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Organizational Processes

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Security governance should address every aspect of an organization, including the organizational processes of acquisitions, divestitures, and governance committees. Acquisitions and mergers place an organization at an increased level of risk. Such risks include inappropriate information disclosure, data loss, downtime, or failure to achieve sufficient return on investment (ROI). In addition to all the typical business and financial aspects of mergers and acquisitions, a healthy dose of security oversight and increased scrutiny is often essential to reduce the likelihood of losses during such a period of transformation.

Similarly, a divestiture or any form of asset or employee reduction is another time period of increased risk and thus increased need for focused security governance. Assets need to be sanitized to prevent data leakage. Storage media should be removed and destroyed, because media sanitization techniques do not guarantee against data remnant recovery. Employees released from duty need to be debriefed. This process is often called an exit interview. This process usually involves reviewing any nondisclosure agreements as well as any other binding contracts or agreements that will continue after employment has ceased.

When acquisitions and mergers are made without security considerations, the risks inherent in those obtained products remain throughout their deployment life span. Minimizing inherent threats in acquired elements will reduce security management costs and likely reduce security violations.

It is important to evaluate the risks associated with hardware, software, and services. Products and solutions that have resilient integrated security are often more expensive than those that fail to have a security foundation. However, this additional initial expense is often a much more cost-effective expenditure than addressing security deficiencies over the life of a poorly designed product. Thus, when considering the cost of a merger/acquisition, it is important to consider the total cost of ownership over the life of the product's deployment rather than just initial purchase and implementation.

Acquisition does not relate exclusively to hardware and software. Outsourcing, contracting with suppliers, and engaging consultants are also elements of acquisition. Integrating security assessments when working with external entities is just as important as ensuring a product was designed with security in mind.

In many cases, ongoing security monitoring, management, and assessment may be required. This could be an industry best practice or a regulation. Such assessment and monitoring might be performed by the organization internally or may require the use of external auditors. When engaging third-party assessment and monitoring services, keep in mind that the external entity needs to show security-mindedness in their business operations. If an external organization is unable to manage their own internal operations on a secure basis, how can they provide reliable security management functions for yours?

When evaluating a third party for your security integration, consider the following processes:

 On-Site Assessment Visit the site of the organization to interview personnel and observe their operating habits.

 Document Exchange and Review Investigate the means by which datasets and documentation are exchanged as well as the formal processes by which they perform assessments and reviews.

 Process/Policy Review Request copies of their security policies, processes/procedures, and documentation of incidents and responses for review.

 Third-Party Audit Having an independent third-party auditor, as defined by the American Institute of Certified Public Accountants (AICPA), can provide an unbiased review of an entity's security infrastructure, based on Service Organization Control (SOC) reports. See Chapter 15 for details on SOC reports.

For all acquisitions, establish minimum security requirements. These should be modeled after your existing security policy. The security requirements for new hardware, software, or services should always meet or exceed the security of your existing infrastructure. When working with an external service, be sure to review any service-level agreement (SLA) to ensure that security is a prescribed component of the contracted services. When that external provider is crafting software or providing a service (such as a cloud provider), then a service-level requirement (SLR) may need to be defined. An SLR is a statement of the expectations of service and performance from the product or service of a vendor. Often, an SLR is provided by the customer/client prior to the establishment of the SLA (which should incorporate the elements of the SLR if the vendor expects the customer to sign the agreement).

Two additional examples of organizational processes that are essential to strong security governance are change control/change management (see Chapter 16, “Managing Security Operations”) and data classification (see Chapter 5, “Protecting Security of Assets”).

(ISC)2 CISSP Certified Information Systems Security Professional Official Study Guide

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