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Security Policies and Implementation Issues

Lesson 3

Information Security Policy Implementation Issues

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Security Policies and Implementation Issues

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1

People Are Key

People must understand key concepts of security policies

Makes application of policy easier in unanticipated circumstances

People must be motivated to follow policy

Pride

Self-interest

Success

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Security Policies and Implementation Issues

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8/31/2016

2

People Are Key (Continued)

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Security Policies and Implementation Issues

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3

Personality Types

People may be more than one personality type

Types blend but one may emerge as dominant

Leverage strengths and weaknesses during implementation

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Security Policies and Implementation Issues

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8/31/2016

4

Commander

Drifter

Attacker

Pleaser

Performer

Avoider

Analytical

Achiever

Demanding, forceful

Laid back, lack discipline

Angry, critical, egotistical

Kind, thoughtful, self-sacrificing

Witty, charming, focal point

Dependable, consistent, avoid

extra work

Disciplined, precise, detail-oriented

Result-oriented

Leadership, Values, and Ethics

Leaders

Demonstrate ethical behavior

Require ethical behavior from employees

Recognizes and works with various personality types

Works with others to achieve goals

Works with others to gain support for and adherence to security policies

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Security Policies and Implementation Issues

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Values

Goals

Training

Support

Reward

Organizational Structure

Affects employee behavior

Provides insight into management priorities

Influence and authority of the Information Security Officer based on position in the org chart

Down in the IT department, not much influence and authority

Reporting directly to CFO or CIO, more influence and authority

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Security Policies and Implementation Issues

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6

Typical Organizational Chart

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Security Policies and Implementation Issues

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CISO Reporting Directly to CFO

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Security Policies and Implementation Issues

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8

CISO Organizational Chart

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Security Policies and Implementation Issues

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CISO role appears several layers deep.

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Flat Organizations: Positive Aspects

Limited number of layers between top and bottom employee ranks

Leaders are close to the workers that deliver products and services

Faster decision making

More confidence to innovate

Security policies are not abstract

Leaders responsible for product and services

Decentralized authorities

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Security Policies and Implementation Issues

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10

Challenges for Flat Organizations

Span of control can become too wide

No time to bring every problem to management for resolution

Need high caliber teams comfortable with independent decision making

May have problems with conflicting statements to regulators by the subordinate and senior leadership

When defining a security policy, must decide clearly how issues are to be identified, catalogued, debated, and escalated

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Security Policies and Implementation Issues

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11

Hierarchical Organizations

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Security Policies and Implementation Issues

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Who Benefits from Hierarchical Organizations

Large organizations

Senior leaders are more detached from day-to-day operations

Messages from senior leaders have to be reinforced through all management layers

Advantages of a Hierarchical Model

Hierarchy of specializations

Disadvantages

Communication lines are more clearly defined

Depth of knowledge in a subject area tends to be greater

Matrix relationships can be complex

Lack of accountability

Communication breakdowns

Too many touchpoints and personalities must be engaged

Overcoming User Apathy

Engage leadership and adjust implementation strategy to include role-based explanation of policy

Reinforce importance and value of information security through ongoing awareness program

Leadership should set the expectation that policy will be followed and monitor compliance

Increase involvement by introducing redundancy – don’t rely on a single individual whenever possible

Leadership should seek opportunities to recognize and reward compliance

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Security Policies and Implementation Issues

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13

Relevance of Executive Management Support

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Security Policies and Implementation Issues

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Data supporting policy implementation aligned with business objectives

Business objectives identified align with compliance laws or regulations required to conduct business

Security policy implementation can expect executive management support

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Data aligns with business objectives

Business objectives align with compliance regulations

Security policy implementation can expect executive management support

Lack of Executive Management Support

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Security Policies and Implementation Issues

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Data supporting policy implementation not aligned with business objectives

Business objectives identified do not align with compliance laws or regulations required to conduct business, or are unclear and have insufficient support from leadership

Security policy implementation can expect to fail without executive management support

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Data does not align with business objectives

Business objectives do not align with compliance regulations, or are unclear

Security policy implementation can expect to fail without executive management support

Policy Implementation Steps

Adapted from “Kotter’s Eight-Step Change Model.”

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Security Policies and Implementation Issues

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16

Roles

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Security Policies and Implementation Issues

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Information security officer

Accountable for identifying, developing, and implementing security policies.

Accountable to ensure corresponding security controls are designed and implemented.

Executive

A senior business leader accountable for approving security policy implementation.

Responsible for driving the security message within an organization and ensuring the security policy implementation is given appropriate priority.

Compliance officer

Accountable for monitoring adherence to laws and regulations.

Data owner

Approves access rights to information.

Data manager

Individual responsible for establishing procedures on how data should be handled.

Ensures data is properly classified.

Data custodian

Responsible for the day-to-day maintenance of data.

Back up and recover data as needed.

Grant access based on approval from the data owner.

Data user

End user of an application.

Accountable for handling data appropriately.

Auditor

Accountable for assessing the design and effectiveness of security policies.

May be internal or external to the organization.

May offer formal opinions in writing.

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Information Security Officer

Executive

Compliance Officer

Data Owner

Data Manager

Auditor

Data Custodian

Data User

Policy Framework Components

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Policy

Standards

Procedures

Guidelines

Defines how an organization performs and conducts business functions and transactions with a desired outcome

An established method implemented organization-wide

Steps required to implement a process

A parameter within which a policy, standard, or procedure is suggested

Common Frameworks

Control Objectives for Information and related Technology (COBIT)

ISO/IEC 27000 series

National Institute of Standards and Technology (NIST) Special Publications

Example: SP 800-53, “Recommended Security Controls for Federal Information Systems and Organizations

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Security Policies and Implementation Issues

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19

Access Control Policy Branch

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Security Policies and Implementation Issues

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Access Control Policy Branch of a Policy and Standards Library

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20

Creating a Security Policy Framework

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Security Policies and Implementation Issues

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Set a budget

Assemble a team

Select a commonly accepted framework as a foundation

- COBIT, ISO/ISC 27000 series, NIST SPs

Use a content management system, if possible

Cross-reference your security documents with standards

Coordinate development with other departments in the organization

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Set a budget

Assemble a team

Select a basic framework

Creating a Security Policy Framework (Continued)

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Security Policies and Implementation Issues

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Set a budget

Assemble a team

Select a commonly accepted framework as a foundation

- COBIT, ISO/ISC 27000 series, NIST SPs

Use a content management system, if possible

Cross-reference your security documents with standards

Coordinate development with other departments in the organization

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22

Use a content management system

Cross-reference standards

Coordinate with other departments

Roles Related to a Policy and Standards Library

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Security Policies and Implementation Issues

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CISO

- Establishes and maintains security and risk management programs for information resources

Information resources manager

- Maintains policies and procedures that provide for security and risk management of information resources

Information resources security officer

- Directs policies and procedures designed to protectinformation resources; identifies vulnerabilities,develops security awareness program

Owners of information resources

- Responsible for carrying out the program that uses the resources. This does not imply personal ownership. These individuals may be regarded as program managers or delegates for the owner.

Custodians of information resources

- Provide technical facilities, data processing, and other support services to owners and users of information resources

Technical managers (network and system administrators)

- Provide technical support for security of information resources

Internal auditors

- Conduct periodic risk-based reviews of information resources security policies and procedures

Users

- Have access to information resources in accordance with the owner-defined controls and access rules

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CISO

Information resources manager

Information resources security officer

Owners of information resources

Roles Related to a Policy and Standards Library (Continued)

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Security Policies and Implementation Issues

© 2015 Jones and Bartlett Learning, LLC, an Ascend Learning Company

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CISO

- Establishes and maintains security and risk management programs for information resources

Information resources manager

- Maintains policies and procedures that provide for security and risk management of information resources

Information resources security officer

- Directs policies and procedures designed to protectinformation resources; identifies vulnerabilities,develops security awareness program

Owners of information resources

- Responsible for carrying out the program that uses the resources. This does not imply personal ownership. These individuals may be regarded as program managers or delegates for the owner.

Custodians of information resources

- Provide technical facilities, data processing, and other support services to owners and users of information resources

Technical managers (network and system administrators)

- Provide technical support for security of information resources

Internal auditors

- Conduct periodic risk-based reviews of information resources security policies and procedures

Users

- Have access to information resources in accordance with the owner-defined controls and access rules

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Custodians of information resources

Technical managers

Internal auditors

Users

Information Systems Security Considerations

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Security Policies and Implementation Issues

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Unauthorized Access to and Use of the System

Unauthorized Disclosure of the Information

Disruption of the System or Services

Modification of Information

Destruction of Information Resources