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5

Managing Risk to an Acceptable Level

Attachment is the great fabricator of illusions; reality can be attained only by

someone who is detached.

Simone Weil, 1909–1943

Risk analysis is a much discussed area in the information security field

for several reasons. First, risk analysis is core to understanding the state

of information security that exists within the company. The process of

risk analysis uncovers how well the control environment is protecting the

information assets. Second, risk analysis helps organizations target the in-

formation security expenditures where they are most needed and are

used to allocate funds to the appropriate security controls. Finally, risk

analysis and management is very subjective in nature and tends to be

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more art than science. Even though the process may be more art than sci-

ence, there are still processes that can be followed to increase the likeli-

hood that the risk analysis will be useful to the organization and provide

visibility into the risks that the organization is exposed to. Artists are very

creative in nature and can look at an object and see something different

that a normal person may see. He then paints that object using tech-

niques, or the science, that he has learned to create the appropriate tex-

ture, shading, design, symmetry, and so forth to express the image he is

feeling. Many times the artist explores with different substances and

types of painting, drawing, sculpturing, and so on to provide the desired

end state through trial and error. The security officer or risk manager

creates a risk assessment in a similar manner, starting with a methodol-

ogy, concepts, and experiences, and formulating the best depiction of the

organization. Just as the finished painting is an expression of a snapshot

in time, so is the risk assessment.

Risk in Our Daily Lives

Everyday we are subject to threats and are vulnerable to some event hap-

pening that is not desired and not within our control. We cannot stop the

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threat from occurring, however, we can minimize the impact of the event

by the steps that we have taken or will take when the event happens.

Consider the protection we implement daily to protect our automobiles

from theft. Most of us lock the car doors when we park our car at the

mall. The car manufacturers have decided that on more expensive cars

that the risk of being stolen is perceived to be greater and therefore have

implemented alarms and flashing lights inside the cars to act as a deter-

rent. Some consumers feel an alarm is not enough and have equipped

their vehicles with a tracking device, such as one made by LoJack, to no-

tify the police of vehicles’ whereabouts if stolen. Other consumers have

felt that a lock over the steering wheel, known as the “club” would pro-

vide the adequate level of protection. And then there is the limousine

driver that would not leave his vehicle unattended under any conditions.

In the automobile example, each of us may make a different decision

when it comes to the security that we would place on our car. We arrive

at our decisions based upon our past experiences, the value we place on

our cars, the likelihood that we believe it will be stolen, will be reim-

bursed for the car if it is stolen through insurance, or our general feeling

that society is either a good place with primarily good people or an inher-

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ently bad place with many ill-intentioned people. Some individuals may

feel it is perfectly normal to leave the engine running while running into

the mall for “just a second.”

We take risks unconsciously every day whether or not we recognize it

at the time. We may cross the street 30 times a day and it never enters our

mind of the risks we are taking. Then one day, you receive a phone call

that your 17-year-old son has been hit by a car going 25 miles per hour

through a crosswalk protected by a school crossing guard. Is the solution

to keep him home from school in the future? Erect a bridge over the

street to cross? Put up additional signs advising cars to slow down more

in the school zone? Each of these could be implemented, albeit at differ-

ent costs. So we accept the risk, and after an event happens, we are typi-

cally more cautious and aware of the potential dangers. Our goal should

be to identify as many threats up front so that we do not have to incur the

damage of each event to learn from it. We should not need to be hit by a

car to understand the risks of crossing the street or have our car stolen

before we lock our car doors.

Accepting Organizational Risk

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Just as we accept a certain amount of risk in our daily lives, organizations

accept daily risk also, whether or not they have completed a formal risk

analysis. Risk in inherent in everything that we do and there is no such

thing as a risk-free activity. Why do banks offer an interest rate to hold

your money in the form of a certificate of deposit (CD)? Because there is a

risk that the money will be worth less in the future due to inflation and

we need to be compensated for that risk that our money will be worth

less in the future. The stock market compensates traditionally at 11% over

time for stocks. Why? Because of the risk we are taking in investing in

these companies that their products or services may not produce the ex-

pected income. Whether investors recognize this or not, whether invest-

ing in CDs or stocks, they are taking on risk and are being compensated

for the risk.

The danger for an organization occurs when risks are being accepted

implicitly without providing the visibility that the risk is being accepted.

In this scenario, the company may be taking on more risk than they can

afford to take on. For example, say that a small office space is available at

a great price on the second floor of a building occupied by other tenants.

The company could proceed on the basis that the office space is the per-

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fect size and very cost competitive. However, if the buildings surround-

ings were not evaluated properly, they may be taking on too much risk. If,

for example, there was a restaurant directly below them, they would be

taking on the risk of business disruption or permanent loss should the

restaurant have a fire. A risk analysis would reveal the threat, and while

the threat could still be accepted (e.g., off-site backups or paperless scan-

ning put in place to minimize the impact of the damage should a fire oc-

cur), the acceptance would be a conscious decision based upon review of

the facts. This approach is much better than waiting until the event hap-

pens and being unaware of the risks that are being implicitly accepted.

Just Another Set of Risks

Executives face risk-based decisions every day. Should the new product

be launched? Should we open 100 more stores? Does it make sense to

merge with this other organization? Should we close this factory and

move the jobs to another state? Should we compete for this business? And

so on. The risks related to protecting the information assets of the organi-

zation represent just another set of risks.

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The security officer needs to be cognizant of this fact when delivering

the risk message. Just as the executive must accept a certain amount of

risk to proceed with any plan, the security officer must be willing to facili-

tate the risk discussion without an all-or-nothing approach to risk.

Security departments traditionally have been criticized for their first re-

action to a new idea being similar to “No, we can’t do that, it would not be

secure.” This posturing has earned many security departments of the dis-

tinction of being the “‘no’ department.” What does this say about the level

of risk acceptance that the security officers feel the organization should

accept? The answer is none. A better approach is to examine what the de-

sired end state the executive is trying to achieve and work toward a solu-

tion to enable the use of the technology or process in a secure manner.

Management Owns the Risk Decision

The security officer acts as the facilitator for the risk decisions and should

not be the one making them. Risk is owned by the management of the

company, as it is through their operational areas that the risk is present

and through their areas with which the risk must be controlled. The secu-

rity officer must manage risk within his or her own departments as well,

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and they are the owners ensuring that agreed upon policies and proce-

dures are followed to mitigate the risk.

Security officers and their teams bring security expertise to the discus-

sion, which will assist in management making informed decisions.

Alternatives can be presented and recommendations made, however, the

level of risk accepted is decided by management after the information

has been presented. One useful technique to ensure that risk is appropri-

ately understood and accepted is to formally require that the person ac-

cepting the risk sign a document accepting the risk. When some people

have to apply their signature to a document, they tend to review what is

being agreed upon more closely.

A risk acceptance agreement could include the following key items:

Description of the threat/vulnerability

Description of the mitigating controls currently implemented

Residual (remaining) risk to the organization

Controls evaluated but not implemented and reason why

Justification for accepting risk

Level of risk (high, medium, low)

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Timeframe of the acceptance (typically no more than 1 year)

Future plans to mitigate risk

Departments impacted

Approximate dollar impact expected should the vulnerability be

exploited

Signature(s)/title(s)

By including these variables, it should be clear that the risk must have a

business justification, is not approved for an indefinite period, and must

have a plan for mitigating the risk now as well as providing for a future

scenario where the acceptance form is not needed.

Qualitative versus Quantitative Risk Analysis

One of the difficulties with performing risk analysis is the availability of

objective risk information from past experiences. Companies do not typi-

cally share information of the risks they have accepted or the occurrence

of unfavorable events. Consulting firms typically establish a practice for

risk consulting and leverage their firm’s internal knowledge across

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clients, or databases that have been accumulated by the government of

other software companies producing risk management products.

Quantitative risk analysis attempts to place a dollar value on the cost of

accepting risk versus the cost of implementing controls to reduce the risk

level. These analysis can be very voluminous as each risk is measured us-

ing statistical information or historical dollar values and probabilities of

the event occurring.

Qualitative risk analysis is widely used due to the relative each of un-

derstanding and speed of the analysis. This analysis estimates the poten-

tial loss or impact and the likelihood that the events would occur in a

manner similar to the quantitative analysis, with the exception of using

values such as Low, Medium, and High for probabilities and impacts. This

is in contrast to attempting to use dollar values for the impacts, which is

very difficult to obtain agreement, and probability factors for the likeli-

hood. Since there is no universally accepted master accurate “probability

database,” the quantitative method tends to try to apply precision to an

assessment that is inherently subjective. For this reason, the quantitative

method has limited use and the qualitative method is easier for manage-

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ment to quickly grasp the risks of terms of Low, Medium, and High

values.

Risk Management Process

The quantitative risk analysis process has the ability to provide a great

deal of information, however, for many organizations, a qualitative risk

analysis can arrive at similar conclusions in less time with less cost.

Quantitative analyses give the appearance of providing precise measure-

ments or dollar amounts related to the risk; however, these calculations

are also many times based upon the same subjective probability mea-

sures that the qualitative measures are based upon. In practice, manage-

ment seems to grasp the more simplistic high, medium, and low assign-

ments to risk coming out of the qualitative analysis. For this reason, the

subsequent sections outline a very pragmatic step-by-step approach to

risk analysis that can be used for almost any size organization. Those fa-

miliar with the NIST 800-30 risk management process will recognize the

approach, as this is consistent with the concepts articulated there (NIST,

2002).

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Risk Analysis Involvement

To properly conduct a security risk analysis, the right technical and man-

agement staff need to be included. The resulting analysis is only as good

as the accurate picture that can be painted of the current environment.

The list of involved participants should include

Chief information officer

Chief security officer/security director/security manager

Senior management

Middle management

Internal audit

System and information owners

Business and functional management owners

IT security practitioners

Infrastructure personnel

There will be others that may need to be called into the process to par-

ticipate in the interviews, such as facilities, data center manager, human

resources, and physical security.

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Step 1: Categorize the System

Documenting the business application of the system ensures that the sys-

tem or area being assessed is clear to those involved in the interviews

and the person analyzing the system. The business description should in-

clude only the business specifics of the system. What is the system being

used for? Who will be the users? What is the primary functionality? The

definition establishes the scope and boundaries under review.

Once the business functions have been written, the technical descrip-

tion of the infrastructure, at a high level, is documented. This provides

the basis for review of the technical components of the system that is sup-

porting the business function.

The controls that are implemented to protect a system and its informa-

tion ultimately depend upon the criticality and sensitivity categorization

of the system. For low criticality systems, it would be unnecessary to

spend the same amount for controls as what is spent to protect systems

that have been categorized as high criticality or sensitivity. This is analo-

gous to building a 15-foot-high fence around your house to keep the

neighbors from looking into your yard.

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The Federal Information Processing Standard (FIPS) 199 provides guid-

ance for categorizing systems according to their attributes of confidential-

ity, integrity, and availability (NIST, 2004). As shown in Table 5.1, a system

is categorized as high for confidentiality if the loss of confidentiality

could be expected to have a severe or catastrophic adverse effect on orga-

nizational operations, organizational assets, or individuals. If the loss of

confidentiality was deemed to have a serious effect, then the system

would be categorized as medium with respect to confidentiality. Likewise,

if the effect is determined to be limited, then categorization would be low

for confidentiality.

Table 5.1 System Categorization

FIPS

PUBLICATION

199

LOW MODERATE HIGH

Confidentiality The loss of

confidentiality

could be expected

to have a limited

The loss of

confidentiality

could be expected

to have a serious

The loss of

confidentiality

could be expected

to have a severe or

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adverse effect on

organizational

operations,

organizational

assets, or

individuals.

adverse effect on

organizational

operations,

organizational

assets, or

individuals.

catastrophic

adverse effect on

organizational

operations,

organizational

assets, or

individuals.

Integrity The loss of

integrity could be

expected to have

a limited adverse

effect on

organizational

operations,

organizational

assets, or

individuals.

The loss of

integrity could be

expected to have

a serious adverse

effect on

organizational

operations,

organizational

assets, or

individuals.

The loss of integrity

could be expected

to have a severe or

catastrophic

adverse effect on

organizational

operations,

organizational

assets, or

individuals.

Availability The loss of

availability could

be expected to

The loss of

availability could

be expected to

The loss of

availability could

be expected to

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have a limited

adverse effect on

organizational

operations,

organizational

assets, or

individuals.

have a serious

adverse effect on

organizational

operations,

organizational

assets, or

individuals.

have a severe or

catastrophic

adverse effect on

organizational

operations,

organizational

assets, or

individuals.

Source: National Institute of Standards and Technology (NIST). 2004. Standards for secu-

rity categorization of federal information and information systems, FIPS PUB 199.

http://csrc.nist.gov/publications/fips/fips199/FIPS-PUB-199-final.pdf

The categorization continues by looking at the dimensions of integrity

and availability using similar criteria. If the loss of integrity could be ex-

pected to have a severe or catastrophic effect on organizational opera-

tions, assets, or individuals, this would cause the categorization with re-

spect to integrity to be categorized as high, serious would cause the cate-

gorization to be medium, and if limited it would be low. Similarly, the

availability dimension is categorized as high, medium, and low depend-

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ing upon the severe or catastrophic, serious, or limited effects of a loss of

availability.

The final categorization of the system is done by reviewing each of the

categorizations for confidentiality, integrity, and availability, and select-

ing the categorization that best protects the system. For example, if both

confidentiality and availability are considered high, and integrity is con-

sidered a medium concern, then an appropriate response would be to se-

lect those controls that would provide a high level of assurance. For ex-

ample, the Centers for Medicare and Medicaid Services (CMS) determined

that the health records of the Medicare population should be rated as

high, primarily due to the high confidentiality requirement and the dam-

age that would be caused if the records were inadvertently disclosed to

the wrong parties (CMS, 2009). This would undermine the trust in the

government’s (and their contractors) ability to protect the health insur-

ance information. Availability is important, but a lesser concern, as the

information is not needed on an immediate, real-time basis for the pay-

ment of claims. This would contrast with a provider of ATM services,

where although confidentiality would be very important, availability

would be very important as well.

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By now the question that may be coming to mind is, “How do I accu-

rately decide between severe, catastrophic, serious, or limited?” This as-

sessment, as with much of risk analysis as previously stated, is of a sub-

jective nature. The best way to answer this is to evaluate what the impact

would be in terms of shutting down the business for a few days, or caus-

ing a high public relations nightmare, or causing an unrecoverable situa-

tion. The higher the categorization of the system, the more stringent and

more expense will have to be incurred to protect the system. Google and

Yahoo Internet-facing search engines would assuredly garner a high

availability rating and require security controls of high redundancy hard-

ware to ensure the availability. They would also need extensive monitor-

ing for attacks and proactive measures to detect denial of service attacks.

In other words, classifying the system is an important step as all other

controls that are selected flow from the categorization. The NIST 800-53

controls (shown in Chapters 8 to 10) provide a set of controls and en-

hancements to the controls based upon the categorization of the system

(high, medium, or low).

Step 2: Identify Potential Dangers (Threats)

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Threats are those dangers that have the potential to cause harm to our

business and the systems that we support. Threats are not necessarily

what have happened in the past but rather those dangers that our organi-

zations face that we should have a response in place for. A threat may or

may not be exploited, as we may not be vulnerable to that threat because

of other control measures that have been implemented. Each organiza-

tion should brainstorm the specific threats specific to their industry,

which may include human, environmental/physical, or technical threats.

Human Threats    As long as we have people working in our organiza-

tions, they will be our most valuable asset and also at the same time con-

sidered a threat. Through acts of carelessness, inadvertent compromises

of security or malicious intent, the human factor must be considered as a

threat source. A listing of potential human threats are shown in Figure

5.1

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Figure 5.1 Human threats.

Environmental/Physical Threats    Environmental risks typically are fo-

cused on the environmental systems protecting the computing environ-

ments in data centers and server rooms where temperature and humidity

control is important to protect the associated equipment. Other threats

such as fires, lack of power, and so forth are noted in Figure 5.2.

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Figure 5.2 Environmental/physical threats.

Technical Threats    Technical threats such as authorized access, infra-

structure intrusion, or inadvertent configuration errors can permit an in-

truder to exploit the vulnerabilities of the system and compromise or

gain access to information. Technical threats are shown in Figure 5.3.

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Figure 5.3 Technical threats.

Step 3: Identify Vulnerabilities That Could Be Exploited

Once the threat has been defined, the next step is to identify the vulnera-

bilities that can be exploited by the threat. The threat may be thought of

as the source of the attack, and the vulnerability is that which is exploited

to cause harm. A burglar standing outside a warehouse may be consid-

ered a threat, and the degree that he will be able to break into the ware-

house depends upon the level of vulnerabilities that exist within the

warehouse. Vulnerability may be that the windows could be broken, the

doorjamb could possibly be opened with a credit card, or the lock could

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be picked. The burglar could also pose as a warehouse worker and gain

entry during the daytime hours.

Vulnerabilities may exist within our computing environments if we

have not applied the most current patch levels or applied a consistent,

current baseline configuration to our systems. The intruder decides to

gain unauthorized access (the threat) and exploit one or more vulnerabil-

ities, such as a vulnerability found within the Windows 7 operating sys-

tem, application software, in-house developed software, or a customized

vendor product.

A good question to ask when determining vulnerabilities that may be

exploited is to ask the question: What could go wrong? A technique that

may have been invented by 3-year-olds worldwide is to ask why five

times to get to the real root cause of the issue, while along the way this

will also identify the vulnerabilities and the controls that could be imple-

mented. After the vulnerabilities are determined, the risk analysis can

proceed forward with examining the existing controls.

Step 4: Identify Existing Controls

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Since our organizations are not starting at day one when the risk analysis

is conducted, odds are that we have implemented controls to manage

some of the risk. In the warehouse burglar example noted earlier, we

may have implemented bars over the windows, cameras scanning the

parking lot, visitor badge control, and a night-duty guard to protect the

premises. We may have also placed steel plates over the doorjambs to

prevent tampering with the door. The controls that we believe are miti-

gating some of the risk of exploitation of the vulnerability should be

listed.

The chapters on managerial, technical, and operational controls

(Chapters 8, 9, and 10) provide a good starting reference to determine

what types of controls should be considered. There tends to be a prefer-

ence to provide automated controls to replace manual controls, however,

there are instances where the manual controls may still be more effec-

tive. For example, few organizations have done away completely with se-

curity guards, as they still provide an effective deterrent when used in ad-

dition to technical controls such as mounted cameras, proximity readers,

and alarm systems.

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Step 5: Determine Exploitation Likelihood Given Existing Controls

Step 5 is where the rubber starts to meet the road, where an assessment

of the first factor in determining risk, likelihood, or probability is deter-

mined. This is not a mathematical calculation based upon statistical prob-

abilities as may be the case in the quantitative method. This value is an

expression of the likelihood that the vulnerability is likely to be exploited

given the existing control environment. A qualitative description is as-

signed to the likelihood starting from a low of negligible likelihood (un-

likely to occur) to extreme (likely to occur multiple times per day) as

shown in Figure 5.4.

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Figure 5.4 Likelihood of occurrence.

This assessment should be made by individuals responsible for the

business and facilitated by the security officer. Ownership of the likeli-

hood determination cannot occur if the security officer is determining

how often an event may occur, unless it is related to vulnerability within

his domain that he has knowledge of. Let’s say for example that there is a

policy in place that users are not to share user accounts, but there is no

control in place that would prevent concurrent logins other than a formal

policy instructing the users not to share an account. The security officer

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may learn through the incident reporting process that individuals are

sharing an account at least several times a month. In the absence of a

technical control to prevent this access, this would be assigned a likeli-

hood of very high based upon the frequency of the event.

An important point to note is that likelihood is one component of risk,

and at this point the “risk level” has not been determined. It is advisable

to keep the conversation about the likelihood of occurrence and not about

risk, or managers will immediately jump to discussing high, medium, or

low risk level without having the complete foundation (likelihood and im-

pact) to determine risk. A “hold off, we’re getting to that next” stance is

warranted here.

The warehouse burglar in the earlier example may have had a low like-

lihood of exploiting the vulnerability given the existing controls that were

in place, as it appears that most of the known areas of vulnerability were

already implemented (since this company was broken into frequently in

the past, last year it upgraded its control environment as a result of the

prior risk analysis).

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As with the rest of the risk analysis, the likelihood should be examined

with a fresh set of eyes, meaning that what was decided as the likelihood

last year is irrelevant. New controls may have been put in place, existing

controls may have been removed, and the intensity of the threat may

have changed. For example, tracks may have been laid for a new high-

speed train going past the data center or a fuel storage plant may be con-

structed, both creating potential vulnerabilities that did not previously

exist. Alternatively, an office may have closed and the vulnerabilities that

were identified with the office are no longer relevant. A prudent ap-

proach is to review and update the risk assessment annually and perform

a ground-up risk assessment every 3 years.

Step 6: Determine Impact Severity

This step assumes that the vulnerability has been exploited and now the

organization must deal with the harm that was done by the action. An im-

pact designed as minor, according to Figure 5.5, would require minimal

effort to repair the system. If the impact was large, designated as critical,

then the impact would be expected to result in an extended outage.

Figure 5.5 provides a quick means to assign an impact to the event.

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Figure 5.5 Severity of impact.

Management and technical staff are in the best position to explain what

would happen if the system was lost for a day or a shipment was not de-

livered. Finance areas are also excellent sources of information when cal-

culating the loss of productivity per hour when a system is down. E-com-

merce websites can calculate the approximate lost dollar volume when

their sites become unavailable. Depending upon the time of year, the

severity may increase, such as online retailers during the holiday season.

A recently quoted statistic indicated that 13% of Black Friday sales came

from Cyber Monday (the Monday following Black Friday).

If the burglar was able to break into the warehouse in our example,

this would have caused considerable damage, as the warehouse was full

of shipments to a key manufacturer that needed the goods shipped to-

morrow. If those goods were damaged or stolen, we could have lost a

client. According to Figure 5.5, this may be assessed as damaging, or

damage to reputation, loss of public confidence.

Step 7: Determine Risk Level

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Step 7 is where the risk level is determined based upon the likelihood and

the impact level. Using the table shown in Figure 5.6, the likelihood of oc-

currence is located in the first column, and the impact severity is located

in the row across the top. These are then used to find where the likeli-

hood and impact intersect in the table, indicating a risk level of low, mod-

erate (or medium), or high. For example, in our burglar example, the like-

lihood was low and the impact severity was damaging, resulting in a risk

level of moderate.

Figure 5.6 Risk determination.

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This process is repeated for each of the threat and vulnerability pairs

until each has been addressed and assigned a risk level. The risks are

then prioritized from high to medium to low. The low risks should be

worked on only after the high and medium risks have been addressed,

unless they are simple changes that will not divert substantial resources

from addressing the higher risk items.

The best part about this method is that the risk was determined by fo-

cusing the discussion on (1) likelihood of occurrence and (2) impact sever-

ity. Nowhere in the discussion was risk mentioned up until this step. This

step still does not debate risk but merely establishes the risk based upon

the matrix. Management can always decide to raise or lower the risk level

at this point; however, it should be cautioned that this should be based

upon a reevaluation of the likelihood or the severity. Sometime manage-

ment may have good reason to increase the risk rating to ensure that it

receives some attention within the organization.

Step 8: Determine Additional Controls

Now that the risks have been identified, it is necessary to identify controls

to mitigate or reduce the risk level to an acceptable level. Typically the fo-

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cus is on the high risks that should be remediated as soon as is feasible.

Moderate or medium risks should also be handled urgently and plans cre-

ated to address their implementation. It may not be clear at the moment

precisely what solutions will be implemented at this juncture, but plans

of action to investigate the alternatives can be created until it is clear

what solutions will be implemented.

Once the control has been identified that will reduce the risk, the resid-

ual likelihood, residual severity impact, and the resulting residual risk is

recalculated. Controls should at least bring the high risks to medium, the

mediums to lows, and if the lows are addressed at this time, they should

be eliminated. Some organizations will retain all risks as a low risk, be-

cause even though the vulnerability has been addressed by a control,

there is always a risk (albeit low) that the vulnerability may be exploited.

Other organizations take the viewpoint that they do not want to see any

mitigated vulnerabilities on the report, as it gives the wrong impression.

The security officer needs to be aware of the culture of the organization

and how the risk level will be perceived.

Risk Mitigation Options

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The preceding overview of the risk analysis process provides a frame-

work for conducting a risk analysis. The most likely outcome is that new

risks will be uncovered through the analysis and the company can focus

resources toward mitigating the vulnerabilities and reducing the risk lev-

els. In addition to implementing their own controls to resolve the issue,

there are other additional options for managing the risk.

Risk Assumption

The organization may decide that the risk does not represent an unac-

ceptable risk outside the company’s risk appetite and chooses to accept

the risk. The organization may continue to operate, or plan to implement

additional controls in the future. This strategy is perfectly acceptable pro-

vided that the risk being assumed has been analyzed and the financial

implications have been accepted by the appropriate parties. As indicated

in an earlier section, formalizing this process with a risk acceptance letter

is preferable.

Risk Avoidance

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Risk can be avoided by eliminating the cause of the risk or the conse-

quence. A server may have an old version of the operating system, such

as Windows 2000, which has much vulnerability that can be exploited

due to the aging of the system. Instead of upgrading the system to a new

operating system, the system itself may be retired, thus eliminating the

vulnerability.

Risk Limitation

Adding other preventative or detective controls to the process might re-

duce the adverse impact of the risk. In the earlier example of shared lo-

gins, software may be purchased to prevent the concurrent login on those

systems (such as windows) that do not have the native capability and con-

figuration settings made on other systems that do. Monitoring of logs

could also be implemented.

Risk Planning

All vulnerabilities may not be able to be addressed at the present time

and the construction of a plan for mitigating the current and future vul-

nerabilities would be put in place.

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Risk Research

If the vulnerability cannot be immediately remediated, the fact that the

vulnerability exists may be acknowledged with plans to research viable

alternatives.

Risk Transference

Losses are compensated for by purchasing insurance or transferring risk

via contract. Rates are many times dependent upon the level of security

controls that exist or external evaluations of the controls.

Conclusion

Risk analysis must be done for each organization to address the unique

circumstances and risks they face. The process described in this chapter

provides a very logical, systematic process for determining the risks that

are specific to the company. If these processes are followed consistently,

over time the review process of the existing threats becomes easier and

more time can be spent addressing the new threats to the organization.

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1.

2.

3.

The process does not have to be a lengthy one either. The facilitated

risk analysis process (FRAP), for example, may be completed in days ver-

sus weeks or months (Peltier, 2001). Having personally been involved in

the FRAP for an electronic commerce site, whereby a group of individuals

get together for a couple of days in a conference room to analyze and

come to consensus on the risks, there are clearly approaches such as this

that can gather information quickly and provide an assessment of the

risk that can be very effective. The risks determined from these ap-

proaches can then be managed according to their risk level and be man-

aged as part on an ongoing risk management program.

Suggested Reading

National Institute of Standards and Technology (NIST).Iuly 2002. Risk manage-

ment guide for information technology systems.

http://csrc.nist.gov/publications/nistpubs/800-30/sp800-30.pdf

Centers for Medicare and Medicaid Services. March 19, 2009. CMS information se-

curity risk assessment (IS RA) procedure. Version 1.0-Final.

http://www.cms.gov/informationsecurity/downloads/IS_RA_Procedure

Peltier, T. R. 2001. Information security risk analysis. New York Auerbach.

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4. National Institute of Standards and Technology (NIST). 2004. Standards for secu-

rity categorization of federal information and information systems, FIPS PUB 199.

http://csrc.nist.gov/publications/fips/fipsl99/FIPS-PUB-199-final.pdf