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Information Security Governance

Governance is the process of managing, directing, controlling, and influencing organizational decisions, actions, and behaviors. The ISO 27002:2013 Organization of Information Security domain objective is “to establish a management framework to initiate and control the implementation and operation of information security within the organization.” This domain requires organizations to decide who is responsible for security management, the scope of their authority, and how and when it is appropriate to engage outside expertise. Julie Allen, in her seminal work “Governing for Enterprise Security,” passionately articulated the importance of governance as applied to information security:

“Governing for enterprise security means viewing adequate security as a non-negotiable requirement of being in business. If an organization’s management—including boards of directors, senior executives and all managers—does not establish and reinforce the business need for effective enterprise security, the organization’s desired state of security will not be articulated, achieved or sustained. To achieve a sustainable capability, organizations must make enterprise security the responsibility of leaders at a governance level, not of other organizational roles that lack the authority, accountability, and resources to act and enforce compliance.”

The Board of Directors (or organizational equivalent) is generally the authoritative policy-making body and responsible for overseeing the development, implementation, and maintenance of the information security program. The use of the term “oversee” is meant to convey the Board’s conventional supervisory role, leaving day-to-day responsibilities to management. Executive management should be tasked with providing support and resources for proper program development, administration, and maintenance as well as ensuring strategic alignment with organizational objectives.

What Is a Distributed Governance Model?

It is time to bury the myth that “security is an IT issue.” Security is not an isolated discipline and should not be siloed. Designing and maintaining a secure environment that supports the mission of the organization requires enterprise-wide input, decision making, and commitment. The foundation of a distributed governance model is the principle that stewardship is an organizational responsibility. Effective security requires the active involvement, cooperation, and collaboration of stakeholders, decision makers, and the user community. Security should be given the same level of respect as other fundamental drivers and influencing elements of the business.

Chief Information Security Officer (CISO)

Even in the most security-conscious organization, someone still needs to provide expert leadership. That is the role of the CISO. As a member of the executive team, the CISO is positioned to be a leader, teacher, and security champion. The CISO coordinates and manages security efforts across the company, including IT, human resources (HR), communications, legal, facilities management, and other groups. The most successful CISOs successfully balance security, productivity, and innovation. The CISO must be an advocate for security as a business enabler while being mindful of the need to protect the organizational from unrecognized harm. They must be willing to not be the most popular person in the room. This position generally reports directly to a senior functional executive (CEO, COO, CFO, General Counsel) and should have an unfiltered communication channel to the Board of Directors.

In smaller organizations, this function is often vested in the non-executive-level position of Information Security Officer (ISO). A source of conflict in many companies is whom the ISO should report to and if they should be a member of the IT team. It is not uncommon or completely out of the question for the position to report to the CIO. However, this chain of command can raise questions concerning adequate levels of independence. To ensure appropriate segregation of duties, the ISO should report directly to the Board or to a senior officer with sufficient independence to perform their assigned tasks. Security officers should not be assigned operational responsibilities within the IT department. They should have sufficient knowledge, background, and training, as well as a level of authority that enables them to adequately and effectively perform their assigned tasks. Security decision making should not be a singular task. Supporting the CISO or ISO should be a multidisciplinary committee that represents functional and business units.

Information Security Steering Committee

Creating a culture of security requires positive influences at multiple levels within an organization. Having an Information Security Steering Committee provides a forum to communicate, discuss, and debate on security requirements and business integration. Typically, members represent a cross-section of business lines or departments, including operations, risk, compliance, marketing, audit, sales, HR, and legal. In addition to providing advice and counsel, their mission is to spread the gospel of security to their colleagues, coworkers, subordinates, and business partners.

Organizational Roles and Responsibilities

In addition to the CISO and the Information Security Steering Committee, distributed throughout the organization are a variety of roles that have information security–related responsibilities. For example:

  • Compliance Officer—Responsible for identifying all applicable information security–related statutory, regulatory, and contractual requirements.
  • Privacy Officer—Responsible for the handling and disclosure of data as it relates to state, federal, and international law and customs.
  • Internal audit—Responsible for measuring compliance with Board-approved policies and to ensure that controls are functioning as intended.
  • Incident response team—Responsible for responding to and managing security-related incidents.
  • Data owners—Responsible for defining protection requirements for the data based on classification, business need, legal, and regulatory requirements; reviewing the access controls; and monitoring and enforcing compliance with policies and standards.
  • Data custodians—Responsible for implementing, managing, and monitoring the protection mechanisms defined by data owners and notifying the appropriate party of any suspected or known policy violations or potential endangerments.
  • Data users—Are expected to act as agents of the security program by taking reasonable and prudent steps to protect the systems and data they have access to.

Each of these responsibilities should be documented in policies, job descriptions, or employee manuals.

Regulatory Requirements

The necessity of formally assigning information security–related roles and responsibilities cannot be overstated. The requirement has been codified in numerous standards, regulations, and contractual obligations—most notably:

  • Gramm-Leach-Bliley (GLBA) Section 314.4: “In order to develop, implement, and maintain your information security program, you shall (a) Designate an employee or employees to coordinate your information security program.”
  • HIPAA/HITECH Security Rule Section 164.308(a): “Identify the security official who is responsible for the development and implementation of the policies and procedures required by this subpart [the Security Rule] for the entity.”
  • Payment Card Industry Data Security Standard (PCI DDS) Section 12.5: “Assign to an individual or team the following information security management responsibilities: establish, document, and distribute security policies and procedures; monitor and analyze security alerts and information, and distribute to appropriate personnel; establish, document, and distribute security incident response and escalation procedures to ensure timely and effective handling of all situations; administer user accounts, including additions, deletions, and modifications; monitor and control all access to data.”
  • 201 CMR 17: Standards for the Protection of Personal Information of the Residents of the Commonwealth – Section 17.0.2: “Without limiting the generality of the foregoing, every comprehensive information security program shall include, but shall not be limited to: (a) Designating one or more employees to maintain the comprehensive information security program.”

Creating a culture of security requires positive influences at multiple levels within an organization. Security champions reinforce by example the message that security policies and practices are important to the organization. The regulatory requirement to assign security responsibilities is a de facto mandate to create security champions.

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