Building a Model for Security Governance, Risk and Compliance

I recently began to think about how to integrate security seamlessly into an organization — without having security activities and processes pigeonholed into a stovepipe like physical security (the 3 Gs, guns, guards and dogs); or in the rarified atmosphere of the IT Department.

Other business processes are already thought of as an integral part of a business.  Think personnel, finance, shipping, sales.  All basic parts of any organization, including government agencies (which are another kind of business), have these different categories but security is never mentioned as one of these basics.

Of course, my readers know that none of the other pieces would get very far without good, or even great security.  You can’t run an organization without locks on the doors.  You can’t run a network with security controls or it would just collapse into a heaping pile of spam within a few hours and become totally useless.

So if we wanted to integrate security and use the risk assessment process to do it — what are the pieces we would integrate?   One night over dinner with other security people, we started to build a security model, which could then by assessed and each category would have steps which could be combined to create THE PERFECT INTEGRATED SECURITY GOVERNANCE MODEL!!

I am open to suggestions about other aspects but here’s the list of the ones we started off with:

1.  Access Controls

2.  Accountability

3.  Budget/Fiscal Responsibility

4.  Compliance

5.  Information Technology

6.  Investigations

7.  Measurement/Evaluation

8.  Personnel Management

9.  Policies & Procedures (Ps & Ps)

10. Risk Assessment & Management

11.  Security Planning

12.  Training and Awareness

In the model I’m proposing, each of these areas could by quantified into a 5-step program with zero meaning no progress in that area, and five meaning it has been integrated into the organization as a standardized, budgeted process.

Send me an email if you’d like to see a graphic of the model.  The point of a model is to get an idea of where you are on the pathway to integration of the security model into the business process.  For example, you could find out that you doing great on access control and technology, but not so good on accountability or awareness.  Then you could put more emphasis, or resources into those deficient areas.

If you’ve ever read this blog before, you know that my mantra is, “if you can’t measure it — you can’t manage it” (quote by the late, great Dr. Peter Drucker).

While listening to talk radio people discussing the problems of AIG, I heard another great line, “Companies that are ‘to big to fail’ … are probably ‘to big to manage’.   And that’s probably right, because those companies, with tentacles out into industries all over the world, are probably ALSO TOO BIG TO MEASURE!

So having metrics applies to all these corporate processes and managing security using metrics must be an idea whose idea has come.   Often the security departments in companies are isolated from the C-level and may not be included as often as other corporate or department managers are.    This is why the breakdown occurs that leads to weakness in compliance with regulations, which can destroy the entire organization, or, if you’re a bank, can lead at a CDO (Cease and Desist
Order).

Often these twelve critical security elements are absolutely essential to the running of the organization and that is why it is important to create a management model to measure how they are working in YOUR organization!