Three years ago I attended an Information Security Strategy session to debate what future steps we should be taking in the organisation where I work. We had put together 12 of the South African consultants that we most respected to discuss the issue, spent two days positioning ourselves and understanding the landscape and then we got down to the nitty gritty of deciding actions.
Everybody couched their opinion cautiously: it’s not easy to identify what way a large ship should turn; but the same comments came out repeatedly: do an assessment against best practise, identify the weaknesses and build a plan of action. Compile an ISMS framework, get executive buy-in and support, review policy: nothing that we had not heard repeatedly. ISO 27000 was bandied about as the start point and the end goal. I then asked whether anyone had ever seen ISO27000 effectively implemented in any large organisation. Nobody around the table had.
I asked the same question of a senior consultant from one of the big four consultancies this week, and got the same answer: as much as ISO27000 is part of our lexicon, it is too big, expensive and daunting for organisations of any scale to have embraced and implemented. Very little has changed in three years.
I thought about this again when we recorded the 2011 preview Pubcast in January: I queried during the discussion what we were likely to see on the PCI front this year – and got an interesting response: pushback. The opinion was that PCI is perceived as too expensive for retailers to adopt that some organisations would resist, and may consider the fines to be just the cost of doing business.
And now we have the Protection of Private Information Bill, threatening to provide one more set of requirements that organisations are obliged to fulfil – if it ever finds its way to being enacted! The conference halls are full of advice on how to address the issue, the consultants have compiled their frameworks of advice; and again I find myself wondering what the impact of yet another requirement is likely to be on the InfoSec industry.
I think we can all see some immediate effects:
• An industry has built up around ISO27000, another around PCI and we will see the same occur with privacy. Every product imaginable will come pre-configured with capabilities to address the requirements out of the box. Similarly, consultants will provide insights at a cost, perform assessments and make any number of recommendations that should be followed;
• Practitioners will highlight these requirements earnestly during the budget cycle, talk about fines and reputational damage and – if they are successful – identify programmes of work that will run every risk of over ambition;
• Government will address this at the pace that government does, may choose to make examples of some intransigents, but will provide a legal requirement with insufficient resources to police it, and a juristic system poorly equipped to understand it.
Perhaps I should explain: I am not opposed to the creation of any best practise, guideline or legal framework. This is a difficult enough profession and we need whatever directives will assist. My problem is: I don’t know to what degree they will actually make organisations more secure. Because here’s the problem: these frameworks, while laudable and created with the best possible intentions are out of step with almost every other aspect of business:
• While there is a growing focus on consumer privacy, the same consumers are consciously giving away their information. The underside to the freedom of social networks is that they lull users into sharing details without a clear sense of who is accessing this information, with the result that organisations invest effort and money protecting data which is often (at least partly) in the public domain already;
• These frameworks are expensive at a time when the world has not yet emerged from a recession, and business budgets are used either on cost containment or the early phases of business growth. The same practitioners that are obliged to deliver on these requirements are struggling to access funds to do so;
• Attacks are being levelled against organisations by increasingly well funded and organised protagonists: there is an imbalance between the effectiveness of the attackers (who have only to find one weakness) and the defenders (who must defend everything). This has led to the view that organisations must adopt risk-based (and hence more narrowly defined) approaches to protecting their assets: they simply cannot afford the cost in money and effort to implement these all-encompassing models.
So where does this leave us? The models are as legitimate as they have always been. They are as valuable as they were intended to be and nobody is suggesting that they should be abandoned – but they should be seen in the context of what is appropriate in any organisation at a given time. Sometimes more value can be achieved by just fixing the obvious: I have seen organisations pursuing accreditations and building elegant risk management frameworks while not satisfactorily addressing their most basic security requirements.
There is a lot of talk about how Information Security should be aligned to the business; but business is about nuance and agility: the need to re-divert resources quickly in order to satisfy customer requirements; the need to collaborate across strategy, inbound logistics, operations, delivery and finance – and these models don’t do that. At best they provide some assurance that things are being done more securely – at worst, pursuing overambitious implementations, they layer in cost.
Information Security is – firstly – about applying thought to the state of the company and the risk it faces, then addressing the obvious risks, and ensuring that the work is in line with business requirements. The frameworks help – and provide invaluable insights – but are no replacement for the hard work of thinking the problem through, taking measurements and making the hard choices that will best assist the business.