Identifying applicable threats is a good step to take before defining security controls your organisation should put in place. There are various techniques to help you with threat modelling but I wanted to give you some high-level pointers in this blog to get you started. Of course, all of these should be tailored to your specific business.
I find it useful to think about potential attacks as three broad categories:
1. Commoditised attacks. Usually not targeted and involve off-the-shelf-malware. Examples include:
- Ransomware (Maersk ransomware attack)
- Crypto mining (Hackers enlisted Tesla’s public cloud to mine cryptocurrency)
- Denial of service (Biggest-Ever DDoS Attack (1.35 Tbs) Hits Github Website)
2. Tailored attacks. As the name suggests, these are tailored and can vary in degree of sophistication. Examples include:
- Business email compromise (Online money transfer provider Xoom suffers multimillion-dollar fraud)
- Retail website breach (British Airways data breach)
- Data exfiltration (Private data of 500 million Marriott guests exposed in massive breach)
3. Accidental. Not every data breach is triggered by a malicious actor. Therefore, it is important to recognise that mistakes happen. Unfortunately sometimes they lead to undesired consequences, like the below:
- Human error (London Sexual Health Clinic Fined £180,000 for Data Breach)
- Insecure engineering practices (The NHS is blaming a coding error for 150,000 patients in England being involved in a data breach)
- Mishandling of data (Personal details of as many as 500 NHS doctors were exposed after an internal spreadsheet containing their details was published online)
Information security professionals can use the above examples in communications with their business stakeholders not to spread fear, but to present certain security challenges in context.
It’s often helpful to make it a bit more personal, defining specific threat actors, their target, motivation and impact on the business. Again, the below table serves as an example and can be used as a starting point for you define your own.
|Threat actor||Description||Motivation||Target||Impact on business|
|Organised crime||International hacking groups||Financial gain||Commercial data, personal data for identity fraud||Reputational damage, regulatory fines, loss of customer trust|
|Insider||Intentional or unintentional||Human error, grudge, financial gain||Intellectual property, commercial data||Destruction or alteration of information, theft of information, reputational damage, regulatory fines|
|Competitors||Espionage and sabotage||Competitive advantage||Intellectual property, commercial information||Disruption or destruction, theft of information, reputational damage, loss of customer|
|State-sponsored||Espionage||Political||Intellectual property, commercial data, personal data||Theft of information, reputational damage|
You can then use your understanding of assets and threats relevant to your company to identify security risks. For instance:
- Failure to comply with relevant regulation – revenue loss and reputational damage due to fines and unwanted media attention as a result of non-compliance with GDPR, PCI DSS, etc.
- Breach of personal data – regulatory fines, potential litigation and loss of customer trust due to accidental mishandling, external system compromise or insider threat leading to exposure of personal data of customers
- Disruption of operations – decreased productivity or inability to trade due to compromise of IT systems by malicious actor, denial of service attacks, sabotage or employee error
Again, feel free to use these as examples, but always tailor them based on what’s important you your business. It’s also worth remembering that this is not a one-off exercise. Tracking your assets, threats and risks should be part of your security management function and be incorporated in operational risk management and continuous improvement cycles.
This will allow you to demonstrate the value of security through pragmatic and prioritised security controls, focusing on protecting the most important assets, ensuring alignment to business strategy and embedding security into the business.
The focus of many of my projects is on risks. I’ve observed through multiple assessments in various companies and industries a lack of formalised risk management process. Some of the plans may exist but they are not linked to specific risks and risk reduction levels are not being measured and reported on appropriately.
The security function can be effective in responding to incidents but the strategic risk-driven planning is often missing. The root cause of this state of affairs is often can be generalised as low maturity of the security function. If that’s the case, the team spends most of its time fighting fires and have little capacity to address the challenges that cause these fires in the first place.
To address this, I assess current state of the security function, define the target maturity level and then develop a high-level roadmap to achieve that desired state.
If the company is geographically distributed, noticeable differences usually exist between a number of business units in terms of overall policy framework. The suggestion here is to define a baseline level of security controls across the entire enterprise. The first step in defining these is to understand what we are trying to protect – the assets.
Modern corporations own a wide range of assets that enable them to operate and grow. They broadly include physical and non-physical assets, people and reputation. Engagement from appropriate parts of the business to identify these is important here as potential attacks to these assets might negatively affect the operations.
By understanding the assets we are able to better identify risks, enable effective detection and response, and prioritise controls and remediation efforts better.
It also helps to conduct a bottom-up review of assets to understand what exactly we’ve got there, focusing on the most critical ones and creating and updating asset inventories.
Understanding the asset base and setting standards and guidance for protecting them will focus the efforts and help you prevent and better respond to security issues.
Assets are tightly linked to threat actors, because it’s not enough to know what we need to protect – we also need to know what we are protecting our assets against. Threat actors vary in their motivation and ability and – depending on the company – include nation states, organised crime, insiders, hacktivist, competitors, etc.
A combination of assets and threats helps us to define risks.
Identifying risks and placing them on a heat map helps determine the inherent, residual and target risks. Inherent risks show the level of risk assuming all the controls or remediating measures were absent or failing. Think of it as if security function didn’t exist. It’s not a happy place where we see the majority of risks have high impact and likelihood being in the top right hand side corner of the chart.
Luckily, security function does exist and even if they don’t have a formalised risk management process, they are usually doing a good job in addressing some of these risks.
Current level of risk is taking into account all the controls and remediating measures in place. The initial impact and likelihood is usually reduced and sometimes to an acceptable level agreed by the business. The idea here is although further reduction of impact and likelihood is possible, it might not be cost-effective. In other words, the money might be better spent in addressing other risks.
Target risks is the future state risk level once additional controls and remediation measures are implemented by the security team.
The main takeaway here is that a formalised risk management approach (with accompanying processes and policies) is needed to ensure all risks are identified and tracked over time, and the appropriate resources and efforts are spent on the top priority risks.
Scientists in various fields adopt statistical methods to determine relationships between events and assess the strength of such links. Security professionals performing risk assessments are also interested in determining what events are causing the most impact.
When analysing historical data, however, they should remember that correlation doesn’t always imply causation. When patterns of events look similar, it may lead you to believe that one event causes the other. But as demonstrated by the chart above, it is highly unlikely that seeing Nicolas Cage on TV causes people to jump into the pool (although it may in some cases).
Thom Langford: Security risk is just one of the many types of risks a business faces on a day-to-day basisPosted: June 10, 2014
Interview with Thom Langford, Director of security risk management
Could we start with your personal story: your beginnings and how you got to where you are.
I was always interested in computers. My first computer was a Sinclair Spectrum 48K. I’ve always had a technology fascination. I got very much into this during school and university, and my first job was as a VAX/VMS operator, running overnight batch jobs. It was a physically tiring job, as we had to print 70,000 to 100,000 pages at night to have them delivered to the client and a 24-hour shift system, which got me to learn how to work under pressure. I then got into PCs in a big way, and moved from supporting Autodesk CAD products, to being an IT manager for a small systems integration company in Swindon. When the company was bought out by Coopers and Lybrand and subsequently merged with Price Waterhouse, to become PwC, I became known as a “builder of things”. I built a retail solutions centre, both the technology and the physical environments, from the ground up.
I subsequently built a client showcase development centre in Heathrow, a fast-track product delivery centre in London, and was also doing client work in Swansea building an innovation centre. Again, this included building both the IT as well as the physical environment: buildings, walls, the electrics and the soft furnishings, everything, basically.
I then moved to Sapient as an IT and facilities manager, which was a bit of an odd combination, although a natural move given my previous experience. I was doing that job for a number of years, initially for London and then for our global offices, when I noticed a gap in our capabilities around security, disaster-recovery and business continuity. I then spoke to one of our C level executives, and he agreed. He broadened the scope somewhat further and then asked me to start 10 days later. So it was a very rapid move for me into security. Even though I had already had a strong background in physical and IT security, this was a very different world for me. I tried to get qualified very quickly, which is something that is very difficult when you have little to no budget, which happens when you start mid-year. So I basically begged, borrowed and stole everything. We brought together a team and got a CISO on board and that’s basically where we are today. Right now I am the acting CISO. I am responsible for teams based out of India and North America, working to strengthen our security posture both internally as well as to the industry.
You are responsible for risk management. What is your view on risk management in general? How do you think is your view different from others, if at all?
I think everybody has a view on risk management, and it is not always a good one. Traditionally, risks are seen as bad and that have to be removed. They never change and the same risks are going to be there all the time. This was, at least, my perspective in the beginning. Everything is static and you live in the world of Excel spread sheets: you list your risks in them, you list what you are going to do about them, how you are going to measure them, and then you decide whether you’ve fixed them or not. Nobody was able to tell me whether a risk was acceptable or otherwise. This was basically as far as I saw, within my responsibility: to act as the conscience of a company, because that was my job. That attitude has changed for me a lot in the last 4 years. If you are the conscience of the business, the business will be stifled quite dramatically because of your security implementations. Actually, all you are doing is reducing their ability to work effectively because you don’t see the big picture of how the business operates.
Security risk is just one of the many types of risks a business faces on a day-to-day basis: socioeconomic, financial, geopolitical, legal, personnel, everything has to be taken into account. To say that a business cannot carry out an activity based on one aspect or one facet of risk, I think, is the entirely wrong thing to do. You should act more as an enabler and to become more of a yes person than a no person.
When identifying risks you will probably need the help of different stakeholders. How do you identify these different stakeholders? How do you manage the relationship with them? How do you get people to speak up?
Risk in security is just one facet of security in any business. So any enterprise should have a risk committee that is composed by a delivery group, a legal group, a financial group, etc. As long as you are measuring your risks in the same way, whether it’s in ordinal numbers or any kind of format that makes sense, those risks will be filtered as they rise up through the organisation. So if you have, for instance, 1000 security risks on your risk register, a single figure of risks should be reaching the very top of the organisation. Any more than that is an indication of people not being empowered enough to deal with risks as they emerge. Not everybody in the organisation will be able to address a risk, and so therefore, it needs to be escalated.
Escalation is not a bad thing: it’s about getting people who are better qualified or more capable or have more authority of dealing with something than you are. Not because you are incapable, but because they are in a better position than you to do so. So from the thousands that arise at the very bottom level, only a few will reach the higher levels, where they can be better dealt with.
As far as stakeholder management, it is much easier to deal with senior level stakeholder management and just seeing the very tip of the iceberg. As long as they are empowering everyone else and they can be sure that they have the tools to deal with the bulk of it all, the easier it is. This way you don’t have to deal with this vast spreadsheet concerning every single case. By empowering everybody in the organisation, it is easy for them to see why it is important to deal with risks directly. If the people at the top levels don’t want to deal with the stuff that reaches them, they basically delegate it to somebody else back down, in which case, it is being dealt with in the end.
So filtering is one approach, which is about empowering people at various levels of the organisation to recognise and deal with the risks as they feel appropriate and qualified to do so.
There are two main trains of thought in information security, namely, compliance-based and risk-based. What’s your approach, and why do you think is it more beneficial?
I think compliance is extremely useful, but it is not the be-all and end-all. Let’s say that you are using ISO 27001, for example, where measuring risk is a core part of it. But if all you are trying to do is to get the certification, you’re only engaging in security theatre. You’re only doing what is required to get the auditor happy and you are ticking things off and writing procedures, but nobody really knows anything about it. Nobody is paying any actual attention to it, apart from that one day in which you make sure that the right people are in the right office, and the auditor has that long lunch that you need, etc. So it’s a start, but it is not the way to go.
Whereas a proper risk-based approach will actually make that conversation continue way beyond the initial compliance. It’s a bit of an old argument “compliance doesn’t equal security”, which it can be if it is taken in the right sense and with the right approach. But all too often, organisations will stop at compliance and not continue with real risk-based security. An example of that is a risk register that is only looked at once a year: that is compliance. A risk register should be looked at on a regular basis to ascertain that risks haven’t changed, or if likelihoods haven’t changed, or if exploitations have changed, if risk appetites have changed within the organisation, for example. If it becomes a living and breathing document, then you are looking more at a risk-based approach to security. If it’s just a mechanical once-a-year, tick-tick-tick format, then you are in a compliance environment.
What should companies do in order for them to shift from this traditional compliance approach to the risk-based one?
I think that it is about coming back to understanding what are the benefits of security and the objectives of the business. If you can connect the benefits of your security program to the ability for a company to sell more of its products, to safely enter riskier markets (because they are able to handle their data more securely), to give confidence to their clients, to bring confidence to the industry (or to whatever regulatory body that looks after them), then that’s when you can actually get more done as a result of your security program. If you are just doing security for security’s sake, we go back to being just a conscience again.
So it’s about connecting your security programme to the goals of the business. If you haven’t even read your company’s annual report, how do you know what your security programme is supporting? If you haven’t attended a shareholder meeting or an earnings call, you can’t really know what you are doing. You only have to do this a few times to get your bearings. If you don’t understand what the core purpose of the business is, how can you actually align your security with it? It’s like IT giving out computers with Linux and Open Office when the company actually needs Windows with Microsoft Office. Linux and Open Office are perfectly acceptable approaches, but the choice for them is not aligned with the business’ needs, which probably include cross-compatibility and other functions that only Microsoft Office can do. If you don’t know what the business needs from security, you need to find out: talk, listen, read, whatever it takes to find out what it is that the business needs from you.
Let’s say that you are assigned as security manager within a company. What are the first things that you would do in your first weeks?
You need to talk: you talk as broadly and as highly as you need to understand where you are standing and what is required. Talk to as many people as possible. For instance, if you are in a manufacturing plant, you start by talking to the people on the shop floor and see how they operate. Talk to the shift leaders and the managers there. If you are consultancy, start by talking to the programme directors, to the business development people and to the partners. It doesn’t matter where you are: start talking from the ground upwards, so you actually understand what it is they do and how they do it, what they need and what they know.
These conversations might be very short, or you might run into people who don’t know much, in which case you are starting with a blank slate and you can bring your own influence onto them. If the floor leader tells you that smokers are leaving the shop doors open to go have their cigarette break, well, that’s a problem you have already identified. It’s a small issue, but potentially important. If you start solving their problems, perceived or otherwise, then you start to build fanatical advocates for security.
If you understand that the CFO’s primary goal is to ensure that he’s able to get reports and the payroll out on a monthly basis, then you can start focusing more on the integrity and availability of the data. You can then prioritize for a disaster-recovery and business continuity, so that they have the confidence that what you are actually doing is helping them do their job more easily and they are able to sleep at night. If you CFO is staying awake the night before payday because he’s not sure if his Oracle systems are going to stay up and running overnight, then that’s a problem that you can fix. So you need to communicate, talk and listen: in fact, listen twice as much as you talk, because you’ve got two ears and one mouth, and find out what peoples’ problems are, perceived or otherwise.
Nasim Taleb in his book The Black Swan provides the following examples of Mirage Casino’s four largest losses:
- $100 million from a tiger mauling
- Unsuccessful attempt to dynamite casino
- Neglect in completing tax returns
- Ransom demand for owner’s kidnapped daughter
How many of these losses could’ve been identified and managed appropriately?
John Adams in his research Risk, Freedom and Responsibility suggests that “Risk management is not rocket science – it’s much more complicated.” He further elaborates on this point in his research: “The risk manager must […] deal not only with risk perceived through science, but also with virtual risk – risks where the science is inconclusive and people are thus liberated to argue from, and act upon, pre-established beliefs, convictions, prejudices and superstitions.”
According to Adams, there are three types of risk:
- Directly perceptible risks are dealt with using a proper judgment. “One does not undertake a formal, probabilistic, risk assessment before crossing the road.”
- Risks perceived through science are subject to formal risk managementprocess. “Here one finds not only biological scientists in lab coats peering through microscopes, but physicists, chemists, engineers, doctors, statisticians, actuaries, epidemiologists and numerous other categories of scientist who have helped us to see risks that are invisible to the naked eye. Collectively they have improved enormously our ability to manage risk – as evidenced by the huge increase in average life spans that has coincided with the rise of science and technology.”
- Virtual risk is not perceived through science, hence people are forced to act based on their convictions and beliefs.“Such risks may or may not be real, but they have real consequences. In the presence of virtual risk what we believe depends on whom we believe, and whom we believe depends on whom we trust.”
Klein in his Streetlights and shadows: searching for the keys to adaptive decision making suggests the following issues with risk management:
- It works best in well-ordered situations
- Fear of speaking out may result in poor risk identification
- Organisations should understand that plans do not guarantee success and may result in a false sense of safety
- Risk Management plans may actually increase risk.
Klein also identifies three risk decision making approaches:
- Prioritise and reduce
- Calculate and decide
- Anticipate and adapt
To illustrate individual’s decision-making process while dealing with risk, Adams introduces another concept called “Risk thermostat”
The main idea behind it is that people vary in their propensity to take risks which is influenced by the perception of risk, experience of losses, and potential rewards.
People tend to overestimate spectacular but rare risks, but downplay common risks. Also, personified risks are perceived to be greater than anonymous risks.
The protection measures also can be introduced to only increase perceived security, rather than implement actual mechanisms. A possible example might be using National Guard in airports after 9/11 to provide re-assurance. However, such a security theatre has other applications in relation to motivation, deception and economics.
Finally, Adams discusses the phenomenon of risk compensation and appropriate adjustments which take place in the risk thermostat. He argues that introducing safety measures changes behavior: for example, seat belts can save a life in a crash, so people buckle up and take more risks when driving, leading to an increased number of accidents. As a result, the overall number of deaths remains unchanged.
Interview with Jitender Arora – Information Security & Risk Executive (Financial Services)
Could you please start by telling us about your background?
I am a Computer Science and Engineering graduate, with Masters Degree in Consultancy Management. I had been a very technical, hands-on person from the very beginning of my career. I spent the first two years building firewalls, proxy servers and hardening UNIX servers. After few years, I was presented with an opportunity to move into information security and risk. At the time, I was working for Wipro Technologiesand they were building a Security Consultancy Practice, which would be front-ending with their customers, and working on the projects. The organisation was recruiting for this practice from other parts of the organisation so I decided to move into this new practice which proved to be a very exciting and challenging assignment. That’s where my journey in terms of “information security and risk”started from. Later, I had leadership roles in organisations like Adobe Systems and Agilent Technologies. I moved to the UK around 8 years ago, and that’s when my journey began working in the financial services sector.
What do you do now?
Around four years ago, I decided to quit my job and start my own small consulting firm with two friends I had met at RBS. We did a good job for two years, and build a good profitable business. Unfortunately, due to some unavoidable circumstance the partnership didn’t work out and we decided to amicably part ways. After that, I didn’t want to jump into the first thing that came along, and so I focused on my independent journey as Interim Executive in leading business transformation and change programs that address governance, risk and compliance problems faced by my client organisations. My engagements are outcome oriented to deliver the specific outcome for the client organisation. Over the last 3 or 4 years, I have built a strong reputation of being an outcome-oriented management consultant.
You are a very well known speaker within the industry. What made you decide to engage in this sort of activities as well?
It was not an intentional choice. I was once having a conversation with my best mate, Javvad Malik, around the need for new speakers at conferences who are able to present a different point of view. In a way, Javvad encouraged (or should I say pushed, Thank You Jav) me to go ahead and speak at conferences. At that point, I wasn’t too keen on it because I have always felt anxious about speaking in a public forum. Additionally, English is not my first language, which represented another barrier. But I decided to face my fear, and just go along with it. When I actually started speaking, I received an encouraging response from the audience and attendees liked my take on topics which they said provided a unique perspective. Being a very pragmatic consultant, I usually have a different point of view, as opposed to being a paranoid view. I approach security & risk problems and issues as a business person which provides a different perspective, so that’s where I think I got some good recognition from the market, especially in the speaking circuit. I believe speaking engagements not only present an opportunity for building your own personal brand but also helps sharpen your selling and marketing skills. The way you approach people, build their perception of you, sell yourself and your ideas, it’s a very good skill to have which is not generally taught in school or at university. Now, I encourage my colleagues and professionals to speak at events.
Returning to what you were saying about being an outcome oriented consultant, could you please elaborate on how changes can be implemented within organisations when these changes involve people and their behaviour? How do you address the people aspect of security?
As a security professional, when you implement a new security control, you are usually changing the way people are operating. A very simple example would be when implementing a control in terms of how people access production system. So if you go into an organisation in which their practices have been acceptable for the past 10 years, and you suddenly tell them that they can no longer follow same practice, you are, in a way, taking a privilege away from them and they will react accordingly. The analogy that I usually use for this is if I suddenly tell my son, who normally watches 1 hour of T.V. a day for the past several years, that he cannot watch it without taking permission every time and not more than 30mins from now on. He will not like it and will most likely rebel and show his displeasure.
As security professionals we try to change the process, and we want to introduce a certain level of governance on top of it. It’s very important to manage the people aspect of implementing such changes for security. You need to get people on your side before you actually implement these controls. It is a lot about socialising, and communicating, which brings me back to the point on selling and marketing. You have to package, sell and market these changes by conveying the message that “even though we are taking this privilege away from you by implementing these controls, we are going to give you something in return: We will guarantee that you run your business in a compliant manner and do not get audit findings or regulatory issues in which you will have to invest to address them”. So returning to the original example, it’s about establishing a secure way of accessing production systems which, although might be different from existing methods and might involve a little extra work, will ensure that everybody can continue to do their job while being compliant. We will create a robust production access environment: “So let’s be proactive and address this situation together before someone else comes and asks us to fix it.”
There are some of security professionals who scare the clients and users as a strategy for avoiding unwanted behaviour, by telling them, for example, that they might even risk getting fired. What is your opinion on this approach?
If you scare people too much, they will be scared as long as you are in front of them, but the behaviour won’t change. The objective should be to change the behaviour, and when we say “behaviour”, we are referring to the way people operate on a day-to-day basis. Make sure that they don’t see this as a temporary situation, but as a routine. A very simple example for this would be physical security guards. We have security guards in all the office buildings who are standing on the side, observing people, looking for individuals who may seem malicious or suspicious. But they don’t intimidate people around them. You might even be able to approach them for directions and they will kindly answer if they can help. But the moment they detect somebody suspicious, they will intervene. Now let’s imagine that instead of having these friendly security personnel, we had big bouncers who are aggressive. Would you feel okay approaching them? Sometimes security in our context operates like those big nightclub bouncers, because it is intimidating. So business people stop inviting you as a security professional to their business initiatives because they see security as the big intimidating bouncer: as a problem. For them, if you bring security in, you are bringing a problem in. That needs to change, and it largely depends on relationships and how you manage those relationships, how you come across in your meetings with them, and what they main message of your proposition is: “we are not taking anything away from you, we are going to help implementing new controls that will allow you to run your business in a secure and compliant manner meeting legal and regulatory obligations.”So it’s a trade-off and it’s a lot about perception, so the scaring tactic I don’t think works for too long.
You have come up with a way of selling all of your services to the executives and they understand the value of them. What about the actual people who use the service?
I think of executives as the same as the end-users, so the methods I use to sell security doesn’t change at for different levels. It’s the way you deliver message and what message you deliver has to be adapted for different levels. Business executives will normally focus on how you are going to solve the problems that will allow the business to address the compliance issues and meet regulatory requirements. They are the ones that get chased around by the auditors and the regulators. But for the end-users, compliance is not their problem. They never get to own or see these auditing issues. From their perspective, they have a business to do, a server to manage, an infrastructure to run, they want to operate the way they have done so far. So if bringing in new security controls doesn’t mean making life difficult, they are happy to participate. As a security professional, that’s the message that you can give: “we are not here to make your life difficult, but to make sure you have the right tools to do your job effectively in a secure and compliant manner.”
As a preliminary step to implementation, would you have to first understand what it is people normally do on a day-to-day basis?
Absolutely. The very first thing I like to do is to see these users or consumers of these controls as my key stakeholders. One thing I always do in any of these change programmes is approach stakeholders including user groups in their working environment, and make them feel comfortable. Ask them, listen to them and understand what their problems are. What is it that they like that they would like to keep, and what they don’t like that they would like to have changed, and what is it that they might have seen somewhere else and might be a good thing to include as part of this change. Key benefit from being in listening mode is that people become part of the journey because they have largely contributed to the creation and design of these new controls. The key to success is to approach any change from human psychological perspective and engaging them by asking, listening and taking their feedback on board. Another thing that I always make sure to do is to fix the things they don’t like in the existing environment. Listen to people; understand what they like, what they don’t like, make sure you can fix their problems, and if they want something else, try to help them get it: get them on your side. Make them feel like they are part of this journey and also give them credit for their contribution to the success.
Let’s imagine that a security manager decides to implement a security policy in any given company. Let’s say that they take a standard framework like, say, ISO 27001, they tweak it a bit and apply it into the company’s environment. Do you see any potential problems with this?
Frameworks are a good start. But what lots of organisations do is that they lift the framework as is and if you look at the policies in most of them, there is not much difference. But if you think of different types of organisations like the financial services, investment banking, or law firms, you have many different environments: you have different drivers and they come with a very different set of challenges. A lot of professionals, who write policies, do so in isolation. They don’t spend time understanding how a specific organisation carries out its business. An interesting question would be, once a policy is written, whom do you want to be the target audience? Is the policy being written by security people, to be interpreted by security people? Or is a policy being written by security people, to be understood by security people, when in reality it is supposed to be meant for business people? In one of my previous engagements, I had security experts writing the policy, and I then hired a technical writer to review, proof-read and rewrite the policy. The end products between the policy written by the security experts and by the technical writer were completely different: the latter was much more understandable by the business community. We don’t realise that, unless an external person comes along and starts asking questions –“oh, what do you mean by this?”- that the language is not easily understandable for everyone. So I believe that every organisation should hire competent technical writers to translate their security policy, standards and guidance from specialised security jargon into a language that is understandable for business people.
So once your policy is written in understandable terms for everyone, how do you make people read it and comply?
The first thing I do in any organisation is that I visit their homepage and type in “information security”. If the policy doesn’t come up as the first search result, something is wrong. If people can’t find the security policy, how can you expect them to read it? How can you expect them to comply?
Another thing that I have done in few organisations is to conduct a simple survey, by asking three simple questions to business community:
- Do you know that we have an information security department?
- Do you know services this department has to offer?
- Do you know how to contact them if you need it?
It’s very eye-opening and you get lots of strange responses from the business people. Many times they do not know how to contact the security department or what services they provide. If they don’t know you exist, how can they possibly approach you? We can have a fantastic policy embedded in some website, but nobody is looking at it nor reading it.
Another problem is that security policies are long documents: They are not exciting, they are not novels. So I wouldn’t expect business people to read each and every bit and understand it. The probability to succeed can increase if you can provide them a platform where they are able to search when they need to and know where to go and look for answers when they need it. And this touches the point of approachability and availability of the policy and guidance.
But lets focus on the policy itself. How many policies do we have in a typical regulated organisation that we expect employees to read and comply with? E.g. security, anti-money laundering, acceptable use, expenses, travel and anti-bribery policy etc: it’s a huge list. Think about how long it takes an individual to read those policies, understand, remember and follow them. We’re human, it’s not possible. What’s important is that on a day-to-day basis there are some aspects that you need to demonstrate and follow as a normal business user and whenever in doubt go and seek answers. I like to refer to this as “acceptable behaviour”, not only in terms of privacy and security but overall behaviour.
You can take key messages from all of your relevant policies, and communicate them in friendly, simplistic and interesting terms linking it back to acceptable behaviour. It’s not the computer-based training (CBT) that can change human behaviour, but human-to-human interaction. It’s about helping people understand how to do what they do on a day-to-day basis, how to make their daily life easier and making the information accessible if they need to know more.
To wrap it up, you have mentioned previously that it is important to build a good security culture within the organisation. How do you define a good security culture?
A good analogy for this would be our behaviour regarding airport security, what we know we can do and what not to do, as well as reporting anything that may look suspicious. We are generally aware of our surroundings, especially when we are in an unknown territory. This is very natural to us in the physical world where we can see, hear and touch things in our surroundings. The challenge now is that we are spending so much of our time in this virtual world, where our senses can’t be used in the same way. We have to ask ourselves what key risk indicators in this virtual world are. How should we conduct ourselves in this virtual world? This is the kind of awareness that needs to be built into people’s behaviour. I think this journey should start from earlier stages in life, when people are being schooled. When I was in school, when I was growing up, my parents used to tell me: don’t talk to strangers, don’t accept anything from strangers, don’t give away your personal information to people you don’t know well, and so on. It’s an advice on how to conduct yourself safely in the physical world. Now, those messages have to change. You need to build a culture into the newer generations who are now and will be spending so much of their time in the virtual world. The definition of stranger in the virtual world is different from that in the physical world. The definition of “acceptable behaviour”in this virtual world has to be different from physical world. The definition of those risk indicators haven’t changed. One cannot expect behaviour to change on the first day a person joins the workforce, because by that time, behaviours are already formed.
The moment people become security aware, they become security advocates who can help spread this awareness on behalf of the security department. The organisations have to start a chain-reaction by making a few people security-aware and sending the message across the organisation. Everybody becomes self-aware at some point and starts thinking on his/her own about what is right and wrong. But this doesn’t happen because of computer-based training or policies. It is the change in human behaviour that is required in the long-term.
Thank you Jitender