Tuesday, November 3, 2015

Policy and Compliance Are Not Enough

The information security business seems to have strayed a bit from its roots. The roots of digital information security really began decades ago by the people who built and maintained systems. They may have wanted to either protect information or keep people out. While our nature as humans is more sharing and collaborative than it is secretive and isolationist, the reality is that we all have times when we need our secrets and spaces where we can store information that no one else can get to unless we specifically allow it. The problem comes when you start allowing a lot of users into the system or if you start connecting a lot of systems together into networks. Then we need additional protections in place to make sure everyone’s little corral of horses stays their own little corral of horses, unless they choose to set up a petting zoo.

Ultimately, there are competing priorities when it comes to information security. There is the pure security-focused no one gets in unless they are specifically allowed in priority. On the other end, there is the perspective that the business owns everything and so it gets to set the rules. The problem that arises here is that rather than these two ends working together to find a middle, the money for the security end is tied up in the focus on the business priorities.

This is where we find a conundrum. Sure, you can say that without the business, there are no systems to protect. As a result, the business should always set the priorities. This has the potential to work well if the business truly owns its resources and has a stake in protecting them. The problem arises when the business has no stake in the resources that are under the control of the information technology and information security people. I’m losing you, right? Okay, let’s talk about case studies.

Using a very simple scenario that can be extrapolated to much higher levels. Let’s say you are a company who wants to start up a loyalty card for your customers. This will allow you to learn a lot about the people who spend money with you and you can feed a little back in discounts or other goodies. Without the goodies, what is to entice people to sign up for your loyalty card so you can gather all of that data? Suddenly, though, your business has a resource that it has no stake in. You are storing names, addresses and phone numbers of a large number of your customers. What happens to your business if that information is stolen? It could be that absolutely nothing happens. If you aren’t storing credit cards or other financial data with those records, it could be you don’t even need to let anyone know, depending on the breach notification laws where you do business.

Even if you do have to notify someone, what has actually been lost? Some names and addresses. No big deal, right? If there is no downside to the business if that information is lost, what is the incentive to do everything possible to protect that information? This is where the problem of business-driven security comes in. The information that has been stolen doesn’t actually belong to the business. It belongs to the customers of the business. Since it doesn’t belong to the business and there is no actual impact to the business from its loss — maybe you have to shut down your loyalty card program, which doesn’t lose sales. It just means less marketing information that you can make use of to be more effective.

Business-driven security starts with the security policy. This is a very high-level statement of expected outcomes. There is nothing at all about implementation in the policy. That comes in a set of standards that fall out of the policy. An acceptable use policy, which is common, may simply say that anyone making use of a company resource like a computer and the enterprise network will do so in a business-appropriate manner. That’s it. That’s the policy. There are countless ways to implement that policy. The standards that are defined underneath that policy will get into more detail but still won’t get into specific technologies and implementations. Instead, you get a more fine-grained set of requirements for what meeting that policy should look like.

The notion of making sure that you are achieving your policy goals is called compliance. This is also a word used in relationship to meeting regulatory requirements. Some businesses may need to meet requirements set down by the Payment Card Industry (PCI) if they deal with credit or debit cards. Others may have requirements set down by the Federal Depositors Insurance Corporation (FDIC). This would be common with banks and other similar financial companies. Making sure that you are meeting these requirements is also called compliance. As a result, compliance is big business. Meaning, there is a lot of money in auditors coming in to make sure you are following the appropriate rules.

Meeting a set of rules, however, that are very high level statements of expected outcomes may not necessarily be the right things to be paying attention to. Here’s an example. A business has a security awareness training program for all its users. Every user has to take this training. An auditor may come in and determine whether the business is really getting all of its users through security training. If the business has a goal of getting, say 97% of users through training in a month and they hit 98%, they have achieved their objective.

Is this the right objective, though? Are the right topics being covered in the training? How is retention of the training being measured? Does this training actually help improve the overall security posture of an organization?

These are all questions that are not answered in this scenario but they are potentially far more important than the question of the percentage of users who have successfully made it through training. What it comes down to is clearly defining the problem. If you haven’t identified the problem well enough, your measurements are likely to be meaningless.

Large businesses are often driven by this compliance mentality and auditors and security professionals are often driven by meeting objectives that bear no relation to improving the security posture of an organization. A business can meet all of its compliance objectives and still be breached. This happens all of the time. The large companies you have read about all have robust security policies and compliance programs in place. The problem is that the security policies are all around protecting the business.

So, back to the scenario from above. If the business is about protecting the business but the business is storing information about a third party (its customers), where does the third party get a say in protecting its information? Once the information is stolen, it’s too late to walk away from the business and research shows that in most cases, businesses are not impacted financially by these breaches. Certainly, their stock prices are not impacted over the long term. Where is the place at the table for the stakeholders who have the most to lose from a security breach?