larger organisations - not out of the question, just hard to justify as a legitimate investment, given such limited resources.

I'm idly wondering if there is some way to reduce the assurance costs for micro-SMEs without decimating the benefits - some sort of lightweight assurance maybe?  Perhaps self-assessment would work, based on a maturity approach similar to the controls table in the Adaptive guideline. Or even simpler checklists prompting SME management to review, consider and evaluate their situation.

At the same time, RMF uses "system" to mean IT system, I think, rather than the broader interpretation as a collection of organisational resources  and activities associated with achieving objectives (or something along those lines). Perhaps NIST might consider explicitly extending the risk landscape beyond the IT sphere.

Hmmmmmmmmm.

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

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