In the highly regulated industries of finance, healthcare and energy, a focus on governance, risk and compliance (GRC) is crucial to effectively combat a cyber security breach. Unfortunately, when considering international data sharing, this can become overwhelmingly complex, writes Tom Kellermann. In today’s evolving cyber landscape, it’s less about balancing GRC and more about enacting proactive risk management as the main focus, with governance as an important element of that.
Typically, compliance is based on operational and regulatory risk management. Given the hostility of cyber space and the rapidly evolving threat landscape, just being technically compliant isn’t enough. Organisations must also be more proactive in preventing risk in other areas (such as reputational risk, for example). Reputational risk management, where there’s no governing or compliance standard, is an organisation’s worst nightmare. True reputational risk management isn’t just about crisis communications post-breach. Rather, it’s a part of proactive risk management that starts before you’ve been attacked, and before your impacted network can begin to attack your customers and partners.
Governance, as illustrated by the General Data Protection Regulation (GDPR), cannot slowly be rolled up, and it’s not solely about privacy as privacy and cyber security are interdependent. If balance is the ultimate goal, organisations should find it by empowering the CISO to be equal to or greater than the CIO. They must have their own resources, authorities and reporting regime that allows them direct access to the company’s Board.
Moreover, the CISO and CIO need to be in close collaboration with regards to technology decisions and security implications so these two departments can successfully partner against security risks. Yes, governance will always sit on top. It’s the defensive-minded head coach that determines the culture of the team, but without at least equality between the CISO and the CIO, organisations are inviting significant risks as they roll out technologies and mobile apps, or outsource with specific companies that haven’t been properly vetted from a cyber security risk perspective.
Priority for traditional compliance
Unfortunately, greater priority is always going to be given to traditional compliance for two key reasons. First, most organisational structures place a CISO under the CIO whose priorities nearly always come first. These priorities typically put the organisation on the offensive and include increasing access, efficiency, resiliency and speed to support the growing needs of the business, all of which expand an organisation’s attack surface. With limited time and budget and a rapidly changing technological landscape, this often leaves little left for a defensive strategy.
Second, CIOs are encouraged to maintain plausible deniability, where under legal precedent they cannot be criminally liable if a breach were to occur if they weren’t aware that a security gap existed. Unfortunately, this can lead to a tendency to avoid proactive penetration tests and threat hunting exercises. These would offer evidence that something has gone wrong, and that the CIO was aware of any back doors or vulnerabilities within the company’s systems and didn’t take any action against them, increasing their personal liability.
With these challenges in mind, organisations can work to achieve a balance between risk management and compliance by taking the following actions:
*Create a culture that’s focused on privacy and underpinned by cyber security
*Empower the CISO and the defensive mindset so that it’s equal to the authority and budget of the CIO
*Transition the conversation away from just IT to one around risk management and brand protection, while proactively conducting regular compromise assessments across the infrastructure and the company’s information supply chain. In the long run, it’s all about the sustainability of the brand.
We can all agree that taking a strong stance on GRC is necessary to successfully mitigate a cyber attack. It’s how to approach them that needs serious consideration. By focusing on proactive risk management, organisations should reconsider the power governance has, how to effectively address risk and what being compliant truly means for the CIO, the CISO and the entire Board of Directors.
Tom Kellermann is Chief Cyber Security Officer for Carbon Black