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IT Governance Information Security Governance
This chapter covers CISA Review Manual up to Section 2.7 IS Management Practices. Much of 2.7 is not included for this Information Security course, particularly designed for undergraduates. The vocabulary for 2.7 Sourcing is included, but hiring/promotion/training/termination, most of outsourcing are not included. IS Roles & Responsibilities are not discussed, but Segregation of Duties is covered in the Fraud presentation. Risk is covered in the Risk Presentation. Much or some of CISM Chapter 1 and 4 is also covered in this presentation. Sections of CISM Chapter 1 and 4 are covered in other presentations: Risk, Security Program Development, Network Security.
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Acknowledgments Material is sourced from:
CISA® Review Manual 2011, © 2010, ISACA. All rights reserved. Used by permission. CISM® Review Manual 2012, © 2011, ISACA. All rights reserved. Used by permission. Author: Susan J Lincke, PhD Univ. of Wisconsin-Parkside Reviewers/Contributors: Todd Burri, Kahili Cheng Funded by National Science Foundation (NSF) Course, Curriculum and Laboratory Improvement (CCLI) grant : Information Security: Audit, Case Study, and Service Learning. Any opinions, findings, and conclusions or recommendations expressed in this material are those of the author(s) and/or source(s) and do not necessarily reflect the views of the National Science Foundation.
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Objectives Students should be able to:
Describe IT governance committees: IT strategic committee, IT steering committee, security steering committee** Describe mission, strategic plan, tactical plan, operational plan Define quality terms: quality assurance, quality control Describe security organization members: CISO, CIO, CSO, Board of Directors, Executive Management, Security Architect, Security Administrator Define policy, compliance, IT Balanced Scorecard, measure, ISO 9001, enterprise architecture Define sourcing practices: insource, outsource, hybrid, onsite, offshore Define policy documents: data classification, acceptable usage policy, access control polices Plan/schedule a security implementation.
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Corporate Governance Corporate Governance: Leadership by corporate directors in creating and presenting value for all stakeholders IT Governance: Ensure the alignment of IT with enterprise objectives Responsibility of the board of directors and executive mgmt The big idea here is that IT Governance serves the business, not itself (or IT). ‘presenting value’ = helping the organization pursue it’s goals, i.e. not an unnecessary expenditure. Stakeholders are anyone who has an interest in organizational goals (and is affected by policies) including business managers, partners, employees, and investors.
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IT Governance Objectives
IT delivers value to the business IT risk is managed Processes include: Equip IS functionality and address risk Measure performance of delivering value to the business Comply with legal and regulatory requirements The main goal of business is to provide value to the shareholders and be a good community neighbor (e.g., obey laws) The main purpose of IT is to support the business in its goals of providing value to the shareholders.
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IT Governance Committees
IT Strategic Committee Focuses on Direction and Strategy Advises board on IT strategy and alignment Optimization of IT costs and risk Board members & specialists IT Steering Committee Focuses on Implementation Monitors current projects Decides IT spending IT Strategic is highest level – they APPROVE business strategy and may help to DEFINE/DECIDE it. IT Steering is lower than IT Strategic, but involves management. Think Steering = Deciding where to turn when driving a car. The car is still on the ground and navigates through real traffic. Business executives (IT users), CIO, key advisors (IT, legal, audit, finance)
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IT Strategy Committee Main Concerns
Alignment of IT with Business Contribution of IT to the Business Exposure & containment of IT Risk Optimization of IT costs Achievement of strategic IT objectives This group provides direction and high-level overview. They will be concerned that: IT plans align with business plans IT delivers promised benefits and objectives All understand risk IT Delivers IT services at optimized costs Group can track IT performance via metrics, scheduling, costs IT Strategy Committee ensures availability of IT resources, skills and infrastructure to meet strategic objectives IT Strategy Committee provides direction to management relative to IT strategy Source: CISA® Review Manual 2011 © 2010, ISACA. All rights reserved. Used by permission.
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IT Steering Committee Main Concerns
Make decision of IT being centralized vs. decentralized, and assignment of responsibility Makes recommendations for strategic plans Approves IT architecture Reviews and approves IT plans, budgets, priorities & milestones Monitors major project plans and delivery performance This is the functions of the lower management committee, the one which steers. They monitor progress of projects, detailed funding.
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Strategic Planning Process
Strategic: Long-term (3-5 year) direction considers organizational goals, regulation (and for IT: technical advances) Tactical: 1-year plan moves organization to strategic goal Operational: Detailed or technical plans Strategic is highest level and involves Directors and top executives. Each level below that involves lower level rungs on the management/employee ladder.
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Security Strategic Planning
Risk Mgmt – Laws Governance – Policy Organizational Security Data classification Audit – Risk analysis Business continuity Metrics development Incident response Physical security Network security Policy compliance Metrics use The aspects covered at each level (Strategic/Tactical/Operational) are each listed beside that level. Thus, Risk Management is a Strategic Plan concern, while metrics use and policy compliance is an Operational Plan concern. Some concerns are concerns of two levels, such as Incident Response, which is a concern both at the Tactical and Operational levels.
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Strategic Planning Strategy: Achieve COBIT Level 4
Tactical: During next 12 months: Each business unit must identify current applications in use 25% of all stored data must be reviewed to identify critical resources Business units must achieve regulatory compliance A comprehensive risk assessment must be performed for each business unit All users must undergo general security training Standards must exist for all policies CMM = Capability Maturity Model COBIT is a IT maturity model provided by ISACA. Level 4 means that all processes are documented and measured (via statistics). Levels range between 0 and 5. Here, the Tactical implements the Strategic goal of achieving COBIT level 4.
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Standard IT Balanced Scorecard
Establish a mechanism for reporting IT strategic aims and progress to the board Mission = Direction E.g.: Serve business efficiently and effectively Strategies = Objectives E.g.: Quality thru Availability Process Maturity Measures = Statistics E.g.: Customer satisfaction Operational efficiency The IT Balanced Scorecard defines IT’s goals and how the goals will be measured. The mission is the direction for the department. The strategies are the specific objectives that support the mission. The measures are the statistics or measurements to determine whether the objectives and mission is being accomplished. Both the management committees would be interested in this performance summary data.
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IT Balanced Scorecard Financial Goals
How should we appear to stockholder? Vision: Metrics: Performance: Internal Business Process What business processes should we excel at? Customer Goals How should we appear to our customer? Learning and Growth Goals How will we improve internally? The IT Balanced scorecard can address different areas, such as Financial goals, customer goals, internal business process goals, and learning and growth goals.
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Case Study: IT Governance Strategic Plan – Tactical Plan
Objective Time frame Perform strategic-level security, includes: 1 yr Perform risk analysis 6 mos. Perform BIA Define policies Strategic Plan Objective Time frame Incorporate the business 5 yrs Pass a professional audit 4 yrs In the Workbook/Case Study, you will prepare a Strategic Plan, Tactical Plan and Operational Plan. Notice that the business longer-term goals are part of the Strategic Plan. The Tactical plan begins to achieve those goals, with shorter term goals.
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Case Study: IT Governance Operational Planning
Objective and Timeframe Responsibility Hire an internal auditor and security professional 2 months: March 1 VP Finance Establish security team of business, IT, personnel: 1 month: Feb. 1 VP Finance & Chief Info. Officer (CIO) Team initiates risk analysis and prepares initial report 3 months: April 1 CIO & Security Team The Operational Plan sets out specific tasks, milestone dates, and responsible persons.
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Enterprise Architecture
Constructing IT is similar to constructing a building It must be designed and implemented at various levels: Technical (Hardware, Software) IT Procedures & Operations Business Procedures & Operations Data Functional (Applic.) Network (Tech) People (Org.) Process (Flow) Strategy Scope Enterprise Model Systems Model Tech Model Detailed Representation This model is for defining Business & IT system Horizontal = Different aspects to be considered Vertical = Different levels of abstraction Enterprise Model = Business Model Systems Model = Architecture of systems Technology Model = Technology selection Detailed Representation = Configuration of Technology If each entry is filled in, then the design is complete.
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What advantages can you think of for insourcing versus outsourcing?
Sourcing Practices Insourced: Performed entirely by the organization’s staff Outsourced: Performed entirely by a vendor’s staff Hybrid: Partial insourced and outsourced Onsite: Performed at IS dept site Offsite or Nearshore: Performed in same geographical area Offshore: Performed in a different geographical region What advantages can you think of for insourcing versus outsourcing? Advantages outsourcing: Advantages insourcing: Economies of scale for reusable component software Retain control over IS More experience or cheaper Loss of internal IS experience Disgruntled employees
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Quality with ISO 9001 ISO 9001: Standard for Quality Mgmt Systems. Recommendations include: Quality Manual: Documented procedures HR: Documented standards for personnel hiring, training, evaluation,… Purchasing: Documented standards for vendors: equipment & services Gap Analysis: The difference between where you are and where you want to be ISO 9001 is a worldwide quality standard from the International Standards Organization (ISO) that evaluates organizations to determine their maturity. There is a focus on Project Management and Defined Processes. HR = Human Resources Gap analysis is an important concept. It defines where you currently are and where you want to be.
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Quality Definitions Quality Assurance: Ensures that staff are following defined quality processes: e.g., following standards in design, coding, testing, configuration management Quality Control: Conducts tests to validate that software is free from defects and meets user expectations Quality Assurance: Determines that the process (or creation/factory) is a quality process. Therefore few errors will occur since defects do not ever enter the process. Quality Control: Concerned with testing. After we build something we test it. Often both exist – and should.
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Performance Optimization
Phases of Performance Measurement include: Establish and update performance metrics Establish accountability for performance measures Gather and analyze performance data Report and use performance results Note: Strategic direction for how to achieve performance improvements is necessary Performance measurement tries to determine how effective a process is by using metrics (statistics) to gauge the performance of the current process versus future process. Recent thought is that managers can’t simply expect higher numbers without defining good strategies to get there – otherwise, people may cheat to get those numbers without actually improving anything.
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Categories of Performance Measures
Performance Measurement: What are indicators of good IT performance? IT Control Profile: How can we measure the effectiveness of our controls? Risk Awareness: What are the risks of not achieving our objectives? Benchmarking: How do we perform relative to others and standards? Measures are effectively statistics. This provides some categories for performance metrics.
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IS Auditor & IT Governance
Is IS function aligned with organization’s mission, vision, values, objectives and strategies? Does IS achieve performance objectives established by the business? Does IS comply with legal, fiduciary, environmental, privacy, security, and quality requirements? Are IS risks managed efficiently and effectively? Are IS controls effective and efficient? These are functions that an IS Auditor would we concerned with relative to IT governance. Fiduciary = Financial
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Audit: Recognizing Problems
End-user complaints Excessive costs or budget overruns Late projects Poor motivation - high staff turnover High volume of H/W or S/W defects Inexperienced staff – lack of training Unsupported or unauthorized H/W S/W purchases Numerous aborted or suspended development projects Reliance on one or two key personnel Poor computer response time Extensive exception reports, many not tracked to completion These are things that an auditor would look for.
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Audit: Review Documentation
IT Strategies, Plans, Budgets Security Policy Documentation Organization charts & Job Descriptions Steering Committee Reports System Development and Program Change Procedures Operations Procedures HR Manuals QA Procedures Contract Standards and Commitments Bidding, selection, acceptance, maintenance, compliance Auditors would review this documentation. Do they follow best practices? Do they document processes well?
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Question The MOST important function of the IT department is:
Cost effective implementation of IS functions Alignment with business objectives 24/7 Availability Process improvement 2 – Alignment with enterprise objectives
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Question Product testing is most closely associated with which department: Audit Quality Assurance Quality Control Compliance 3. Quality Control = Test Audit and Compliance verify controls are defined and implemented properly – but this assumes product testing, not security controls. Quality Assurance is concerned with quality throughout the process.
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Question “Implement virtual private network in the next year” is a goal at the level: Strategic Operational Tactical Mission 3 This is a 1-year type general goal that can be broken down into multiple smaller Operational goals.
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Question Which of the following is not a valid purpose of the IS Audit? Ensure IS strategic plan matches the intent of the enterprise strategic plan Ensure that IS has developed documented processes for software acquisition and/or development (depending on IS functions) Verify that contracts followed a documented process that ensures no conflicts of interest Investigate program code for backdoors, logic bombs, or Trojan horses 4 – The auditor is most concerned with documented processes and implementation. Where documentation is voluminous (e.g., code or transactions) randomly selected or selectively chosen samples may be evaluated.
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Question Documentation that would not be viewed by the IT Strategy Committee would be: IT Project Plans Risk Analysis & Business Impact Analysis IT Balanced Scorecard IT Policies 1 – Project Plans. The IT Strategy Committee is the highest level committee, and thus would be interested in high-level documentation, such as Risk, BIA, IT Balanced Scorecard, and policies. However detailed project plans are not a concern.
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Information Security Governance
Policy Risk The previous section was on IT. This section is on IT Security.
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Information Security Importance
Organizations are dependent upon and are driven by information Software = information on how to process Data, graphics retained in files Information & computer crime has escalated Therefore information security must be addressed and supported at highest levels of the organization This slide emphasizes the increasing importance of both IS in the organization, as well as the escalation in computer crime. Thus, it would be appropriate to have an IS security representative at the highest levels of the organization.
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Security Organization
Review Risk assessment & Business Impact Analysis Define penalties for non-compliance of policies Board of Directors Defines security objectives and institutes security organization Executive Mgmt Senior representatives of business functions ensures alignment of security program with business objectives The CISO exists whether one is allocated or not. If the responsibility is not explicitly delegated then it will be held by default by the Chief Information Officer (CIO), Chief Technical Officer, Chief Financial Officer, or Chief Executive Officer. Again the positions on the top are the highest level. The Security Steering committee consists of senior representatives of business functions in combination with IS security. The point is ‘alignment with business objectives’. Other positions: Chief Risk Officer (CRO) Chief Compliance Officer (CCO) Security Steering Committee Chief Info Security Officer (CISO)
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Security Governance Strategic Alignment: Security solution consistent with organization goals and culture Risk Management: Understand threats and cost-effectively control risk Value Delivery: Prioritized and delivered for greatest business benefit Performance Measurement: Metrics, independent assurance Resource Management: Security architecture development & documentation Process Integration: Security is integrated into a well-functioning organization ISACA really stresses Strategic Alignment: IS serves business. For a doctor’s office, the primary aim is not implementing a VPN. The primary aim is to serve patients, and this includes having patient records available full time. Also, staying legal is very important – all aspects of HIPAA are important. Process Integration: Security is not just the security department’s responsibility. It should be everyone’s responsibility.
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Executive Mgmt Info Security Concerns
Reduce civil and legal liability related to privacy Provide policy and standards leadership Control risk to acceptable levels Optimize limited security resources Base decisions on accurate information Allocate responsibility for safeguarding information Increase trust and improve reputation outside organization
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Legal Issues International trade, employment may be liable to different regulations than exist in the U.S. affecting: Hiring Internet business Trans-border data flows Cryptography Copyright, patents, trade secrets Industry may be liable under legislation: SOX: Sarbanes-Oxley: Publicly traded corp. FISMA: Federal Info Security Mgmt Act HIPAA: Health Insurance Portability and Accountability Act GLBA: Gramm-Leach-Bliley: Financial privacy Etc. The column on the right are security-oriented regulation for the U.S. The left column indicates that regulation for other countries differs from the U.S., often in these areas.
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Road Map for Security (New Program)
Documentation Interview stakeholders (HR, legal, finance) to determine org. issues & concerns Security Issues Develop security policies for approval to Mgmt Security Policies Info Security Steering Committee The steering committee is comprised of department heads or other management types. Their participation ensures both that security is aligned with business objectives and that management is on board with the security program. The IS Steering Committee is developed as part of the first step gathering interested parties. This committee is then involved with the further steps. The left-hand side shows documentation this is created or read by each stage. In other words, Security Policies are developed, then used to generate training materials. Conduct security training & test for compliance Training materials Improve standards Develop compliance monitoring strategy
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Security Relationships
CISO Exec. Mgmt Human Res. Busi-ness Legal Dept IT Opera- tions Quality Control Pur- chasing S /W Dev. Security Strategy, Risk, & Alignment Security requirements Access control Hiring, training, roles & responsibility, Incident handling Security requirements in RFP Contract requirements Security requirements sign-off, Acceptance test, Access authorization The Security Manager needs to establish and maintain relationships throughout the organization. RFP= Request for Proposal: A document sent to vendors stating requirements and asking for bids Security requirements and review Change control Security upgrade/test Laws & Regulations Security monitoring, Incident resp., Site inventory, Crisis management
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Security Governance Framework
The security strategy must be linked with business objectives. The security organization must be devoid of conflicts of interest. A security framework considers all 4 of these aspects.
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Secure Strategy: Risk Assessment
Five Steps include: Assign Values to Assets: Where are the Crown Jewels? Determine Loss due to Threats & Vulnerabilities Confidentiality, Integrity, Availability Loss = Downtime + Recovery + Liability + Replacement Estimate Likelihood of Exploitation Weekly, monthly, 1 year, 10 years? Compute Expected Loss Risk Exposure = ProbabilityOfVulnerability * $Loss Treat Risk Survey & Select New Controls Reduce, Transfer, Avoid or Accept Risk See Risk presentation for more details on this and subsequent Risk slides. This is here for review and emphasis. Risk is important to get management buy-in. Without management support, security has little opportunity. If they can see how expensive it is to ignore security, then perhaps they are willing to pay for it. The risk aspect puts a $ value on the security functions.
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Example Policy Documents
Data Classification: Defines data security categories, ownership and accountability Acceptable Usage Policy: Describes permissible usage of IT equipment/resources End-User Computing Policy: Defines usage and parameters of desktop tools Access Control Policies: Defines how access permission is defined and allocated After policy documents are created, they must be officially reviewed, updated, disseminated, and tested for compliance
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Compliance Function Compliance: Ensures compliance with organizational policies E.g.: Listen to selected help desk calls to verify proper authorization occurs when resetting passwords Best if compliance tests are automated Automated tests could include: PC check for good passwords, open applications, security settings Check for backup tape/disk registration Comparison of access control planned versus actual Compliance: ongoing process Ensures adherence to policies Time Audit: Snapshot of compliance in time
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Compliance Program – Security Review or Audit Test
Objective: Is our web-interface to DB safe? Scope: Penetration test on DB Constraints: Must test between 1-4 AM Approach: Tester has valid session credentials Specific records allocated for test Test: SQL Injection Result: These problems were found: … This shows the format of a security review (audit test)
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Security Positions Security Architect
Design secure network topologies, access control, security policies & standards. Evaluate security technologies Work with compliance, risk mgmt, audit Security Administrator Allocate access to data under data owner Prepare security awareness program Test security architecture Monitor security violations and take corrective action Review and evaluate security policy The security administrator does system administration things related to security. The Security architect understands more about security and can do more related to design.
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Security Architect: Control Analysis
Do controls fail secure or fail open? Is restrictive or permissive policy (denied unless expressly permitted or vice versa?) Does control align with policy & business expectation? Where are controls located? Are controls layered? Is control redundancy needed? Policy Placement Does control protect broadly or one application? If control fails, is there a control remaining? (single point of failure) If control fails, does appl. fail? Implemen- tation Efficiency Have controls been tested? Are controls self-protecting? Do controls meet control objectives? Will controls alert security personnel if they fail? Are control activities logged and reviewed? Here are some good control objectives, and audit questions. Effectiveness Are controls reliable? Do they inhibit productivity? Are they automated or manual? Are key controls monitored in real-time? Are controls easily circumvented?
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Control Practices These may be useful in particular conditions:
Automate Controls: Make technically infeasible to bypass Access Control: Users should be identified, authenticated and authorized before accessing resources Secure Failure: If compromise possible, stop processing Compartmentalize to Minimize Damage: Access control required per system resource set Transparency: Communicate so that average layperson understands control->understanding & support Trust: Verify communicating partner through trusted 3rd party (e.g., PKI) Trust No One: Oversight controls (e.g., CCTV) Segregation of Duties: Require collusion to defraud the organization Principle of Least Privilege: Minimize system privileges CCTV=Close Circuit Television
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Security Administrator: Security Operations
Identity Mgmt & Access control System patching & configuration mgmt Change control & release mgmt Security metrics collection & reporting Control technology maintenance Incident response, investigation, and resolution Identity management = authentication System patching: updating OS and applications with security fixes, as required. Change control: Documenting and tracking changes to systems
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Summary of Security Mgmt Functions
Develop security strategy Linked with business objectives Regulatory & legal issues are addressed Sr Mgmt acceptance & support Complete set of policies Standards & Procedures for all relevant policies Security awareness for all users and security training as needed Classified information assets by criticality and sensitivity Without senior management support, everyone will be too busy to do security. Therefore, this is of utmost importance.
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Summary of Security Mgmt Functions
Effective compliance & enforcement processes Metrics are maintained and disseminated Monitoring of compliance & controls Utilization of security resources is effective Noncompliance is resolved in a timely manner Effective risk mgmt and business impact assessment Risks are assessed, communicated, and managed Controls are designed, implemented, maintained, tested Incident and emergency response processes are tested Business Continuity & Disaster Recover Plans are tested If you have policies, you must monitor that employees adhere to the policies. Controls assume that procedures are documented and technologies provided for security. Compliance ensures that the policies are implemented. Companies that are audited are actually tested for all this. This is not just theory.
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Summary of Security Mgmt Functions
Develop security strategy, oversee security program, liaise with business process owners for ongoing alignment Clear assignment of roles & responsibilities Security participation with Change Management Address security issues with 3rd party service providers Liaise with other assurance providers to eliminate gaps and overlaps Liaise = communicate/meet/come to agreement 3rd Party service providers: You contract with an organization that contracts with another organization. Change management – a formal procedure for proposing, approving and introducing changes into a process
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Question Who can contribute the MOST to determining the priorities and risk impacts to the organization’s information resources? Chief Risk Officer Business Process Owners Security Manager Auditor 2
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Question A document that describes how access permission is defined and allocated is the: Data Classification Acceptable Usage Policy End-User Computing Policy Access Control Policies 4 – Access Control Polices is concerned with permissions. Acceptable Use and End-User Computing are concerned with end user use of computers, including access. But Access Control Policies are detailed directions on how permissions are granted.
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Question The role of the Information Security Manager in relation to the security strategy is: Primary author with business input Communicator to other departments Reviewer Approves the strategy 1 Primary author – with help from business mgmt. Security strategy is approved by Executive Mgmt.
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Question The role most likely to test a control is the:
Security Administrator Security Architect Quality Control Analyst Security Steering Committee Security Administrator – like a system administrator runs security software & hardware
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Question The Role responsible for defining security objectives and instituting a security organization is the: Chief Security Officer Executive Management Board of Directors Chief Information Security Officer “Instituting the security organization” … can’t be the CSO or CISO who is part of the security organization (since you can’t institute yourself). So Executive Management is the correct answer: 2. Board of Directors approves security objectives, but does not define them. CSO = Security guard management
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Question When implementing a control, the PRIMARY guide to implementation adheres to: Organizational Policy Security frameworks such as COBIT, NIST, ISO/IEC Prevention, Detection, Correction A layered defense Controls are designed from Policy
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Question The persons on the Security Steering Committee who can contribute the BEST information relating to insuring Information Security success is: Chief Information Security Officer Business process owners Executive Management Chief Information Officer 2 Business Process owners. They know the most what needs protecting. They provide the requirements for security.
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Reference Slide # Slide Title Source of Information 4
Corporate Governance CISA: page 87, 88 6 IT Governance Committees CISA: page 90 7 IT Strategy Committee 12 Standard IT Balance Scorecard CISA: page 91 16 Enterprise Architecture CISA: page 94, 95 Exhibit 2.5 17 Sourcing Practices CISA: page 106 18 Quality with ISO 9001 CISA: page 112 19 Quality Definitions CISA: page 116 20 Performance Optimization CISA: page 113, 114 21 Categories of Performance Measures CISA: page 114 32 Security Organization CISA: page 94, 95 Exhibit 2.4 33 Security Governance CISA: page 92, 93 39 Secure Strategy: Risk Assessment CISM: page 100 40 Example Policy Documents CISA: page 100 43 Security Positions CISA: page 116, 117
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