Best practices for implementing a company-wide risk analysis program
For most organizations today, the threat surface is broad and getting broader. There are the obvious concerns like the user base, remote or BYOD computing, on-premises infrastructure, and cloud, SaaS, and virtual environments. But as companies and supply chains become more intertwined, CISOs need to look harder at off-prem and outsourced resources, or overseas suppliers and assets.
The associated risk management programs are also constantly evolving, and that’s likely due to outside influences such as client contract requirements, board requests and/or specific security incidents that require security teams to rethink and strengthen their strategy. Not surprisingly, CISO’s today face several dilemmas: How do I define the business impact of a cyber event? How much will it cost to protect our company’s most valuable assets? Which investments will make the business most secure? How do we avoid getting sidetracked by the latest cyber breach headline?
A mature risk analysis program can be thought of as a pyramid. Customer-driven framework compliance forms the base (PCI/ISO frameworks required for revenue generation); then incident-driven infrastructure security in the middle (system-focused security based on known common threats and vulnerabilities); with analysis-driven comprehensive coverage at the pinnacle (identification of assets, valuations, and assessment of threat/vulnerability risk).
How do you kickstart that program? Here are five steps that I’ve found effective for getting risk analysis off the ground.
Determine enterprise-specific assets
The first step is determining what is critical to protect. Unlike accounting assets (e.g., servers, laptops, etc.), in cybersecurity terms this would include things that are typically of broader business value. Often the quickest path is to talk with the leads for different departments. You need to understand what data is critical to the functioning of each group, what information they hold that would be valuable to competitors (pricing, customers, etc.) and what information disclosures would hurt customer relationships (contract data, for instance).
Also assess whether each department handles trade secrets, or holds patents, trademarks, and copyrights. Finally, assess who handles personally identifiable information (PII) and whether the group and its data are subject to regulatory requirements such as GDPR, PCI DSS, CCPA, Sarbanes Oxley, etc.
When making these assessments, keep three factors in mind: what needs to be safe and can’t be stolen, what must remain accessible for continued function of a given department or the organization, and what data/information must be reliable (i.e., that which can’t be altered without your knowledge) for people to do their jobs.
Value the assets
Once you’ve identified these assets, the next step is to attach a value. Again, I make three recommendations: keep it simple, make (informed) assumptions, and err on the side of overestimating. The reason for these recommendations is that completing a full asset valuation for an enterprise would take years and wouldn’t ever be finished (because assets constantly change).
Efficient risk analysis requires a more practical approach that uses broad categories, which can then be prioritized to understand where deeper analysis is needed. For instance, you might use the following categories, and assign values based on informed assumptions:
- Competitive advantage – the items/processes/data that are unique to your company and based on experience. These are items that would be of value to a competitor to build on. To determine value, consider the cost of growing a legitimate competitor in your dominant market from scratch, including technology and overhead.
- Client relationships – what directly impacts customer relationships, and therefore revenue. This includes “availability” impacts from outages, SLAs, etc. Value determination will likely be your annual EBIT goal, and impact could be adjusted by a Single Loss Exposure.
- Third-party partnerships – relating to your ability to initiate, maintain or grow partner networks, such as contractors, ISPs or other providers. When valuing, consider the employee labor cost needed to recruit and maintain those partners.
- Financial performance – items that impact your company’s ability to achieve financial goals. Again, valuation might equate to annual EBIT.
- Employee relations – the assets that impact your ability to recruit and retain employees. Valuation should consider the volume of potential losses and associated backfill needs, including base salaries, bonuses, benefit equivalencies, etc.
Determine relevant threats, assess vulnerability, and identify exposures
When it comes to analyzing risk from threats, vulnerabilities and exposures, start with the common security triad model for information security. The three pillars – Confidentiality, Integrity and Availability (CIA) – help guide and focus security teams as they assess the different ways to address each concern.
Confidentiality touches on data security and privacy; it entails not only keeping data safe, but also making sure only those who need access, have it.
Integrity reflects the need to make sure data is trustworthy and tamper-free. While data accuracy can be compromised by simple mistakes, what the security team is more concerned with is intentional compromise that’s designed to harm the organization.
Availability is just what it sounds like – making sure that information can be accessed where and when needed. Availability is an aspect of the triad where security teams need to coordinate closely with IT on backup, redundancy, failover, etc. That said, it also involves everything from secure remote access to timely patches and updates to preventing acts of sabotage like denial of service or ransomware attacks.
In undertaking this part of the risk assessment, you’re using this security triad to determine threats, and then identifying exposure and assessing vulnerability to better estimate both the potential impact and probability of occurrence. Once these determinations are made, you’re ready for the next step.
AV = assigned Asset Value (quantitative/qualitative) as identified above.
EF = the Exposure Factor, a subjective assessment of the potential percentage loss to the asset if a specific threat is realized. For example, an asset may be degraded by half, giving an EF of 0.50.
From this we can calculate the Single Loss Expectancy (SLE) – the monetary value from one-time risk to an asset – by multiplying AV and EF. As an example, if the asset value is $1M, and the exposure factor from a threat is a 50% loss (0.50) then the SLE will be $500,000.
Risk definition also takes this one step further by using this SLE and multiplying it by a potential Annualized Rate of Occurrence (ARO) to come up with the Annualized Loss Expectancy (ALE). This helps us understand the potential risk over time.
When working through these figures, it’s important to recognize that potential loss and probability of occurrence are hard to define, and thus the potential for error is high. That’s why I encourage keeping it simple and overestimating when valuing assets – the goal is to broadly assess the likelihood and impact of risk so that we can better focus resources, not to get the equations themselves perfectly accurate.
Implement and monitor safeguards (controls)
Now that we have a better handle on the organizational risks, the final steps are more familiar territory for many security teams: implementing and monitoring the necessary and appropriate controls.
You’re likely already very familiar with these controls. They are the countermeasures – policies, procedures, plans, devices, etc. – to mitigate risk.
Controls fall into three categories: preventative (before an event), detective (during) and corrective (after). The goal is to try to stop an event before it happens, quickly react once it does, and efficiently get the organization back on its feet afterward.
Implementing and monitoring controls are where the rubber hits the road from a security standpoint. And that’s the whole point of the risk analysis, so that security professionals can best focus efforts where and how appropriate to mitigate overall organizational risk.