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Crisc All One Exam 2nd

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100% found this document useful (2 votes)
4K views424 pages

Crisc All One Exam 2nd

Uploaded by

gassurance0
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
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To Rebekah, Nathan, and Shay.
—Peter H. Gregory
For Thomas, Lauren, and Max.
I am very, very lucky.
—Dawn Dunkerley
I’d like to dedicate this book to
my family, who was very
understanding and patient with
me while I wrote this book. To
my wife Barbara; my children
Greg, Sarah, and AJ; and my
grandchildren, Sam, Ben,
Evey, Emmy, big Caleb, and
now, little Caleb: you guys are
the world to me.
—Bobby E. Rogers
ABOUT THE AUTHORS

Peter H. Gregory, CRISC, CISM®, CISA®, CDPSE™,


CIPM®, CISSP®, DRCE, CCSK™, is a 30-year career
technologist and a security leader in a regional
telecommunications company. He has been developing and
managing information security management programs since
2002 and has been leading the development and testing of
secure IT environments since 1990. Peter has also spent many
years as a software engineer and architect, systems engineer,
network engineer, and security engineer.
Peter is the author of more than 40 books about information
security and technology, including Solaris Security, CISM
Certified Information Security Manager All-in-One Exam
Guide, and CISA Certified Information Systems Auditor All-in-
One Exam Guide. He has spoken at numerous industry
conferences, including RSA, Interop, (ISC)² Congress, ISACA
CACS, SecureWorld Expo, West Coast Security Forum, IP3,
Source, Society for Information Management, the Washington
Technology Industry Association, and InfraGard.
Peter serves on advisory boards for cybersecurity education
programs at the University of Washington and the University
of South Florida. He was the lead instructor for nine years in
the University of Washington certificate program in applied
cybersecurity, a former board member of the Washington State
chapter of InfraGard, and a founding member of the Pacific
CISO Forum. Peter is a 2008 graduate of the FBI Citizens
Academy and a member of the FBI National Citizens
Academy Alumni Association. Peter is an executive member
of the CyberEdBoard and the Forbes Technology Council.
Peter resides with his family in Washington state and can be
found online at www.peterhgregory.com.
Dawn Dunkerley received a PhD in information systems from
Nova Southeastern University in 2011 with a doctoral focus on
information security success within organizations. Her
research interests include cyberwarfare, cybersecurity, and the
success and measurement of organizational cybersecurity
initiatives. Dr. Dunkerley holds a number of professional
certifications, including CRISC, CISSP, CISSP-ISSAP®,
CISSP-ISSEP®, CISSP-ISSMP®, CSSLP®, and CompTIA
Security+™ certifications.
Bobby E. Rogers is an information security engineer working
as a contractor for Department of Defense agencies, helping to
secure, certify, and accredit their information systems. His
duties include information system security engineering, risk
management, and certification and accreditation efforts. He
retired after 21 years in the U.S. Air Force, serving as a
network security engineer and instructor, and has secured
networks all over the world. Bobby has a master’s degree in
information assurance (IA). His many certifications include
CRISC, CISSP-ISSEP, CEH™, and MCSE: Security, as well
as the CompTIA A+™, Network+™, Security+, and
Mobility+™ certifications.

About the Technical Editor


Matthew Webster has more than 25 years of experience in
both IT and cybersecurity and is the author of Do No Harm:
Protecting Connected Medical Devices, Healthcare, and Data
from Hackers and Adversarial Nation States. Within his realm
of experience has been multiple security officer positions,
including chief information security officer. Matthew clearly
has a passion for cybersecurity, which is evidenced by the fact
that he has earned more than 20 IT and cybersecurity
certifications, including Certified in Risk and Information
Systems Control (CRISC), Certified Information Systems
Auditor (CISA), GIAC Law of Data Security & Investigations
(GLEG), and Certified Information Systems Security
Professional (CISSP).
Matthew has worked in and around many companies
throughout the northeast U.S. in a variety of capacities, and he
has built many cybersecurity programs from the ground up. As
a skilled professional, Matthew has spoken in a range of
contexts, including in person and at online events.
CONTENTS AT A GLANCE

Chapter 1 Governance
Chapter 2 IT Risk Assessment
Chapter 3 Risk Response and Reporting
Chapter 4 Information Technology and Security
Appendix A Implementing and Managing a Risk
Management Program
Appendix B About the Online Content
Glossary
Index
CONTENTS

Acknowledgments
Introduction
Chapter 1 Governance
Organizational Governance
Organizational Strategy, Goals, and
Objectives
Organizational Structure, Roles, and
Responsibilities
Organizational Culture
Policies and Standards
Business Processes
Organizational Assets
Risk Governance
Enterprise Risk Management and Risk
Management Frameworks
Three Lines of Defense
Risk Profile
Risk Appetite and Risk Tolerance
Legal, Regulatory, and Contractual
Requirements
Professional Ethics of Risk Management
Chapter Review
Quick Review
Questions
Answers
Chapter 2 IT Risk Assessment
IT Risk Identification
Risk Events
Threat Modeling and Threat Landscape
Vulnerability and Control Deficiency
Analysis
Risk Scenario Development
IT Risk Analysis and Evaluation
Risk Assessment Concepts, Standards,
and Frameworks
Risk Assessment Standards and
Frameworks
Risk Ranking
Risk Ownership
Risk Register
Risk Analysis Methodologies
Business Impact Analysis
Inherent and Residual Risk
Miscellaneous Risk Considerations
Chapter Review
Quick Review
Questions
Answers
Chapter 3 Risk Response and Reporting
Risk Response
Risk and Control Ownership
Risk Treatment/Risk Response Options
Third-Party Risk
Issues, Findings, and Exceptions
Management
Management of Emerging Risk
Control Design and Implementation
Control Types and Functions
Control Standards and Frameworks
Control Design, Selection, and Analysis
Control Implementation
Control Testing and Effectiveness
Evaluation
Risk Monitoring and Reporting
Risk Treatment Plans
Data Collection, Aggregation, Analysis,
and Validation
Risk and Control Monitoring Techniques
Risk and Control Reporting Techniques
Key Performance Indicators
Key Risk Indicators
Key Control Indicators
Chapter Review
Quick Review
Questions
Answers
Chapter 4 Information Technology and Security
Enterprise Architecture
Platforms
Software
Databases
Operating Systems
Networks
Cloud
Gateways
Enterprise Architecture Frameworks
Implementing a Security Architecture
IT Operations Management
Project Management
Business Continuity and Disaster Recovery
Management
Business Impact Analysis
Recovery Objectives
Recovery Strategies
Plan Testing
Resilience and Risk Factors
Data Lifecycle Management
Standards and Guidelines
Data Retention Policies
Hardware Disposal and Data Destruction
Policies
Systems Development Life Cycle
Planning
Requirements
Design
Development
Testing
Implementation and Operation
Disposal
SDLC Risks
Emerging Technologies
Information Security Concepts, Frameworks,
and Standards
Confidentiality, Integrity, and Availability
Access Control
Data Sensitivity and Classification
Identification and Authentication
Authorization
Accountability
Non-Repudiation
Frameworks, Standards, and Practices
NIST Risk Management Framework
ISO 27001/27002/27701/31000
COBIT 2019 (ISACA)
The Risk IT Framework (ISACA)
Security and Risk Awareness Training Programs
Awareness Tools and Techniques
Developing Organizational Security and
Risk Awareness Programs
Data Privacy and Data Protection Principles
Security Policies
Access Control
Physical Access Security
Network Security
Human Resources
Chapter Review
Quick Review
Questions
Answers
Appendix A Implementing and Managing a Risk
Management Program
Today’s Risk Landscape
What Is a Risk Management Program?
The Purpose of a Risk Management
Program
The Risk Management Life Cycle
Risk Discovery
Types of Risk Registers
Reviewing the Risk Register
Performing Deeper Analysis
Developing a Risk Treatment
Recommendation
Publishing and Reporting
Appendix B About the Online Content
System Requirements
Your Total Seminars Training Hub Account
Privacy Notice
Single User License Terms and Conditions
TotalTester Online
Technical Support
Glossary
Index
ACKNOWLEDGMENTS

From Peter:
I am immensely grateful to Wendy Rinaldi for affirming the
need to have this book published on a tight timeline. My
readers, including current and future risk managers, deserve
nothing less.
Heartfelt thanks to Wendy Rinaldi and Janet Walden for
proficiently managing this project, facilitating rapid
turnaround, and equipping us with the information and
guidance we needed to produce the manuscript.
Many thanks to Janet Walden and Nitesh Sharma for
managing the editorial and production ends of the project and
to Bart Reed for copyediting the book and further improving
readability. I appreciate KnowledgeWorks Global Ltd. for
expertly rendering my sketches into beautifully clear line art
and laying out the pages. Like stage performers, they make
hard work look easy, and I appreciate their skills.
Heartfelt thanks to Matt Webster (the author of Do No
Harm and former CISO at Galway Holdings) for his
invaluable tech review of the entire manuscript. Matt’s
experience in security leadership and risk management
resulted in many improvements in the manuscript. A thanks
also to others, including Mark Adams.
Many thanks to my literary agent, Carole Jelen, for her
diligent assistance during this and other projects. Sincere
thanks to Rebecca Steele, my business manager and publicist,
for her long-term vision and for keeping me on track.
Bobby and Dawn, thank you for including me and
welcoming me to this project. The first edition of this book
was entirely yours, and I’m honored to have been included in
this edition. I have enjoyed working with you and on this
project. But most important to me: it has been a pleasure
getting to know both of you better. You both have my deepest
respect.
Despite having written more than 40 books, I have
difficulty putting into words my gratitude for my wife,
Rebekah, for tolerating my frequent absences (in the home
office) while I developed the manuscript. This project could
not have been completed without her loyal and unfailing
support and encouragement.
From Dawn:
I continue to be proud to call Bobby Rogers my coauthor
and friend. I couldn’t ask for a better partner in crime.
Many thanks to Peter Gregory for jumping in and
improving our work. Thank you, Peter, for the guidance and
support!
McGraw Hill continues to provide both excellent editors
and excellent people to guide our projects along the way; we
could not have pulled off this project without them and their
consistent support.
A big thank you to our technical editor, Matthew Webster.
You did a great job keeping us on our toes.
Finally, I heartily acknowledge the contribution of my
family and friends who have supported me throughout my
various crazy endeavors. I could not ask for more than the love
and encouragement I receive every day toward pursuing my
goals. Thank you all.
From Bobby:
First, I’d like to thank all the good folks at McGraw Hill
and their associates for guiding us throughout this book,
helping us to ensure a quality product. Wendy Rinaldi, Caitlin
Cromley-Linn, and Janet Walden were awesome to work with,
making sure we stayed on track and doing everything they
could to make this a wonderful experience. We’re very
grateful to them for giving us the chance to write this book and
believing in us every step of the way. Nitesh Sharma of
KnowledgeWorks Global Ltd. was great to work with as
project manager, and I’m happy to work again with Bart Reed,
our copy editor on this project, who always manages to make
me sound far more intelligent with his improvements to my
writing.
Dawn Dunkerley has been one of my best friends for
several years now, and I also consider her one of the smartest
folks in our profession, so I was doubly happy to have her
coauthor this book once again. She has added some fantastic
insight and knowledge to this book; we couldn’t have done it
without her. Thanks much, Dawn!
I would also like to offer a profound thanks to Peter for
agreeing to be our coauthor on this project. Three minds are
definitely better than two, and Peter brought a new insight into
ISACA’s certifications and processes that we did not have for
the first edition. His work in rewriting, revamping,
redesigning, and rearranging the book material to make it
more closely align to ISACA’s exam requirements was a
critically needed improvement for this book to continue to be a
great reference and study guide for the exam.
Matthew Webster deserves some special thanks because, as
the technical editor, he had a difficult job, which was to make
sure we stayed reasonable and technically accurate throughout
the book. Matthew definitely contributed to the clarity,
understanding, and technical accuracy of the text. Thanks for
all your help, Matthew!
Most importantly, I would like to thank my family for
allowing me to take time away from them to write, especially
during the difficult times we live in right now. To my wife,
Barb, my children and their families, Greg, Sarah and Sara, AJ
and Audra, and my grandchildren, Sam, Ben, Evey, Emmy,
and big Caleb, and now, my first great-grandson, little Caleb: I
love all of you.
From Peter, Dawn, and Bobby:
We are so grateful for Matthew Webster’s contributions to
the completeness and quality of this book. Through his
experience in risk management and control, Matthew provided
expert commentary and many suggested changes that made the
book that much better. Thank you, Matthew!
INTRODUCTION

Welcome to the All-in-One Exam Guide for ISACA’s Certified


in Risk and Information Systems Control (CRISC) exam! This
book will help you study for, and successfully pass, one of
ISACA’s premier certification exams, the CRISC exam. This
exam is designed to test your knowledge of a wide variety of
topics related to risk management and information systems
controls. The exam focuses on business and IT risk
management in enterprise infrastructure and designing and
implementing IT security controls to mitigate risk.
Every day, it seems, data is breached at some of the largest
organizations in the world. Recently we’ve seen breaches in
the U.S. government, in the healthcare industry, and even at
tech giants such as Microsoft, LinkedIn, and Facebook.
Ransomware attacks alone are a plague on thousands of
companies in nearly every country in the world. No
organization, no matter what size, is immune to the threat of
data breaches or, for that matter, data theft or loss. However,
effective risk management can reduce the possibility of data
breaches and strengthen business processes and IT
infrastructures and even contribute to their efficient use.
Information system controls reduce the likelihood of adverse
events having a significant impact on the organization and
should be carefully planned for and considered.
This book covers basic risk concepts, risk assessments,
standards and frameworks, and information security control
design and implementation. We also cover the essential
concepts, terminology, and definitions that risk management
practitioners and security professionals need to be effective in
these areas. In the book’s four main chapters, we cover all four
of the top-level domains as well as the task and knowledge
statements listed in the official ISACA exam objectives.
Appendix A discusses the pragmatic ways in which a security
leader can successfully implement a risk management
program.
While you don’t have to be an expert already in all the
areas we discuss, having experience in some of these areas,
such as risk concepts, helps. A good, broad background of
experience and knowledge in information security will give
you an advantage in your studies for this exam. Of course,
you’ll get a good background in all these subjects throughout
the book.
Passing the CRISC exam not only places you in a class of
professionals recognized for their experience and expertise in
this field, but it also serves to quantify and validate your
knowledge of advanced risk management and security topics.
After passing this exam, you’ll be able to show that not only
are you qualified, but you are certified in these areas. This
book is designed to help get you there.

Purpose of This Book


Let’s get the obvious out of the way: this is a comprehensive
study guide for the information security and risk management
professional who needs a reliable reference for individual or
group-led study for the CRISC certification. This book
contains the information that CRISC candidates are required to
know. While this book is one source of information to help
you prepare for the CRISC exam, it should not be thought of
as the ultimate collection of all the knowledge and experience
that ISACA expects qualified CRISC candidates to possess—
no one publication covers all this information. The other thing
you’ll need, just as important as suitable study material in our
minds, is experience. There’s no substitute for practical,
hands-on experience. You should make every effort to learn all
aspects of the ISACA CRISC exam material we discuss in this
book.
This book also serves as a reference for aspiring and
practicing security and risk professionals and leaders. The
content required to pass the CRISC exam is the same content
that practicing security and risk professionals need to be
familiar with in their day-to-day work. This book is a
definitive CRISC exam study guide as well as a desk reference
for those who have already earned their CRISC certification.
The pace of change in the information security and risk
management industry and profession is high. Rather than
contain every detail and nuance of every law, practice,
standard, and technique in information security and risk
management, this book shows the reader how to stay current in
the profession. Indeed, the pace of change is one of many
reasons that ISACA and other associations require continuous
learning to retain one’s certifications. It is crucial to
understand key facts and practices in security and risk
management and learn how to stay current as they continue to
change. However, despite the high rate of change in
information security, there’s good news: the techniques for risk
management itself change very slowly. The principles of risk
assessments, risk management, and risk treatment are solid
and time-proven. Much of this book is devoted to these
practices.
This book is also invaluable for security and risk
management professionals who are not in a leadership
position. You will gain considerable insight into today’s
security and risk management challenges. This book is also
helpful for IT, privacy, and business management
professionals who work with risk management professionals
and need a better understanding of what they are doing and
why.
Finally, this book is an excellent guide for anyone exploring
a career in information security and risk management. The
study chapters explain all the relevant technologies,
techniques, and processes used to manage a modern risk
management program. This is useful if you are wondering
what the risk management profession is all about.

How to Use This Book


This book covers everything you’ll need to know for ISACA’s
CRISC certification examination. Each chapter covers specific
objectives and details for the exam, as defined by ISACA in its
job practice areas. The chapters and their sections correspond
precisely to the CRISC job practice that ISACA updates from
time to time.
Each chapter has several components designed to
effectively communicate the information you’ll need for the
exam.
• The topics covered in each chapter are listed in the first
section to help you to map out your study.
• Tips are included in each chapter that offer great
information on how concepts you’ll study apply in a
place that we like to call “the real world.” Often, they
give you a bit more information on a topic covered in
the text.
• Exam Tips are included to point out areas you need to
focus on for the exam. Note that they won’t give you
any exam answers, but they will help you know about
important topics you may see on the test.
• Notes may be included in a chapter as well. These are
bits of information that are relevant to the discussion
and that point out extra information.
• Fifteen practice questions appear at the end of each
chapter and are designed to allow you to attempt some
exam questions on the topics covered in the domain.
Appendix A is designed to help you understand the
practical side of risk management, particularly for security
leaders who need to develop or improve the risk management
function in an organization. All three of us have many years of
experience; this is our gift to you so that you have the greatest
chance to succeed.
Appendix B contains information on how to access the
online practice exam questions that accompany this book. The
TotalTester engine allows you to test yourself in either Practice
or Exam mode, or by narrowing down to a specific domain.
About This Second Edition
ISACA, like other certification organizations, periodically
updates the job practice for CRISC and its other certifications.
In 2020, we expected that ISACA would update the CRISC
job practice in 2021, which prompted us to prepare to write
this second edition reflecting these updates.
The first edition of this book was organized by subject
matter and included a mapping from the book to the CRISC
job practice. This arrangement allowed the book to tell the risk
and control story logically, and the mapping table in the book
helped readers understand what parts of the book
corresponded to what parts of the CRISC job practice.
This second edition has been rearranged: the chapters and
sections in the book now precisely correspond to the areas of
the CRISC job practice, so it is no longer necessary to include
a practice-to-book mapping. This new structure simplifies
readers’ desire to read more about a particular topic in the job
practice.
ISACA is somewhat academic in its approach to the
arrangement of the CRISC job practice areas. For this reason,
we added an appendix that describes the development and
operation of a risk management program from a practical point
of view. This appendix helps to fill the gap between the
CRISC job practice and what it really takes to succeed.
Bobby and Dawn, the coauthors of the first edition, asked
the publisher if Peter Gregory could be added to the writing
team for the second edition. Peter’s familiarity with ISACA,
its certifications, and his experience writing All-In-One Exam
Guides for ISACA and IAPP certifications have helped
improve this second edition. This book is the finished product
of our collective service to you, our readers.

Becoming a CRISC Professional


To become a CRISC professional, you are required to pay the
exam fee, pass the exam, prove that you have the necessary
education and experience, and agree to uphold ethics and
standards. To keep your CRISC certification, you are required
to take at least 20 continuing education hours each year (120
hours in three years) and pay annual maintenance fees. This
life cycle is depicted in Figure 1.

Figure 1 The CRISC certification life cycle


The following list outlines the primary requirements for
becoming certified:
• Experience A CRISC candidate must submit verifiable
evidence of at least three years of professional work
experience in IT risk management and IS control.
Experience must be verified and gained within the ten-
year period preceding the application date for
certification or within five years from passing the exam.
No waiver options are available.
• Ethics Candidates must commit to adhering to ISACA’s
Code of Professional Ethics, which guides the personal
and professional conduct of those certified.
• Exam Candidates must receive a passing score on the
CRISC exam. A passing score is valid for up to five
years, after which the passing score is void. A CRISC
candidate who passes the exam has a maximum of five
years to apply for CRISC certification; candidates who
pass the exam but fail to act after five years will have to
retake the exam if they want to become CRISC
certified.
• Education Those certified must adhere to the CRISC
Continuing Professional Education Policy, which
requires a minimum of 20 continuing professional
education (CPE) hours each year, with a total
requirement of 120 CPEs over the course of the
certification period (three years).
• Application After successfully passing the exam,
meeting the experience requirements, and having read
through the Code of Professional Ethics and Standards,
a candidate is ready to apply for certification. An
application must be received within five years of
passing the exam.

Experience Requirements
To qualify for CRISC certification, you must have completed
the equivalent of three years of total work experience in at
least two of the CRISC domains. Additional details on the
minimum certification requirements, substitution options, and
various examples are discussed next.

NOTE Although it is not recommended, a CRISC candidate


can take the exam before completing any work experience
directly related to information security management. As long
as the candidate passes the exam and the work experience
requirements are filled within five years of the exam date, and
within ten years from the application for certification, the
candidate is eligible for certification.

Direct Work Experience


You are required to have a minimum of three years of work
experience in IT risk management and IS control. This is
equivalent to 6000 actual work hours, which must be related to
at least two of the CRISC job practice areas, listed next. One
of these two job practice areas must be in Governance or IT
Risk Assessment.
• Governance Establish and maintain organizational
governance and risk governance programs and
frameworks. Determine roles and responsibilities as
well as develop policies, standards, business processes,
risk appetite, and risk tolerance, aligned with business
culture and compliance with legal, regulatory, and
contractual requirements.
• IT Risk Assessment Establish and maintain processes
to identify and analyze risk, including vulnerability
management, threat modeling, risk assessments, and
business impact analysis. Develop and maintain a risk
register.
• Risk Response and Reporting Establish and maintain
risk treatment and risk response, controls and control
ownership, third-party risk management processes, and
control testing and remediation. Establish and publish
metrics, key performance indicators, key risk indicators,
and key control indicators.
• Information Technology and Security Understand the
principles of information technology and security,
including enterprise architecture, IT operations, project
management, business continuity and disaster recovery
planning, data life cycle, systems development life
cycle, security awareness training, and privacy.
All work experience must be completed within the ten
years before completing the certification application or within
five years from initially passing the CRISC exam. You will
need to complete a separate Verification of Work Experience
form for each segment of experience.

Substitution of Experience
Unlike most other ISACA certifications, there are no available
experience waivers or substitutions. Instead, you are required
to have three or more years of experience in IT risk
management and IS control, as described in the preceding
section.

NOTE We recommend you also read the CRISC certification


qualifications on the ISACA website. From time to time,
ISACA does change the qualification rules, and we want you
to have the most up-to-date information available.

ISACA Code of Professional Ethics


Becoming a CRISC professional means you agree to adhere to
the ISACA Code of Professional Ethics, which is a formal
document outlining those things you will do to ensure the
utmost integrity and that best support and represent the
organization and certification.
Specifically, the ISACA Code of Professional Ethics
requires ISACA members and certification holders to do the
following:
• Support the implementation of, and encourage
compliance with, appropriate standards and procedures
for the effective governance and management of
enterprise information systems and technology,
including audit, control, security, and risk management.
• Perform their duties with objectivity, due diligence, and
professional care, in accordance with professional
standards.
• Serve in the interest of stakeholders in a lawful manner,
while maintaining high standards of conduct and
character and not discrediting their profession or the
association.
• Maintain the privacy and confidentiality of information
obtained in the course of their activities unless
disclosure is required by legal authority. Such
information shall not be used for personal benefit or
released to inappropriate parties.
• Maintain competency in their respective fields and
agree to undertake only those activities they can
reasonably expect to complete with the necessary skills,
knowledge, and competence.
• Inform appropriate parties of the results of work
performed, including the disclosure of all significant
facts known to them that, if not disclosed, may distort
the reporting of the results.
• Support the professional education of stakeholders in
enhancing their understanding of the governance and
management of enterprise information systems and
technology, including audit, control, security, and risk
management.
Failure to comply with the ISACA Code of Professional
Ethics can result in an investigation into a member’s or
certification holder’s conduct and, ultimately, disciplinary
measures, including the forfeiture of their hard-won
certification(s).
You can find the full text and terms of enforcement of the
ISACA Code of Professional Ethics at
www.isaca.org/credentialing/code-of-professional-ethics.

The Certification Exam


The certification is offered throughout the year in several
examination windows. You have several ways to register;
however, we highly recommend you plan and register early
regardless of your chosen method.
In early 2022, the schedule of exam fees in U.S. dollars was
• CRISC application fee: $50
• Regular registration: $575 member/$760 nonmember
As we write this, we’re emerging from the global COVID-
19 pandemic. During the pandemic, ISACA and other
certification bodies adapted and developed remotely proctored
exams that permitted test-takers to sit for a certification exam
from their residence. We have observed that ISACA has
returned to tests administered at testing centers while
continuing to offer remotely proctored exams for those who
prefer remote testing. We’ll discuss both options in this
section.

NOTE We recommend you pay close attention to


information on ISACA’s website regarding testing logistics
and locations.
Once registration is complete, you will immediately receive
an e-mail acknowledging your registration. Next, you will
need to schedule your certification exam. The ISACA website
will direct you to the certification registration page, where you
will select a date, time, and (optionally) location to take your
exam. When you confirm the date, time, and location for your
exam, you will receive a confirmation via e-mail. You will
need the confirmation letter to enter the test location—make
sure to keep it unmarked and in a safe place until test time.

Onsite Testing Center


When you arrive at the test site, you will be required to sign
in, and you may be required to sign an agreement. Also, you
will be required to turn in your smartphone, wallet or purse,
and other personal items for safekeeping. The exam proctor
will read aloud the rules you are required to follow while you
take your exam. These rules will address matters such as
breaks, drinking water, and snacks.
While you take your exam, you will be supervised by the
proctor, and possibly you will be monitored by video
surveillance in the test center to make sure no one can cheat on
the exam.

Remote Proctored Testing


If you have registered for a remote proctored exam, you need
to make sure you meet all the technical requirements. ISACA
has published the “Remote Proctoring Guide,” which includes
all the necessary technical requirements and describes the
step-by-step procedures for taking the exam.
A remote proctored exam means you’ll be taking the exam
on your own computer in your residence or other location.
You’ll be in live contact with an exam proctor, and your
webcam will be turned on throughout the exam so that the
proctor can observe you while taking the exam to ensure you
are not cheating through the use of reference materials (books
or online). The proctor may ask you to show them the room
where you are taking the exam to ensure you do not have
reference materials or information anywhere in view.
To be eligible for a remote proctored exam, you must have
a supported version of Windows or macOS, a current Google
Chrome or other Chromium browser (such as Brave or
SRware Iron), a webcam with at least 640×480 resolution, a
microphone, and a stable broadband Internet connection. You
must have the ability to install the PSI Secure Browser and
modify firewalls and other administrative tasks on the day of
the exam (this requires you have administrative privileges on
the computer you are using—which might be a problem if you
are using a company-issued computer).
You’ll be required to log in to your My ISACA account
when your exam is scheduled. Next, you’ll navigate to your
certifications, find the exam you have scheduled, and launch
the exam. You’ll be directed to perform several tasks,
including installing the secure browser and closing several
other programs on your computer, including other web
browsers and programs like Adobe Reader, Word, Excel, and
any others that could include reference material.
You are not permitted to speak or perform gestures at any
time during the exam. In short, you cannot be seen to perform
any action that might be an indication of aid by an accomplice
or the presence of reference material.
You’ll be required to verify your ID by holding it near your
webcam so that the proctor can see it to confirm that you are
not having someone else take the exam for you. You will also
be required to use your webcam to show the entire room to
your proctor.
After all steps have been completed, the proctor will release
the exam to you, and you may begin.

Exam Questions
Each registrant has four hours to take the multiple-choice
question exam. There are 150 questions on the exam,
representing the four job practice areas. Each question has four
answer choices, of which you can select only one best answer.
You can skip questions and return to them later, and you can
also flag questions that you want to review later if time
permits. While you are taking your exam, the time remaining
will appear on the screen.
When you have completed the exam, you are directed to
close it. At that time, the exam will display your pass or fail
status, with a reminder that your score and passing status are
subject to review.
You will be scored for each job practice area and then
provided one final score. All scores are scaled. Scores range
from 200 to 800; however, a final score of 450 is required to
pass.
Exam questions are derived from a job practice analysis
study conducted by ISACA. The areas selected represent those
tasks performed in a CRISC’s day-to-day activities and
represent the background knowledge required to develop and
manage an information security program. You can find more
detailed descriptions of the task and knowledge statements at
https://www.isaca.org/credentialing/crisc/crisc-exam-content-
outline.

Exam Coverage
The CRISC exam is quite broad in its scope. The exam covers
four job practice areas, as shown in Table 1.

Table 1 CRISC Exam Practice Areas


Independent committees have been developed to determine
the best questions, review exam results, and statistically
analyze the results for continuous improvement. Should you
come across a horrifically difficult or strange question, do not
panic. This question may have been written for another
purpose. A few questions on the exam are included for
research and analysis purposes and will not be counted against
your score. The exam contains no indications in this regard.

Preparing for the Exam


The CRISC certification requires a great deal of knowledge
and experience from the CRISC candidate. You need to map
out a long-term study strategy to pass the exam. The following
sections offer some tips and are intended to help guide you to,
through, and beyond exam day.

Before the Exam


Consider the following list of tips on tasks and resources for
exam preparation. They are listed in sequential order.
• Read the candidate’s guide For information on the
certification exam and requirements for the current year,
see the ISACA Exam Candidates Information Guide: go
to www.isaca.org/credentialing/crisc and look for the
Exam Candidate Information Guide download links.
• Register If you are able, register early for any cost
savings and solidify your commitment to moving
forward with this professional achievement.
• Schedule your exam Find a location, date, and time,
and commit.
• Become familiar with the CRISC job practice areas
The job practice areas serve as the basis for the exam
and requirements. Beginning with the 2021 exam, the
job practice areas have changed. Ensure your study
materials align with the current list, shown at
https://www.isaca.org/credentialing/crisc.
• Know your best learning methods Everyone has
preferred learning styles, whether self-study, a study
group, an instructor-led course, or a boot camp. Try to
set up a study program that leverages your strengths.
• Self-assess Run through practice exam questions
available online (see Appendix B for more information).
ISACA may offer a free CRISC self-assessment.
• Study iteratively Depending on how much work
experience in information security management you
have already, we suggest you plan your study program
to take at least two months but as long as six months.
During this time, periodically take practice exams and
note your areas of strength and weakness. Once you
have identified your weak areas, focus on those areas
weekly by rereading the related sections in this book,
retaking practice exams, and noting your progress.
• Avoid cramming We’ve all seen the books on the
shelves with titles that involve last-minute cramming.
Just one look on the Internet reveals various websites
that teach individuals how to cram for exams most
effectively. Research sites claim that exam cramming
can lead to susceptibility to colds and flu, sleep
disruptions, overeating, and digestive problems. One
thing is certain: many people find that good, steady
study habits result in less stress and greater clarity and
focus during the exam. Because of the complexity of
this exam, we highly recommend the long-term, steady-
study option. Study the job practice areas thoroughly.
There are many study options. If time permits,
investigate the many resources available to you.
• Find a study group Many ISACA chapters and other
organizations have formed specific study groups or offer
less-expensive exam review courses. Contact your local
chapter to see whether these options are available to
you. In addition, be sure to keep your eye on the ISACA
website. Also, use your local network to find out
whether there are other local study groups and other
helpful resources.
• Recheck your confirmation letter Do not write on or
lose your confirmation letter. Put it in a safe place and
note what time you will need to arrive at the site. Note
this on your calendar. Confirm that the location is the
one you selected and is located near you.
• Check logistics Check the candidate’s guide and your
confirmation letter for the exact time you are required to
report to the test site (or log in from home if you
registered for a remote proctored exam). A few days
before the exam, check the site—become familiar with
the location and tricks to getting there. If you are taking
public transportation, be sure you are looking at the
schedule for the day of the exam: if your CRISC exam
is scheduled on a Saturday, public transportation
schedules may differ from weekday schedules. If you
are driving, know the route and where to park your
vehicle.
• Pack Place your confirmation letter and a photo ID in a
safe place, ready to go. Your ID must be a current,
government-issued photo ID that matches the name on
the confirmation letter and must not be handwritten.
Examples of acceptable forms of ID are passports,
driver’s licenses, state IDs, green cards, and national
IDs. Ensure you leave food, drinks, laptops, cell phones,
and other electronic devices behind, as they are not
permitted at the test site. For information on what can
and cannot be brought to the exam site, see the CRISC
exam candidate guide at
https://www.isaca.org/credentialing/crisc.
• Make a notification decision Decide whether you want
your test results e-mailed to you. You will have the
opportunity to consent to e-mail notification of the
exam results. If you are fully paid (zero balance on
exam fee) and have agreed to the e-mail notification,
you should receive a one-time e-mail approximately
eight weeks from the date of the exam with your results.
• Sleep Make sure you get a good night’s sleep before the
exam. Research suggests that you should avoid caffeine
at least four hours before bedtime, keep a notepad and
pen next to the bed to capture late-night thoughts that
might keep you awake, eliminate as much noise and
light as possible, and keep your room a suitable
temperature for sleeping. In the morning, rise early so as
not to rush and subject yourself to additional stress.

Day of the Exam


On the day of the exam, follow these tips:
• Arrive early Check the Bulletin of Information and
your confirmation letter for the exact time you are
required to report to the test site. The confirmation letter
or the candidate’s guide explains that you must be at the
test site no later than approximately 30 minutes before
testing time. The examiner will begin reading the exam
instructions at this time, and any latecomers will be
disqualified from taking the test and will not receive a
refund of fees.
• Observe test center rules There may be rules about
taking breaks. This will be discussed by the examiner,
along with exam instructions. If you need something at
any time during the exam and are unsure as to the rules,
be sure to ask first. For information on conduct during
the exam, see the ISACA CRISC candidate guide at
https://www.isaca.org/credentialing/crisc.
• Answer all exam questions Read the questions
carefully, but do not overanalyze them. Remember to
select the best solution. There may be several
reasonable answers, but one is better than the others. If
you aren’t sure about an answer, you can mark the
question and return to it later. After going through all
the questions, you can return to the marked questions
(and others) to read them and consider them more
carefully. Above all, don’t try to overanalyze questions,
and do trust your instincts. Do not try to rush through
the exam, as there is plenty of time to take as much as a
few minutes for each question. However, at the same
time, do watch the clock so that you don’t find yourself
going too slowly that you won’t be able to answer every
question thoughtfully.
• Note your exam result When you have completed the
exam, you should see your pass/fail result. Your results
may not be in large, blinking text; you may need to read
the fine print to get your preliminary results. If you
passed, congratulations! If you did not pass, do observe
any remarks about your status; you will be able to
retake the exam—there is information about this on the
ISACA website.
If You Did Not Pass
Don’t lose heart if you did not pass your exam on the first
attempt. Instead, remember that failure is a stepping stone
to success. Thoughtfully take stock and determine your
improvement areas. Go back to this book’s practice exams
and be honest with yourself regarding those areas where
you need to learn more. Reread the chapters or sections
where you need to know more. If you participated in a
study group or training, contact your study group coach or
class instructor if you feel you can get any advice from
them on how to study up on the topics you need to master.
Take at least several weeks to study those topics, refresh
yourself on other topics, then give it another go. Success is
granted to those who are persistent and determined.

After the Exam


A few weeks from the exam date, you will receive your exam
results by e-mail or postal mail. Each job practice area score
will be noted in addition to the overall final score. All scores
are scaled. Should you receive a passing score, you will also
receive the application for certification.
Those unsuccessful in passing will also be notified. These
individuals will want to closely look at the job practice area
scores to determine areas for further study. They may retake
the exam as many times as needed on future exam dates, as
long as they have registered and paid the applicable fees.
Regardless of pass or fail, exam results will not be disclosed
via telephone, fax, or e-mail (except for the consented e-mail
notification).

NOTE You are not permitted to display the CRISC moniker


until you have completed certification. Passing the exam is not
sufficient to use the CRISC anywhere, including e-mail,
résumés, CVs, correspondence, or social media.

Applying for CRISC Certification


To apply for certification, you must submit evidence of a
passing score and related work experience. Keep in mind that
you have five years to use this score on a CRISC certification
application once you receive a passing score. After this time,
you will need to retake the exam. In addition, all work
experience submitted must have been within ten years of your
new certification application.
To complete the application process, you need to submit the
following information:
• CRISC application Note the exam ID number as found
in your exam results letter, list the information security
management experience and any experience
substitutions, and identify which CRISC job practice
area (or areas) your experience pertains to.
• Verification of Work Experience forms These must be
filled out and signed by your immediate supervisor or a
person of higher rank in the organization to verify your
work experience noted on the application. You must fill
out a complete set of Verification of Work Experience
forms for each separate employer.
As with the exam, after you’ve successfully mailed the
application, you must wait approximately eight weeks for
processing. If your application is approved, you will receive an
e-mail notification, followed by a package in the mail
containing your letter of certification, certificate, and a copy of
the Continuing Professional Education Policy. You can then
proudly display your certificate and use the “CRISC”
designation on your résumé, e-mail and social media profiles,
and business cards.

NOTE You are permitted to use the CRISC moniker only


after receiving your certification letter from ISACA.

Retaining Your CRISC


Certification
There is more to becoming a CRISC professional than merely
passing an exam, submitting an application, and receiving a
paper certificate. Becoming a CRISC professional is an
ongoing and continuous lifestyle. Those with CRISC
certification agree to abide by a code of ethics, meet ongoing
education requirements, and pay annual certification
maintenance fees. Let’s take a closer look at the education
requirements and explain the costs involved in retaining
certification.

Continuing Education
The goal of continuing professional education requirements is
to ensure that individuals maintain CRISC-related knowledge
to better develop and manage security management programs.
To maintain CRISC certification, individuals must obtain
120 continuing education hours within three years, with a
minimum requirement of 20 hours per year. Each CPE hour is
to account for 50 minutes of active participation in educational
activities.

What Counts as a Valid CPE Credit?


For training and activities to be utilized for CPEs, they must
involve technical or managerial training that is directly
applicable to information security and information security
management. The following list of activities has been
approved by the CRISC certification committee and can count
toward your CPE requirements:
• ISACA professional education activities and meetings.
• If you are an ISACA member, you can take Information
Systems Control Journal CPE Quizzes online or
participate in monthly webcasts. For each webcast,
CPEs are rewarded after you pass a quiz.
• Non-ISACA professional education activities and
meetings.
• Self-study courses.
• Vendor sales or marketing presentations (ten-hour
annual limit).
• Teaching, lecturing, or presenting on subjects related to
job practice areas.
• Publication of articles and books related to the
profession.
• Exam question development and review for any ISACA
certification.
• Passing related professional examinations.
• Participation in ISACA boards or committees (20-hour
annual limit per ISACA certification).
• Contributions to the information security management
profession (ten-hour annual limit).
• Mentoring (ten-hour annual limit).
For more information on what is accepted as a valid CPE
credit, see the Continuing Professional Education Policy
(https://www.isaca.org/credentialing/how-to-earn-cpe/#cpe-
policy).

Tracking and Submitting CPEs


Not only are you required to submit a CPE tracking form for
the annual renewal process, but you also should keep detailed
records for each activity. Records associated with each activity
should have the following:
• Name of attendee
• Name of sponsoring organization
• Activity title
• Activity description
• Activity date
• Number of CPE hours awarded
It is in your best interest to track all CPE information in a
single file or worksheet. ISACA has developed a tracking
form for your use, which can be found in the Continuing
Professional Education Policy. To make it easy on yourself,
consider keeping all related records such as receipts,
brochures, and certificates in the same place. Documentation
should be retained throughout the three-year certification
period and for at least one additional year afterward. Evidence
retention is essential, as you may someday be audited. If this
happens, you would be required to submit all paperwork. So
why not be prepared?
For new CRISCs, the annual and three-year certification
period begins January 1 of the year following certification.
You are not required to report CPE hours for the first partial
year after your certification; however, the hours earned from
the time of certification to December 31 can be utilized in the
first certification reporting period the following year.
Therefore, should you get certified in January, you will have
until the following January to accumulate CPEs. You will not
have to report them until you report the totals for the following
year, in October or November. This is known as the renewal
period. During this time, you will receive an e-mail directing
you to the website to enter CPEs earned over the course of the
year. Alternatively, the renewal will be mailed to you, and then
CPEs can be recorded on the hard-copy invoice and sent with
your maintenance fee payment. CPEs and maintenance fees
must be received by January 15 to retain certification.
Notification of compliance from the certification
department is sent after all the information has been received
and processed. Should ISACA have any questions about the
information you have submitted, it will contact you directly.

Sample CPE Submission


Table 2 contains an example of a CPE submission.
Table 2 Sample CPE Submission

CPE Maintenance Fees


To remain CRISC certified, you must pay CPE maintenance
fees each year. These fees are (as of early 2022) $45 for
members and $85 for nonmembers each year. These fees are in
addition to ISACA membership and local chapter dues
(neither of which is required to maintain your CRISC
certification).

Revocation of Certification
A CRISC-certified individual may have their certification
revoked for the following reasons:
• Failure to complete the minimum number of CPEs
during the period.
• Failure to document and provide evidence of CPEs in an
audit.
• Failure to submit payment for maintenance fees.
• Failure to comply with the Code of Professional Ethics
can result in investigation and ultimately can lead to
revocation of certification.
If you have received a revocation notice, you will need to
contact the ISACA Certification Department at
[email protected] for more information.

Living the CRISC Lifestyle


Being a CRISC involves a lot more than passing the exam,
participating in continuous learning, and paying the annual
maintenance fees. There are numerous opportunities to get
involved in local, national, and global activities and events that
will help you grow professionally and meet other risk
management professionals.

Find a Local Chapter


ISACA has over 200 local chapters in nearly 100 countries
around the world. Chances are there is a chapter near you.
Peter attended many ISACA chapter meetings and other
events in Seattle when he lived there, where engaging speakers
spoke on new topics, and where he met many like-minded
security and audit professionals over the years.
Local chapters rely entirely on volunteers, and there is
room for you to help in some way. Better chapters have
various programs, events, study groups, and other activities
that enrich participants professionally. For us, most of our
ISACA experience happens in our local chapter.

Attend ISACA Events


ISACA puts on fantastic in-person conferences with world-
class keynote speakers, expert presentations, vendor
demonstrations and exhibits, a bookstore, and opportunities to
meet other security, risk, and audit professionals. We find
ISACA conferences enriching to the point of being
overwhelming. There are so many learning and networking
opportunities that we find ourselves nearly exhausted at the
end of an ISACA conference.

Join the Online Community


ISACA has an online community known as Engage, in which
participants can discuss any topic related to security, risk,
audit, privacy, and IT management. You can read and
participate in online discussions, ask questions, help others
with their questions, and make new professional connections.
You can join Engage at https://engage.isaca.org/.

Pay It Forward Through Mentorship


If you are at the point in your career where you qualify for and
have a reasonable prospect of passing the CRISC exam,
chances are you have had a mentor or two earlier in your
career, and maybe you have one now. As you grow in your
professional stature, others will look to you as a potential
mentor. Perhaps someone will come out and ask you if you
would consider mentoring them.
The world needs more, and better, information security
professionals and leaders. Mentoring is a great way to “pay it
forward” by helping others get into the profession and grow
professionally. You will also find that mentoring will enrich
you as well.

Volunteer
As a nonprofit organization, ISACA relies on volunteers to
enrich its programs and events. There are many ways to help,
and one or more of these volunteer opportunities might be
suitable for you:
• Speaking at an ISACA event Whether you do a
keynote address or a session on a specific topic,
speaking at an ISACA event is a mountaintop
experience. You can share your knowledge and
expertise on a particular topic with attendees, but you’ll
learn some things, too.
• Serving as a chapter board member Local chapters
don’t run by themselves—they rely on volunteers who
are working professionals who want to improve the lot
of other professionals in the local community. Board
members can serve in various ways, from financial
management to membership to events.
• Starting or helping a CRISC study group Whether as
a part of a local chapter or at large, consider starting or
helping a group of professionals who want to learn the
details of the CRISC job practice. We are proponents of
study groups because study group participants make the
best students: they take the initiative to take on a big
challenge to advance their careers.
• Writing an article ISACA has online and paper-based
publications with articles on a wide variety of subjects,
including current developments in security, privacy,
risk, and IT management from many perspectives. If
you have specialized knowledge on some topic, other
ISACA members can benefit from this knowledge if
you write an article.
• Participating in a credential working group ISACA
works hard to ensure that its many certifications remain
relevant and up to date. Experts around the world in
many industries give their time to ensure that ISACA
certifications remain the best in the world. ISACA
conducts online and in-person working groups to update
certification job practices, write certification exam
questions, and publish updated study guides and
practice exams. Peter contributed to the first working
group in 2013 when ISACA initially developed the
CRISC certification exam; he met many like-minded
professionals, some of whom he is still in regular and
meaningful contact with.
• Participating in ISACA CommunITy Day ISACA
organizes a global effort of local volunteering to make
the world a better, safer place for everyone. Learn about
the next CommunITy Day at
https://engage.isaca.org/communityday/.
• Writing certification exam questions ISACA needs
experienced subject matter experts who are willing to
take the time to write new certification exam questions.
ISACA has a rigorous, high-quality process for exam
questions that includes training. Who knows—you
could even be invited to an in-person workshop on
writing exam items. You can find out more about how
this works at https://www.isaca.org/credentialing/write-
an-exam-question.
You can learn about these and many other volunteer
opportunities at https://www.isaca.org/why-isaca/participate-
and-volunteer.
Please take a minute to reflect on the quality and richness
of the ISACA organization and its many world-class
certifications, publications, and events. These are all fueled by
volunteers who made ISACA into what it is today. Only
through your contribution of time and expertise will ISACA
continue in its excellence for future security, risk, privacy, and
IT professionals. And one last thing you can only experience
on your own: volunteering not only helps others but enriches
you as well. Will you consider leaving your mark and making
ISACA better than you found it?
Continue to Grow Professionally
Continuous improvement is a mindset and a lifestyle that is
built in to IT service management and information security—
it’s even a formal requirement in ISO/IEC 27001! We suggest
that you periodically take stock in your career status and
aspirations, be honest with yourself, and determine what
mountain you will climb next. If needed, find a mentor who
can guide you and give you solid advice.
While this may not immediately make sense to you, know
this: helping others, whether through any of the volunteer
opportunities listed previously or in other ways, will enrich
you personally and professionally. We’re not talking about
feathers in your cap or juicy items on your résumé, but rather
the growth in character and wisdom that results from helping
and serving others, particularly when you initiated the helping
and serving.
Professional growth means different things to different
people. Whether it’s a better job title, more money, a better (or
bigger or smaller) employer, a different team, more
responsibility, or more certifications, embarking on long-term
career planning will pay dividends. Take control of your career
and your career path—this is yours to own and shape as you
will.

Summary
Becoming and being a CRISC professional is a lifestyle, not
just a one-time event. It takes motivation, skill, good
judgment, persistence, and proficiency to be a strong and
effective leader in the world of information security
management. The CRISC was designed to help you navigate
the security management world with greater ease and
confidence.
Each CRISC job practice area will be discussed in detail in
the following chapters, and additional reference material will
be presented. Not only is this information helpful in studying
prior to the exam, but it is also meant to serve as a resource
throughout your career as an information security management
professional.
CHAPTER 1
Governance
In this chapter, you will:
• Understand the concepts of organizational governance
and how goals and objectives support it
• Learn about structure, roles, and responsibilities
• Analyze how organizational risk culture is facilitated
through the definition of risk appetite and risk tolerance
• Understand the concepts of enterprise risk management,
associated frameworks, and the ethics of risk
management
This chapter covers Certified in Risk and Information
Systems Control Domain 1, “Governance.” The domain
represents 26 percent of the CRISC examination.

The CRISC Task Statements relevant to this domain focus on


governance and how it applies in this context to the
organization, particularly executive management. The
governance aspects of risk for an organization, as well as the
relationships between enterprise risk and IT risk, are also
explored. The chapter also examines risk management
governance and how it is implemented in the organizational
structure and culture. Governance also applies to overall laws,
regulations, and even risk frameworks, so we will discuss
those at length. In those governance discussions we will
explain both external governance and internal governance,
including policies and standards. Internal governance also
includes management oversight, such as business process
reviews, risk appetite and tolerance, as well as contractual
obligations regarding risk management. Other topics related to
the Task Statements we will touch on here and look at in depth
in other chapters include elements of risk such as assets and
their value, threats, vulnerabilities, likelihood, and impact.
Although many organizations will “do the right thing” in
terms of due diligence and care, upholding their legal and
ethical responsibilities and such, many other organizations
either do not or don’t do it to the same standards. This is why
governance is so vitally important to an organization.
Governance ties all these elements together. Governance sets
standards, whether they are legal, ethical, or otherwise, and
attempts to “standardize” what organizations do in terms of
their obligations to stakeholders and society in general. As
you’ll see in this chapter, governance comes from different
sources, both outside the organization and within it. It is a
synthesis of enforced requirements and organizational
leadership culture. Also, governance is necessary to ensure
that organizations treat systems and data with care and, again,
perform their due diligence and due care duties when dealing
with data protection and risk.
In this chapter, we will focus on organizational governance
and how it applies to all the different elements of an
information security management system: mission, strategy,
goals and objectives, roles and responsibilities, culture, risk,
and even ethics.

Organizational Governance
Governance is the glue that holds all the different framing
elements of an organization together: its mission, strategy,
goals, and objectives. Governance establishes the requirements
an organization must meet and consists of both internal and
external governance. External governance comes in the form
of laws, regulations, professional and industry standards, and
other sources of requirements imposed on the organization
from the outside. Internal governance typically supports
external governance through policies, procedures, and
processes. For example, if a law imposes requirements to
protect certain sensitive data using specific controls or to a
certain standard, then policies and procedures further support
those requirements by formalizing and codifying them within
the organization. Policies and procedures can also be
independent of external governance and simply reflect the
organization’s culture, needs, and values, usually established
by its executive management. In any event, governance is the
controlling factor for the organization; governance keeps the
organization on the right focus and ensures that it is meeting
its compulsory requirements, such as obedience to laws, as
well as performing its due diligence and due care
responsibilities.
In addition to imposing requirements on the organization,
governance also refers to the structure by which the
organization is led and regulated. Again, this could come from
external or internal sources. External sources for governance
could consist of an external board of directors or regulatory
agencies. These entities ensure that the organization is led
from the perspective of responsibility and accountability.
Internal governance comes from internal business leaders and
reflect business drivers not related to externalities. In reality,
good governance typically reflects a balance between both
internal and external business drivers.
The infrastructure framework of the organization—in the
form of strategy, goals, objectives, mission statements, and so
on—supports governance, as we will discuss further in this
chapter.

Organizational Strategy, Goals, and


Objectives
Businesses exist with clear missions, goals, and objectives.
The organization is in business for a particular purpose, not
merely because people want to come to work every day and
socialize. Missions, goals, and objectives directly relate to why
the organization is in business in the first place, whether that is
to develop and market a product or provide a service.
Organizational senior management defines the business’s
mission, goals, and objectives, typically on a strategic or long-
term level. Senior management also defines the levels of risk
tolerance and appetite based on factors that include the market
space, the operational environment, the economy,
governmental regulation, and so on. These risk levels directly
articulate with and support the business mission, balancing
business opportunities that can generate revenue and move the
business forward with potential negative events that may cause
the business to fail or at least have a detrimental impact on the
organization.

EXAM TIP Remember that risk appetite and tolerance are


directly related to the business mission, although different
business pursuits may have varying levels of each. Senior
management sets those levels based on the potential rewards
from risky opportunities and the amount of loss the
organization could endure if those rewards don’t materialize.

Organizational Structure, Roles, and


Responsibilities
How the business is organized can help drive how it deals with
risk in several ways. Most businesses are organized from a
functional perspective; in other words, departments and other
hierarchical structures are established to take care of specific
functions that contribute to the business goals and objectives.
For example, in a production-driven business, there may be a
manufacturing or production department, an engineering
department, a research and development department, and an
assembly line. There will likely be additional departments that
cover support functions, such as marketing, accounting and
finance, public relations, and so on. A hospital, on the other
hand, will be organized according to its specific functions,
such as the emergency department, surgery, neurology,
radiology, and so on. Businesses in other markets or areas will
be organized differently as well. In any case, the organization
of the business is structured as its mission and business
purposes dictate. Certain functions can be found in any
business, such as information technology, information security,
and even legal compliance. These functional areas may have
the primary function of dealing with risk, but an important
thing to consider is that all different organizational structures,
from lower-level work sections to higher-level departments
and divisions, have responsibilities regarding risk.
The organization must look at its structure and decide how
each individual unit will manage risk at its own level,
understanding that risk management should be uniform
throughout the entire organization. Another consideration is
that risks tend to “roll up” or be combined at the higher levels
of an organization. For example, risks that the accounting
department incurs are only a part of the risks at higher
organizational levels and are included in their risk
management processes. Each lower-level unit in an
organizational hierarchy has risks that are part of the next
higher level’s risk considerations. While individual units may
be responsible for only a small piece of the overall
organizational risk, their parent units also bear responsibility
for managing that risk, as well as the risk of other subordinate
units. Another concept relating to organizational structures is
that the risk incurred by one part of the organization is borne
by all parts of the organization; there is almost no such thing
as a risk that only affects one small part of the business. Risk
ripples across the entire organization in some way.
Each individual unit, whether it is a unit in the lower levels
of the business hierarchy or at the highest levels, should take
steps to identify, evaluate, and assess risks at its level. Risks
may be thought of as tactical, operational, and strategic.
Tactical risks are those that are encountered by smaller-level
production sections—those that carry out the day-to-day work
of the organization. Operational risks can span several work
units and relate to how the business conducts its functions, as
well as how the different work units interact with each other.
Strategic risk is borne at the higher levels of the organization,
including senior management, and involves risks incurred by
leading the business toward opportunities and away from
decisions that exceed the organization’s capacity for risk
appetite and tolerance. Respectively, these three types of risks
also correspond to short-term, mid-term, and long-term risks
as well.
Regardless of the level of risk incurred within the
organization, there should be an enterprise risk management
strategy and program in place to deal with the lower-tier,
middle-tier, and higher-tier risks as well as ensure that the risk
management strategy handles risks consistently and uniformly
in alignment with the organization’s risk tolerance and
appetite. Governance from the higher levels of the
organization affects risk appetite and tolerance and shapes the
organization’s risk management strategy throughout all the
different hierarchical levels. The organizational structure must
support that governance, as well as clearly define lines of
authority and responsibility in terms of risk leadership and
management.

Organizational Culture
Organizational culture is the term that describes how people
treat each other and how people get things done. Many
organizations establish a set of values that define the norms of
behavior. Terms like respect, collaboration, and teamwork are
often seen in these values. Some organizations will publish
formal value statements and print them for display in lobbies,
offices, and conference rooms.
The way that an organization’s leaders treat each other and
the rest of the organization sets an example for behavioral
norms. Often, these norms reflect those formal values, but
sometimes they may differ. One could say that an
organization’s stated culture and its actual culture may vary a
little, or a lot. The degree of alignment itself is a reflection of
an organization’s culture.
An organization also has a risk culture, which is essentially
how the organization as an entity feels about and deals with
risk. This culture is developed from several sources. First, it
can come from the organization’s leadership, based on their
business and management philosophies, attitudes, education,
and experience. It can also come from the organization’s
governance. Remember that governance is essentially the rules
and regulations imposed on the organization by either external
entities (in the form of laws, for example) or internally by the
organization itself. In any case, the culture of the organization
really defines how the organization feels about risk and how it
treats risk over time. We will talk later about how two
concepts, risk tolerance and risk appetite, support the
organizational risk culture.

Policies and Standards


Different types of controls work together to protect an
organization, many of which have a technical focus. However,
while the more technical approaches are quite often the stars
of the cybersecurity show, the importance of the good old
policy cannot be understated. In fact, without a policy, quite
often, the security program will fall flat due to a lack of
governance, management involvement, and accountability.
This objective covers different types of policies and how they
work together to form the underlying foundation of human and
process control, ensuring a balanced and effective security
program.
To provide effective security, security policy and procedure
creation must begin at the top of an organization with senior
management that understands, supports, and holds personnel
accountable to the written policies. Remember that
organizational policies must articulate with external
governance, such as requirements found in laws and
regulations, or the management philosophies and tolerances of
the organization’s leadership. These policies and procedures
must then flow throughout the organization to ensure that
security is useful and functional at every level of the
organization. Understanding organizational security must
begin with an understanding of the basic laws, regulations, and
legal jurisdiction that policies must be informed by in order to
protect not only the organization and its assets but also its
employees and customers.
Management creates policies based on its leadership
philosophies, culture, industry standards and requirements,
and, most importantly, external governance. Policies articulate
with all these items and represent management’s directives in
upholding these requirements. Policies specific to risk
governance include a body of documents that may start with
the Risk Management Strategy, which details the
organization’s overall strategy, methodology, and long-term
desires for managing risk. Policies support the strategy, as well
as governance requirements, such as those that may be found
in laws or regulations that dictate that certain risk management
activities must take place within the organization. An example
of a risk-related policy would be a risk management or risk
assessment policy, which dictates the organization’s
requirements for risk management, assessment and analysis,
risk treatment, and risk monitoring. This policy may be brief
or detailed but will usually state roles and responsibilities, the
risk management methodology adopted by the organization,
and the requirement to implement detailed risk management
procedures.

Business Processes
The organization’s mission is the reason that it exists, whether
this is producing goods, offering services, and so on. A shoe
manufacturer is in the business of making shoes; therefore, its
mission is to make good quality shoes. Most businesses have a
mission statement that describes their mission. While the
mission is the overall reason for existence, business processes
are the activities that carry out that mission. A shoe
manufacturer’s business processes could be as high level as
manufacturing, sales, and marketing, but even those higher-
level processes are broken down into activities, such as sewing
cloth and leather, developing types and styles of shoes, and
selling them to retailers. These are all processes that support
the business. Each of these business processes also incurs
some level of business risk. There could be risks in the
manufacturing process due to the types of materials or specific
manner of attaching the shoe soles to the rest of the shoe. A
faulty process could mean that the shoes are of lesser quality
than other competitors or that the styles don’t meet the
demands of consumers. This, in turn, will lead to fewer sales
or more consumer returns. Regardless of whether they are
higher-level processes or more detailed activities and tasks,
each of these is supported by one or more systems or sets of
data. These systems also incur risk, but of a different nature.
The risk incurred by the systems includes the ability to
effectively use those systems and data to support the different
business processes. Therefore, IT (or even cybersecurity) risk
directly informs business process risk since it could affect the
ability of the organization to carry out its business processes
and, in turn, its overall mission.
Business processes are “owned” by different managers
within the organization. This means that the business process
owners are responsible for both the day-to-day and long-term
operations and success of the process. This also means,
ordinarily, that they are the primary owners of the business
risk associated with the process. Of course, higher-level
management bears ownership and responsibility for both the
process and risk also, but these are typically the people in
charge of the business process.
Better organizations will take a formal approach with
regard to the development and management of business
processes. Documents that describe processes, roles and
responsibilities, and key assets may be formally managed with
business process change management and periodic review and
be kept in official repositories to ensure that no unauthorized
changes occur.
Organizations with higher maturity will develop metrics
and even key performance indicators (KPIs) associated with
each business process. This allows management to understand
the quantity and quality of business process output, which can
be used to determine tactical and strategic improvements that
can make processes more effective and efficient. Risk
practitioners must work hand-in-hand with business process
owners to develop these KPIs, as well as associated key risk
indicators (KRIs) and key control indicators (KCIs).
NOTE KPIs, as well as KRIs and KCIs, are covered in more
detail in Chapter 3, where we discuss risk response and
reporting as part of Domain 3.

Organizational Assets
Company assets can include physical items, such as computer
and networking equipment, office machines (for example,
scanners and copiers), work facilities, and information
processing centers, as well as nonphysical items, such as
valuable data. Asset identification involves identifying both
types of assets and determining their value. Asset values must
be established beyond the mere capital costs; a true asset
valuation should consider several factors. For example, a
consideration should be the cost to repair or recover the asset
versus simply replacing the asset outright. Often, repairing the
asset may be less expensive in the short run, but the cost of the
different components required to conduct a repair should be
considered. Also, it’s important to remember that this might
only be a temporary solution—one that could come back to
haunt you (and your pockets) in the long run.
Asset management is the collection of activities used to
oversee the inventory, classification, use, and disposal of
assets. Asset management is a foundational activity, without
which several other activities could not be effectively done,
including vulnerability management, device hardening,
incident management, data security, and some aspects of
financial management.
In information security, asset management is critical to the
success of vulnerability management. If assets are not known
to exist, they may be excluded from processes used to identify
and remediate vulnerabilities. Similarly, it will be difficult to
harden assets if their existence is not known. What’s more, if
an unknown asset is attacked, the organization may have no
way of directly realizing this in a timely manner. If an attacker
compromises an unknown device, the attack may not be
known until the attacker pivots and selects additional assets to
compromise. This time lag could prove crucial to the impact of
the incident.
Asset Identification
A security management program’s main objective (whether
formally stated or not) is the protection of the organization’s
assets. These assets may be tangible or intangible, physical,
logical, or virtual. Here are some examples of assets:
• Buildings and property These assets include real
estate, structures, and other improvements.
• Equipment This can include machinery, vehicles, and
office equipment such as copiers, printers, and scanners.
• IT equipment This includes computers, printers,
scanners, tape libraries (the devices that create backup
tapes, not the tapes themselves), storage systems,
network devices, and phone systems.
• Virtual assets In addition to the tangible IT equipment
cited, virtual assets include virtual machines and the
software running on them.
• Supplies and materials These can include office
supplies as well as materials used in manufacturing.
• Records These include business records, such as
contracts, video surveillance tapes, visitor logs, and far
more.
• Information This includes data in software
applications, documents, e-mail messages, and files of
every kind on workstations and servers.
• Intellectual property This includes an organization’s
designs, architectures, patents, software source code,
processes, and procedures.
• Personnel In a real sense, an organization’s personnel
are the organization. Without its staff, the organization
cannot perform or sustain its processes.
• Reputation One of the intangible characteristics of an
organization, reputation is the individual and collective
opinion about an organization in the eyes of its
customers, competitors, shareholders, and the
community.
• Brand equity Similar to reputation, this is the perceived
or actual market value of an individual brand of product
or service that is produced by the organization.

Sources of Asset Data


An organization that is building or improving its security
management program may need to build its asset inventory
from scratch. Management will need to determine where this
initial asset data will come from. Some sources include the
following:
• Financial system asset inventory An organization that
keeps all of its assets on the books will have a wealth of
asset inventory information. However, it may not be
entirely useful: asset lists often do not include the
location or purpose of the asset and whether it is still in
use. Correlating a financial asset inventory to assets in
actual use may consume more effort than the other
methods for creating the initial asset list. However, for
organizations that have a relatively small number of
highly valued assets (for instance, an ore crusher in a
gold mine or a mainframe computer), knowing the
precise financial value of an asset is highly useful
because the actual depreciated value of the asset is used
in the risk analysis phase of risk management. Knowing
the depreciated value of other assets is also useful, as
this will figure into the risk treatment choices that will
be identified later.

TIP Financial records that indicate the value of an asset do


not include the value of information stored on (or processed
by) the asset.
• Interviews Discussions with key personnel for the
purposes of identifying assets are usually the best
approach. However, to be effective, several people
usually need to be interviewed to be sure to include all
relevant assets.
• IT systems portfolio A well-managed IT organization
will have formal documents and records for its major
applications. While this information may not encompass
every IT asset in the organization, it can provide
information on the assets supporting individual
applications or geographic locations.
• Online data An organization with a large number of IT
assets (systems, network devices, and so on) can
sometimes utilize the capability of online data to
identify those assets. An organization with cloud-based
assets can use the asset management portion of the
cloud services dashboard to determine the number and
type of assets in use there. Also, a systems or network
management system often includes a list of managed
assets, which can be a good starting point when creating
the initial asset list.
• Security scans An organization that has security
scanning tools can use them to identify network assets.
This technique will identify authorized as well as
unauthorized assets.
• Asset management system Larger organizations may
find it more cost effective to use an asset management
application dedicated to this purpose, rather than rely on
lists of assets from other sources.
None of these sources should be considered accurate or
complete. Instead, as a formal asset inventory is being
assembled, the security manager should continue to explore
other sources of assets.

Collecting and Organizing Asset Data


It is rarely possible to take (or create) a list of assets from a
single source. Rather, more than one source of information is
often needed to be sure that the risk management program has
identified at least the important, in-scope assets it needs to
worry about.
NOTE As part of IT governance, management needs to
determine which person or group is responsible for
maintaining asset inventories.
It is usually useful to organize or classify assets. This will
help to get identified assets into smaller chunks that can be
analyzed more effectively. There is no single way to organize
assets, but here are a few ideas:
• Geography A widely dispersed organization may want
to classify its assets according to their location. This
will aid risk managers during the risk analysis phase
since many risks are geographic-centric, particularly
natural hazards.
• Service provider An organization utilizing one or more
Infrastructure as a Service (IaaS) providers can group its
assets by service provider.
• Business process Because some organizations rank the
criticality of their individual business processes, it can
be useful to group assets according to the business
processes they support. This helps the risk analysis and
risk treatment phases because assets supporting
individual processes can be associated with business
criticality and treated appropriately.
• Organizational unit In larger organizations, it may be
easier to classify assets according to the organizational
unit they support.
• Sensitivity Usually ascribed to information, sensitivity
relates to the nature and content of that information.
Sensitivity usually applies in two ways: to an individual,
where the information is considered personal or private,
and to an organization, where the information may be
considered a trade secret. Sometimes sensitivity is
somewhat subjective and arbitrary, but often it is
defined in laws and regulations.
• Regulation For organizations that are required to follow
government and other legal obligations regarding the
processing and protection of information, it will be
useful to include data points that indicate whether
specific assets are considered in scope for specific
regulations. This is important because some regulations
specify how assets should be protected, so it’s useful to
be aware of this during risk analysis and risk treatment.
There is no need to choose which of these methods will be
used to classify assets. Instead, an analyst should collect
several points of metadata about each asset (including
location, process supported, and organizational unit
supported). This will enable the security manager to sort and
filter the list of assets in various ways to better understand
which assets are in a given location or which ones support a
particular process or part of the business.

TIP Organizations should consider managing information


about assets in a fixed-assets application.

Risk Governance
Risk governance has several different aspects. As mentioned
earlier, governance provides the overall requirements of what
the organization must adhere to and could include legal,
ethical, safety, and professional requirements. Risk
governance, then, describes the requirements that the
organization must adhere to in terms of managing both
business and IT risk. Laws, regulations, and other external
governance can dictate portions of risk governance, as can
internal governance, which comes in the form of policy. Risk
governance is also set forth by executive management in the
form of risk appetite and tolerance, risk strategy, and
throughout the various policies that support risk management.
Risk governance includes adopting a risk assessment and
analysis methodology, risk treatment and response options,
risk monitoring processes, and so on. A multitude of risk
governance and management frameworks have been published
to assist in this process, which we will discuss next.

Enterprise Risk Management and Risk


Management Frameworks
Enterprise risk management (ERM) is the practice of
identifying and managing strategic risk in an organization.
This includes topics such as macroeconomics, market risk,
regulations, workforce, information technology, and
cybersecurity. The individual risks in ERM will cite various
uncertainties and scenarios that, if realized, may have a
negative impact on the organization’s long-term viability.
Standards and frameworks help provide a standardized,
industry-accepted approach toward managing risk. While
they’re certainly not perfect, they provide a baseline for an
organization to recognize the key steps toward understanding
and categorizing the risks to its business, implementing the
appropriate security controls to lower risk to an acceptable
level, and continually monitoring the residual risk and report
the status to management. Each standard and framework has
its own pluses and minuses, and we will discuss two of the
more commonly used: the ISACA Risk IT Framework and the
National Institute of Standards and Technology (NIST) Risk
Management Framework. Keep in mind that this discussion
serves only to introduce you to the frameworks.

ISACA Risk IT Framework


Originally published in 2009, the ISACA Risk IT Framework
is a common risk management framework you should be
aware of. ISACA wanted to create a framework that merges
the traditional IT models with a more risk-focused mindset.
Within the ISACA model, the activities considered key are
grouped into processes, which in turn are grouped into three
domains: Risk Governance, Risk Evaluation, and Risk
Response. You will see many of the same concepts that you’ll
find within this book (and even this chapter), so it’s definitely
a worthwhile model to review. The Risk Governance domain
discusses risk appetite, risk tolerance, and communicating risk
to leadership. The Risk Evaluation domain includes an
understanding of the impacts to the business and the risk
scenarios, developed through the inclusion of internal and
external environmental factors, risk management capability, IT
capability, and IT-related business capability. The Risk
Response domain covers the risk response definition, risk
response prioritization, and key risk indicators (KRIs). The
framework also describes risk response options such as risk
avoidance, risk mitigation, risk sharing and transfer, and risk
acceptance.

NIST Risk Management Framework


NIST Special Publication 800-37, Revision 2, “Guide for
Applying the Risk Management Framework to Federal
Information Systems,” along with other supporting
publications from NIST (part of the U.S. Department of
Commerce), makes up the defining volumes of the Risk
Management Framework (RMF). The RMF is composed of
seven steps:
1. Prepare.
2. Categorize information systems.
3. Select security controls.
4. Implement security controls.
5. Assess security controls.
6. Authorize information systems.
7. Monitor security controls.
Security categorization requires the information systems
and associated information to be categorized based on an
impact analysis. When selecting a set of security controls, you
must take into account the security categorization as well as
any previous assessments of risk. Following this step, you
implement the security controls that were previously selected
and then assess their effectiveness and the overall success of
the controls in lowering the risk to the accepted level. Finally,
the security controls need to be continually monitored so that
you’re sure they continue to operate as intended. You also
need to consider any changes that come into effect across the
organization (think location, mission, security classification, or
other underlying factors).
You will notice many additional concepts within NIST
Special Publication 800-37 that are germane to the CRISC
exam; for example, the early steps of the RMF discuss
categorizing and selecting appropriate security controls (which
we will discuss later in the book), while other steps correspond
to the implementation, assessment, and continuous monitoring
of controls (covered throughout this book). For these reasons
alone, it’s a great idea to read this document to understand
how the steps work together and how they are similar (and
sometimes different) from other frameworks.

Three Lines of Defense


ISACA makes a distinction of three lines of defense in
managing enterprise risk. These are operational management,
risk management and compliance functions, and auditing and
accountability. These lines are different events which are
implemented at different levels of the organization, across
business processes, as part of the wider enterprise risk
management program. The personnel responsible for these
three lines of defense are the risk owner, who is ultimately
accountable and responsible for how risk is treated, and the
risk practitioner, who is responsible for the day-to-day risk
management functions.

Operational Management
Operational management refers to the tactical management
activities that take place at the business unit or business
process level. At this level, risk is managed on a day-to-day
basis by monitoring control effectiveness as well as any risk
associated with the business process itself or its supporting
systems. This line of defense may be implemented by the risk
practitioner, the business process owner, or even IT and
cybersecurity personnel. This is the layer in which controls are
operated as a part of business processes and often
implemented as a part of information systems.

Risk and Compliance Management


This line of defense involves proactively monitoring and
managing risk associated with IT support systems, security
controls that are implemented to protect the systems, and risk
associated with overall business processes. This is where the
organization’s risk management program shines; implementing
the activities associated with the risk governance framework is
part of this critical line of defense. This includes overall risk
assessment and analysis, risk response, and continuous risk
monitoring.
Compliance management involves ensuring that the
organization, its business processes, and the supporting IT
systems comply with any governance requirements, whether
they come from inside the organization or from external
entities. Compliance directly leads to auditing processes and
systems, discussed next.
While risk and compliance management are connected,
they are separate and distinct entities. Risk can be variable in
nature and changes over time, whereas compliance is typically
a binary (yes/no, compliant/noncompliant) mentality.
However, there is usually some overlap between these two
areas, particularly in control assessments and risk analysis, as
both risk management and compliance management often
require control and risk assessments. Business process owners
and senior managers, as well as senior risk practitioners,
typically are involved with this line of defense.

Auditing and Accountability


In the world of risk management, auditing involves
continuously monitoring risk levels to ensure they fall within
acceptable levels of risk appetite and tolerance, as well as
monitoring the controls, management processes, and responses
that maintain acceptable risk levels. This could mean auditing
at the process level (account management, for instance) or
even at the overall organizational risk level, and every area of
interest in between. Auditing ensures that processes and
activities are being conducted in accordance with governance
and serves to further ensure accountability.
While auditing and accountability are not exactly the same
thing, they are complementary. Accountability, in terms of risk
management, ensures that risk owners are both responsible and
accountable for managing risk at an acceptable level within
their area of responsibility. In short, accountability ensures
they are doing their job. Accountability is connected to
auditing in the respect that only through auditing processes
and activities do we determine if those processes and activities
are fulfilling the governance and risk management
requirements that risk owners are responsible for meeting.

Risk Profile
A risk profile encompasses an overall asset, organization, or
business process under review and includes detailed
information on all aspects of those items and how they
contribute to, mitigate, or influence risk. The risk profile for a
system, for instance, would present detailed information on all
the different characteristics of the system, its security controls,
the risk assessment and analysis for the system, the risk
responses for the system, and ongoing management for that
risk. Risk profiles periodically change based on a variety of
factors, including the criticality or sensitivity of the system,
the vulnerabilities inherent to the system, the threats that may
exploit those vulnerabilities, and the mitigating security
controls that protect the system. Regulations and societal
norms also influence risk profile, particularly in areas such as
data privacy. The risk profile is used to actively manage
ongoing risk and ensure that it remains within acceptable
levels.

Risk Appetite and Risk Tolerance


As discussed previously, the culture of the organization really
defines how the organization feels about risk and how it treats
risk over time. Risk capacity is the amount of loss an
organization can incur without seriously affecting its ability to
continue as an organization. More resilient organizations can
endure greater loss than those that aren’t as resilient. How
resilient an organization is can sometimes be informed by its
risk culture. As part of the organization’s risk culture, there are
its risk appetite and risk tolerance. These are different terms
you also need to know to understand risk. Risk appetite is, in
effect, how much risk an organization is willing to deal with in
any given endeavor. This is the general level of risk that an
organization is willing to accept in the course of its business.
An organization’s risk appetite is driven by the corporate risk
culture and by the environment in which the organization
exists (market, regulation, and other external factors).
Risk tolerance, on the other hand, is the acceptable level of
deviation in risk for a particular endeavor or business pursuit.
Risk tolerance is how much variation from the expected level
of risk the organization is willing to put up with. There’s a
certain amount of risk in every business enterprise or pursuit;
however, the organization may not be able or willing to
tolerate large deviations from what it considers its acceptable
level of risk on an endeavor.

EXAM TIP Know the differences between risk appetite and


risk tolerance; risk appetite involves how much risk the
organization is willing to endure, whereas risk tolerance is
how much variation from that amount is acceptable to the
business for a particular venture. Risk culture drives both of
these factors.

Legal, Regulatory, and Contractual


Requirements
Governance imposed by entities external to the organization
usually takes the form of laws, regulations, professional
standards and requirements, and so on. Often, it is simply
enough for laws and regulations to be in place, or for a
company to formally accept professional standards for these
requirements to be imposed on an organization. Sometimes,
however, governance is also imposed as part of contractual
requirements between organizations. Including governance
requirements in contracts, even if an organization would
otherwise not be required to meet those requirements, makes
them legally enforceable. In any event, organizations are
required to fulfill their obligations imposed by these external
governance sources.
Additionally, laws, regulations, and other governance
sources often conflict with or even supplement each other. For
example, one regulation may require a specific level of
protection for sensitive data, and another law or regulation
may require additional layers of protection based on the
characteristics of the data, the organization, or the industry.
For example, privacy data and healthcare data are often
regulated by multiple sources of governance. In this event, the
organization must implement internal policies and procedures
to fulfill the requirements of all governance imposed on it.
Even in the case of professional standards, such as those
imposed by the Payment Card Industry Data Security Standard
(PCI DSS), organizations must fulfill the requirements
imposed on them if they have agreed to do so through contract
or by virtue of their industry. In this example, organizations
aren’t legally required to comply with this standard, but by
virtue of the fact that they process credit card transactions,
they are required by the credit card industry and can be
censured or banned from processing transactions by the credit
card companies if they do not comply with the requirements.
Compliance with legal and regulatory requirements is a
critical factor in most organizations, and many of these
requirements also impose risk management requirements as
well, so risk management is often dictated, to a degree, by
governance. In fact, many laws and regulations, such as the
Health Insurance Portability and Accountability Act (HIPAA),
require a formalized risk management program. Risk
governance frameworks, such as the NIST Risk Management
Framework, also require formalized risk management. These
frameworks can also be included in any other laws,
regulations, contracts, or other governance requirements
imposed on an organization.

Professional Ethics of Risk Management


Most organizations, particularly professional ones, have
requirements for a code of conduct or professional ethics. This
is especially true in the cybersecurity and risk management
professions. These codes of ethics regulate the behavior of
professionals and ensure that they maintain high standards of
behavior. Most of the industry-recognized professional
certifications also require adherence to a code of ethics, and
ISACA is no exception.
ISACA’s Code of Professional Ethics can be found at
https://www.isaca.org/credentialing/code-of-professional-
ethics and is imposed on all organizational members and
certification holders. ISACA also implements procedures for
filing complaints against professionals bound to uphold those
ethical standards in the event they fail to do so. The ISACA
Code of Professional Ethics (paraphrased here) includes
provisions for the following:
1. Supporting and complying with standards and
procedures for governance and management of
information systems and technology
2. Performing duties professionally, with due diligence
and care, as required by professional standards
3. Conducting activities in a lawful manner and
maintaining the high standards of conduct and character
required by the profession and ISACA
4. Ensuring privacy and confidentiality of sensitive
information obtained in the course of professional
duties
5. Maintaining competency in the professional field
6. Full disclosure and impartiality regarding results of
work performed to ensure that the results of that work
are not distorted
7. Supporting professional education in the areas of
governance and management of enterprise information
systems and technology, including auditing, controls,
security, and risk management

Chapter Review
Organizational governance drives how an organization
conducts itself within legal, regulatory, and even self-imposed
constraints. Governance focuses on legal compliance, due
diligence and care, and ethical behavior. This governance can
come from both external and internal sources in the form of
laws, regulations, professional standards, and internal policies
and procedures. Risk management is often a requirement
included in governance standards.

Quick Review
• Governance guides the conduct of an organization in
terms of legal and ethical behavior.
• Governance can come from external and internal
sources.
• External governance is imposed through laws,
regulations, professional standards, risk frameworks,
and contract requirements.
• Internal governance comes from internal policies and
procedures.
• The organization’s mission, goals, and objectives must
include and support governance requirements.
• Senior management defines risk appetite and tolerance
for the organization.
• Risk capacity is the amount of loss an organization can
incur without its very existence being threatened.
• Risk appetite is the amount of risk an organization is
willing to take on in pursuit of its mission.
• Risk tolerance is the level of variance from the appetite
an organization is willing to permit for any particular
business venture.
• An organization’s mission, goals, and objectives are
typically defined at the strategic or long-term level.
• Organizational structure can affect an organization’s
ability to deal with risk in terms of its risk culture,
appetite, tolerance, and resilience.
• Organizational business units, which consist of various
business processes, must deal with both business and IT
risk at the process level.
• Business process risk contributes to the overall
organizational risk and is managed at various levels,
starting with the risk owner, who is responsible and
accountable for risk management for a particular set of
business processes or business units.
• An enterprise risk management strategy and program
must be in place to deal with lower-, middle-, and
higher-tier risks. Risk governance drives the enterprise
risk management program.
• Organizational risk culture defines how an organization
feels about and deals with risk and comes from the
organization’s leadership and governance.
• Organizational policies are internal governance that
reflects the management philosophy, culture, and
directives of senior leaders.
• Policies are intended to articulate with external
governance.
• Organizational assets include anything of value to the
organization, including physical equipment, facilities,
human assets, and information.
• Asset management is a collection of activities used to
manage the inventory, classification, use, and disposal
of assets.
• The three lines of defense in managing enterprise risk
are operational management, risk and compliance
management, and auditing accountability.
• The risk profile consists of detailed information on all
aspects of an asset and how those aspects contribute to,
mitigate, or influence risk.
• The risk profile is used to manage risk for an asset.
• Governance can be imposed by laws, regulations, and
contracts, which are legally enforceable.
• Codes of conduct and ethics dictate the behavior of risk
management professionals.

Questions
1. An organization is subject to healthcare regulations that
govern the protection requirements of individual health
data. Which of the following describes this type of
governance?
A. External
B. Internal
C. Regulatory
D. Professional
2. Your company handles credit card transaction processing
as part of its business processes. Which of the following
best describes the source and type of governance it may
incur because of these business processes?
A. Internal, policies and procedures
B. External, industry standards
C. External, laws and regulations
D. Internal, industry standards
3. Your organization is structured into various departments,
and each of these has its own activities that support the
mission, goals, and objectives of the organization. These
activities are decomposed from a high level and include
various tasks to support the various business units. Which
the following best describes these activities?
A. Operational management
B. Organizational strategy
C. Business processes
D. Risk management functions
4. An organizational culture that is averse to risk and change
is more likely to have the following in terms of risk
appetite and tolerance?
A. High risk appetite, low risk tolerance
B. Low risk appetite, high risk tolerance
C. Low risk appetite, low risk tolerance
D. High risk appetite, high risk tolerance
5. Which of the following roles is the lowest level of
responsibility in terms of risk ownership for a business
process or unit?
A. Organizational CEO or president
B. VP for risk management
C. Risk practitioner
D. Business process owner
6. Which of the following is the level of variation or
deviance an organization is willing to accept for a
particular business venture?
A. Risk appetite
B. Risk tolerance
C. Risk acceptance
D. Risk capacity
7. A small business unit in the production department is
incurring risk for one of its lower-level business
processes. Although this risk is focused on the business
process and not at the organizational level, it must be
accounted for in the overall organizational risk
assessment. At what level should this risk be considered?
A. Organizational risk
B. Operational risk
C. Strategic risk
D. Tactical risk
8. An organization needs to create its internal risk
management program and begins with risk governance.
Which of the following should the organization create
first?
A. Risk strategy
B. Risk management policy
C. Risk assessment procedure
D. Risk management methodology
9. Which of the following describes why the organization
exists?
A. Organizational mission statement
B. Organizational strategy
C. External governance
D. Organizational policy
10. Which of the following activities is considered
foundational, without which other management activities,
such as vulnerability management, incident management,
and data security, could not be accomplished?
A. Configuration management
B. Risk management
C. Asset management
D. Financial management
11. Which of the following is not one of the three domains
listed in ISACA’s Risk IT Framework?
A. Risk Governance
B. Risk Evaluation
C. Risk Assessment
D. Risk Response
12. Which of the following requires that a risk practitioner
perform duties professionally, with due diligence and
care, as required by professional standards?
A. Risk IT Framework
B. NIST Risk Management Framework
C. ISACA Code of Professional Ethics
D. Laws and regulations
13. A risk manager is analyzing a risk item and intends to
recommend that risk acceptance be the recommended
treatment. Which of the following must the risk manager
consider to make this determination?
A. Risk awareness
B. Risk capacity
C. Risk tolerance
D. Risk appetite
14. The organization’s legal counsel is considering the
prospect of real estate prices, including office space
leasing costs, increasing significantly in the next five
years. What level of risk management should be used to
manage this risk?
A. Asset
B. ERM
C. Program
D. Market
15. All of the following are factors that influence an
organization’s culture except which one?
A. Published values
B. Policies
C. Leadership behavior
D. Behavioral norms

Answers
1. A. Laws and regulations are a form of external
governance.
2. B. This describes an external source of governance in the
form of industry standards, specifically the Payment Card
Industry Data Security Standard (PCI DSS).
3. C. Business processes are the activities that support the
organizational mission and can be broad or broken down
into detailed activities and tasks.
4. C. An organization that is risk averse likely has both a
low risk appetite and low risk tolerance.
5. D. Although various levels of organizational management
may be responsible and accountable for risk, the lowest
level of risk ownership for a business process or unit is
the business process owner.
6. B. Risk tolerance is the amount of variation or deviation
an organization is willing to accept from its risk appetite
that a particular business venture may incur.
7. D. Tactical risks are those encountered by smaller
production sections—those that carry out the day-to-day
work of the organization. A lower-level business process
may be considered to have a tactical risk.
8. A. The risk strategy for the organization should be
created first because it provides long-term direction for
the risk management program. The risk management
strategy also supports external governance. Policies and
procedures are created afterward to support the strategy
as well as implement external governance.
9. A. The organizational mission statement is developed by
the organization to describe its overall mission, which is
its very reason for existence.
10. C. Asset management is one of the foundational activities
on which other activities depend (vulnerability
management, configuration management, and so on)
because assets must be inventoried and accounted for
first.
11. C. Risk Assessment is not one of the domains covered in
the Risk IT Framework. The three domains are Risk
Governance, Risk Evaluation, and Risk Response.
12. C. The ISACA Code of Professional Ethics establishes
requirements for ethical conduct and behavior that all
certified professionals must adhere to, including the
requirement to perform all duties professionally, with due
diligence and care, as required by professional standards.
13. C. Risk tolerance determines the amount of risk an
organization will accept for any individual risk situation.
14. B. A risk matter such as macroeconomic risk generally
will be managed by an organization’s enterprise risk
management (ERM) program.
15. B. Of the available choices, an organization’s policies are
the least likely to influence an organization’s culture.
CHAPTER 2
IT Risk Assessment
In this chapter, you will:
• Understand the role of risk assessments and risk
analysis in the risk management life cycle
• Learn about the techniques used to identify various
types of risks
• Become familiar with risk identification and risk
analysis techniques such as threat modeling,
vulnerability analysis, control deficiency analysis, root
cause analysis, and risk scenario development
• Understand the concepts and steps taken in a risk
assessment
• Be familiar with the role and structure of a risk register
• Understand the concepts of inherent risk and residual
risk
This chapter covers Certified in Risk and Information
Systems Control Domain 2, “IT Risk Assessment.” The
domain represents 20 percent of the CRISC examination.

The CRISC Task Statements relevant to this domain address


several key activities present in a risk management program,
starting with conducting IT risk assessments and the impact of
IT risks on the organization’s objectives or operations. These
risk assessments should identify and evaluate threats,
vulnerabilities, and risks, and they should be recorded in an IT
risk register. In many organizations, the IT risk register would
be integrated into an enterprise risk management program, if it
exists. IT risk assessments should evaluate the existence and
effectiveness of IT controls and identify the need for new or
changed controls based on risk. This risk and control
information should be reported to stakeholders to facilitate
risk-driven decision-making, aligning with the organization’s
established risk appetite and risk tolerance. IT risk personnel
should periodically evaluate new and changing technologies
for changes to risk. The risk management program should be
aligned to industry frameworks and standards.
IT risk assessments are performed to identify risks
associated with a specific scope of business operations or
information technology in an organization. The purpose of
identifying risks is the need for an organization to be aware of
specific hazards that, if unchecked, could interrupt business
operations and incur additional cost. Business executives and
owners don’t want bad and unexpected things to happen;
rather than stick their heads in the sand, it’s wiser to identify
those risks and see what can be done about them. The
alternative means flying blind and being unaware of risk
scenarios, some of which may be highly likely to occur.
This chapter explores the broad picture of IT risk
assessment, which is the search for—and identification of—
various risks. We also explore the detailed view of risk
analysis, which is the careful examination of individual risks,
to better understand them in detail and explore various
remedies. Conceptually, risk assessment and risk analysis are
simple enough, but because there are so many ways in which
risk assessments and risk analyses may occur, and many
standards and techniques for each, all of this can become a
clutter.
In our opinion, ISACA’s layout of this domain, IT Risk
Assessment, isn’t quite right. Both the macro (risk assessment)
and micro (risk analysis) are scattered throughout the two
main parts of the domain. We will, however, stay true to the
structure of the domain, like it or not, but we’ll be sure to
clarify the context within risk management in each section.
IT risk assessments and risk analysis, covered in this
chapter, are a part of the overall risk management life cycle,
depicted in Figure 2-1. Risk governance, including risk profile,
risk appetite, and risk tolerance, are covered in Chapter 1,
while risk treatment, emerging risks, third-party risk
management, controls, and risk reporting are covered in
Chapter 3.
Figure 2-1 The components of risk management

IT Risk Identification
IT risk identification comprises the activities performed to
identify various types of risks associated with an
organization’s use of information technology. The types of IT
risks that can be identified fall into these categories:
• Strategic This category represents broad themes,
including whether IT is aligned to the business and
providing services required by the business, and
whether IT can support and respond to changes in
business strategy.
• Operational This category represents many issues,
including IT service management, service quality,
production schedule, resilience, and tactical matters
such as scheduling and availability.
• Cybersecurity This represents issues related to the
ability of internal and external threat actors to
compromise information systems or the information
stored in them.
• Privacy This represents both cybersecurity-related risks
as well as business practices related to the handling of
personal information.
• Supply chain This includes the availability of products
such as laptops, servers, and components, plus services
like tech support, and service providers, including SaaS,
PaaS, and IaaS. Supply chain itself has both operational
and cybersecurity-related risks.
• Compliance This represents IT-related activities that an
organization may be required to perform due to a
regulation, policy, or contract terms.
Security professionals need to train themselves to recognize
new risks. While at times they may be bold and obvious,
sometimes they will be subtle and easily missed for what they
are. Often, significant risks are identified when they are least
expected. In many organizations, IT risks are not apparent
until a threat event occurs. The activities that may lead to the
realization of new risks include the following:
• Audits An audit may identify a deficiency in a business
process or system that warrants more than remediation-
and-forget-it treatment. Often, this requires that a
security analyst or risk manager study the audit
deficiency to understand its root cause. Rather than
think of the deficiency as a one-time (or repeated)
mistake, perhaps the design of the control is the cause,
or something even broader such as the overall design of
a system or set of business processes. Where there’s
smoke, there’s fire—sometimes.
• Security and privacy incidents A security or privacy
incident may reveal a latent problem that has been
waiting to be discovered. The risk may not be directly
related to the incident or its cause. It could be
discovered by accident while an incident responder or
security analyst investigates an incident more deeply.
• Penetration tests While penetration tests can identify
specific vulnerabilities, sometimes it’s essential to read
between the lines and understand the overall theme or
meaning of the penetration test results.
• News and social media articles Information about
breaches, cybercriminal organizations, new tools and
innovations, and other cybersecurity topics can spur a
risk manager to identify a risk inside their organization.
We have all experienced this in our careers; an example
that comes to mind is this: news of a critical website
vulnerability at a competitor’s organization was widely
reported. Our management contacted us to see whether
we had the same or a similar exposure.
• Security advisories Advisories on vulnerabilities and
active attacks draw attention to specific actions and
technologies. A formal cyberthreat intelligence or attack
surface reduction program will subscribe to and
consume all such advisories to determine whether the
organization is vulnerable and then take action if
needed. We consider these advisories to be more tactical
than we would include in overall risk identification.
However, sometimes an advisory will help us realize
that something systemic isn’t quite right in our
organization and that we want to capture that idea while
it’s on our minds.
• Networking Discussions about information technology,
security, or privacy with professionals in other
organizations can trigger the realization of a risk in
one’s own organization. We do caution you on this
point: a risk in one organization, even when similar
practices or technologies are in play, does not
necessarily mean that another organization has the same
risk.
• Whistleblowers A disgruntled or concerned employee
may choose to remain anonymous and disclose
information about a condition or practice that may
represent a genuine risk to the organization.
• Passive observation During the course of work, a risk
manager or other cybersecurity staff may realize a
heretofore undiscovered risk. Sometimes a risk can lie
before us for an extended period of time until some
conversation or thought triggers a new realization.
• Threat modeling This is a particular type of risk
assessment, typically focused on an individual
information system or business process, to identify
likely threat scenarios.
• Secure configuration assessments Configurations that
are insecure or out of compliance can be a source of
critical risks. This can be out of compliance with
configuration baselines like the Center for Internet
Security. Others can be basic settings such as password
strength or length.
• Governance assessments Governance can be a huge
impact on how well the process runs. For example, if
there are not status checks on systems, the systems may
not be configured properly, thus increasing the risk to
the organization.
• Data governance risks For some organizations, how
data is used or shared can be very risky. For example, if
a contract explicitly forbids the sharing of data, but data
is being shared anyway, there can be legal
repercussions. Reviewing the data governance process
is an important part of protecting the data.
• Privacy assessments For some companies, privacy is
becoming a greater concern due to enhanced regulation.
Not being aware of the laws can have a huge impact on
the privacy of data and can lead to fines and lawsuits.
• Risk-aware culture The extent to which leaders,
management, and staff in an organization are trained to
recognize risk will result in better outcomes, including
more effective security and privacy by design, and a
willingness to accept that risks are always present and
can be managed. Security awareness training should
include risk awareness.
• Risk assessments This is the wide gate through which
many risks will be identified and analyzed. We’re
putting this last on the list for a few reasons: risk
assessments generally have a specified scope and are
aligned to a specific framework of controls, so risk
analysts are, by design, looking only for particular types
of risks in specific places. These blinders can sometimes
prevent someone from seeing certain types of risks, or
risks in specific contexts or places.
Our hope here is that you will realize the discovery of risk
can occur in many ways. The best tool the risk manager can
obtain is an open mind, which is free to explore the
possibilities of IT risk in the organization.

NOTE The context of IT risks includes on-premises and


cloud and service-provider uses of information technology.
Brainstorming and Risk Identification
Brainstorming some concept or idea in front of a
whiteboard with other colleagues is one of our favorite
activities (and one that we miss—we write this during the
COVID-19 pandemic in which most office workers are
isolated in their homes). In a brainstorming session,
participants each have whiteboard pens and write down
ideas that come to mind on some specific topic.
Alternatively, one person writes down ideas spoken by
others in the room.
The rule of brainstorming is this: silly ideas are not to be
rejected, because that silly idea could lead to a great idea.
For example, office workers are brainstorming ideas on
what color to paint the office. Let’s join the discussion.
“White.”
“Light brown.”
“Light gray.”
“Plaid.”
Wait a minute. Plaid isn’t a color. But they write it down
anyway. This prompts another to say, “Let’s paint it two
colors: white on interior walls to reflect light, and light gray
on other walls.”
Rejecting “plaid” might not have led the team to the
solution they ultimately chose, which was a bit different
from what they all expected: a single color.
Thought and discussions about risk are no different.
Dare to think outside the box and consider other ideas,
which could lead you to new discoveries.

Risk Events
Risk events are the specific scenarios that, if they occurred,
would inflict some impact on an organization’s ongoing
operations. A risk event includes a description of one or more
threat scenarios, the identification of the types of threat actors,
statements of vulnerabilities that could enable a threat scenario
to occur, the value of relevant assets, and the probability of
occurrence.

The Vocabulary of Risk


Every profession has its own lexicon—big words that
represent complex topics. We aren’t experts in every field, so
for each of us, sometimes we overhear conversations on some
professional topic that are sprinkled with words whose
meaning we may not fully comprehend. Our profession,
cybersecurity risk management, is no different in this regard.
Those of us in the industry occasionally hear “lay” persons
misuse these words. For example, we may overhear someone
in IT say, “That missing patch is a serious threat.” A risk
manager might hear that and think to themselves, that person
is using the term threat incorrectly. However, we should not
fault them for trying.
Here are the primary terms in the profession:
• Asset A tangible or intangible possession, such as a
server, device, program, database, other data,
intellectual property, or equipment.
• Vulnerability A specific weakness in a system, process,
or person that could fail to prevent some unwanted
event. An example of a vulnerability is an easily picked
lock on a door.
• Threat An event, should it occur, that would bring harm
to some asset. An example of a threat is a person who
wants to break into a building and has lock-picking
tools in their possession (and the skills to use them).
• Impact The result on an organization should a threat
occur.
• Attack An offensive action that results in potential
harm to an asset.
• Risk The possibility and impact of harm that could
occur to an asset, based on the asset’s value, and any
related vulnerabilities and threats.
Here are some additional terms that are often used:
• Threat actor The person or thing that would carry out a
threat if they chose to. Examples of threat actors include
a lone hacker and a military-based cyberhacking unit.
• Threat realization A threat that is carried out and
causes some harm to an asset.
• Threat modeling A specific type of analysis performed
to better understand likely attack scenarios.
• Event A more common term that is synonymous with
threat realization.
• Exploit (noun) A specific tool or method that can be
used to carry out a threat.
• Exploit (verb) The act of attacking an asset, made
easier by the presence of a vulnerability.
• Inherent risk The risk associated with a specific type
of activity, before controls are considered.
• Probability (also known as likelihood) The chance that
a specific threat event would occur, generally within a
period such as one year.
• Residual risk The risk that remains after any risk
reduction has been applied.
• Risk register A listing of risks that have been
identified.
• Risk analysis The examination of one or more specific
risks.
• Risk assessment An examination of a process or
system to identify and describe one or more risks.
• Risk treatment A decision made about potential action
to be taken concerning a specific risk.
• Risk management The life-cycle process that includes
risk assessments, risk analysis, and risk treatment.
These are just the basic terms used in risk management,
defined briefly here. These terms, and several others, are
explained in detail throughout this chapter. Figure 2-2 depicts
threat agent, threat, vulnerability, impact, and risk concepts.

Figure 2-2 Threats, vulnerabilities, likelihood, and impact


Here are some statements you might overhear in a
conversation with IT risk managers:
• “A threat actor could exploit that vulnerability on
Internet-facing assets, resulting in a serious incident.”
• “Threat modeling revealed additional vulnerabilities in
the new system.”
• “The risk assessment identified new risks that have been
entered into the risk register.”

Types of Risk Events


Several types of risk events can occur that are related to an
organization’s uses of information technology. The potential
range of risk events includes scenarios such as the following:
• Breaches
• Equipment failure
• Extortion
• Natural disasters
• Fires and floods
• Sabotage
• Intrusion, data theft, and ransomware
• New regulations
• Regulatory fines
• Staff turnover
• Supplier shortages
• Strikes, riots, and demonstrations
• Terrorist attacks and acts of war

Threat Modeling and Threat Landscape


A common approach to assessing risk is the consideration of
the universe of relevant threats that are reasonably likely to
occur. Such an occurrence may compromise information or
information systems, thus impacting business processes.
Threat assessments and threat modeling are the primary
activities used to identify relevant threats and how they may
harm systems or processes.

Threat Modeling
Threat modeling is a risk identification technique that involves
examining every possible threat agent, action or event, attack
vector, and vulnerability for a given system, asset, or process,
and then modeling or simulating how it could progress and the
damage that could occur. Threat modeling has its origins in the
U.S. and U.K. defense industries. A threat assessment
examines how these threats could affect the particular asset,
organization, or system you are looking at, in context, and it
can be done on one of several levels, either simultaneously or
separately. For example, you could perform a threat
assessment on a new system being developed or installed. You
would examine the different threat agents and threats that
could affect that particular system. You could also look at an
organizational process, or even the entire organization itself,
and perform a comprehensive threat assessment. In addition to
scaling a threat assessment, as we just described, you could
look at threats from a particular perspective, performing a
threat assessment specifically for technical threats, physical
ones, or even external operating environment threats. This
relates to the scope of the assessment. For example, you could
look at the technical aspects of a given system or examine
threats inherent to the processes and procedures associated
with a particular business unit. Figure 2-3 shows this scoping
and scaling process.
Figure 2-3 Scoping and scaling a threat assessment
As this figure illustrates, you could scale an assessment to
include only specific systems within some functional regions.
You could scope it by examining not only all the threats that
apply to the technical aspects of systems in those particular
functional areas but also threats that affect associated business
or management processes. You could have any combination of
scope and scale that the organization needs to fulfill its
assessment goals.
Threat landscape is a term that connotates a visual
metaphor for considering all the threats that have been
examined and identified as relevant to a given system or
process. A risk manager could be overheard as saying, “The
threat landscape for our online commerce system is
particularly hostile,” meaning there are many significant
threats that need to be considered as controls and defenses are
designed.
Table 2-1 illustrates how threat agents and threats could be
categorized, given factors such as intent, relationships, skills,
and so on. Note that these could affect any number or
combination of elements (processes, systems, and so on)
within an organization. You could categorize threats and threat
agents using these characteristics and develop others that
frame and define threats and threat agents for your
organization.

Table 2-1 Characteristics of Threat Agents


Note that this information is only a sampling of what you
may come up with in a threat assessment. You may also break
down some of these elements into far more specific ones,
based on your needs and the organization and systems you are
focused on. For example, a defense contractor or military
organization would likely have a more specific set of threats
and agents in its assessment than a nonprofit, charitable
organization.
NOTE Appendixes D and E in National Institute of
Standards and Technology (NIST) Special Publication 800-30,
“Guide for Conducting Risk Assessments,” offer a more
comprehensive list of threat agents and their related threats.
Threat modeling is sometimes easier when preceded by a
vulnerability assessment. You may wish to perform a threat
assessment to determine what threats and threat agents exist to
exploit those vulnerabilities. These threats can be internal or
external, human-made, or natural, and they should match up
with a discovered vulnerability. To complete the development
of a given risk scenario, you should also consider the time and
location characteristics of a potential scenario. Remember that
you are developing scenarios down to the most practical level
of detail possible; you will have developed many different
possible scenarios for an asset, each covering a particular
threat–vulnerability pairing by the time you are done. You
should then look at the existing controls you have in place to
determine how effective they are in protecting an asset.
Organizations considering adopting new technology should
include threat modeling in their analysis as a part of an
evaluation. Threat modeling will give the organization a
glimpse into the scenarios that could occur if proper
safeguards and controls were not implemented.

TIP Threat and vulnerability assessments are discussed a


great deal in this chapter. These two assessment processes are
critical to understanding the elements that formulate the risk
for an asset.

Vulnerability and Control Deficiency


Analysis
Vulnerability and control deficiency analysis are important
parts of risk analysis. These focus on the weaknesses in a
system or process that could result in a potentially serious
incident if exploited by a threat actor. The basic question that a
risk analyst would ask about a given asset is, “What weakness
in this system or process could be exploited by a threat actor in
a successful attack?”
When stated this way, a risk analyst might think only of
human-initiated incidents and overlook a broad class of
vulnerabilities that are not associated with a human threat
actor. Examples of non-human-initiated threats include the
following:
• Lack of off-site backup media that makes disaster
recovery difficult in the case of a fire or flood that
damages on-site systems and backup media.
• Excessive current load on power supply circuits that
could result in overtemperature or power failure.

Vulnerability Analysis
Vulnerability analysis is a detailed examination of
vulnerabilities that may exist or vulnerabilities that have been
determined to exist. A vulnerability assessment can give you
information about the weaknesses inherent to one or more
assets. The vulnerability assessment might include examining
all aspects of an asset or capability to determine any
vulnerability it has, including the physical, technical, and
operational vulnerabilities inherent to the asset. For example,
technical vulnerabilities can be related to configuration issues
or lack of hardening on a network device. Physical
vulnerabilities could relate to the lack of physical protection
for the network device. Operational vulnerabilities might
include the lack of backup processes or configuration control
exercised for the device.

Control Deficiency Analysis


In this section, we will discuss control analysis in detail. It’s
essential to understand how controls fit into the overall risk
analysis process; you perform a control analysis before
determining risk since existing controls that are already in
place may be effective to varying degrees in mitigating risk.
Simply examining threats, vulnerabilities, assets, impact, and
likelihood without considering existing controls and
protections in place doesn’t do justice to the risk analysis
process. Not accounting for existing controls would
dramatically skew risk assessments and render an unrealistic
risk determination. The goal here is to examine existing
controls, determine how effective they are, and use that
determination in analyzing the impact to assets if threats
exploit vulnerabilities and the likelihood of that exploitation.
Typically, results of your documentation, observation,
interviews, and testing will likely also be part of your control
analysis. We’ll look at different aspects of control analysis in
the following sections. You’ll also receive some more in-depth
information on controls in Chapter 3, focusing on various
aspects of how they are designed, implemented, and used to
respond to risk.

Evaluating Existing Control Effectiveness


As we stated earlier, risk analysis often involves evaluating the
effectiveness of existing controls. This is because risk doesn’t
exist in a vacuum filled with only threats, vulnerabilities, and
assets. Almost all assets have controls that serve to protect
them from harm. These controls may or may not be sufficient
to protect against particular threats. In some cases, however, a
control may be implemented that significantly lowers the risk
to an asset by decreasing the likelihood of a threat exploiting a
vulnerability or by protecting the asset sufficiently enough to
reduce the impact in the event a threat is realized. This is part
of the risk assessment and analysis process, which involves
identifying and prioritizing assets, performing threat and
vulnerability assessments, and determining what controls exist
and how effective they are in protecting against identified
risks.
Controls fall into broad categories: administrative,
technical, and physical or operational. Controls can also be
categorized based on function, classifying them as preventive,
detective, and deterrent. When identifying controls that apply
to a given resource, process, asset, or system, you should look
at all these different categories to determine what controls
exist. Administrative controls will be in the form of policies or
procedures and can protect an asset by detailing requirements
that users must abide by. Technical controls can protect assets
by providing logical protections, including strong
authentication, restrictive permissions, and other access
controls. Physical and operational controls can provide asset
protection in the form of operational procedures and physical
barriers, which separate unauthorized persons from the asset
and prevent them from physically accessing the asset.
Consider all these different categories of controls when
attempting to identify any controls that may be protecting
assets.
Once you have identified all the different controls
protecting a given asset, you should determine what functions
they are required to serve and how well they’re performing
those functions. Controls are designed to perform different
functions (in some cases, only one function, but often many
functions). Economy of use is a critical aspect of applying
controls to assets; organizations that can use fewer controls to
cover more security functions can reduce costs and more
effectively use the resources they have.
Just as threats and vulnerabilities are often paired together,
controls are often identified to counter specific threats or
vulnerabilities. While we discuss the value of performing
threat and vulnerability assessments, seemingly as different
activities, often they are conducted simultaneously, along with
control analysis, to get a better idea of how these three
elements balance with each other. Threats exploit
vulnerabilities; however, controls can reduce the likelihood or
impact of threat realization and mitigate the weaknesses that
vulnerabilities provide. So, there is a relationship among these
three elements, making it valuable to sometimes look at all
three of them simultaneously in a concerted effort.
In assessing control effectiveness, you should examine how
well a particular control protects against a given threat or
reduces a specific vulnerability. This can be a subjective
process, but can be more objective if performed as part of an
in-depth penetration test (discussed later in this chapter in the
section, “Risk Assessment Concepts, Standards, and
Frameworks”). For example, a threat assessment may give you
only the potential threat events that could affect a given asset,
and a vulnerability assessment may tell you only what
potential vulnerabilities exist on the system. Neither tells you
how effective a control may be in reducing the effects of the
threat or vulnerability unless you attempt to exploit the
vulnerability during penetration testing. However, by also
understanding the Common Vulnerability Scoring System
(CVSS) score associated with a vulnerability, you can better
understand the effort required to perform an attack, and the
potential harm that can result from an attack. Only then will
you truly know how effective the control is; if a given
vulnerability isn’t easily exploitable, then, realistically, the
control may be more effective than a cursory review would
indicate. Likewise, a penetration test may indicate that a
control is not as effective as you might have thought initially.
Vulnerability assessments describe theoretical weaknesses,
whereas penetration tests attempt to exploit vulnerabilities and
give more realistic estimates of how effective controls are.
When evaluating controls as part of a risk analysis, you
may report them as ineffective, partially effective, or effective
in reducing impact or likelihood. You also might use a
semiquantitative scale that indicates control effectiveness from
a range of numerical values. Each of the various control
frameworks often provides guidance on assessing the
effectiveness of the controls in that particular framework. For
example, the catalog of controls found in NIST Special
Publication 800-53, “Security and Privacy Controls for
Federal Information Systems and Organizations,” is
supplemented by an assessment methodology found in its
companion volume, Special Publication 800-53A, “Assessing
Security and Privacy Controls in Federal Information Systems
and Organizations,” which describes how to assess and report
the effectiveness of each control. Figure 2-4 shows an example
of an NIST control from SP 800-53 R5, and Figure 2-5 shows
the corresponding assessment guidance for the same control in
SP 800-53A R5.
Figure 2-4 The AC-5 control from NIST SP 800-53 R5
Figure 2-5 Assessing the AC-5 control, from NIST SP 800-
53A R5

EXAM TIP Control analysis includes identifying controls,


determining their required function, determining whether they
are effective in meeting that function, and identifying gaps
between the desired and end states of how well controls
protect assets.

Control Gaps
A control gap is a situation where controls either do not exist
or are not sufficient to provide adequate protection for an asset
to reduce either impact or likelihood (and thereby risk) to an
acceptable level. In this situation, after the lack of existence or
effectiveness of the control is established, the organization
must remediate the problem. We won’t go into much depth on
remediation here; that’s the subject of the Risk Response and
Reporting domain, which you’ll read about in Chapter 3.
However, during your analysis, you must identify control gaps
and make recommendations for possible response options that
would close those gaps. You may identify gaps in physical,
technical, or administrative controls, even when other types of
controls perform some security and protection functions. For
example, suppose an organization implements account
management processes, such as creating accounts in a
standardized fashion, verifying identities before user accounts
are created, and so on. In that case, the organization has
operational and technical controls in place that help provide
secure account management. However, if the organization has
no written policy that requires this process and dictates that it
be performed consistently, how can the organization be
assured that these procedures will always be followed
uniformly and in a secure manner? If there is no policy, the
organization leaves it up to individual account operators to
perform this function as they want, regardless of how “most
people do it.” In this case, a control gap would be that,
although the organization is applying some level of control
over this process, there is no written policy ensuring that it is
standardized.

Control Recommendations
Once you’ve identified existing controls, determined how
effective they are, and identified gaps between the current and
desired end states of controls, you should be able to make
sound, risk-based recommendations to senior managers on
how controls should be supplemented, added, or changed.
Recommending controls is a risk-based process; remember
that there is a risk that you are trying to minimize, but you
must balance this between control functionality and economy
of resources. You have several considerations to keep in mind
when making control recommendations:
• What more could be done to supplement or change
existing controls to close the gap between current and
desired end states of risk?
• Should new or different controls be applied to replace
existing ones?
• What are the costs involved in applying additional
controls, and do they exceed the value of the asset or the
costs to replace it?
• Would additional controls require retooling or
significantly changing the infrastructure, processes, or
asset itself?
• Would additional controls require new personnel or
training for current personnel?
• Can additional controls be implemented that also reduce
risks in other areas (economy of use)?
The answers to these questions, at least some of them, will
determine how you make the recommendations to
management about closing the “control gap.” Both the cost of
implementation and the return on investment (ROI) received
from implementing new controls or strengthening existing
ones will affect management’s acceptance of the
recommendations. The asset value, or impact if it were
significantly damaged or lost, will also affect how well the
recommendation is received. Implementing a costly control to
protect an asset worth less in terms of impact is not usually an
economically sound decision. Organizational levels of risk
appetite and tolerance will also affect control
recommendations since any new or additional control must
reduce risk enough to fall within those levels. In general, when
recommending ways to close the control gap, whether it is by
introducing new controls, modifying existing ones, or
modifying the infrastructure to reduce likelihood or impact,
you should do the following:
• Try to leverage existing controls that can be used across
the board to include additional assets.
• Look for “quick wins” first—controls that are quickly
and inexpensively implemented (such as policies,
training, procedure changes, and so on).
• Prioritize control recommendations with risk; the
greater the risk, the more attention to those particular
control gaps.
• Be realistic in your recommendations: You can’t reduce
risk to absolute zero, you don’t have all the resources
you would like at your disposal, and you don’t have to
offer a 100 percent solution. Sometimes a 70 percent
solution is better than a 0 percent solution.
• Provide alternatives to your primary recommendation
for each control gap. Give management alternatives
based on cost, level of risk reduction, and effectiveness.

Considering Risk and Control Ownership


Risk and control ownership are issues that must be considered
during a risk analysis. Depending on how the organization is
structured and the risk management strategy, risk ownership
may be assigned to one or several different managers,
spanning multiple functional areas. This is because the risk
that affects one area likely affects other areas, so many
different people may have responsibility for affected areas and
be required to deal with and respond to risk. Control
ownership should also be examined; often, controls that
provide protections for a given asset or many systems may not
fall under the operational purview of the risk owner. Some
controls span the entire organization and protect multiple
assets rather than only a specific system. These are referred to
as common controls, and the responsible entity for these
controls is the common controls provider. For example,
consider physical security controls. There may be a physical
security officer for the organization that oversees guards,
personnel security, and access to secured areas. They may also
be responsible for locks, closed-circuit televisions (CCTVs),
and physical intrusion detection systems and alarms. These
controls serve to protect information systems and data assets
that might be in a secure data center. Risks may be presented
to the person who is responsible for information systems in the
data center. However, the controls that serve to protect them
may belong to the physical security functional area. This will
require some coordination between the different functional
areas if controls managed by one functional area are
insufficient to protect assets managed by another area. This
may also affect organizational structures, budgets, and
resource allocations.

CAUTION Risk, asset, and control owners are not always


the same person, functional area, department, or organization.
It’s essential that you identify these particular owners early in
the assessment process and maintain careful coordination and
communication between these and other relevant stakeholders
within the boundaries of your authority and assessment scope.
Different types of owners can result in politically sensitive
issues that revolve around resourcing, responsibility,
accountability, and, sometimes, blame.
Root Cause Analysis
Root cause analysis, or RCA, is a method of problem-solving
that seeks to identify the root cause of an event, situation, or
problem. Often, when an event that disrupts business
operations occurs, an organization wants to perform an RCA
to determine what happened, why it occurred, and what
changes can be made to help prevent a recurrence of the
incident.
An example of RCA that is often the subject of publicity is
the analysis of an airplane crash. Here, investigators carefully
attempt to reconstruct the crash to determine the ultimate
cause, whether it was the failure of a component, pilot error, or
something else. In cybersecurity, an organization besieged by
ransomware will perform an RCA to determine how and
where the attack originated.
Here are the steps in a typical root cause analysis:
1. Identification The RCA begins with a concise
description of the incident or situation being analyzed.
This is the starting point in an RCA.
2. Chronology Using available event data, analysis of the
incident or situation includes a detailed look at how the
incident or situation unfolded.
3. Differentiation Here, an investigator identifies all the
details related to the event or situation to determine
which details are causal (contributed to the event or
situation) and which are non-causal (did not contribute
to the event or situation). Investigators realize that
many events have more than one causal factor.
4. Causal analysis Each detail or factor is analyzed to
determine the degree to which it contributed to the
incident or situation. This often leads to the
identification of the one causal factor, the root cause,
that represents the initiation of the events that led to the
incident being investigated.
5. Identification of corrective actions For each causal
action that contributed to the incident or situation, the
RCA will identify corrective actions that would reduce
the probability or impact of a similar incident in the
future.
A simplistic approach to RCA is known as the five whys.
This is an iterative technique in which the analyst looks at the
incident or situation (or a causal factor) and asks, why did that
occur? In the following example, a ransomware attack
encrypted numerous files on a file server:
1. First track: Focus on the end user’s PC.
• Why? Ransomware successfully implanted itself on
an end user’s PC.
• Why? The PC’s antivirus was not up to date.
• Why? The PC was on a new network segment not
monitored by the antivirus server.
• Why? Network engineers did not inform IT security
of the new network segment (a causal factor).
2. Second track: Focus on the file server.
• Why? The end user had global write permissions on
the file server.
• Why? It is a standard practice to grant global write
access to end users, which reduces the number of
access requests (a causal factor).
• Why? There are not enough service desk
technicians to fulfill access requests in a more
restrictive environment (a causal factor).
3. Third track: Focus on the end user.
• Why? The end user opened an attachment
containing malware in an e-mail message.
• Why? The end user believed that the e-mail was
sent from an executive in the company.
• Why? The end user did not recognize the indicators
of a phishing message.
• Why? The end user did not attend security
awareness training.
• Why? Security awareness training is not required (a
causal factor).
• Why? Company executives do not believe that
employees should be required to spend time away
from their duties in training.
In this situation, three broad root causes were identified:
first, the end user’s PC was on a network not being monitored
by central antivirus software because of a communication
breakdown; second, the end user had excessive permissions on
the file server because of a practice of loose permissions; third,
end users are not required to attend security awareness
training. Corrective actions will likely be recommended for all
three tracks.

Risk Scenario Development


A risk scenario is a business-impacting event that consists of a
threat, threat actor, vulnerability, and asset. You could say that
a risk scenario is a statement about a hypothetical risk event
that could reasonably occur, based on known facts about
threats, threat actors, and an asset’s vulnerabilities. Such a
description of a risk event can help risk managers and business
executives better understand what would otherwise be an
abstract concept.
Risk scenario development is performed during a risk
assessment after assets, threats, and vulnerabilities have been
tabulated. Risk scenarios are the potential real-world events
identified in risk assessment data that communicate the risks
that have a tangible impact on business operations.
Risk managers can approach scenario development from
two perspectives: top-down and bottom-up. Both are explained
here.
NOTE Threat actors are not only human entities but also
events such as natural disasters.

Top-Down Risk Scenario Development


Top-down risk scenario development associates risks with
business goals and objectives. The purpose of top-down risk
scenario development is to identify scenarios that, if realized,
would adversely impact those business goals and objectives.
Similarly, top-down risk scenario development can associate
risks with key business assets. Again, top-down risk scenarios
would be related to those assets. Figure 2-6 depicts the
extraction of top-down risk scenarios from risk assessment
results.

Figure 2-6 Extracting top-down risk scenarios from a risk


assessment
Risk assessment and risk analysis are logical, analytical
activities. Risk scenario development, on the other hand,
particularly top-down risk scenario development, is by far an
intuitive, creative activity. In pop culture, one would associate
risk assessment and analysis as left-brain activity, with top-
down risk scenario development as right-brain activity.
The primary benefit of using top-down risk scenarios is the
ability to communicate risks more clearly to executive
management. As the developers and promoters of corporate
goals and objectives, senior executives should understand the
various types of IT risks that could threaten to delay or
increase the effort or cost required to achieve them.
Risk managers should look to outside sources to identify
realistic risk scenarios. Trade journals and even mainstream
media report on cybersecurity and other disruptive IT-related
events. Developing a more compelling narrative than “this
scenario happened to them, and it could also happen to us” can
be difficult.

Bottom-Up Risk Scenario Development


Bottom-up risk scenario development focuses on specific
assets (or groups of assets) or threats. Bottom-up risk
scenarios are more technical than top-down scenarios and less
likely to be conveyed to executive management. However, this
technique can help risk managers better understand the scope
and nature of various types of risks. Ultimately this may help
risk managers refine their top-down risk scenario development
by giving them additional information about the universe of
risks they are dealing with.

Risk Scenario Development Considerations


Risk scenario development is vital in risk analysis and
management, where risks that may initially be abstract are
refined and translated into tangible statements of risks to
business operations. Absent this transformation, risk scenarios
will be little more than an intellectual exercise.
To be successful, risk managers need to ensure that the risk
scenarios are:
• Relevant to the business Risk scenarios should indicate
specific relevance and impact to the organization
instead of being generic.
• Kept current An organization’s use of technology (at
both the macro and micro levels) changes over time,
meaning risks will vary in magnitude.
• Communicated to management with a purpose
Often, risk scenarios are the way that new risks are
shared with management to proceed to risk treatment—
that is, to make decisions about what to do about new
risks. This is often the only time that management is
informed of risks.

IT Risk Analysis and Evaluation


After a risk has been identified (which is covered in the first
part of this chapter), it can next be examined. Risk analysis is
the detailed examination of a risk to better understand basic
factors, including the likelihood and impact of risk occurrence
and the development of a measure that might be enacted to
reduce probability or impact. Risk analysis helps determine the
overall level of risk for a particular system, an asset, business
process, or even the entire organization. Part of risk analysis
involves discussions of findings with risk and control owners,
as well as senior managers in the organization. During these
discussions, you may discover other factors that influence the
likelihood and impact levels or even affect threats,
vulnerabilities, and assets. You’ll also look at the existing
controls and determine how effective they are in meeting risk,
as well as look at recommended additional controls. Finally,
you will report risk analysis results to senior managers and
generate a risk report after this process is complete. We’ll
discuss these topics in more detail in this section. Figure 2-7
shows a familiar variation of the 5×5 likelihood and impact
table, demonstrating how different levels of likelihood and
impact are evaluated together to produce a qualitative risk
level.
Figure 2-7 Likelihood and impact are evaluated together to
produce a risk level.

Risk Assessment Concepts, Standards,


and Frameworks
Risk assessments are performed to identify, understand, and
enable organizations to make intentional decisions about
individual risks. There is considerable detail within the
workings of risk assessments, as discussed in this section.
Many of the terms you’ll encounter on the CRISC exam are
generic and may have different definitions based on the
different frameworks or standards you are using in practice.
The term assessment is one such term that may confuse you.
For the purposes of taking the exam, and in this book, an
assessment refers to the overall combination of steps of
identifying, evaluating, and analyzing risk. Remember that
risk identification involves identifying the threats,
vulnerabilities, assets, and existing controls. On the other
hand, evaluation focuses on determining the likelihood and
impact if the vulnerabilities are exploited by the threats,
resulting in damage to the asset. Risk analysis puts everything
together, informs the organization about the risk involved, and
helps determine how effective existing controls are and the
gaps between current and desired risk states.
Risk assessment processes sometimes include the risk
identification piece of the process but are often separate from
this part, depending on the framework or standard you are
using. In general, this process includes threat source and event
identification, vulnerability identification, control analysis,
likelihood determination, impact analysis, risk determination,
control recommendations, and results documentation; these
steps follow the same pattern and path as we’re describing
here for you in terms of identifying risk and then evaluating it.
We’ll describe some of these generic processes here in this
chapter.

NOTE Different risk analysis methodologies and


frameworks use varying terms with the same or different
definitions. You should always look at a term given its context
and particular framework or methodology.

Types of Assessments
Several types of assessments can be performed to determine
the presence of risks, threats, or vulnerabilities in a system or
process. Some of the techniques discussed here involve
different ways of thinking about risk, while others employ
manual or automated tools to examine information of some
type.
• Risk assessment An assessment technique used to
identify and classify various risks associated with
systems or processes.
• Gap assessment An assessment of processes and/or
systems to determine their compliance to policies,
standards, or requirements.
• Threat modeling Also known as a threat assessment,
this is a threat-centric technique used to identify specific
threat scenarios that may occur. Threat modeling is
discussed in more detail earlier in this chapter.
• Vulnerability assessment An assessment used to
identify specific vulnerabilities that may be present in
processes and/or systems.
• Maturity assessment An assessment of processes or
capabilities to determine their maturity, generally
according to a maturity standard such as the capability
maturity model integration (CMMI) or the NIST
cybersecurity framework (CSF).
• Penetration test This is an examination of systems,
networks, or applications that identifies exploitable
vulnerabilities. Tools used in a penetration test include
port scanners, sniffers, protocol analyzers, fuzzers,
password crackers, and specialized tools to identify
specific vulnerabilities. A penetration test not only
identifies but also validates a vulnerability by exploiting
it—or demonstrating how it can be exploited if actual
exploitation would bring harm to the asset (important
when pen testing a production system).
• Data discovery A manual or automated activity in
which tools or techniques are used to examine the
contents of a target system to determine the presence of
specific types of data. Data discovery may also involve
an examination of access rights to specific types of data.
• Architecture and design review A manual activity in
which the architecture or design of a process or system
is examined to identify potential weaknesses.
• Code review A manual activity in which software
source code is examined for logic errors and security
vulnerabilities.
• Code scan An automated activity in which a code-
scanning program or tool examines software source
code to identify vulnerabilities and other defects.
• Audit A formal inspection of a control or process to
determine whether it is being followed and meets its
objectives. Audits are discussed briefly in this book and
fully in CISA Certified Information Systems Auditor All-
In-One Exam Guide.

Scope of an Assessment
Before an assessment can begin, its scope needs to be
determined. By this, we mean that the systems, processes,
locations, teams, and/or time periods that are the focus of the
assessment need to be formally established and
communicated.
The opposing forces that influence scope are the desire to
make it large enough to identify hard-to-find risks, but small
enough to be efficient and complete in a reasonable period. A
balance must be reached that enables the assessment to
succeed.

Collecting Data for an Assessment


One of the challenges for a risk assessor is collecting and
managing all the data for an assessment. On one end of the
spectrum, the assessor may find it challenging to get the bare
minimum of relevant data for a particular asset, including
threats and threat actors, and vulnerabilities, as well as
protective controls. On the other end of that same spectrum,
the assessor may gather so much data that it is overwhelming
to analyze and gauge its relevance to the assessment effort.
Another challenge is the source of the data. While the best
data comes from authoritative sources with expertise in
various areas, such as the asset or system in question, current
threats, and so on, the assessor must be able to separate fact
from opinion and collect truly objective data versus subjective
data. Objective data is evidence that supports an assertion
about an asset or risk that can be proven or verified through
independent means. Subjective data, on the other hand, is data
whose validity is subject to opinion. For example, auditing
typically produces objective data in the form of audit logs
(assuming they are secured) that detail events that occur on a
system and trace those events back to individuals, thus
ensuring accountability. Events in question can be verified
through the audit logs. However, system administrators who
assert that they regularly audit system activities but have no
audit logs to prove this can’t have their claims verified.
Additionally, if no policies or procedures require auditing or
show how to perform those tasks, these events can’t be
independently verified either.
Data can come in various forms, including performance
data, statistical analysis, historical data, trends, and narrative
form. The assessor should establish the relevance of data as it
is collected and determine how it relates to relevant risk
questions concerning threats, vulnerabilities, likelihood,
impact, assets, and controls. Overwhelming amounts of data
can be reduced to relevant summaries and analyzed,
sometimes in aggregate, using various automated statistical
analysis and database tools.
Data collection typically uses a combination of four
methods designed to gather various types of qualitative and
quantitative data from different sources. These collection
methods complement and support one another, filling in gaps
from one method and verifying information collected from
another. The four main data collection methods are conducting
interviews, reviewing documentation, observing systems and
assets in operation, and performing technical testing on assets.
They are described in more detail in the following sections.
Conducting Interviews One of the best methods to start
collecting data involves interviewing key personnel, such as
asset owners, system administrators, security personnel, and
other people with direct knowledge of essential aspects of the
asset, relevant threats and vulnerabilities, and controls. These
interviews are known as walkthroughs. Interviews should be
scheduled with key personnel and consist of relevant questions
that answer questions relating to security posture, processes
and procedures, asset characteristics, and implemented
security controls. The assessor should carefully record the
results of the walkthrough through concise meeting notes or
recording devices for later reference. Keep in mind that while
interview data should usually be considered subjective in
nature, it can be used as a starting point to gather knowledge
and facts about a system that can be later verified using other
means, such as documentation, system observation, and
testing.
Reviewing Documentation Documentation is a mainstay of a
risk assessment. A well-documented process or system
indicates its characteristics, security requirements, and
whether the people responsible for the process or system have
defined measures in place to fulfill security responsibilities.
Documentation gives an assessor a wide variety of information
on how the process or system is routinely used, whether a
security patch program is in place, who has access to systems
and data, what policies exist to define security requirements,
and how the system is securely configured. Documentation
can be either paper-based or electronic; it can come from
spreadsheets, databases, network devices, systems, written
procedures, physical access logs, and so on. Examples of
documentation include organizational policies, processes and
procedures, backup and restore procedures, security officer
appointment letters, and so on. While not strictly
documentation (unless printed), audit logs and configuration
files could also be considered in this category since they
provide documentary evidence that supports an assertion of
how events were recorded or how a system was configured.
Documentation also serves to verify data collected from other
sources, such as interviews. Remember, if you don’t document
something in the security assessor world, you can’t prove that
you’ve done it.
Observing and Verifying Systems and Assets Sometimes it’s
not enough to interview personnel and review documentation.
Unfortunately, people can lie or be mistaken in interviews, and
documentation can be falsified. Observing a process or system
in operation can verify whether it is secure and whether its
security functions and controls are working as intended to
protect systems and data. The same is true for physical
security controls. An assessor can easily determine whether a
control is functioning by observing a system operator perform
a security function or visually inspecting a control to ensure it
is in place and implemented properly. Examples requiring the
observation method include gates, guards, and locks; other
examples are watching a system through the boot process,
observing a screen lock go into effect, having a system
administrator demonstrate various security features, and so on.
Performing System Testing Not all data can come from
talking to people, reading system architecture documents, and
watching the system administrator assign permissions to
shared folders and files. Some data must come from
examinations of the system’s configuration, as well as
obtaining relevant data related to patching, vulnerabilities, user
accounts, configuration files, registry settings, and other
technical data. This data is used to determine if a system is
configured properly and securely and what potential
vulnerabilities might exist on the system. This is where the
technical assessment portion of data collection comes into
play. Since technical data can be overwhelming in size and
volume, automated tools are typically used to perform system
security testing. These tools include vulnerability scanners,
sniffers, and other hardware and software tools described later
in this chapter.
During security testing of a system, various types of host-
based and network scans may be performed, along with an in-
depth examination of patches and updates applied to the
system, configuration settings, user accounts, and other
security settings. The system’s rights, permissions, and
privileges and its resources are examined and compared
against security requirements and control functions to ensure
they match. Network protocols and connections are studied,
and the network architecture may be examined to ensure a
sound network design has been implemented. Application
software code reviews and testing, including fuzzing, may be
performed. Authentication and encryption mechanisms are
examined in depth to ensure they are strong and effective and
meet governance and best-practice requirements where
applicable. Physical access controls may be tested to ensure
that physical separation away from systems for unauthorized
users is maintained.
The results of system security assessments (usually in the
form of vulnerability assessments or penetration testing,
discussed in this chapter) are consolidated with the results
from interviews, documentation reviews, and system
observations to form a comprehensive data picture of the
system or asset; these results further inform the controls
analysis and impact determination aspects of risk. Table 2-2
summarizes the different data collection methods you can use
during an assessment.

Table 2-2 Summary of Data Collection Methods During a


Risk Assessment, with Examples

NOTE While you may not be directly tested on data


collection methods, it is a good idea to understand these
methods, as in actual practice, you will likely use them
extensively.
Techniques used to examine systems or processes, evidence
collection, sampling, and other considerations are covered in
greater detail in ISACA’s Certified Information Systems
Auditor (CISA) certification and described fully in the book
CISA Certified Information Systems Auditor All-In-One Exam
Guide.

Risk Assessment Standards and


Frameworks
Some organizations see risk assessment as one large
monolithic process, but many frameworks and standards break
it down into different steps. We’ll look at several important
frameworks, including the National Institute of Standards and
Technology (NIST) SP 800-30, OCTAVE, the ISACA Risk IT
Framework, ISO/IEC 27005, and others. We will go into detail
and examine them from a risk assessment perspective.
Business Alignment
One of the most important considerations for selecting
standards and frameworks is business alignment. When
selecting a standard, whether for risk assessment, risk
management, security controls, or integrated risk
management systems, the risk management leader must
select a framework or standard that best aligns with the
organization’s needs. Selection considerations include the
following:
• Industry sector
• Customer expectations and requirements
• Applicable regulations
• Risk appetite
• Organizational maturity
• Current and future technology in use
Security and risk professionals who strive for business
alignment will achieve better outcomes by building and
selecting processes, frameworks, and standards that are
more likely to succeed.

NIST Special Publication 800-30


NIST Special Publication 800-30, “Guide for Conducting Risk
Assessments,” is a step-by-step guide to performing
qualitative and quantitative risk assessments. The standard
also briefly describes the overall risk management life-cycle
process to provide context for individual risk assessments. The
steps of a risk assessment are as follows:
1. Prepare for assessment. The scope, techniques, records,
personnel, schedule, and other resources are identified.
We also like to consider the threat landscape, although
this is not expressly a part of NIST 800-30.
2. Conduct assessment. The following are the actual risk
assessment steps performed on each target asset defined
in the assessment scope:
a. Identify threat sources and events. All reasonable
threat sources, events, and actors are identified.
b. Identify vulnerabilities and predisposing conditions.
Vulnerabilities in the in-scope processes or systems
are identified. Often, vulnerabilities and threats are
paired and listed. For instance, a threat actor with a
lock pick set is paired with an exterior door with a
substandard key core.
c. Determine the likelihood of occurrence. The
probability that each specific threat will occur is
determined. Often this is an estimation, as there is
generally insufficient data to reliably determine an
accurate probability.
d. Determine the magnitude of impact. This is generally
expressed in qualitative terms in the form of
descriptions of impact on business operations. Also,
this can be expressed in quantitative terms that might
include response and recovery costs.
e. Determine risk. The risk associated with each threat
scenario is calculated, generally as Risk = Impact ×
Probability × Asset Value.
3. Communicate results. The results of the risk assessment
are tabulated as determined at the start of the
assessment. The results are communicated to various
stakeholders in the organization. Often, results are
developed for specific audiences; for instance, an
executive summary may be produced for executives,
while detailed charts will be produced for lower
management and those who will participate in
remediation activities.
4. Maintain assessment. This generally refers to the
activity of risk monitoring, in which a risk manager will
periodically re-examine the assets to determine whether
any changes have occurred in threats, threat actors,
vulnerabilities, impact, or probability of occurrence.
NIST SP 800-30 contains additional resources, including
the following:
• Appendix D: Threat Sources This includes
taxonomies of adversarial and non-adversarial threat
sources, capabilities, intent, and scale.
• Appendix E: Threat Events This includes numerous
adversarial and non-adversarial threat activities that
represent reconnaissance or attack.
• Appendix F: Vulnerabilities and Predisposing
Conditions This is a taxonomy of vulnerabilities and
their characteristics.
• Appendix G: Likelihood of Occurrence This includes
taxonomies related to the probability of threats
occurring.
• Appendix H: Impact This includes various types of
impact on organizations when threats occur.
• Appendix I: Risk Determination This includes
taxonomies used to determine the magnitude of
individual risks.

OCTAVE Methodology
As part of a U.S. government contract with Carnegie Mellon
University, the Operationally Critical Threat, Asset, and
Vulnerability Evaluation (OCTAVE) methodology was
developed to assist organizations in identifying and assessing
information security risk. The methodology was initially
developed by the Software Engineering Institute (SEI) at
Carnegie Mellon University in 1999 and has been updated
over the years to its current version, OCTAVE Allegro, in
2007. OCTAVE uses a concept called workshops, made up of
members of an organization, sometimes including outside
facilitators with risk management and assessment expertise.
The methodology has prescribed procedures, including
worksheets and information catalogs to assist organizational
members, drawn from all functional areas of an organization,
to frame and assess risk based on internal organizational
context (infrastructure, governance, business environment, and
so on). OCTAVE has three iterations: the original OCTAVE,
OCTAVE-S, and OCTAVE Allegro.
OCTAVE and OCTAVE-S The original OCTAVE
methodology was released in 1999 and was designed for
organizations with at least 300 employees. The assumptions
for using OCTAVE included that the organization operates and
maintains multitiered information infrastructure and performs
vulnerability assessments. While OCTAVE is flexible and
allows an organization to tailor its use based on its own
assessment needs, the methodology is performed as three
sequential phases. The first phase covers identifying assets,
threats, protection practices, vulnerabilities, and security
requirements. You can see where this maps to the practices
we’ve described throughout this chapter as determining
threats, identifying assets and their vulnerabilities, and
evaluating existing controls. In the second phase, the members
of the workshop perform assessment activities and evaluate
the infrastructure. In the third phase, the workshop members
develop response strategies for the identified risks.
OCTAVE-S is fundamentally the same as the original
OCTAVE, with a few minor differences. First, OCTAVE-S
was designed to assess smaller organizations, usually with
fewer than 100 people. Second, this iteration relies more on
internal personnel with extensive knowledge of the
organization and its infrastructure and less on outside risk
experts or facilitators. The number of workshop members will
also be considerably less; the team may rely on fewer than ten
key experts in the organization. OCTAVE-S processes and
procedure documents were also written to include more
detailed security-related information. This approach does not
rely on outside security experts or risk facilitators to assist the
team.
OCTAVE Allegro The OCTAVE Allegro methodology,
introduced in 2007, expands the previous two iterations but
does not necessarily replace them. It includes a more business-
centered and operational risk approach to the assessment. It is
also asset-centered in its approach; it focuses on assets and
their use or misuse, the environment they are used in, and how
threats and vulnerabilities specifically target and affect the
assets. Allegro can be used on a scaled basis; either individuals
or workshop teams can use this method without requiring a
high degree of risk management or assessment knowledge and
experience. OCTAVE Allegro is divided into four phases,
which include eight steps. These phases and steps are
described next.
Phase 1: Establish Drivers Step 1: Establish risk
measurement criteria. This step serves to develop and
establish the organization’s methodology and measurement
criteria used to assess risk. OCTAVE uses a qualitative
assessment methodology and measurements but can use
quantitative methods for certain aspects of the overall process,
such as determining likelihood and impact.
Phase 2: Profile Assets Step 2: Develop an information asset
profile. In this step, the organization develops an asset profile,
which is a collection of information that describes the asset,
including its characteristics, priority, impact on the
organization, and value. This profile also contains security
requirements the asset may have.
Step 3: Identify information asset containers. The
information asset container describes how data is stored,
where it is processed, and how it is transported. Containers are
usually networks and systems, including those that the
organization directly operates and those that it outsources.
Phase 3: Identify Threats Step 4: Identify areas of concern. In
this step, potential risk factors are identified and are used to
develop threat scenarios.
Step 5: Identify threat scenarios. In the context of
OCTAVE, threat scenarios describe categories of actors and
the relevant threats in each category. The scenarios are
typically identified by using a threat tree, which simply maps
actors and scenarios.
Phase 4: Identify and Mitigate Risks
Step 6: Identify risks. In this step, consequences such as
impact and likelihood are identified and measured, which
inform risk.
Step 7: Analyze risks. Once impact and likelihood have
been identified and measured, risks are analyzed. During this
step, risk scores are developed. These come from developing
impact and likelihood values, emphasizing impact in
particular, since this is an asset-driven assessment.
Step 8: Select mitigation approach. In this step, risk
response strategies are developed, analyzed, and
recommended.

EXAM TIP OCTAVE is designed for larger organizations,


while OCTAVE-S is intended for use by smaller organizations.
OCTAVE Allegro is scalable for use by individuals or larger
teams working in organizations of various sizes.

ISO/IEC Standards
ISO stands for the International Organization for
Standardization, and IEC stands for the International
Electrotechnical Commission. Together, these two
organizations are responsible for a plethora of information
technology and manufacturing standards used worldwide,
including several that apply to information security and risk
management.
ISO/IEC 27005:2018 Standards in the ISO/IEC 27000 series
are all about information security, and the 27005:2018
standard (“Information technology – Security techniques –
Information security risk management”) supports the common
ideas promulgated in both ISO/IEC 27001 and 27002. The
standard defines the entire risk management life cycle,
including detailed risk assessment principles. The standard
doesn’t offer specific risk management or assessment
methodologies. However, it does serve to describe a
formalized, structured risk management process, such as
developing context, scope, methods, and so on. It also
describes the two primary types of assessment methodologies:
qualitative and quantitative. Additionally, it describes
processes used to develop risk response strategies,
communication with stakeholders, and continuous risk
monitoring.
ISO/IEC 31010:2019 ISO/IEC 31010:2019 is where the meat
of information regarding risk assessments is located for the
ISO/IEC standards. This document, “Risk Management – Risk
Assessment Techniques,” articulates and extends the risk
management principles of ISO/IEC 31000:2018 and provides a
concrete overview of the risk assessment process. This
standard describes risk assessment as the combination of risk
identification, analysis, and evaluation, with a precursor step
of establishing the risk context within the organization. The
standard also addresses communication and consultation with
various stakeholders and management, risk treatment
(response), and monitoring risk.

EXAM TIP Of the ISO/IEC standards, ISO/IEC 31010:2019


is essential for the exam because it covers risk assessments in
detail.

ISACA’s Risk IT Framework


ISACA developed the Risk IT Framework to align with its
COBIT framework. While COBIT is used to manage other
aspects of business infrastructure and risk, the Risk IT
Framework is explicitly used to allow organizations to identify
and manage IT risk. The framework is broken down into three
major process areas: Risk Governance (RG), Risk Evaluation
(RE), and Risk Response (RR). We discussed this framework
briefly in Chapter 1, but the focus of this chapter is on the
assessment process, so we will cover the Risk Evaluation
portion in more depth here.
The Risk Evaluation processes in the Risk IT Framework
don’t cover only assessment; they overlap with the risk
identification areas. In RE processes, business impact is
framed and described, and risk scenarios are also developed.
Risks are assessed and analyzed as well as presented to the
organization’s management. The RE processes are further
broken down into three areas (numbered RE1–RE3), which we
will describe in more detail.
Collect Data (RE1) The data collection process aligns with
some of the risk identification processes we’ve previously
described. During this process, risk management personnel
develop a model for data collection, which provides for
standardized data formats, measurements, and common data
definitions. Data is collected on the various aspects of the
organization and risk scenarios, including the business’s
operating environment, risk factors, threat sources and events,
vulnerability data, and asset data. Data is also collected on the
effectiveness of existing controls in the organization.
Analyze Risk (RE2) In this part of the Risk IT Framework,
the organization begins to assess and analyze risk. First, it
defines the risk analysis scope. The scope determines how
broad and deep the risk analysis efforts will be, what areas the
risk analysis will cover, and which assets will be examined for
risk. To complete this part of the process, you’ll need to
consider all the documentation assembled up to this point: risk
scenarios, asset inventories, breakdowns of business processes,
prioritization of assets, and so on. This will help frame the risk
analysis as well as determine scope.
During this step, IT risk is also estimated. This involves
determining likelihood and impact values associated with the
developed risk scenarios. You will also consider existing
controls and how effective they are as currently installed and
functioning. Likelihood and impact values are considered after
existing controls are considered.
Although risk response is the subject of Chapter 3, you also
identify and consider possible risk response options during this
step of the process. The person assessing the risk may
recommend several different response options, based on the
identified risk. What risk options an organization will use is
determined later in the process and typically with the input and
approval of senior management. Risk response options should
be recommended that reduce risk to an acceptable level
directly based on the risk appetite and tolerance of the
organization. Finally, knowledgeable peers should review risk
analyses to verify that the analysis process is sound and to
validate the results.
Maintain Risk Profile (RE3) A risk profile is a collection of
detailed data on identified IT risks. Risk profiles can cover a
single system or asset but are also often seen as describing
risks on an organization-wide basis. During this risk
evaluation step, a comprehensive document of identified risks
and their characteristics, such as details regarding impact,
likelihood, and contributing factors, is developed and
maintained throughout the asset or system’s life cycle.
Remember that system or asset risk profiles are usually rolled
up into a more comprehensive risk document that covers
systems, assets, and business processes across the entire
organization.
IT assets are also mapped to the business and
organizational processes they support during this step; this
helps translate IT risk to corresponding business risk and
allows management to see how the organization would be
affected if IT risk were realized on specific assets. This also
enables the organization to develop criticality estimates of IT
resources from a business perspective. It’s worth noting that
this is similar to the same process followed during a business
impact assessment (BIA). The key to understanding how IT
risk affects business operations at this point is in
understanding how the capabilities of IT are provided to the
business processes in question and how critical IT is to a
particular business process or operation. Maintaining a risk
profile also means monitoring and updating risk scenarios and
analysis as conditions and risk factors change. This involves
keeping the risk register up to date as well. Finally, the
organization should develop key risk indicators (KRIs) during
this step, specifically focusing on IT resources. While key risk
indicators are discussed in Chapter 3, for now, you should
know that they allow the organization to monitor changes in
risk for given scenarios, enabling the organization to modify
its risk profiles as these indicators change. Table 2-3
summarizes some of the different risk assessment
methodologies available to you.

Table 2-3 Summary of Available Risk Assessment Methods


and Frameworks

EXAM TIP Because this is an ISACA-sponsored exam, it is


a good idea to understand risk assessment terms and processes
from the perspective of the ISACA framework more so than
any other. The ISACA Risk IT Framework directly aligns with
ISO/IEC standards as well.

Risk Ranking
When risks have been identified in a risk assessment, it
generally makes sense to display these risks in an ordered list.
Most often, the highest risks will appear at the top of a list,
indicating the nature of the sequencing. For instance, risks
with the most significant impact may appear first, or perhaps a
composite risk score will be calculated for each risk (based on
probability, impact, and asset value) and risk items sorted by
this overall risk calculation. Risk ranking, then, helps tell the
story of the most critical risks that have been identified.
Risk ranking can be portrayed visually, which helps the
reader better understand the universe of risks that have been
identified. Figure 2-8 shows a risk map that visually indicates
the nature and severity of risks.

Figure 2-8 A risk map visually depicts the severity of risks.

Risk Ownership
To correctly manage and act on unacceptable risks, each risk is
assigned a risk owner. Generally, the risk owner is the
department head or business unit leader associated with the
business process that is the focus of a risk. It is usually not
appropriate to assign risk ownership to IT, as IT is the steward
of information and information systems as well as provides
services as directed by department heads and business unit
leaders.
Similarly, the organization’s cybersecurity leader (often a
CISO) is not the assignee of risks. Instead, the cybersecurity
leader facilitates risk conversations and decisions with
department heads and business unit leaders, particularly those
whose business processes are associated with individual risks.
In risk management, there are usually several different
“owners” associated with each risk, including the following:
• Risk owner This is usually the department head or
business unit leader associated with the business process
where the risk resides. Even if a risk is related to an IT
system, IT is generally not the risk owner. Rarely, if
ever, is the cybersecurity leader assigned as a risk
owner.
• Risk treatment decision-maker This person makes a
business decision regarding the disposition (treatment)
of an individual risk. Risk treatment is discussed fully in
Chapter 3.
• Risk remediation owner This is the person responsible
for any remediation that has been selected as a part of
risk treatment.
An organization’s risk management program charter (or
other formal document) should define the roles and
responsibilities of each type of risk owner.
These and other facets of risk ownership are generally
indicated in the risk register, which is discussed next.

Risk Register
A risk register is a business record containing information
about business risks and their origin, potential impact, affected
assets, probability of occurrence, and treatment. A risk register
is the central business record in an organization’s risk
management program (the set of activities used to identify and
treat risks).
Together with other records, the risk register serves as the
focal point of information that an organization is attempting to
manage risk. Other records include information about risk
treatment decisions and approvals, tracking projects linked to
risks, risk assessments, and other activities that contribute to
the risk register.
When new risks are identified, they are added to the risk
register to be later analyzed, discussed, and decisions will be
made about their disposition.
A risk register can be stored in a spreadsheet, database, or
within an integrated risk management (IRM) tool—formerly
known as a governance, risk, and compliance (GRC) tool—
used to manage risk and other activities in the security
program. Table 2-4 shows a typical risk register entry.
Table 2-4 Sample Risk Register Data Structure

Sources of Information for the Risk Register


Awareness of risks can come from many places and through a
variety of events. The information in Table 2-4 provides some
hints about the potential sources of information that would
lead to the creation of a risk register entry. These sources
include the following:
• Internal and external risk assessment A prime source
for risk register entries, a risk assessment identifies risks
in the organization’s staff (for example, excessive
workload, competency, and training issues), business
processes, and technology.
• Vulnerability assessment The high-level results of a
vulnerability assessment (or penetration test, code
review, social engineering assessment, and so on) may
indicate overarching problems in staff, business
processes, or technology at a strategic level.
• Internal audit Internal audit and other internal control
self-assessments can identify problems in staff, business
processes, or technology.
• External audits Audits performed by external parties
can identify issues in business processes and
information technology.
• Security incident The occurrence of a security incident
may reveal the presence of one or more risks that
require attention. Note that a security incident in another
organization may highlight risks in one’s own
organization.
• Threat intelligence Formal and informal subscriptions
or data feeds on threat intelligence may reveal risks that
warrant attention.
• Industry development Changes in the organization’s
industry sector, such as new business activities and
techniques, may reveal or magnify risks that require
attention.
• New laws and regulations The passage of new laws,
regulations, applicable standards, and private legal
obligations may reveal the presence of risks that require
attention. Also, note that compliance risk (that is, the
possibility that regulators or others may impose fines or
sanctions on the organization) may well be included in
one or more risk register entries if the organization has
identified such risks.
• Consultants A visit by or conversation with an expert
security consultant may reveal previously unknown
risks. The consultant, who may be an auditor or assessor
or may be working in the organization on a project, may
or may not expect to find risks that the organization’s
security manager would want to be aware of.

Updating the Risk Register


Because the risk register is a living document, it should be
periodically updated as risk conditions change. Risk
assessments will provide updated information that should be
included in the risk register and information about ongoing
risk response actions applied to the risk. Whether the risk
register is in the form of an electronic database, spreadsheet,
or another type of document, it should be easy to read and
readily accessible by risk managers and risk owners to stay
updated on the current risk posture of the organization. As
mentioned previously, it also should be considered a sensitive,
access-controlled document. Table 2-5 shows a risk register
and some sample entries.

Table 2-5 Sample Entries in a Risk Register

Risk Analysis Methodologies


As stated earlier in this chapter, risk analysis is the detailed
analysis of a risk identified in a risk assessment. In risk
analysis, we examine a risk and apply techniques to better
understand it from several perspectives:
• Asset identification The asset(s) involved in a
particular risk are identified. This could be an IT or IoT
device, a business application, an entire IT environment
(or specific parts therein), a database, a building, a
procedure, or a business process.
• Vulnerability Various weaknesses related to the asset
are identified that could be exploited by a threat event.
• Threat Various threat scenarios are considered,
particularly those that are reasonably applicable to
identified vulnerabilities.
• Asset value The value of the asset is identified and
considered. Various iterations of risk analysis may
consider different types of asset value, including
replacement cost, repair cost, lost revenue, and more.
For various risk scenarios, it may be necessary to use
and identify different types of asset value. For instance,
one risk scenario may use replacement value while
another might use repair cost.
• Business context Because risk analysis is often an
abstract mental exercise, it is necessary to define the
business context for the risk. For example, risk analysis
is performed on a database server; the business context
is the organization’s financial accounting system that
supports all of the organization’s accounting
department’s business processes. Without identifying
business context, a risk remains abstract, and it is more
difficult to apply risk treatment later on.
• Business impact To be relevant to the business, risk
analysis needs to identify the impact of various threat
scenarios on business processes and operations. For
example, risk analysis focused on access controls on a
database management system containing customer
information would identify business interruption in
scenarios involving data destruction and privacy
breaches with reputation damage and fines in scenarios
involving data theft.
• Risk appetite and risk tolerance The risk analyst
should be familiar with the organization’s stated risk
appetite and risk tolerance to ensure that identified risks
and subsequent risk analysis align with risk appetite and
tolerance. Risk appetite and risk tolerance were
discussed in more detail in Chapter 1.
• Mitigation analysis Once a specific risk is examined,
various mitigation scenarios can be developed. For
each, the risk manager would identify the time required
to perform the mitigation, cost, the changes in the
probability of various threat scenarios, the changes in
impact for each, and the change in risk for each.

Asset Identification, Classification, and Valuation


Identifying the different elements of risk is a necessary
precursor to assessing risk. One of the goals of the
identification process is the development of risk scenarios.
Risk scenarios require that you identify assets, vulnerabilities,
and potential threat events.
Asset identification not only requires you to inventory all of
your assets; you should also determine how critical they are to
your business, decide how sensitive the data they process or
produce is, and characterize or classify the system or asset in
terms of confidentiality, integrity, and availability.
Determining criticality is an essential aspect of the overall risk
management process and typically is done before any
assessment takes place. The NIST RMF process requires that
you perform a system categorization on assets in the first step
of that framework. This system categorization later helps you
to assign controls to the asset based on its criticality factors.
The set of controls you assign to each asset, based on its
criticality, is assessed for effectiveness in mitigating risk and
compliance.
Risk managers may also want to know the value of an asset.
Quantifiable risk analysis requires that some value of an asset
be identified, whether based on replacement cost, salvage cost,
depreciated value, or another method of calculation that
represents the expenditure of resources to return an asset to a
pre-threat event state.

Likelihood Determination and Impact Analysis


Evaluation is the next step of the process. You must determine
the likelihood of a given threat agent initiating a threat or of an
identified threat exploiting a given vulnerability, as well as the
level of impact or harm to the asset if a threat has successfully
exploited a vulnerability. While threats and vulnerabilities in
assets are necessary ingredients to determine risk, they are
static ingredients; in other words, threats, vulnerabilities, and
assets don’t change much. On the other hand, likelihood and
impact are variable and are the primary factors in measuring
risk. People who don’t understand how risk is framed often
mistakenly state risk as a result of only one individual element.
You could say that the risk to an asset is high, for example,
simply because the likelihood of the adverse event occurring is
high. You could also say that risk is high because the level of
impact if an adverse event were to occur would be high.
However, neither of these statements alone really captures the
sense of risk. This is because they do not convey the other
dimension of risk individually since risk is a product of both
likelihood and impact. Additionally, you can’t make these
determinations without the background knowledge of the
threat, the vulnerability, and the asset.

CAUTION Make sure you consider controls and their


effectiveness when analyzing risk since controls can help
decrease likelihood or reduce impact, thereby reducing the
assessed risk for an asset and the organization.
Evaluation involves the measurement of these two primary
factors: likelihood and impact. We’ve already discussed how
there can be different ways to measure these factors based on
subjectivity or concrete values. This is where the discussion on
qualitative and quantitative techniques comes into play. We’ll
go into depth on those assessment techniques next.

EXAM TIP Remember that risk assessments are composed


of the steps of risk identification, evaluation, and analysis.
Identification produces threat–vulnerability pairs, asset
inventories, and risk scenarios. Evaluation covers likelihood
and impact calculations, resulting in risk values. Analysis
looks at the overall application of these factors, as well as
control analysis, to produce a comprehensive picture of risk.

Quantitative and Qualitative Analysis Techniques


You could take two different security professionals, both
trained in the latest standards and practices associated with
risk management, and have them both assess the same system,
and, chances are, they would produce similar reports.
However, they would not be the same. Why is that? It’s
because there are so many different methods of conducting
risk assessment and analysis, depending on what governance
the organization falls under, how the organization has framed
its risk, and so on, that the risk would never be assessed the
same; there are too many variables involved. Add to that
complexity the natural subjectivity of human beings, and you
may have very different risk reports. However, most risk
assessment methodologies are still based fundamentally on the
two primary ways to assess risk: qualitative and quantitative.
Both methods have value, depending on the context of the
situation, and often both methods can be combined. We
discuss these techniques at length in the upcoming sections
and how they can be used together.
Quantitative Quantitative risk analysis uses concrete
(nonsubjective) numerical values and statistical analysis to
calculate the likelihood and impact of risk. Quantitative
methods use numerical values such as dollar figures, statistical
numbers, and other hard-core numerical assignments.
Quantitative risk assessments follow the same general pattern
described previously; you must first list your assets (along
with their replacement costs and exposure factors), calculate
the impact of a full or partial loss of the asset, determine the
likelihood of the adverse event, and come up with the overall
risk to the organization. This might be calculated in terms of
dollars, for example. The following is a scenario that will help
you better understand quantitative risk analysis and some of
the factors that can be quantified and how.
Quantitative Risk Analysis: A Scenario Let’s say you are a
new employee in a small family-owned business that has no
other security professionals employed. You’ve been tasked
with developing a risk management strategy and program for
the business. Suppose the business has a small server farm
located in an older building on your small campus, with
wooden walls, older wiring, no backup electrical power, and
reasonably good fire detection and suppression systems. The
server farm contains four servers, each performing a specific
data-processing function. The data is backed up weekly, but it
takes time to restore, and there is a good likelihood that some
of the data would be lost because of the weekly backup
schedule. Let’s also say (just for the sake of illustration) that
each of these servers costs $10,000 to replace with a new
server (since they don’t make your model any longer unless
you were lucky enough to find a cheaper one on eBay).
You’ve attempted to quantify factors for the owners, such as
recovery time objective (RTO) and recovery point objective
(RPO). These factors tell you how much data you could afford
to lose if a disaster happened (such as a fire burning down that
small wooden building) and how fast you would need to
recover data to resume business operations to avoid suffering a
significant loss of business.
Let’s assume that the small business is in an area prone to
thunderstorms, tornadoes, and hurricanes. One of the natural
incidents that could occur in these areas is a lightning strike
during a thunderstorm, where lightning strikes the metal roof
of the building, and one of the servers suffers a power surge
that completely renders it inoperable. If, after such an event,
an assessment determines that the server can’t be repaired, you
decide to buy another one. The replacement cost of this server
is $10,000. Let’s do some simple quantitative analysis on this
scenario:
Asset value (AV) = $10,000
Exposure factor (EF) = 1 (in this case, a 100 percent
loss of the server and its data)
Single loss expectancy (SLE) = Asset value (AV) ×
Exposure factor (EF) = $10,000
With an SLE of $10,000, you must hope this scenario never
happens. However, based on analysis of historical weather
patterns in the area, and given the shoddy construction and
limited electrical protections of the building the server farm
sits in, this seems to be a likely possibility. So, you should
determine how much the organization is likely to lose, per
year, in such a scenario. You can calculate this if you know a
couple of other pieces of information. First, you need to know
how often to expect a severe storm in the area (say, on an
annual basis). This annualized rate of occurrence (ARO) could
be used with the SLE value given earlier to determine your
loss expectancy for one year.
SLE × ARO = Annual loss expectancy (ALE)
So, given that severe thunderstorms are historically shown
to occur 15 times per year in your area (likelihood), you could
conclude the following:
$10,000 (SLE) × 15 (ARO) = $150,000 in potential
loss per year (ALE)
Obviously, this is a bit of a stretch. Even if there are 15
severe lightning-producing storms per year, it’s not likely that
each one would produce a lightning strike on your server
building every time. Even if that could happen, it’s likely that
after it happens the first time, your small business owners
would invest in a new facility or relocate its servers, thus
reducing the possibility of the other events. So, you might also
do some statistical analysis to determine the likelihood of one
or more of those 15 severe thunderstorms causing a lightning
strike on the server farm building. This analysis might
significantly reduce the likely number of events from 15 to,
say, 3. Now your ALE would be a potential loss of only
$30,000 per year. Keep in mind that the numbers show you the
potential risk to the organization, which is expressed as lost
dollars in terms of revenue and assets.
NOTE These formulas are based on standard basic risk
analysis concepts taught in information security certification
programs, such as CompTIA’s Security+ and (ISC)2’s CISSP
program.
Again, the previous scenario is a simplistic (but not too
unrealistic) example. Other factors could come into play that
are not considered in the previous simple analysis. For
example, suppose the business is losing $1,000 per day in
revenue for every day this server is out of commission, which
the previous calculations do not consider. This consideration is
not only related to the SLE value (since it increases the SLE
over time) but also influences your RTO and RPO values. You
should also realize that this scenario considers only one of the
servers; a better risk assessment should include the possibility
of all the assets being partially or completely lost.
Additionally, it’s possible that a total loss of a server may
not occur; let’s say it’s only a partial loss (say, 40 percent, or
an EF of 0.4), which would reduce the SLE for that single
asset ($10,000 [AV] × 0.4 [EF] = $4,000). So, you must take
all of this into account when performing a quantitative risk
analysis. There are so many other factors that we haven’t
mentioned here that could figure into your SLE values (asset
depreciation, lost labor hours to repair or replace the server,
and so on). However, you can see the basics based on this
simple example.

EXAM TIP Be familiar with the elements of quantitative


risk assessment techniques, such as asset value, exposure
factor, single loss expectancy, annual rate of occurrence, and
annualized loss expectancy.
The final piece of this puzzle is how much it would cost the
organization to reduce this risk. Let’s examine all of the
factors that the organization could influence. First, it could not
affect the weather, so the threat agent and threat can’t be
reduced or eliminated. However, the organization could
address the vulnerability (the server building with its
inadequate protection against bad weather, in this case),
reducing it somewhat by relocating the server farm or even
moving its applications and data to the cloud, for example.
The organization could also reduce the likelihood for that
particular threat-vulnerability pairing if it removed or changed
the nature of the vulnerability itself, as described earlier.
The organization could also reduce the impact of this
specific event in several ways. It could create a real-time
failover cluster for the servers in another location that would
instantly be available if said servers got struck by lightning, or
it could at least have a hot spare server and a recent backup, if
nothing else. The organization can affect the risk factors, but
there is a cost for doing this. What is essential in developing
risk responses is that the organization must balance the cost of
mitigations (for example, acquiring another facility, moving to
the cloud, using server clusters, or at least having hot spares
and better backups) with how much it loses in terms of SLE
and ALE and the added impact of lost revenue per day, as in
this example. The bottom line is that you must find a solution
that isn’t more expensive or impacts the organization to a
degree worse than the risk event itself. Risk responses are
covered in more detail in Chapter 3.
Qualitative A qualitative risk analysis, on the other hand,
involves using subjective scales. These scales could be
numeric (a scale from 1 to 10) or have subjective labels (High,
Medium, and Low, for instance). Qualitative risk analysis can
come from historical trend analysis, experience, expert
opinion, existing internal and external environmental factors,
governance, and other inputs that are not always necessarily
quantifiable but exist and are important nonetheless.
Qualitative risk analysis is appropriate when you must
evaluate risk based on factors that can be hard to quantify,
such as those not typically measured with concrete, repeatable
values. For example, what numerical value could you assign to
a potential impact of the loss of consumer confidence or
damage to reputation? You may attempt to frame it in terms of
lost revenue (an educated guess at best) or loss of business.
For example, you could also survey a sample population to
determine how many people would or would not do business
with the organization after a data breach. However, even that
would be subjective and offer only a small statistical insight
into a hard-to-define measurement.
That’s not to say you couldn’t assign numerical values to
different risk factors, however. Instead of values such as Low,
Medium, and High, you might assign numerical values that
roughly correspond to those levels. For example, you might
use a type of Likert scale, which may have values such as 1
(Very Low), 2 (Low), 3 (Medium), 4 (High), and 5 (Very
High). This might characterize the subjective level of impact
or likelihood the organization wants to assign to a particular
risk event. In assigning these subjective values, you must also
decide how they relate to each other, yielding an overall risk
calculation. In other words, given likelihood values of 1 (Very
Low), 2 (Low), 3 (Medium), 4 (High), and 5 (Very High), and
identical values for impact, what would the overall risk level
be when these two dimensions of risk are viewed together?
How do their values affect each other? NIST Special
Publication 800-30 offers an excellent example of how risk is
calculated using qualitative analysis.

NOTE NIST SP 800-30 refers to numerical scales as


semiquantitative values since they are numerical values that
can be used in calculations but are still subjective in nature (in
other words, they cannot be independently derived or repeated
and are based on informed opinion).
In Figure 2-9, taken from NIST SP 800-30, you can see
how the relationships of likelihood and impact affect different
risk levels. The values of each are correlated, and a qualitative
risk determination results. For example, according to this
figure, a moderate level of likelihood combined with a very
high level of impact results in a level of risk determined as
high. Determining what constitutes a likelihood of moderate
and what is required for an impact level of very high is
subjective. However, it should be defined within the
organization for consistency and standardization.

Figure 2-9 Qualitative assessment of risk (courtesy of NIST


SP 800-30)
Combining Quantitative and Qualitative Techniques If you
think that a qualitative or quantitative assessment alone may
not be enough to adequately capture the different elements of
risk and develop an overall risk determination, you’re right.
While there are instances where each of these techniques can
be used alone, they are used together to varying degrees in
most situations. Each technique is good at producing a
valuable piece of the puzzle, but sometimes you need both a
quantitative perspective and a qualitative perspective on risk.
For example, in the scenario we described earlier for
quantitative risk, say you have numerical values for AV, EF,
SLE, and ALE. These values account primarily for impact.
However, suppose you don’t have enough solid information
for a calculation of likelihood. You might have to give it a
“best guess” that comes from a reasonably well-thought-out
analysis, using anecdotal data or another type of data that can’t
necessarily be quantified but is a reasonably accurate
predictor. You may have to assign likelihood values that are
semiquantitative or the subjective High, Medium, and Low
values. There might also be other subjective factors
contributing to these values, so you would not have a purely
quantitative assessment. Suppose you added “customer
confidence” or “reputation” into the discussion on impact or
loss to the company, for instance. Those would almost have to
be qualitative values, so the assessment couldn’t always be
expressed in exact numerical terms that are easily repeatable
or defendable.
In practice, most risk assessments are usually qualitative
with some quantitative elements, or vice versa. There are
usually few purely quantitative or entirely qualitative
assessments performed. You should understand the elements
and characteristics of both, however, for the exam and your
profession.

Other Analysis Techniques


Now that you know the basics of qualitative and quantitative
techniques, there are a few specific techniques, based on both
of these methods, that we will discuss here so you are familiar
with them for the exam. Note that professionals have
developed dozens of different techniques over the years to
assess risk; you’ll find that most of them fall into either the
qualitative or quantitative methodology. The ISO/IEC
31010:2019 standard we briefly described earlier lists more
than 30 such techniques in its appendixes. Some of them
approach assessments from different directions, but most of
them have several things in common. We’ll discuss just a few
of these in the following sections.
Fault- and Event-Tree Analysis A fault-tree analysis is a
method where the analyst starts with a risk event and looks for
all possible causes. This is diagrammed as a tree, with the risk
event at the root and the causes extending away as branches.
This analysis is used to discover all of the potential causes of
the event (threats and threat actors in this case) to be further
analyzed for likelihood. Like the fault tree, the event-tree
analysis is also diagrammed as a tree structure but takes the
opposite approach (bottom-up instead of top-down). In event-
tree analysis, an initiating event is at the root of the tree, with
all possible consequences (impacts) diagrammed from the root
as branches (as opposed to causes of the event in fault-tree
analysis). Both fault tree and event tree are predictive analysis
tools; in other words, they seek to predict relationships
between causes, events, and consequences. Figures 2-10 and
2-11 show examples of fault-tree and event-tree analysis
diagrams, respectively.

Figure 2-10 An example of a fault-tree analysis diagram


Figure 2-11 An example of an event-tree analysis diagram
Figure 2-10 shows a risk event (in this case, a firewall
failure), with the potential causes shown as no rule configured,
a firewall appliance failure, and unknown or unusual traffic.
Note that the risk event itself is the root of the tree.
Conversely, in Figure 2-11, an event-tree diagram, the risk
event (in this case, a break-in to a corporate facility) is also at
the root. However, the branches leading away are the potential
consequences, not the causes.
Factor Analysis of Information Risk The Factor Analysis of
Information Risk (FAIR) is a semiquantitative methodology
used to determine the probable loss event frequency and
magnitude for individual risks.
The FAIR methodology consists of four stages:
• Identify scenario components This step identifies the
asset at risk, as well as the threat community being
analyzed.
• Evaluate loss event frequency Activities in this stage
include an estimation of threat event frequency, threat
capability, protective control strength, vulnerabilities,
and the frequency of loss events.
• Evaluate probable loss magnitude This stage is used
to develop worst-case and most likely loss magnitude.
• Derive and articulate risk Derived from the values
established in earlier steps, the level of risk is calculated
and portrayed.
The FAIR methodology is presented in the book Measuring
and Managing Information Risk: A FAIR Approach, by Jack
Freund and Jack Jones. An organization known as the FAIR
Institute offers membership, training, and events and is found
at www.fairinstitute.org.
Bow-Tie Analysis A bow-tie analysis uses diagrams to
analyze and explain relationships between various risk
elements, from causes (threats) to events and then to impacts
(consequences). It is similar to both the fault-tree analysis and
the event-tree analysis. It looks at the various causes of a risk
event (fault tree) and analyzes the consequences of the event
(event tree). The difference, however, is that the bow-tie
analysis looks at the intervening characteristics of the events
and causes, such as the path by which the cause leads to the
event and then the consequences. Figure 2-12 illustrates a
bow-tie diagram. In this figure, the adverse event is shown as
the center of the bow tie, with potential causes on the left and
possible consequences on the right.

Figure 2-12 An example of a bow-tie analysis diagram


Other Methods As mentioned, there are too numerous other
methods to perform the different types of assessments to
discuss them all here. Some of these methods focus on data
collection, while others emphasize different group analysis
techniques. All are, again, some variation of either the
qualitative or quantitative method and may require looking at
specific aspects of data to determine various elements of risk.
Other examples of these techniques include the Delphi
method, which centers on expert opinion from questionnaires;
the Bayesian analysis method, which uses data distribution and
statistical inference to determine risk probability values,
checklists, scenario analysis, and business impact analysis
(described later in this chapter); root-cause analysis (discussed
earlier in this chapter); and various collaborative techniques,
such as brainstorming. You won’t be expected to know all
these methods for the exam, but you should be familiar with
the concepts of qualitative and quantitative analysis and some
of the techniques that use each. For further knowledge on
various assessment and analysis techniques, consult with
ISO/IEC 31010:2019.

EXAM TIP You will not have to know any particular risk
analysis method in detail for the exam, but you should
understand how the qualitative, quantitative, and
semiquantitative methods work.

Business Impact Analysis


A business impact analysis (BIA) is used to identify an
organization’s business processes, the interdependencies
between processes, the resources required for process
operation, and the impact on the organization if any business
process is incapacitated for a time for any reason.
While a BIA is considered a cornerstone of a business
continuity and disaster recovery (BCDR) program, a BIA is
also useful for risk analysis. The BIA reveals the most critical
processes (and underlying resources such as information
systems and other IT infrastructure), giving the risk manager a
better idea of which business processes and systems warrant
the most protection from an operational criticality point of
view.
The presence of a BIA provides a strong indication of the
organization’s maturity through its intention to protect its most
critical processes from disaster scenarios. Correspondingly, the
absence of a BIA may suggest that the organization does not
consider risk management as having strategic importance.

Inventory Key Processes and Systems


The first step in a BIA is the collection of key business
processes and IT systems. Within the overall scope of the
business continuity planning (BCP) project, the objective here
is to establish a detailed list of all identifiable business
processes and systems. The usual approach is developing a
questionnaire or intake form that would be circulated to key
personnel in end-user departments and IT. Figure 2-13 shows a
sample intake form.

Figure 2-13 BIA sample intake form for gathering data about
key processes
Typically, the information collected on intake forms is
transferred to a multi-columned spreadsheet, where
information on all of the organization’s in-scope processes can
be viewed together. This will become even more useful in
subsequent phases of the BCP project, such as the criticality
analysis.

TIP The use of an intake form is not the only accepted


approach when gathering information about critical processes
and systems. It’s also acceptable to conduct one-on-one or
group interviews with key users and IT personnel to identify
critical business processes and systems. We recommend using
an intake form (whether paper-based or electronic), even if the
interviewer uses it herself as a framework for note-taking.
Planning Precedes Action
IT personnel are often eager to get to the fun and meaty
part of a project. Developers are anxious to begin coding
before design, system administrators are eager to build
systems before they are scoped and designed, and BCP
personnel fervently desire to start designing more robust
system architectures and tinker with replication and backup
capabilities before key facts are known. In business
continuity and disaster recovery planning, completing the
BIA and other analyses is critical, as the analyses help
define the systems and processes most needed before
getting to the fun part.

Statements of Impact
When processes and systems are being inventoried and
cataloged, it is also vitally important to obtain one or more
statements of impact for each process and system. A statement
of impact is a qualitative or quantitative description of the
impact on the business if the process or system were
incapacitated for a time.
For IT systems, you might capture the number of users and
the names of departments or functions affected by the
unavailability of a specific IT system. Include the geography
of affected users and functions if that is appropriate. Here are
some sample statements of impact for IT systems:
• Three thousand users in France and Italy will be unable
to access customer records, resulting in degraded
customer service.
• All users in North America will be unable to read or
send e-mail, resulting in productivity slowdowns and
delays in some business processes.
Statements of impact for business processes might cite the
business functions that would be affected. Here are some
sample statements of impact:
• Accounts payable and accounts receivable functions
will be unable to process, impacting the availability of
services and supplies and reducing revenue.
• The legal department will be unable to access contracts
and addendums, resulting in lost or delayed revenue.
Statements of impact for revenue-generating and revenue-
supporting business functions could quantify financial impact
per unit of time (be sure to use the same units of time for all
functions to be easily compared with one another). Here are
some examples:
• Inability to place orders for materials will cost at the
rate of $12,000 per hour.
• Delays in payments will cost $45,000 per day in interest
charges and late fees.
As statements of impact are gathered, it might make sense
to create several columns in the main worksheet so that like
units (names of functions, numbers of users, financial figures)
can be sorted and ranked later.
When the BIA is completed, you’ll have the following
information about each process and system:
• Name of the process or system
• Who is responsible for its operation
• A description of its function
• Dependencies on systems
• Dependencies on suppliers
• Dependencies on key employees
• Quantified statements of impact in terms of revenue,
users affected, and/or functions impacted

Criticality Analysis
When all of the BIA information has been collected and
charted, the criticality analysis (CA) can be performed.
Criticality analysis is a study of each system and process, a
consideration of the impact on the organization if it is
incapacitated, the likelihood of incapacitation, and the
estimated cost of mitigating the risk or impact of
incapacitation. In other words, it’s a somewhat special type of
risk analysis that focuses on key processes and systems.
The criticality analysis needs to include, or reference, a
threat analysis. A threat analysis is a risk analysis that
identifies every threat that has a reasonable probability of
occurrence, plus one or more mitigating controls or
compensating controls, and new probabilities of occurrence
with those mitigating/compensating controls in place. To give
you an idea of what this looks like, refer to Table 2-6, which
provides a lightweight example of what we’re talking about.
Table 2-6 Sample Threat Analysis for Identifying Threats and
Controls for Critical Systems and Processes
In the preceding threat analysis, notice the following:
• Multiple threats are listed for a single asset. In the
preceding example, we mentioned just eight threats. For
all the threats but one, we listed only a single mitigating
control. For the extended power outage threat, we listed
two mitigating controls.
• The cost of downtime wasn’t listed. For systems or
processes where you have a cost per unit of time for
downtime, you’ll need to include it here, along with
some calculations to show the payback for each control.
• Some mitigating controls can benefit more than one
system. That may not have been obvious in this
example. However, in the case of an uninterruptible
power supply (UPS) and an electric generator, many
systems can benefit, so the cost for these mitigating
controls can be allocated across many systems, thereby
lowering the cost for each system. Another example is a
high-availability storage area network (SAN) located in
two different geographic areas; although it’s initially
expensive, many applications can use the SAN for
storage, and all will benefit from replication to the
counterpart storage system.
• Threat probabilities are arbitrary. In Table 2-6, the
probabilities are for a single occurrence in an entire year
(for example, 5 percent means the threat will be realized
once every 20 years).
• The length of the outage was not included. You may
need to include this also, particularly if you are
quantifying downtime per hour or another unit of time.
It is probably becoming evident that a threat analysis and
the corresponding criticality analysis can get complicated. The
rule here should be as follows: the complexity of the threat and
criticality analyses should be proportional to the value of the
assets (or revenue, or both). For example, in a company where
application downtime is measured in thousands of dollars per
minute, it’s probably worth taking a few weeks or even months
to work out all of the likely scenarios and a variety of
mitigating controls and then work out which ones are the most
cost-effective. On the other hand, for a system or business
process where the impact of an outage is far less costly, a good
deal less time might be spent on the supporting threat and
criticality analysis.

Recovery Objectives and Next Steps


After the criticality analysis is performed, business continuity
planners will establish a metric known as maximum tolerable
downtime (MTD). This is the amount of time that the
organization can tolerate a business process being
nonfunctional before the ongoing viability of the business
itself (or a major part of it) is at risk. Note that MTD is a
theoretical figure that the organization will not attempt to
verify.
Busines impact analysis is often used to establish recovery
objectives that drive the development of disaster recovery
plans. Recovery objectives and disaster recovery planning are
discussed in more detail in Chapter 4.
Inherent and Residual Risk
Our coverage of the IT Risk Assessment domain in the CRISC
certification concludes with a discussion of inherent and
residual risk. These two concepts bring a small degree of
added complication to the overall risk management and risk
treatment concepts.
Risk treatment is discussed in full detail in Chapter 3.

Inherent Risk
No personal or business activity is entirely free of risk, and
some activities are inherently more risky than others. The
concept of inherent risk expresses the level of risk associated
with a process or activity before applying any protections or
safeguards. In the vernacular, some activities are just riskier
than others.
Take, for example, two personal activities: gardening and
hang gliding. We would state that the inherent risk associated
with hang gliding is significantly higher than that of
gardening. With hang gliding, any number of realistic
scenarios can result in the death of the hang glider. At the
same time, gardening is relatively safe, and death by gardening
is highly unlikely. In both gardening and hang gliding, the
probability of risk realization is relatively low, although the
impact of risk realization is decidedly higher for hang gliding.
One approach to risk analysis is assigning inherent risk to a
process or system, and then calculating changes to risk after
protective controls and safeguards are applied. This helps a
risk analyst understand the changes in risk when individual
controls and safeguards are applied, and it better informs
management of the full nature of risk for a given part of the
organization.

Residual Risk
The risk management and risk treatment processes tend to
reduce risk, but they rarely eliminate all risk. Instead, risk
mitigation and risk transfer reduce risk to a lower level. This
“leftover” risk is known as residual risk.
Residual risk is best explained with a real-world example.
An organization’s workforce is equipped with laptop
computers running Windows or macOS, neither of which
utilizes whole-disk encryption. Risk analysis suggests that the
risks associated with the theft or disappearance of an
unencrypted laptop computer are quite high, with potential for
a significant security or privacy incident, depending on whose
laptop computer is lost or stolen.
In this scenario, the organization decides to implement
whole-disk encryption on all of its laptop computers. Note that
this measure does nothing to change the probability of laptop
computers being lost or stolen. However, this measure changes
the impact significantly. While, with whole-disk encryption,
the organization need no longer worry about the potential data
compromise, the stolen laptop will still need to be replaced.
The residual risk, in this example, is the financial risk
associated with the funds required to purchase a new laptop
computer, plus any labor needed to make it ready for
employee use.
To continue this example further, this residual risk is one in
which the residual risk may still be a risk that warrants further
analysis and treatment. Analysis of the risks associated with
the need to replace a lost or stolen laptop computer could
result in a recommendation of the purchase of security cables
that are issued to each employee, together with directives that
laptop computers are to be locked to a piece of furniture (or
locked in a safe) when not in the direct control of the
employee. This measure reduces the probability of theft or
loss, but not the impact: if the laptop computer is stolen, it
must still be replaced, but theft is less likely to occur since, at
least some of the time, employees will use those cable locks,
reducing the number of opportunities for someone to steal
them.
Larger and more complex risk scenarios may require
multiple rounds of risk analysis and risk treatment. However,
an organization will eventually reach the point where the
residual risk is low enough that business leaders and
department heads will accept the residual risk.
Often, risk analysis, risk treatment, and residual risk are
more complicated than this. A risk assessment performed on a
business process or information system is likely to identify
multiple risks, which should be considered in whole as well as
individually. It may be easier to understand all the risks
together to compare various types of risks and risk treatment
options when considered together. Sometimes, a single risk
treatment measure may mitigate more than one of the
identified risks. Figure 2-14 visually depicts multiple rounds
of risk analysis and risk treatment until the final remaining risk
is accepted.

Figure 2-14 Risk reduction through multiple rounds of risk


treatment
Let’s go back to our stolen laptop example for a moment.
Imagine that multiple risks are identified in a stolen laptop
scenario, all having to do with the compromise of different
types of information: personally identifiable information (PII)
such as human resource information, non-public financial
information, intellectual property, and trade secrets. Whole-
disk encryption will reduce the impact of all four of these
scenarios to near zero.

Miscellaneous Risk Considerations


There may be other options to consider when performing risk
assessments, which may or may not be applicable in an
organization. Understanding industry and compliance models
related to an organization’s industry can be absolutely critical
to using the risk assessment to pass an audit or ensure legal
compliance. There may be unique methodologies used by the
organization to illustrate different aspects of a cybersecurity
program.
For companies that have protected health information
(PHI), there are extra considerations that should be followed
related to the data from a legal standpoint because those
companies should follow Health Insurance Portability and
Accountability Act (HIPAA) regulations. In this case, tying in
each risk to confidentiality, integrity, and availability is
required by HIPAA. This can be as simple as creating a new
column on a risk register that denotes if confidentiality,
integrity, or availability is affected by the risk. It is a simple
additional step that can help demonstrate not only compliance
with HIPAA, but a deeper understanding of how the risks may
affect an organization.
The enforcement arm of HIPAA is the Office of Civil
Rights (OCR). Working with their regulations, they have risk
requirements that need to be assessed for legal compliance
reasons. The OCR does not expect companies to follow their
exact risk methodology so long as the concerns are fully
applied within the risk framework of the organization. If there
ever is a HIPAA violation where the OCR becomes involved,
considerations like this and assessing confidentiality, integrity,
and availability can make regulators feel more at ease related
to the violation and sometimes help reduce the overall
penalties.
Stepping away from HIPAA considerations, sometimes
organizations may choose to follow or report to others using
frameworks such as NIST CSF (described previously). In this
case, as with the confidentiality, integrity, and availability
example, the NIST CSF functions (Identify, Protect, Detect,
Respond, Recover) may be used in the same way. This can
sometimes be useful to help business executives who do not
understand the intricacies of cybersecurity to understand, at
least at a high level, why certain risks are so important to
consider.
Another option that may or may not be helpful depending
on the organization is the concept of materiality. Materiality
comes from the audit world and denotes a fundamental flaw in
a specific program. For example, if there is no antivirus in an
organization, that is a fundamental flaw and thus a material
weakness. Adding a column like this into a risk register is yet
another way that organizations can create extra emphasis
around a risk management program.
It should be clear that there are a number of ways
organizations can approach risk. In some instances, it is not so
much about being right or wrong concerning a risk
methodology but rather about working through the right flavor
of risk within an organization.

Chapter Review
IT risk identification consists of activities performed to
identify various types of risks associated with an
organization’s use of information technology, including
strategic, operational, cybersecurity, privacy, supply chain, and
compliance risks.
The types of activities where risks may be identified
include risk assessments, audits, incidents, penetration tests,
news and social media, advisories, threat modeling, word of
mouth, whistleblowers, and passive observation.
Threat modeling is a risk identification technique that
involves examining every possible threat agent, action or
event, attack vector, and vulnerability for a given system,
asset, or process, and then modeling or simulating how it
could progress and the damage that could occur.
Vulnerability and control deficiency analysis are important
parts of risk analysis, focusing on weaknesses in a system or
process that could result in a potentially serious incident if
exploited by a threat actor.
Root cause analysis, or RCA, is a method of problem-
solving that seeks to identify the root cause of an event,
situation, or problem.
A risk scenario is a potential real-world, business-
impacting event that consists of a threat, threat actor,
vulnerability, and asset.
Risk analysis is a detailed examination of a risk to better
understand basic factors, including the likelihood and impact
of risk occurrence, and the development of a measure that
might be enacted to reduce likelihood or impact.
Several types of assessments can be used to identify risks,
including a gap assessment, threat modeling, vulnerability
assessment, maturity assessment, penetration test, data
discovery, code review, architecture review, design review,
code scan, audit, and risk assessment.
Several techniques are used in a risk assessment to identify
risks, including interviews, documentation review,
observation, and system testing.
Risk ranking is the process of sequencing risks, generally
with the greatest risks appearing first.
A risk owner is the owner of a business process or system
that focuses on an identified risk.
A risk register is a business record containing information
about business risks and their origin, potential impact, affected
assets, probability of occurrence, and treatment.
A risk analysis is the detailed analysis of a risk that has
been identified in an activity, such as a risk assessment.
Quantitative risk analysis uses concrete (nonsubjective)
numerical values and statistical analysis to calculate the
likelihood and impact of risk. On the other hand, a qualitative
risk analysis involves using subjective scales, such as a
numeric scale from 1 to 10, or subjective values, such as High,
Medium, and Low.
There are several risk analysis techniques, including fault-
and event-tree analysis, factor analysis of information risk
(FAIR), and bow-tie analysis.
A business impact analysis (BIA) is used to identify an
organization’s business processes, the interdependencies
between processes, the resources required for process
operation, and the impact on the organization if any business
process is incapacitated for a time for any reason.
A statement of impact is a qualitative or quantitative
description of the impact on the business if the process or
system were incapacitated for a time.
A criticality analysis is a study of each system and process,
a consideration of the impact on the organization if it is
incapacitated, the likelihood of incapacitation, and the
estimated cost of mitigating the risk or impact of
incapacitation.
Inherent risk is the level of risk associated with a specific
activity or function before applying any protective controls or
safeguards.
Residual risk is the risk that remains after any risk transfer
or risk mitigation that may have been performed.
The materiality of a risk may help to highlight its
importance to management.

Quick Review
• CRISC candidates and risk managers must be familiar
with the vocabulary of terms related to risk assessment
and risk analysis, including asset, vulnerability, threat,
impact, attack, and risk.
• CRISC and IT Risk Management consider cybersecurity
risks and operational risk, workforce risk, privacy risk,
and compliance risk.
• Appendixes D and E in NIST Special Publication 800-
30, “Guide for Conducting Risk Assessments,” offer a
comprehensive list of threat agents and their related
threats.
• Risk, asset, and control owners are not always the same
person, functional area, department, or organization.
• Risk analysis is a detailed, focused examination of a risk
performed as a part of an overall risk assessment.
• The scope of an assessment determines the boundaries
of inquiry and analysis of a process or system.
• Well-known risk assessment standards include NIST SP
800-30 (Guide for Conducting Risk Assessments),
OCTAVE, ISO/IEC 27005 (Information technology –
Security techniques – Information security risk
management), ISO/IEC 31010 (Risk Management –
Risk Assessment Techniques), and ISACA’s Risk IT
Framework.

Questions
1. Awareness of new risks can be obtained through all of the
following activities except which one?
A. Security advisories
B. Privacy incidents
C. Budget reviews
D. Audits
2. In a discussion about the security of endpoint devices,
one security professional described that some endpoints’
antivirus programs are not functioning correctly. What is
this a description of?
A. Threat
B. Vulnerability
C. Risk
D. Threat model
3. A security specialist is examining a particular preventive
control and has determined that the control is not
operating as designed. What term describes the state of
the control?
A. Undocumented
B. Inefficient
C. Fail-open
D. Ineffective
4. A risk analyst reviewing a business process has identified
a control gap. What is the meaning of this conclusion?
A. A control exists but is undocumented.
B. A control does not exist.
C. An earlier risk assessment determined that a control
is not necessary.
D. A new risk has been discovered.
5. Several security professionals are discussing a recent
security incident. The discussion is proceeding through
the phases of the incident and the conditions preceding
the incident in order to understand why those conditions
occurred. What are the security professionals performing?
A. Root cause analysis
B. Incident debrief
C. Incident forensics
D. Reverse engineering
6. What is the primary purpose for risk scenario
development?
A. To identify the highest rated risks
B. To quantify the highest rated risks
C. To prepare an executive briefing
D. To associate risks with business objectives
7. A risk manager wants to better understand the factors in
particular business processes that could lead to an
incident. What activity should the risk manager perform?
A. Risk analysis
B. Threat modeling
C. Vulnerability analysis
D. Root cause analysis
8. Hackers, cybercriminal organizations, disgruntled
employees, and hurricanes are known as what?
A. Threat agents
B. Threat actors
C. Threats
D. Attacks
9. An auditor has contacted an organization’s data center
security manager and has requested a walkthrough. What
is the auditor asking for?
A. A meeting to discuss one or more security controls
B. A tour of the data center
C. An explanation for a recent incident
D. Interpretation of a security report
10. What does NIST Special Publication 800-30 describe?
A. A risk management methodology
B. A risk assessment methodology
C. Security and privacy controls
D. Audit procedures for security and privacy controls
11. A security analyst is finishing up a risk assessment and is
about to identify the risk owner for each risk in the report.
In general, who should be the risk owner for each risk?
A. The board of directors
B. The CISO or CIRO
C. The CIO
D. The related business process owner
12. Which of the following is the best description of a risk
register?
A. A list of threat agents and threat actors
B. A list of identified risks
C. The root cause analysis (RCA) for a security incident
D. A list of likely risk scenarios
13. A risk manager is performing risk analysis on a specific
risk to better understand the risk and to identify potential
remedies. Various aspects of the initial risk and its
potential remedies are scored on a scale of 1–10. What
type of risk analysis is being performed?
A. Qualitative risk analysis
B. Quantitative risk analysis
C. Semiquantitative risk analysis
D. Factor Analysis of Information Risk (FAIR)
14. An organization has performed a risk analysis of a
complex scenario. Two different mitigation strategies
have been approved that will reduce the original risk to a
much lower level. The risk that remains after these
mitigation strategies have been completed is known as
what?
A. Inherent risk
B. Leftover risk
C. Residual risk
D. Accepted risk
15. Which of the following is the best method for managing
residual risk?
A. Subject it to risk analysis and risk treatment.
B. Retain it on the risk register and consider it as
accepted.
C. Retain it on the risk register and label it as closed.
D. Add it to the cumulative total of risk tolerance.

Answers
1. C. Awareness of risks can be obtained through numerous
sources and activities, such as audits, incidents,
advisories, threat modeling, assessments, and news
articles. Budget reviews are an unlikely source of
information about new risks.
2. B. The matter of a failure of a protective control such as
antivirus or a firewall is known as a vulnerability. The
basic terms of risk, such as vulnerability, threat, control,
and risk, are sometimes misused.
3. D. A control that is not operating as designed is
considered ineffective. To reach this conclusion, an
analyst or auditor needs to understand the objective of the
control and determine whether the control as it is
presently operating meets that objective.
4. B. A control gap is a situation where a control does not
exist, but should exist. A control gap can also describe a
situation where a control is not properly designed or
implemented.
5. A. A root cause analysis (RCA) attempts to get to the
ultimate explanation of an incident, by proceeding
backward through time to ask “why” specific conditions
or events occurred.
6. D. Risk scenario development is performed to associate
specific risks with specific business objectives or
business activities. Risk scenario development makes
risks more tangible by describing their potential impact
on the organization in business terms.
7. C. A vulnerability analysis is a detailed examination of a
process or system to discover vulnerabilities that a
credible threat agent could exploit.
8. A. Threat agents are the entities, human or not, that may
perform actions that could cause harm to an organization,
its processes, or its systems.
9. B. A walkthrough with an auditor is a discussion where a
control owner describes the operation of one or more
controls and answers specific questions about them.
10. B. NIST SP 800-30, “Guide for Conducting Risk
Assessments,” is a step-by-step guide to performing
qualitative and quantitative risk assessments. The
standard also briefly describes the overall risk
management life-cycle process to provide context for
individual risk assessments.
11. D. The owner of individual risks should be the business
unit leader or department head that manages business
processes most closely related to those risks. In rare
circumstances, risks should be assigned to the CIO,
CISO, or CIRO.
12. B. A risk register is a master list of all credible risks that
have been identified and are awaiting further analysis,
treatment, or follow-up.
13. A. Qualitative risk analysis uses a scoring scheme such as
“high-medium-low” or a simple numeric scale such as 1–
3, 1–5, or 1–10.
14. C. Residual risk is the risk that remains after risk
treatment (whether mitigation, transfer, or avoidance) has
been completed.
15. A. The best way to manage residual risk is to include it in
the risk register and then subject it to the usual risk
analysis, risk scenario development, and risk treatment.
3 CHAPTER

Risk Response and Reporting


In this chapter, you will:
• Understand the concepts of risk and control ownership
• Understand the various risk treatment and response
options
• Learn about the risk response process
• Understand risk response options and how to align
choices with business objectives
• Understand how controls are designed, implemented,
and evaluated
• Learn methods to document and assess risk responses
• Understand and define key performance indicators
(KPIs)
• Understand and define key risk indicators (KRIs)
This chapter covers Certified in Risk and Information
Systems Control Domain 3, “Risk Response and Reporting.”
This domain comprises 32 percent of the CRISC
examination.

The CRISC Task Statements relevant to this domain address


several key activities present in risk response and reporting,
beginning with the collection of information about an
organization’s business and IT environments as well as
identifying impacts to the organization’s objectives and
operations. This includes the identification and evaluation of
threats and vulnerabilities and establishing accountability by
assigning risk and control ownership. An IT risk register is
used to document the risk profile. Identifying risk appetite and
tolerance and conducting security awareness training help to
promote a risk-aware culture. IT risk assessments and risk
analysis help to identify control deficiencies that bring about
risk responses, risk treatment plans, and the design and
implementation of controls—all of which should be validated.
Risk reporting includes the use and monitoring of key control
indicators, key risk indicators, and key performance indicators.
Assessments of controls and analysis of risks can help
understand their maturity and effectiveness. New and
emerging technologies should be evaluated to identify changes
in risks. All of this should drive risk-driven decision-making.
In this chapter, we will review the concepts that comprise
CRISC Domain 3, which is focused on risk response and
reporting. There is a natural progression from the risk framing,
analysis, and assessment discussions in the previous chapters,
which covered CRISC Domains 1 and 2, to the discussion of
risk response in this chapter; you will see that many of the
outputs from those processes lead directly to this chapter
because an organization generally wants a meaningful
response to any risk to itself and its systems and data. After
discussing how risk responses are chosen, we will discuss how
to implement those risk responses, including how to design,
develop, and adjust controls, and then, finally, how to report
on risk.

Risk Response
Every organization has risk. The leaders of smart
organizations, however, have determined how they will deal
with that risk appropriately for their business context. Will
they accept all risks? Will they transfer some risks to a third
party, such as an insurance company? These are some
questions that need to be considered within the risk response
process, as discussed in this chapter.
We will also discuss the major control frameworks within
the field and how they are incorporated into risk response. You
should note that risk is different for every organization; risk
within an educational context is different from a financial
context, which is different from a government context. Also
keep in mind that IT risks are different from business or
mission-oriented risks. It’s important to note that the mission
of the organization helps to shape risk responses as well. This
is why it’s so important that organizations conduct a thorough
risk analysis and understand and prioritize the response
options that are right for them. You should also remember that
the risks to the business, the business goals and objectives, and
the systems supporting those functions should all be
considered throughout the risk response process. It’s easy as
an IT professional to forget that the business objectives are the
top priority, but to maximize efficiency and effectiveness (and
to pass the exam), you should keep that in mind.

Risk and Control Ownership


Risk and control ownership are issues that must be considered
during a risk assessment and response. Depending on how the
organization is structured and how the risk management
strategy has been developed, risk ownership may be assigned
to one or several different managers, spanning multiple
functional areas. This is because the risk that affects one area
likely affects other areas as well, so many different people
may have responsibility over affected areas and be required to
deal with and respond to risk.
Control ownership is also something that should be
examined; often controls that provide protections for a given
asset or a number of systems may not fall under the
operational purview of the risk owner. Some controls span the
entire organization and protect multiple assets, rather than only
a specific system. These are referred to as common controls,
and the responsible entity for these controls is the common
controls’ provider. For example, consider physical security
controls. There may be a physical security officer for the
organization who is in charge of guards, personnel security,
and physical access to secured areas. They may also be
responsible for locks, closed-circuit televisions (CCTVs), and
physical intrusion detection systems and alarms. All of these
controls serve to protect information systems and data assets
that might be in a secure data center. Risks may be presented
to the person who is responsible for information systems in the
data center, but the controls that serve to protect them may
belong to the physical security functional area. This would
require some coordination between the different functional
areas if controls managed by one functional area are
insufficient to protect assets managed by another area. This
may also affect organizational structures, budget, and
allocation of resources.
It is normally important that risk and control owners be
identified and documented on the risk register. This helps
assign responsibility and accountability for risks, the
responses, and the controls. Additionally, the risk and control
owners should be given the authority to carry out
responsibilities in reducing risk and implement controls as
needed. Both risk and control owners, as part of this authority,
should have some level of control over budgets, personnel,
equipment, and other resources required under the purview of
their responsibilities. If owners are given authority to carry out
their responsibilities, they can be held accountable when risk
is not properly responded to or when controls are ineffective in
reducing risk.

NOTE Risk, asset, and control owners are not always the
same person, functional area, or even organization. It’s
important that you identify these particular owners early in the
assessment process and maintain careful coordination and
communication between these and other relevant stakeholders,
within the boundaries of your authority and assessment scope.
Having different types of owners can result in politically
sensitive issues that revolve around resourcing, responsibility,
accountability, and sometimes even blame.

Risk Treatment/Risk Response Options


Having developed your understanding of risk, you should also
develop an understanding of the corresponding risk response
options. These options will help you bring your risk down to a
level of risk tolerance your organization can accept.
Understand that this is not just merely responding to risk; risk
treatment and response options should also meet the needs of
the mission, business goals and objectives, and overall
organizational strategy. A risk response option whose focus is
only to reduce risk in a vacuum may interfere with the normal
business operations or reduce the effectiveness of the business
when performing its mission. Therefore, you should consider
risk responses not just within the context of simply reducing
risk; they must also reduce risk and not adversely impact
business processes at the same time. Within this context,
consider how you would recommend your organization
respond to risk effectively but with a balanced approach. We’ll
discuss the different risk response options in the next few
sections.

Risk Mitigation
Risk mitigation generally involves the application of controls
that lower the overall level of risk by reducing the
vulnerability, the likelihood of a successful threat exploiting
that vulnerability, or the impact to the asset if the risk were to
be realized. Mitigation actions come in a number of forms; a
policy requiring nightly offsite backups of critical data can
mitigate the risk of data loss, for instance. Similarly, applying
a newly released web browser patch can mitigate the risk of
exploitation. The goal is to get the risk down to a level
considered acceptable by the organization’s leadership. We
will discuss controls and their implementation a bit later in the
chapter, but for now you should understand that you may have
to add new controls; update, upgrade, or even change controls;
or even in some cases change the way your business processes
work. All of these actions are designed to mitigate or reduce
risk.

Risk Sharing
Risk sharing (often referred to as risk transference) entails the
use of a third party to offset part of the risk. Risk sharing can
involve the outsourcing of some activities to a third party to
reduce the financial impacts of a risk event in many cases.
Sharing offsite (co-location) assets and contractual obligations
with other entities is one way that organizations implement
risk sharing; a cloud service provider can be used within this
scenario. The cloud provider might be contractually obligated
to assume part of the financial impact in the event of a breach,
but be aware that there is a potential loss of brand goodwill or
other intangible assets that can be difficult to offload. Another
example of risk sharing is the use of an insurance service to
cover the financial impacts (at least partially) of a breach;
however, the intangible losses mentioned previously would
still be present. The point is that risk sharing (or transference)
typically only works with a portion of the risk; it does not
reduce all of the risk. Therefore, multiple risk response options
used concurrently will likely be needed.

EXAM TIP Don’t forget that use of a risk-sharing scheme


does not totally absolve an organization of its responsibilities;
organizations may still retain responsibility—and more
importantly, accountability—if there is loss of data or revenue.
Additionally, legal liabilities may also be involved.

Risk Acceptance
There will always be some level of residual risk, no matter
how many controls you implement or the amount of insurance
you purchase. Again, the goal is to get the risk down to a level
considered acceptable by the leadership. Risk acceptance
occurs when the active decision is made to assume the risk
(either inherent or residual) and take no further action to
reduce it. The word active is critical here; risk acceptance is
different from being risk ignorant in that the risk is identified,
alternatives are considered, and a conscious decision is made
to accept it. A good example of this would be when you have
taken all practical steps to reduce the risk of an attack from a
malicious entity. Your organization may have installed
perimeter security devices, strong authentication methods, and
intrusion detection systems, which will reduce the risk
significantly. However, since risk cannot be completely
eliminated, there is always a chance that an attacker may enter
the infrastructure through some other means. This residual risk
may have to be accepted because it might be financially
unwise to invest more resources into further mitigating the
risk. Similarly, a company might choose to willfully ignore
government-mandated control implementation that would
incur fines or other financial penalties, assuming that the
financial cost incurred would be less than the cost of
implementing the controls. As we will also discuss, the value
of the asset may be far less than the cost of implementing any
mitigating controls, so in those cases risk acceptance may be
the right choice.
Note that risk acceptance of any kind should be a formal
management decision, and fully documented, along with
provisions to monitor the risk, typically through the risk
register. As with all risk response options, management should
be cognizant of monitoring risk, since it frequently changes,
and in turn make changes to the response as dictated by the
changing operating environment, new technologies, and the
threat landscape.

EXAM TIP It’s important to note that risk acceptance


doesn’t insinuate ignorance; it’s an active acknowledgment
and conscious decision to accept risk as it is, assuming it is at
a level that is comfortably within risk appetite and tolerance
ranges.

Risk Avoidance
Risk can be avoided through a number of methods. Sometimes
risk can be avoided by simply choosing not to participate in
the activity that incurs the risk. For example, an organization
may decide that a particular business venture or entry into a
new market would incur far more risk than it is willing to take
on. Perhaps you don’t need to conduct the activity at all.
Avoiding risk can mean eliminating risk associated with a
particular activity by not performing that planned activity.
Risk avoidance is the option taken when, after all risk
treatment options, including mitigating controls, have been
considered, the level of risk is still not acceptable. An
organization might choose not to take on a proposed project
because of the probability of failure and subsequent loss of
capital, for example. Another scenario might be the
organization choosing to not adopt a cloud solution because of
the level of sensitivity of information that would be stored
within the cloud. In any event, risk avoidance does not simply
mean ignoring the risk, as some people may be led to believe.
Risk avoidance requires careful thought and planning as well
as balancing the level of risk incurred in following a particular
path versus eliminating the risk by not following that path at
all.

Evaluating Risk Response Options


Risk mitigation, sharing, acceptance, and avoidance are all
valid options you should consider using (sometimes at the
same time) to lower the risk level you face. The key is to use
these options together; you want to balance risk and reward to
maximize the benefits. These benefits can be financial or some
other, perhaps difficult to quantify, benefit (such as morale,
partnerships, or long-term strategy).
One of the key considerations in balancing risk options is
the cost and effectiveness of any response option. For
example, as briefly mentioned, if the value of the asset to the
organization is much lower than the security controls it would
take to protect it, is risk mitigation or reduction the right
option? You should also consider the effectiveness of the
controls; if all possible controls you could implement still
don’t reduce the risk to an acceptable level, are they worth it?
Other factors that should be considered in risk response
options include those inherent to the organization itself.
Sometimes organizational design and layout is a factor
because how different divisions and departments are structured
within the organization and who they report to affect resource
allocation, chain of command, and so on. Sometimes these
factors have to be changed in order to implement a good risk
response. Other considerations are governance, including legal
and regulatory requirements, and organizational culture. An
example of how organizational culture can affect a risk
response is when an organization determines that it needs to
pull back administrative privileges from ordinary users—
something that is very much frowned upon in the security
community. While this response may not be expensive in
terms of any required equipment or additional controls, the
cost here is the shock to and pushback from the organizational
culture. People normally do not like giving up what they
already have, and administrative rights is one of those things
that all users seem to believe that they need. Organizational
culture will definitely be an impediment to implementing this
particular risk response.
In evaluating and selecting risk responses, you should
consider all the factors we’ve discussed previously, such as the
cost of the response (and of the potential cost of not
responding), organizational context and associated missions,
risk tolerance, governance, and the simple ease of
implementation.

Third-Party Risk
In today’s business world, an organization rarely functions
independently from other entities. Most businesses are not
entirely independent and self-sustaining; they depend on
suppliers, service providers, and so on to help them bring their
products and services to market. These third parties often
perform services that are outsourced from the organization
because of a lack of infrastructure or simply a desire to not
perform these functions or services internally. A great example
of a third-party service provider is one that provides cloud
services to businesses, such as data storage, applications, and
even entire infrastructures to organizations that don’t have the
means or the desire to create the internal structures needed to
manage them internally. Sometimes it is more cost effective
for an organization to simply hire a third party to perform a
function or provide a service than it is to expend the resources
to create and maintain all of the equipment and processes
itself.
If you recall the risk treatment options discussed earlier,
transferring (or sharing) risk includes the use of third parties to
bear some of the risk in performing certain business functions.
Insurance is the classic example of transferring risk used in
most risk management training texts, but this instance usually
only provides monetary funds in case of a disaster or liability
scenario. Transferring risk to third parties also includes
outsourcing certain functions and services to third parties, so
this, too, is a standard risk treatment method. The
organization, for example, can reduce its risk of accounting
and budget errors with a small, untrained staff by outsourcing
its accounting functions to a third-party accounting firm.
It’s important to note that while this strategy of dealing with
risk is effective and common, the organization is transferring
only risk, not responsibility. The organization almost always
retains final accountability and responsibility for functions and
services outsourced to a third party. For example, transferring
a business’s accounting functions to an outside firm mitigates
risk by transferring some of it to the third party, but the
organization is still ultimately responsible to its stakeholders,
government regulators, banks, and financial obligations, even
if the accounting firm makes an error. As another example, an
organization that makes use of cloud data storage services still
maintains accountability and responsibility for any data stored
with a cloud provider if that provider suffers a breach that
results in the release of sensitive information. While third-
party providers may still incur some level of liability in these
cases, the final liability rests with the organization that
contracted with them. Liability, accountability, and
responsibility are also some of the key risk factors with third
parties that we’ll discuss next.

Third-Party Risk Factors


As indicated earlier, several risk factors relate to the legal
aspects of dealing with third-party providers. Most of these
risk factors deal with trust in the third-party provider or in
dependencies the organization may have on the provider’s
services. For example, the organization must be able to trust
that the third-party provider will provide adequate security for
any data that is maintained in its infrastructure. In addition to
trust, other risk factors include interoperability with existing
systems in the organization, data protection and security, and
legal liability. Remember we said earlier that an organization
can outsource risk to third-party providers, but the
organization typically retains accountability, responsibility,
and legal liability. Some legal liability, however, is levied on
the third-party provider since it usually has a duty to provide
services as well as assurances that those services will meet
certain legal standards, as written in the contract between the
provider and the organization.
The risk factors relating to third-party providers depend on
the types of services provided as well as how the contract
agreements are set up between the organization and the
provider. Some contracts have cybersecurity provisions built
into them. A document known as a service level agreement
(SLA) is the key to reducing risk factors when dealing with a
third-party provider. The SLA stipulates what the third party
must provide in terms of level of service, performance, and so
on. Some of these contracts are specific to the data type
involved. For example, third-party agreements that deal with
protected health information, called business associate
agreements (BAAs), have cybersecurity provisions built into
them. Another common approach is to have companies that
are performing business provide responses to security
questionnaires. There are standardized formats available on
the Internet, but many companies rely on answers from
security frameworks or they design their own set of questions
to assess the security/risk. Companies that are more mature
may perform their own assessments of cybersecurity,
including doing their own audits, penetration testing, evidence
gathering, and so on. In some cases, these can be just as
intensive as an actual audit. All of these methods can be used
as minimal cybersecurity standards for the third-party
providers. In many cases, they result in findings that need to
be remediated in order to conduct business (meet minimal risk
thresholds).

Third-Party Threats
Like the risk factors mentioned earlier, threats associated with
dealing with third-party providers primarily relate to trust and
the contractual and legal aspects of those arrangements.
Threats include failure to provide services as specified in
contracts, failure to meet performance or security levels,
failure to protect data, and loss of availability for systems or
data to an organization’s users. Third-party providers can
certainly succumb to some of the same threats the organization
would, such as natural disasters and so forth. Therefore, some
of the threats could also include loss of service or data for the
business in some of these negative events. Third-party
providers are also susceptible to hacking and malicious
insiders, the same as any organization would be. Therefore,
threats of data loss or disclosure are also present with third-
party providers.

Third-Party Vulnerabilities
Vulnerabilities that result from associations or dealings with
third-party providers include failure to adequately cover
contingencies in contractual agreements, such as system or
data availability or loss, lack of or inadequate security
protections, and service levels that fall below an acceptable
standard. Furthermore, any vulnerabilities that the third-party
provider has inherent to its own organization are,
unfortunately, indirectly incurred by any organization that
deals with the third party, since those vulnerabilities could
affect data in its custody or services provided to others.
Examples of internal vulnerabilities that could affect
organizations for whom the third party provides services
include infrastructure vulnerabilities (such as patch or
configuration management issues, loss of equipment, or
malicious intrusion by hackers), organizational vulnerabilities
(such as loss of revenue or bankruptcy), and even
technological vulnerabilities (such as lack of sufficient
encryption strengths or strong authentication methods). All
these vulnerabilities could indirectly affect any organization
that has a contractual agreement with a third-party provider.

EXAM TIP Remember that even if risk is transferred to a


third party, accountability and responsibility usually remain
with the business.

Third-Party Risk Management


Managing third-party risk can be challenging and is an
ongoing process. The initial risks may change due to a
growing relationship with a business partner, additional data
being sent to a third party, or the threat landscape affecting
risks. Considerations for managing that risk may be performed
yearly, as contracts change, as technology changes, and so on.
As mentioned previously, some assessments are based purely
on questionnaires, but there may be other tools that provide
additional ongoing technical assessments of third parties.
These can be used to help detect whether the effectiveness of a
third party’s security controls is trending in a negative
direction, which in turn can be used as an additional set of
information to more completely inform risk about third parties.

Issues, Findings, and Exceptions


Management
Rarely do our security processes and risk response efforts go
as smoothly as we would like. There are always things that
don’t go as planned. Sometimes there are contentions between
security requirements, competition for resources within the
organization, findings that cannot be easily mitigated, and
other issues and exceptions that must be dealt with. These
departures from planned activities, as well as from our
established configuration baselines, are cause for concern,
especially when we must implement solutions that are outside
the normal security parameters we would like. Security and
risk, like most things in life, involve compromise and balance.
As security and risk practitioners, we are always trying to
balance security, functionality, and resources, which always
seem to be in conflict with each other. Security and
functionality are almost always inversely proportional with
each other; for example, typically the more secure a system is,
the less functional it is for its users, and vice versa. Resources
are always at a premium, and we never have enough money,
qualified personnel, equipment, or facilities to achieve the
level of security we would like. Additionally, risk itself is a
give-and-take. We are often forced to accept a level of risk
based on how cost-effective it is to implement controls to
reduce the risk to a manageable level. In any case, how we
deal with departures from the normal baselines, in the form of
issues, findings, exceptions, and so on is critically important.

Change and Configuration Management


One of the primary sources of issues with our security posture,
in the form of findings and exceptions, is our change and
configuration management processes and status. Remember
that change management is a formal management process
designed to ensure that needed changes are carefully
requested, considered, approved, tested, and implemented in a
safe, secure, and predictable manner. The change management
process, when implemented properly, should allow an
organization to make major changes to the infrastructure
without suffering unexpected or critical consequences.
However, change management can cause issues if emergency
changes must be made for security or other reasons, and there
is simply not enough time to route the change through the
organization’s change control board (CCB). There are also
issues if people do not follow the steps of a proper change
management process, and simply implement changes on the
fly without approval. Both of these issues should be carefully
considered because they could incur additional risk, represent
an undesirable departure from the normal change process, and
must be minimized whenever possible.
Configuration management brings the same challenges.
While change management applies to major infrastructure
changes, configuration management is a subset of that process
and is specific to individual systems. Arbitrarily changing
configurations without careful planning and testing could
result in unstable or unusable systems. If emergency
configuration changes must be made, this represents additional
risk because there may not always be time for the formal
testing and approval process. Configuration management is
also impacted by older or legacy systems that cannot be
updated in the event a critical security issue is discovered,
such as a zero-day vulnerability. These problems could crop
up during a vulnerability scan, where a vulnerability finding is
discovered and the patch for that vulnerability either does not
exist or cannot be implemented on an older system, or on a
system that, if patched, would break line-of-business systems.
This is where an exception would have to be considered: the
company could either allow the system to operate under its
current configuration, while acknowledging the security risk,
or risk the impact of the update on the line-of-business
systems, resulting in a loss of potential revenue. Even when
the risk is considered and an exception must be made, this,
again, is an undesirable departure from the normal process
steps. We will discuss exception management in more detail in
the next section.
Release management is also a subset of change
management and, along the same lines, represents risks when
software must be released ahead of its schedule or before it is
adequately tested and considered for risk. The release
management process must, as much as practical, adhere to
scheduled releases that are tested as much as is practical and
include risk-reduction measures. As discussed in the preceding
paragraphs, emergency releases incur risk and should be
avoided as much as is possible.

Exception Management
No matter how standardized security controls are, there are
always exceptions, and you need to have a process in place to
manage those exceptions and keep them minimized. Consider
the example in the previous section where an operating system
patch cannot be applied because of a legacy application that is
critical to the organization’s mission. This mitigation is
important, but less important than the legacy application and
its associated mission. Exception management, as mentioned
earlier, comes into play here; you should evaluate the risk of
implementing the patch and breaking the application, thus
putting the organization’s mission in jeopardy, versus the risk
of not implementing the patch and dealing with the security
ramifications that come with that decision. Management will
have to make a decision regarding which is the riskier choice.
If the choice is to make an exception and not implement the
patch, you need to document this as an accepted exception to
the policy and track it, usually in the risk register. Perhaps the
patch can be implemented in the future, or another mitigation
could come along and make the exception moot. This is
another aspect of risk acceptance; you are asking management
to accept an ongoing risk, as an exception, because the
response cannot be implemented for whatever reason. Either
way, keeping a close eye on the issue is key to not letting these
exceptions slip through the cracks.
Regardless of where issues, security findings, and
exceptions to normal processes, policies, or baselines occur,
these departures should be avoided as much as possible, and
when they cannot be avoided, they must be carefully
considered, with great care taken to reduce the risks they
present.

Management of Emerging Risk


Risk is not static; it is constantly changing. The dynamic
nature of risk means that it must be constantly monitored,
reassessed, and reevaluated, and risk responses will often need
to change as risk changes. The components of risk, including
threats and vulnerabilities, also change. The organization itself
changes, as it is restructured, as its mission and goals change
over time, as its place in the marketplace evolves, and of
course as its risk appetite and tolerance change. Technologies
also change, and organizations sometimes are in a hurry to
adopt the latest and greatest technology because it becomes
convinced that there is a need to do so; sometimes that need is
indeed valid, but sometimes the technology marketing
machine convinces an organization it has a need where before
it did not. Emerging technologies, and their associated threats,
vulnerabilities, risks, and, by extension, risk responses, must
be constantly evaluated.

Emerging Technologies
New or emerging technologies can present risks to
organizations simply because there are several different
important considerations when integrating the latest
technologies into the existing infrastructure. Many
organizations have an unfortunate tendency to rush out, buy,
and attempt to implement the latest (and often unproven)
technologies on the market, without careful planning or
consideration of the existing infrastructure and how it will
react to the new technologies. One of the primary
considerations organizations must look at is making a business
case for a new technology, which may be to fill a gap that the
older technology does not provide or to provide a capability
that the organization must now have to compete in the market
space. In other words, the company really must justify new
technologies to make them worth the risk they could incur.
At the opposite end of the spectrum, many companies are
averse to investing a great number of resources in new
technologies, instead relying on older, tried-and-true
technologies that have always worked in the past. These
organizations fail to consider the changing threat landscape,
and sometimes the need for maintaining a cutting edge in the
marketplace. The threat landscape can render older
technologies obsolete and ineffective in protecting the
company’s information assets. The market a particular
organization participates in can also drive the need to update
its older technologies to those that make it able to produce
goods and services faster, more efficiently, and to better meet
the needs of its customers.
In any event, emerging technologies present challenges to
organizations that must be considered. These challenges
include the emerging risk factors, vulnerabilities, and threats
that go along with those technologies. We will discuss those in
the next few sections.

Emerging Risk Factors


Emerging technologies have several risk factors inherent to
their integration into the existing infrastructure. If the
organization has been able to justify the implementation based
on a true business need for the emerging technology, it must
consider several risk factors. One of the major risk factors is
interoperability with existing infrastructure. Frequently, newer
technologies don’t work properly with older systems right out
of the box; adjustments might need to be made to the existing
infrastructure to integrate the new technology, or bridging
technologies may be needed to connect the two.
Interoperability doesn’t just involve the right connections; it
can involve data formats and flows, security methods, and
interfaces into other systems. These considerations, and many
others, are risk factors that must be considered before
acquiring and integrating new technologies.
Another risk factor is security. New technologies may have
security mechanisms that are not necessarily backward
compatible with existing ones. Examples include encryption
algorithms and strengths, identification and authentication
technologies, integrity mechanisms, and even redundant or
backup systems. Additionally, the systems may involve a
learning curve that might intimidate users who must now learn
new security methods for the system. The human factor can be
a weak link in the security chain, so either a lack of training or
a lack of adaptability to the new security mechanisms can
introduce risk.
Additionally, system updates and changes can be risky if
not managed properly. Integrating new technologies into the
environment with older ones can introduce both intentional
and unintended changes into the environment, affecting the
stability of the organization’s implementation, operations, and
maintenance of a particular system, so change is also a risk
factor. Even in the disposal or replacement phase of a system’s
life cycle, introducing new technologies to replace older ones
can be problematic if not planned and executed properly. New
technologies that are not adequately tested for functionality,
performance, integration, interoperability, and security may
not be able to adequately replace older systems, resulting in
extended costs and possibly even requiring the extension of
the older systems’ life cycle.

Emerging Threats
Threats resulting from the introduction of new and emerging
technologies into the existing infrastructure are numerous. If
the organization has failed to adequately plan for the new
technology, these threats can become significant. These
include untested or unproven technologies, non-
interoperability, incompatible security mechanisms, and lack
of suitability of the technology for use in the organization. The
organization could also incur additional cost and require more
resources because of a faulty implementation. These threats
can be minimized by careful planning and integrating new
technologies using a stable systems development life cycle
(SDLC) model.
Additionally, organizations should implement both threat
modeling and threat hunting processes into their security
program when new technologies are considered. Threat
modeling and threat hunting can help an organization identify
not only the generic threats that affect all organizations, but
those specific to its own business model, processes, assets,
vulnerabilities, and risk scenarios involving the new
technology.

Emerging Vulnerabilities
As with threats, vulnerabilities that go along with working
with emerging technologies are numerous as well. General
vulnerabilities could include a lack of trained staff committed
to managing and implementing the new technology. Lack of
adequate project planning is also a serious vulnerability that
could affect the organization’s ability to effectively integrate
new technologies. Another vulnerability could be a weak
support contract or other type of warranty, guarantee, or
support for a new technology or system. Most of these
vulnerabilities appear when new technologies are first
implemented and tend to become mitigated or lessened as the
technologies are integrated into the existing infrastructure, but
they still exist.
Beyond general vulnerabilities, new technologies also have
their own inherent technical vulnerabilities. Often these
vulnerabilities are not discovered until long after a technology
has been implemented. Although vendors are increasingly
security conscious in implementing and designing
technologies from a secure perspective, zero-day
vulnerabilities are often discovered months or even years after
those technologies are installed and operational.
To make matters more challenging, some vulnerabilities are
not detectable by vulnerability management tools. They are
only detailed by the vendor, and only if they happen to detail
them. In some situations, this makes monitoring the updates
for the applications all the more relevant to ensure, including
in the vulnerability management process.
When implementing a new technology, organizations
should make an extra effort toward vulnerability scanning and
assessment, and they should pay particular attention to new
vulnerabilities, even those that seem unrelated to the new
technology. Often these vulnerabilities could be indirectly
related and appear because of interoperability or integration
issues with the infrastructure.
In some cases, it may make sense to perform other types of
validations against new technology—especially if there are
additional risk factors such as large amounts of sensitive data.
Validations may include but are not limited to penetration
testing, secure configuration reviews, and application security
testing.
EXAM TIP The key areas of concern with emerging
technologies are interoperability and compatibility. These two
concerns affect the security, functionality, and performance of
the new technologies when they are installed into an existing
infrastructure.

Control Design and


Implementation
A control is a measure or safeguard put into place to protect
organizational assets (including systems, equipment, data,
facilities, processes, and even people), ensure compliance with
laws and regulations or other governance requirements, and
reduce overall risk to the organization and its assets. Controls
can help improve the overall security posture of your
organization through correcting a gap or making up for a
shortfall in another control. Controls can be technical
solutions, such as firewalls or intrusion detection systems, but
they can also be processes, procedures, policies, or physical
controls.
In this part of the chapter we will discuss the various types
and functions of controls as well as different control
frameworks that can help an organization secure its assets. We
will also discuss how an organization can design, select, and
analyze its controls for effectiveness. Additionally, we will
cover the particulars of implementing controls as well as
control testing. So, how do you determine which controls to
apply to your system or whether your existing controls are
good enough? We will discuss this in more depth in the
following sections.

Control Types and Functions


As you may have gathered by now, there are many types of
controls to choose from. However, you can generally group
these controls into a number of broad categories by their
intended type and also by their function. Depending on which
control framework you read, or which cybersecurity or risk
expert you are talking to, these controls may be referred to
differently, as some standards categorize them in different
ways. However, for our purposes and for the CRISC exam,
you need to understand three main types of controls:
administrative (also sometimes referred to as managerial),
technical (sometimes called logical), and physical (also called
operational) controls. The following are examples of each.
Administrative (Managerial)
• Requiring an acceptable use policy to dictate IT usage
within the organization
• Starting a risk management program to identify, lower,
and monitor unacceptable risk levels within the
organization
• Implementing additional policies and procedures within
the organization to support external governance and the
desires of management
Technical (Logical)
• Implementing additional firewalls to protect internal
(non-public-facing) systems
• Adding 802.1X port-based network access control to
deter unapproved assets being added to the network
• Installing an intrusion detection system/intrusion
prevention system (IDS/IPS) to monitor for malicious
activities or violations of policy
Physical (Operational)
• Implementing physical intrusion detection and alarm
systems throughout the facility
• Deploying a human-based guard force to patrol
sensitive areas
• Construction of fencing, bollards, and other physical
obstacles to prevent unauthorized entry into an
organization’s campus
Controls are also categorized by function—that is, what
purpose they serve and how they work. The most common
control functions are deterrent, preventive, detective,
corrective, and compensating. Table 3-1 lists each control type
function, its definition, and an example of the control.

Table 3-1 Control Functions and Descriptions

EXAM TIP Controls may be categorized by function, which


includes preventative, deterrent, detective, corrective, and
compensating controls. Often, controls can serve more than
one function simultaneously, and it may be difficult to
completely categorize them as one particular function or
another.
Note that different control functions can fall within all three
control types; there are deterrent, preventative, detective,
corrective, and compensating controls that are technical,
administrative, or physical. You will also notice some
significant overlap between these types and functions. For
example, video surveillance can be a deterrent control as well
as a detective control. Also, since some experts do not
distinguish between, for example, deterrent controls and
preventative controls, it is important to point out their
difference here.
A deterrent control must be known by an individual or
entity in order for it to be effective since it dissuades them
from committing a policy violation or an illegal act. For
example, a video surveillance camera can be a deterrent
control—if a person sees it in operation, they are less likely to
commit a malicious act because they know they are being
viewed and recorded. This deters them from that act. A
preventative control, on the other hand, does not have to be
known by an individual for it to be effective. An example of
this would be a firewall rule that prevents a user from surfing
to a malicious site. The user doesn’t have to know that the
firewall rule exists in order for it to still be effective and
prevent them from committing this policy violation.
Another difference worth pointing out is the one between
corrective and compensating controls. As indicated in Table 3-
1, compensating controls are implemented to take the place of
a more desired or primary control, which can’t be
implemented for various legitimate business reasons (for
example, lack of resources). Even if the primary control can’t
be implemented, the risk must still be reduced, so a control (or
sometimes multiple controls) is implemented in its place.
Compensating controls are longer-term controls, which are not
likely to be changed anytime in the immediate future.
Corrective controls, however, are temporary, short-term
duration controls. They are designed to correct an immediate
security issue. For example, let’s say that a storm comes
through your area and destroys a section of strong concrete
wall surrounding your facility. Now there is a huge hole in the
perimeter, which could allow an unauthorized person to enter
at the facility grounds. To immediately mitigate this risk, you
may post a guard to patrol that particular area for a few days
until you can come up with something better. Obviously,
keeping a guard there on a long-term basis is not wise
financially or from a resource usage perspective. After a few
days, you might be able to fix the wall, if possible, which
restores the primary control to its operational state. If for some
reason that portion of the wall can’t be fixed, however, you
may install temporary fencing or another physical obstruction
in its place, and supplement it with surveillance cameras, an
intrusion detection system, and additional alarms so that it
would reduce the risk of an intruder entering the area, without
having to keep a guard there all the time. These might be
considered compensating controls since the primary control
(the strong concrete wall) can’t be immediately addressed.
As mentioned previously, control types and functions can
overlap. They can also complement each other. For a given
administrative control (for example, a policy that dictates that
all sensitive data must be encrypted), there is usually a
technical control, such as the encryption mechanism, and
possibly even a physical control, such as hardware encryption
devices being locked in a secure area, to back it up. Again, it
should be pointed out that the various standards and
frameworks, which we’ll discuss in a moment, often
categorized these types and functions of controls differently,
so don’t be surprised if sometimes you see them referred to in
a different manner.

NOTE Some professionals, texts, and frameworks also


include recovery controls as a control function. These controls
could include safeguards such as backups, redundant systems,
and so on. While you likely won’t see this control function
called out on the CRISC exam, simply be aware that
sometimes you will see other control functions, as well as
other control types, such as operational controls, in other
contexts.
Figure 3-1 summarizes some of the key characteristics of
controls and their implementation, with regard to types and
functions. Note that, as depicted in the figure, controls that are
designed to prevent a malicious act or policy violation are
generally known as safeguards, whereas controls that come
into play after a violation has occurred, and must be used to
respond to the event, are called countermeasures.

Figure 3-1 Control characteristics and their implementation

Control Standards and Frameworks


Control standards and frameworks are defined sets of controls
that can be used in a given set of circumstances, market, or
area. Controls are often tied to governance directives and
regulations, but this isn’t always the case. Sometimes different
regulations or even process frameworks reference controls
only to the extent that a control framework is required, but not
to specify which control standard must be used. The Health
Insurance Portability and Accountability Act (HIPAA) is good
example of this scenario because HIPAA requires security and
risk controls, but it does not specify which control set must be
used (although HIPAA guidance does recommend the NIST
control catalog). As another example, while references to
controls are specifically called out in the ISACA Risk IT
Framework (RR 2.1, “Inventory Controls,” and RR 2.4,
“Implement Controls”), the framework itself does not give any
clear guidance on how controls are defined, selected, or
implemented; however, the assumption is that implementing
the framework will show you how to use and evaluate
whichever control set you choose. The NIST Risk
Management Framework (RMF), in contrast, does provide
guidance on how its controls are constructed, used, and
assessed, devoting several publications to this subject.
Specific industry or market environments may require the
use of specific, context-related controls, as indicated in Table
3-2.

Table 3-2 Examples of Areas Requiring Control Standards


Controls in a given framework are often organized
according to a particular area or context, usually by
functionality or relevance. For instance, the CIS and NIST
control standards (discussed shortly) are broken down into
areas, or families, which are categories that apply to a specific
context. As an example, the NIST Physical and Environmental
Protection (PE) controls address physical and environmental
concerns such as physical access control and environmental
factors (lighting, humidity, and temperature), whereas the
NIST Program Management (PM) control family addresses
management processes that often appear as administrative
controls, such as formally appointing a responsible
information security officer. Most other control frameworks
discussed in this chapter similarly categorize controls, usually
by process area or other relevant aspect of context.

TIP You’ll find that most control libraries similarly group


controls into specific categories based on function or context,
and most use specific identifiers for each control.
Which controls from the various frameworks are used by an
organization depends on several factors, including governance,
market segment or area, level of regulation, and internal
factors such as risk tolerance, risk appetite, and maturity of the
risk management processes. We cover more of how controls
are selected, designed, implemented, and used later in this
chapter and in the other chapters, but suffice it to say for now
that controls are usually developed and applied to specific risk
scenarios. These risk scenarios are developed by the
organization or industry as part of their risk identification
process. They describe threats, threat actors, events, time, and
other circumstances, but of course control assignment and use
may be required by legal or regulatory governance, as well as
the needs of the organization that intends to employ them. It’s
also fairly common for an organization to use more than one
control set or framework because it may apply differently to
various aspects of the business or mission areas in an
organization. For example, a hospital may use NIST controls
for some areas but may also be required to use PCI DSS
controls since it may process payments from credit cards as
patients pay for medical services. Oftentimes, controls from
more than one source are applied against one or more areas of
the business.
In examining the various control frameworks, you’ll also
find that there are many similarities between controls in some
instances; often a control in one framework has a close
equivalent in another framework. For example, CIS Control
10, “Malware Defenses,” loosely maps to the corresponding
NIST control, SI-3, “Malicious Code Protection,” but
describes a more generic process than the equivalent NIST
control. There will also be controls that have no matching
control or even context in another framework; these are often
controls that deal with specific instances of risk or security
requirements unique to a particular environment.

NOTE Most control catalogs have controls that can be easily


mapped to controls in other catalogs, although in some cases,
this mapping may be imprecise, may not be as detailed, or may
even map to multiple controls in another control library.

Control Frameworks
Now that we’ve covered some generalities about controls, it’s
time to look at various control frameworks you might use in
your professional career. Keep in mind that some control
frameworks go into more depth than others on their controls;
some controls in a given framework may treat a particular
subject area lightly, whereas others may go into detail on a
particular subject area. Also keep in mind that some control
frameworks are geared toward specific environments or areas,
and not all frameworks are necessarily geared toward security
specifically; some frameworks apply to a broad general
business or risk management area but may have security
controls built into them for specific needs or direct security
actions from a higher level. Not all control frameworks are
technical in nature either; some frameworks apply to security
and risk from a business process perspective rather than a
technical perspective. Some control frameworks are privacy
oriented and provide a different set of controls. The control
frameworks described in the following sections are just some
of the more popular ones you may encounter in your
professional career as a risk practitioner.
NIST The U.S. Department of Commerce’s National Institute
of Standards and Technology (NIST) has produced several
documents—some of which we have already mentioned—that
relate to risk management. The entire Risk Management
Framework (RMF), and all of its different components, spans
several documents. We’re not going to provide a
comprehensive review of the framework and its related
documents here, but we will examine a particular piece of the
framework: the controls catalog. NIST Special Publication
(SP) 800-53, revision 5, “Security and Privacy Controls for
Information Systems and Organizations,” is the control catalog
supporting NIST’s RMF. The NIST controls are a
comprehensive set of security measures and processes
intended to mitigate and reduce risk from an IT security
perspective. The NIST control catalog is divided up into 20
separate control groups, called families, each related to a
particular aspect of IT security.
The NIST control families span a great deal of subject
areas. Each family has several controls in it; there are smaller
families (such as the Awareness and Training family) that may
have as few as six controls, but there are others that have many
different controls that go into great detail on security
measures. An example is the System and Communications
Protection (SC) family, with 51 controls.

EXAM TIP You will likely not be tested on any specific


NIST controls; however, it’s a good idea to have this
knowledge in order to differentiate among the different control
frameworks you may see on the exam, as well as for real life.
PCI DSS The Payment Card Industry Data Security Standard
(PCI DSS) is a set of security requirements levied on
merchants that process credit card transactions. The standard
was developed jointly by the major payment card industry
players, including Discover, Visa, MasterCard, and American
Express. The standard was developed in an effort to impose
security requirements and controls on retailers (merchants and
service providers) to reduce credit card fraud and identity
theft. Note that PCI DSS is not a law; rather, it is an effort by
the credit card industry to self-regulate. Although not a law, it
does have the effect of being mandatory in terms of
governance requirements; retailers must comply with PCI DSS
to be allowed to process credit cards from the major industry
brands. A few U.S. states, however, have codified into their
laws the use of PCI DSS standards.
The PCI DSS (currently in version 3.2.1 as of this writing)
is a set of six control objectives, broken down into 12 major
requirements, which are further broken down into sub-
requirements. Table 3-3 lists the basic PCI DSS requirements.

Table 3-3 PCI DSS Control Objectives and Requirements


On the surface, these objectives and requirements don’t
seem to go into much depth. Understand, however, that PCI
DSS further decomposes the requirements into detailed
processes and procedures. The standard also provides
guidance for testing at the control level. For example,
requirement 5, “Protect all systems against malware and
regularly update antivirus software or programs,” breaks down
into four sub-requirements, some of which break down even
further. Requirement 5.1.2, continuing the example, specifies
continuous monitoring and evaluation of hosts for malware
threats. Overall, there are actually more than 200 sub-
requirements, which are the equivalent of controls.

EXAM TIP You likely won’t be asked any PCI DSS


control–specific questions on the exam, but you should keep in
mind its applicability to merchants and retailers that process
credit card transactions. You can find more detailed
information on the PCI DSS standards at the website of the
PCI Security Standards Council at
https://www.pcisecuritystandards.org/security_standards/.
CIS Controls The Center for Internet Security (CIS) publishes
18 critical security controls, which are essentially areas or
families that decompose into 153 individual safeguards,
spanning three implementation groups. These 18 areas are
similar to other control sets in that they cover areas of
common security concern, including malware, penetration
testing, inventory of software assets, account management,
access control, and so on. The three Implementation Groups
(IGs) are designed to provide a path for progressively
implementing safeguards, with prioritization and scalability in
mind, to help smaller organizations, or those that have limited
resources, implement a minimum of 56 core security controls
that are absolutely necessary to secure systems and data.
The CIS controls were formally known as the SANS Top
20 Critical Security Controls, before the CIS took
responsibility for them in 2015. They were originally
developed by an effort led by the National Security Agency
(NSA) and many other government and industry partners. The
most current version of the CIS controls is version 8,
published in May 2021.
ISO/IEC 27001 Although we’ve primarily discussed different
control sets that originate in the United States (such as PCI
DSS and NIST), most of the various control frameworks map
to, and in some cases originate from, standards used
worldwide and developed by internationally respected
governing bodies. In Chapter 1, we briefly mentioned some of
these standards, including those from ISO and IEC. The ISO
and IEC produce information technology standards used
internationally, including several that apply to information
security and risk management. You may see individual
standards prepared by each of these organizations, but you
may also see combined standards, usually indicated as
ISO/IEC for those standards that are jointly developed. We
discussed standards that applied more specifically to risk
assessments in Chapter 1, but there are also ISO/IEC standards
that are essentially control requirements. Two examples are
ISO/IEC 27001:2013, “Information technology – Security
techniques – Information security management systems –
Requirements,” and its companion guide, ISO/IEC
27002:2022, “Information security, cybersecurity and privacy
protection – Information security controls.” These two
standards, like the ones discussed previously, break down their
controls into different areas or categories and include areas
such as information security policies, human resource security,
asset management, access control, cryptography, and so on.
Since the ISO/IEC 27001 and 27002 standards are developed
by an international standards organization, they can be used
across the globe.
As mentioned earlier, most of the control standards we have
discussed have built-in mappings to help facilitate their
implementation where organizations may have multiple
governance requirements to which they are required to adhere.
Both the NIST and CIS controls have mappings to the
ISO/IEC standards, for example. In examining these control
mappings, a couple points should stand out. First, there’s not
necessarily a straight one-to-one mapping of controls. In some
cases, the requirements for a given control in a control set may
map to one, many, or even none of the other control set’s
controls. Second, controls tend to follow similar patterns and
requirements, such as acceptable use, password requirements,
media and storage, encryption, and so on. Most controls from
the various control sets have these commonalities because all
of them in some way trace back to the three goals of security
(confidentiality, integrity, and availability) as well as the
supporting elements of identification, authentication, and
authorization. This is generally true regardless of which
security control framework you examine.

NOTE You’ll find that many control frameworks are derived


from and map to the ISO/IEC standards. They are international
standards and can be applied across most industries and
market spaces.

Control Design, Selection, and Analysis


The importance of designing, selecting, maintaining, and
monitoring the right controls cannot be understated.
Remember that controls serve three primary purposes:
protecting assets, ensuring compliance, and reducing risk. If
controls are not adequately planned for and implemented, they
will fail to meet any or all three of these purposes. In the next
few sections of this chapter, we will discuss the critical
elements of control design, selection, and analysis.

Control Design
Controls are designed and applied to a system, data, process,
or even organizational element to address a weakness or
vulnerability or to counter a specific threat. Often, controls are
designed to address a specific risk response strategy, such as
risk reduction/mitigation, sharing, avoidance, and acceptance.
Controls are applied to reduce the impact and likelihood
elements of risk, as follows:
• Reduce the likelihood of a threat agent initiating a threat
(deterrence, preventative, and detection controls are
examples).
• Reduce the likelihood of a threat exploiting a
vulnerability (preventative and detection controls).
• Reduce the impact to the organization or asset if a threat
exploits a vulnerability (corrective, compensating, and
recovery controls).
• Reduce the vulnerability (deterrent, preventative,
corrective, and compensating controls all could perform
this action).
Note that none of the scenarios listed earlier describes a
case where a control prevents a threat or a threat actor. Threats
and threat actors exist, and controls can’t really prevent their
existence. Controls can, however, affect how they interact with
vulnerabilities and assets. Also note that all these strategies
may be pursued simultaneously in the case of controls that are
well designed and effective, using the concept of economy of
scale and multiple use of controls.

EXAM TIP Remember that controls can affect the


likelihood or impact of risk elements only by reducing
vulnerabilities or protecting assets. They cannot eliminate or
reduce threats or threat actors; they only serve to reduce the
likelihood or impact resulting from an attempted or successful
exploitation of a vulnerability by a threat.

Control Selection
When an organization selects controls to be applied to protect
systems and minimize risk, several considerations come to
mind. First, the organization should look at its governance
requirements and ensure that its controls meet those
requirements, particularly where specific data protection
requirements are indicated. This may include level of
performance or function of a control (encryption strength, for
instance). The organization also has to look at its existing
infrastructure. It is likely to already have some level of
controls in place, although the controls might not be applied
directly to the system in question. Take, for example, an
organization that has industrial control systems and other types
of operational technologies present. Many of these devices
cannot support basic security measures, such as authentication
or encryption; however, as compensating controls, the
organization could implement network segmentation by
putting them in their own physically or logically separated
subnets and install authentication and encryption mechanisms
specifically for those devices, since they do not have their own
built-in capabilities. If there are existing controls that can
already fulfill the requirements for a control, those should be
used to the maximum extent possible.
Second, controls should be selected also based on their
level of effectiveness, as indicated by the design parameters
we discussed earlier. A control that is minimally effective, and
perhaps meets governance requirements, may still not be
desirable if it does not provide the level of security the
organization needs. Effectiveness also may mean how good
the control is at reducing risk or ensuring compliance. If either
of these levels of functionality or performance are not met by
the control, the organization should consider strengthening or
changing the control.
Third, cost is also an issue with control selection. A control
that costs $10,000 to implement but only protects a single
system that is valued at $2000 is not cost-effective. However,
a control that costs $10,000 and protects several systems, even
if individually they are not high-value systems, but
collectively generate $100,000 in revenue for the organization
per year, is likely more cost-effective. Control selection with
regard to cost should include the cost of the control as well as
the cost to maintain it. This includes spare parts and
components, service contracts, and the cost of qualified
personnel to maintain the control. This is where quantitative
data elements, such as asset value (AV), exposure factor (EF),
single loss expectancy (SLE), and annualized loss expectancy
(ALE), which you learned about in earlier chapters, come into
play, since they affect whether a control is worth it financially
to implement.
Ultimately, security and risk practitioners recommend
controls based on their effectiveness and cost to management,
who must make the decision regarding their implementation. If
the desired controls cannot be implemented, for whatever
reason, both the practitioners and management must consider
selecting appropriate compensating controls, which must be
approved and documented.

Control Analysis
Controls are analyzed at several different points in their life
cycle. They are looked at to ensure they fulfill their basic
functions of asset protection, compliance with governance, and
risk reduction. They’re examined for not only effectiveness
(how well they do their job) but also efficiency (meaning that
they do their job with as little additional effort, resources, and
management as possible). Even if a control is performing its
job functions wonderfully, if the cost to maintain it is
prohibitive, the organization may need to look at changing the
control or its implementation in some fashion.
The most common way to analyze controls is through
controls assessment, where controls are evaluated for their
effectiveness. A control can be evaluated using various
methods, such as interviewing key personnel responsible for
managing and maintaining the control, reviewing the
documentation associated with the control, observing the
control in action, and testing the control through technical
means. These different assessment methods will give a risk
practitioner an idea of how effective the control is in meeting
its primary functions.
Risk assessments for the specific system under review, as
well as the entire organization, will also indicate how well a
control is performing its function. Even if a risk practitioner is
not examining a particular control, levels of increased or
decreased risk for the system itself or the entire organization
would indicate whether or not one or more controls are
effective. Historical and trend analysis methods tell a risk
practitioner how risk has changed over time. They also help
the practitioner predict how risk will change, given changes in
the environment, technology, the threat landscape, and how
effective the control will be. If risk has increased inexplicably,
the practitioner must analyze the different controls designed
and implemented to mitigate that risk.
After controls have been tested and analyzed, results from
those analyses should be recorded on the overall risk register,
particularly with regard to risk the control is supposed to
mitigate. Obviously, management must be informed of any
changes in risk caused by control effectiveness issues.

Control Implementation
Controls aren’t simply installed in infrastructures, even in the
event there is urgency to do so. As we have previously
discussed, some planning goes into control implementation.
Most of this planning focuses on determining the effectiveness
of the control and ensuring it is designed to protect assets,
assist in compliance, and reduce risk. There are also other
considerations when implementing controls, including the
change management process, configuration management, and
testing.

Change and Configuration Management


Change and configuration management processes are critical
during control implementation because, in actuality,
implementing new controls is a change that occurs in the
infrastructure and must therefore be part of the formal change
control process. This involves requesting the change and
presenting a justification as to why it is necessary. In this case,
the change is necessary to fill a gap or need that an existing
control (or the absence of a control) does not fill. Compliance
may also drive the need for the change, since governance may
require that the control be implemented. Risk reduction is also
valid justification for implementing a control in the change
management process. Once the change is requested as part of
the formal process, it is reviewed by the change control board
and approved or returned for amendments to the request. After
it has been approved, it must go through the testing process.
Once it clears the implementation testing process, discussed in
the next section, the change is formally approved and
implemented. If, for some reason, it does not pass the different
types of tests it must go through before implementation, the
change is returned to the requester so that any test failures can
be addressed.
Control implementations may go through different types of
implementation strategies, such as parallel installation and
implementation with like systems, a gradual update to the
system, a phased implementation, or even a clean cut-over
with the system using the new controls. Since the installation
may incur unacceptable downtime for critical systems, this
must be carefully considered. The organization must decide
the appropriate strategy, based on its resiliency, system and
data criticality, and tolerance for any risks that always come
with implementing a significant change in the infrastructure.

Implementation Testing
Although controls undergo testing at various points in their life
cycle, testing before implementation is critical because often it
is difficult to go back to a previous control or a point in time
before the control is implemented. This is especially true if the
infrastructure is significantly altered to accommodate the new
control. Consider a network infrastructure that has a new
firewall or other network security device installed. The
network may have to be rerouted and reconfigured and new
rules configured on the network security device. If for some
reason it is installed without testing and then fails, it may
cause serious impact to business operations if users cannot use
the network, get on the Internet, or otherwise are unable to
perform their duties.
Several types of implementation testing should occur on
new controls before they are implemented. One of the first is
interoperability testing. Interoperability is critical since the
new control must work with existing technologies and
infrastructure. If for some reason they do not work together,
this can cause work stoppages or outages and will impact
business operations. A risk analysis conducted before
implementing a new control should take this into account, and
the organization should be reasonably informed about how the
new technology or control will interact with the existing
infrastructure before it is tested and implemented. Another
type of testing involves testing security mechanisms that are
inherent to the new control, such as authentication and
encryption mechanisms. Not only should they be interoperable
with existing infrastructure, but they should also be tested for
function and performance as well as compliance with any
governance. It would not do to install a security control that
has legacy authentication or encryption mechanisms that do
not meet governance requirements, for example, and therefore
fails to protect systems and data.
Testing a control, especially a complex one, before
implementation ensures that it is interoperable, satisfies
technical requirements, meets governance requirements, and
performs and functions as it should. Understanding the
limitations and operating parameters of a complex control
through testing before implementation is in itself a method of
risk reduction.

Other Implementation Considerations


It goes without saying that implementation of a complex
control has many more aspects to it than are discussed here.
Some of these are resource considerations, such as having
enough money in the budget, having enough qualified people
to install, manage, and monitor the control, not to mention
political considerations within the organization. Consider the
implementation of a relatively “easy” control, such as
revoking administrative rights on user workstations. Not only
will users typically revolt, but managers who are used to
having administrative rights over their own workstations will
complain and likely go to upper management, who may cave
in to those complaints, effectively rendering the control
useless. Users also typically balk at having their systems
offline for any amount of time since it may interrupt their
work. All these issues should all be carefully considered and
decided upon by management, or at the very least kept in mind
by the risk practitioner.
Another aspect of control implementation is
documentation. All steps of the implementation should be
thoroughly documented, as well as any exception items, such
as configuration or interoperability issues that may need to be
addressed later. Documentation also includes policies and
procedures to support the control, change management
records, implementation test results, operator training
materials, schedules for maintenance, and any other
information relevant to the control.

Control Testing and Effectiveness


Evaluation
Control testing and evaluation, as well as analysis, were
discussed earlier in the chapter, but they bear repeating here.
Controls must be tested and evaluated not only prior to
implementation, but also at various points during their life
cycle. Controls should be tested and assessed as part of routine
risk assessments, controls testing, vulnerability and
penetration testing, and so on. Controls are tested not only for
their effectiveness in protecting assets, but also their
compliance with governance and their ability to reduce risk to
acceptable levels. Remember that earlier we discussed four
methods for testing a control:
• Interviews with key personnel, such as operators,
security analysts, engineers, and even managers
• Observation of the control in operation to ensure it does
what it is supposed to do
• Review of any documentation supporting the control,
such as policies, procedures, maintenance records,
architectural diagrams, exceptions, and so on
• Technical testing, such as that conducted during
vulnerability assessments and penetration testing
All of these different types of tests are critical in getting the
complete picture of how well a control is functioning and
performing. The results of control testing should be
documented and reported on in various circumstances as part
of different assessments and tests.
Controls that fail testing or do not perform or function as
expected should be further evaluated in more detail for any
possible changes and any additional increase in risk. A control
may need to be reinstalled, replaced, or upgraded, or
compensating controls may need to be added to strengthen the
function the control is meant to perform.

Risk Monitoring and Reporting


What are the reporting requirements for your organization?
Are they dictated by government regulations, international
business partnerships, or other binding agreements?
Understanding what is required of your organization in terms
of reporting risk is absolutely critical in fulfilling governance
requirements, whether they are imposed by external sources,
such as laws and regulations, or by internal governance, such
as policies published by executive management. You also need
to understand what you should report in any of these contexts.
For example, it is a good idea to report any ongoing risk issues
you have, the status of any ongoing remediation actions, how
your controls are performing, any incidents, and how your
overall risk response activities are performing.
Along with understanding the organization’s risk
environment, it is important to understand your stakeholders
and what their reporting needs are. For example, your board of
directors will likely want a high-level, quarterly presentation
on compliance levels relative to the previously discussed risk
and control environment, as well as security performance
relative to business goals and objectives. Business process
owners, conversely, may want a much more detailed report
about the individual risks identified previously, the new risks
that could potentially come to the forefront, and how different
business units are supporting the risk management program
across the entire organization. It’s important that you
understand how these different stakeholders need different
reporting mechanisms and tools and that you identify clearly
how they expect you to support them through timely and
relevant risk reporting.
When reporting, you can include a few standard items, such
as measured control effectiveness (which can be rolled up to a
higher level, as necessary, for management), any ongoing
issues, any perceived gaps, the status of any remediation
actions, any incidents or risk events that have occurred since
the last report, and the overall trending status of the
effectiveness of the risk management process. Also, identify
ahead of time whether your report will be included as an input
to a greater enterprise report and work to include any
appropriate information needed to facilitate that enterprise-
level view. This will help garner support for the risk program
supporting the business goals and objectives.
You should review the results of any third-party analysis or
audit that has taken place and incorporate the findings into
your understanding of the organization’s risk posture. Has
your organization conducted any type of internal audit or self-
assessment? These will be important to review to see how they
affect the risk profile and where they will need to be included.
We’ve discussed the organization’s tolerance for risk in many
places throughout this book, so suffice it to say that the risk
tolerance should be considered throughout the reporting
process as a key input.
In the end, in order to develop a report that is valuable to
management, a risk professional needs to make sure they have
a clear understanding of the exposures their organization faces,
the active mitigations for those exposures, and the indicators
being used to measure the success or failure of the
organization’s implemented control set, as well as the current
risk posture as measured against the risk appetite. This all
needs to be communicated to the stakeholders. The importance
of articulating risk should not be underestimated; this is a
critical task that ensures management receives accurate and
unbiased information that is both actionable and supports the
overall organizational risk strategy.
Responsible reporting involves helping leadership
understand the risks to the organization and how critical it is to
support its reduction through implementing appropriate
controls, as well as monitoring and managing risk. This needs
to be done in the most clear and concise manner possible,
understanding the concepts of risk, the indicators that have
been chosen, and the current statuses that allow leadership to
make the best-informed decisions possible. Without the best
possible information, we cannot expect organizational
leadership to make informed decisions. You will also need to
interpret technical findings and perhaps portray information in
a manner that is less technical and more business-focused. By
doing this, you will not only make the point that the risk
program is useful, worthwhile, and supports business goals
and objectives, but you will also identify opportunities for the
risk program (and associated reporting) to integrate throughout
the enterprise more cleanly.
No communication is complete without thoroughly
understanding and depicting both the worst-case and most
probable scenarios involved with a risk event. A risk event
could mean many potential losses take place, and not only
those affecting the company’s financial bottom line. There
could be losses to the company’s goodwill, including any
associated brands. Think about major security breaches in
previous years, such as Target, T.J. Maxx, and Sony. The result
of their losses was both tangible (financial) and intangible
(brands associated with a major breach), which is difficult to
quantify. This is also the time to include any other information
pertinent to supporting the recommendations you’ve made,
such as situations where a financial gain could be made
(through exploiting an opportunity), or any outlying legal or
regulatory concerns you might have.

Risk Treatment Plans


While reporting may at first seem to be only an occasional
aspect of risk management, it actually takes place on a
continual basis. Obviously, risk assessments, control
assessments, and different types of tests have their own
reporting requirements that will be accomplished when those
test events are completed. However, reporting can also take
place as continual information is sent to management on a
regular basis.
Some of the most critical pieces of information that should
be reported to management, regardless of a point-in-time test
event, are risk response and treatment options and any plans
used to implement those options. Management should always
have the opportunity to review risk treatment options as they
are developed, and risk practitioners have a responsibility to
make those recommendations formally to management so that
leadership can make the appropriate decisions regarding those
particular treatment options. Understand that simply because a
risk practitioner recommends specific treatments or responses,
this does not necessarily mean that management will approve
those options. Alternative risk treatment responses may be
approved instead, based on information the risk practitioner
doesn’t necessarily have or the priorities of management. This
is particularly true when risk treatment options are expensive
and management is seeking to reduce cost, but balance that
with effective risk response at the same time. It is also true if
management needs to make a broader decision, such as one
that may involve risk avoidance, for example, by taking an
entirely different strategic path within the business. When
reporting on risk treatment options, you should always present
the best recommendation, but also always have alternatives
developed for management to consider. In any event, it’s
important to convey risk treatment options, as well as their
progress, to management on a continual basis, not merely after
they have been implemented.

Data Collection, Aggregation, Analysis,


and Validation
In order to make recommendations on risk treatment, risk
practitioners must have a wide variety of data at their disposal.
The data must be trustworthy and accurate as well as
complete. A risk practitioner can take advantage of multiple
sources of data. Technical data, such as logs, can show how a
control is operating. Real-time data regarding intrusion
detection alerts, user behaviors, and so on is also helpful.
Other data, in the form of risk reports, incident reports, change
and configuration management documentation, as well as
information derived from control assessments should be used
to help inform risk management decisions. The vast multitude
of data available to the risk practitioner, however, might not be
useful to an executive manager. It’s the job of the risk
practitioner to take all this data and distill it down into useful,
actionable information that clearly and concisely conveys how
effective a control is, how it is meeting compliance
requirements, and how it reduces risk. This information should
also convey particulars about changes in risk and how these
changes impact the organization.
Regardless of the source of the data risk practitioners use to
perform risk management activities, the data must be collected
in a sound and verifiable manner and validated as true and
accurate. This is where formalized and documented data
collection and analysis processes can assist. Some data may be
collected in an ad hoc manner, but for the most part, data
should be collected on a regular basis, from verified sources,
and validated using various integrity-checking methods. The
data must also completely describe the situation in the proper
context and, of course, be analyzed by qualified risk
practitioners and cybersecurity personnel. Data may be
synthesized into useful information by reducing it, clarifying
it, and performing trend or historical analysis on it. In any
event, information supplied to management needs to present a
clear, concise, and accurate picture.

Risk and Control Monitoring Techniques


The techniques used to monitor and assess risk, as well as
control effectiveness, should be part of a formalized
methodology adopted by the organization. This is where the
overall risk strategy and associated policies and procedures
come in. The risk strategy is management’s commitment to
risk management and provides an overall long-term direction
for where the organization wants to be in terms of managing
its risk. The risk strategy is a high-level document and does
not necessarily go into detail on the day-to-day risk
management activities in which an organization must engage.
The risk management policy, on the other hand, should go into
further detail on the overall risk management program. This
policy should be handed down by management, with
consultation from the risk practitioner. It should assign roles
and responsibilities as well as dictate what risk management,
assessment, and analysis methodologies the organization
officially uses. The policy can also define risk treatment
options and how they should be considered. Most of the details
required to implement the policy and, in turn, the strategy will
typically be included in various lower-level risk management
procedures, such as procedures used for risk assessment. In
any case, the organization’s risk management and monitoring
processes should be standardized and approved by
management for consistency, reliability, and predictability.

Risk and Control Reporting Techniques


Reporting on risk and controls may use various techniques to
convey data in a clear, accurate, and complete manner. Some
techniques lend themselves to reporting better than others;
narrative reports may often be undesirable except where a
great deal of technical data is needed to support a
recommendation or decision. Graphics and charts, on the other
hand, are sometimes better suited to convey the bottom line to
management, without all the unnecessary details involved in a
technical explanation. Other data presentation techniques, such
as statistical, historical and trend analysis, in the form of
graphs or bar charts, may be useful to present data in the right
way so that management can make an informed decision.
Some of these data reporting techniques include heat maps,
scorecards, centralized dashboards, and real-time information
feeds. Heat maps focus on data that shows areas of red,
yellow, and green, for example, with data points in red
(darker) being the obvious areas of concern, and data points in
the green (lighter) areas being of lesser concern. Figure 3-2
shows an example of a heat map.

Figure 3-2 An example of a heat map


Scorecards are used to collect pieces of data and offer a
comparison with other pieces of data, showing a relative
performance or effectiveness increase, compared to previously
collected data. Centralized dashboards, along with real-time
information feeds, have the goal of showing a one-stop single
view of all the necessary data points risk practitioners and
managers need to view, often in real time, the status of control
effectiveness, compliance, or risk. Often, however, these
dashboards can seem to be very complex and “busy” with
information, so extra effort must be taken to ensure they only
display critical information, in the most simplistic manner
possible, while allowing a risk practitioner or manager to “drill
down” further to obtain more details about a piece of data in
the dashboard.
Regardless of the data presentation technique used,
reporting must be clear, accurate, and complete, and it must
convey the critical information needed for managers to make
meaningful risk-based decisions.

Key Performance Indicators


We have discussed the necessity to test, assess, and evaluate
controls as well as risk itself. Remember that we’re trying to
ensure that controls are effective, meet compliance
requirements, and reduce risk. In order to determine those
things, we have to measure different aspects of the control’s
performance characteristics, both positive and negative. For
this we use various pieces of information, called indicators, to
help us measure these items. Once we identify these
indicators, we can move toward the indicators associated with
measuring and reporting that performance, and current risk
levels, accurately and efficiently.
You will often hear indicators referred to as metrics, and in
this text, those terms are interchangeable for our purposes.
However, the types of indicators, and what they measure,
differ. Key performance indicators (KPIs) are used to
understand and enable the measurement of control
performance. Control performance can be anything from how
often your firewall blocks malicious incoming traffic to how
often your continuity of operations plan is exercised. The level
of “performance” can be different for each organization; it’s
important that you determine performance goals unique to
your organization, based on its own performance goals as well
as its risk appetite and tolerance levels.
So why do you need indicators? How do you know if
you’re doing well (or poorly)? Do you trust your risk team,
hoping that they have some sort of reporting mechanism that
will present stakeholders the correct information? At the end
of the day, you want to be able to monitor and analyze those
indicators to track trends and determine the effectiveness and
efficiency of the controls, and to make decisions for creating
new controls, ditching others, and sounding the alarm when
risk has passed a predefined threshold.
Understanding what a KPI means to your organization
requires you to ask yourself a few questions. What is your
organization’s mission? Are you a research organization
attempting to develop a new cryptographic algorithm? What
things are important to your organization? Does it value
availability above all other attributes (that is, the ability to
conduct business through any fire, storm, hacking attempt, or
any other scenario it may encounter)? Or does your
organization value data privacy and security above any other
consideration? These are questions you need to ask yourself
when developing KPIs. Remember that these KPIs help you
understand how controls are performing to enable all these
attributes. You want to make sure the controls are performing
at the level you expect.
Ideally, KPIs should be “S.M.A.R.T.” in order to be most
effective. In other words, KPIs should be
• Specific
• Measurable
• Attainable
• Relevant
• Timely
When a KPI is S.M.A.R.T., it is tailored to the organization
and the area being measured. The first question you need to
answer is, what are you trying to measure? You should be,
according to the S.M.A.R.T. methodology, specific. Are you
attempting to measure availability? Then you may want to
look at a metric that measures how often your systems go
down—or, conversely, what is the percentage of time your
systems are up?
A KPI also needs to be measurable, in a way that is ensured
to be accurate. In the case of the availability, how would you
measure it accurately? Perhaps you could determine how often
the systems went down based on the “uptime” command in the
UNIX operating system.
When a KPI is attainable, it is readily achievable. For
example, you wouldn’t want to set a performance goal of 100
percent uptime in a situation where you have an entirely new
staff, new equipment, new management, and so on. Perhaps 85
percent is more achievable, and then you can work toward a
higher goal.
KPIs that are relevant matter to your organization. If you’re
in a situation where time is of the essence, such as stock
trading, then availability is essential. Without availability, your
systems cannot buy or sell stocks, and your user base will
quickly move on to another organization that values
availability as much as they do. However, other contexts, such
as educational institutions, may not care so much about
availability. Usability might be of more concern, or the ability
to access content via mobile applications or other cutting-edge
technologies. Take the time to consider what’s important or
relevant to your organization when determining your KPIs.
Finally, timely KPIs allow the data to be collected when
needed to quickly determine the performance of your
measured initiative. You should be able to obtain data for the
metric relatively easily from existing sources and repositories.
In some instances, a KPI may not meet all the criteria of
S.M.A.R.T. For example, a firewall may block a number of
external attacks per month. Depending on the organization,
there may be nothing to attain, but most of the S.M.A.R.T.
criteria is still met. This is perfectly fine in some
circumstances.

Key Risk Indicators


Risk indicators are metrics, much like KPIs, used to determine
if and when the organization has a high probability of risk that
exceeds the defined risk appetite. Not all risk indicators,
however, are key. Key risk indicators (KRIs) are considered to
be highly probable indicators designed to accurately predict
important levels of risk based on defined thresholds.
Along with determining the level of performance for our
controls, we need to determine ways to indicate the risk that
our organization is subject to. KRIs are related to, but separate
from, KPIs, in that KRIs are all about how the metric predicts
current and future risk rather than past performance of a
specific control or set of controls. KRIs are linked to specific
risks and provide an early warning alarm that a risk is
emerging, allowing leadership to be proactive and deal with
that risk sooner rather than later.
ISACA’s Risk IT Framework includes the following criteria
to select KRIs:
• Impact When a risk indicator has a high impact, it is
likely to be a KRI.
• Effort to implement, measure, and report When all
else is equal, the easiest indicator to measure from is the
best.
• Reliability The indicator reliably predicts an outcome.
• Sensitivity The indicator accurately indicates variances
in the risk.
Similarly to the determination of KPIs discussed earlier,
KRIs should be S.M.A.R.T., and they should drill down to the
root cause and not just focus on the symptoms that are
immediately evident. KRIs should include lagging indicators
(indicators that determine current risk after an event has
occurred), leading indicators (which indicate the controls in
place to prevent an event from occurring), and trends (which
consider patterns in the data that indicate risk). Root cause
analysis is also important here in order to determine the root
cause for any risk, not just the symptoms. This is where risk
assessments and analysis, control evaluations, and other types
of data collection and tests come into play, to give you this
information.

Key Control Indicators


As discussed previously, KPIs are used to understand and
enable the measurement of control performance. Key control
indicators (KCIs) are often used interchangeably with KPIs,
but they are really a subset of KPIs, since some KPIs don’t
necessarily relate to controls. KCIs are those specific
indicators that show the relative effectiveness of controls. This
effectiveness, as mentioned before, can be in how well a
control protects an asset, how well a control helps with
compliance with governance (for example, the number of
compliant versus noncompliant controls), and, probably most
importantly in our context, how well the control reduces or
mitigates related risk. It is important that the control indicator
focus on the specific control as well as the particular risk that
the control is meant to mitigate. Associating a KCI with a
broad spectrum of risk is not effective; it should be associated
with a very specific risk scenario. For example, a KCI could
indicate effectiveness of the control in terms of risk reduction,
by showing how it reduces the impact of a particular risk
scenario for a given asset, the likelihood that a threat will
exercise a particular vulnerability, or the vulnerability itself.
KCIs should be developed based on the known
performance tolerances of the control. You should determine
what the normal operating parameters for the control are and
what should be expected based on how the control is
configured and implemented. Baselining control performance
is important so that you understand what normal operation
looks like. Abnormal or anomalous operation, such as a
sudden spike in unknown network traffic, may indicate that
the control is not operating within its normal range. This, in
turn, shows the control may not be as effective as it should be.
Examples of key control indicators might include, but are
definitely not limited to, the following:
• Bandwidth utilization
• Number of false positives or false negatives detected
• Number of instances of malware detected
• Number of incidences per month attributable to user
complacency or policy violations
• Number of vulnerabilities discovered during a scan
Additionally, not all KCIs have to be technical in nature,
although those likely are the majority of the ones many
organizations concern themselves with. KCIs can be
developed for not only technical controls but also
administrative and physical controls as well.
Chapter Review
Once an organization has assessed and analyzed its risk, it
must respond accordingly. In this chapter we discussed several
key areas of risk response, including the different risk
treatment and response options. Risk and control ownership
are key to responsibility and accountability for risk response.
Risk and control owners are not always business process
owners, although they could be. Sometimes controls are
dispersed across an organization and protect multiple assets in
several areas at once. These are called common controls, and
the control owners are common control providers. These
entities are responsible and accountable for risk and its
mitigation, respectively, and must be given the authority to
carry out their responsibilities.
Risk treatment and response options include risk
mitigation, risk sharing or transference, risk acceptance, and
risk avoidance. Risk mitigation involves the reduction of risk
through the implementation of adequate security controls. Risk
sharing involves transferring risk to a third party, such as a
cloud services provider, or through insurance. Note that even
if risk is shared, responsibility and accountability are retained
with the organization. Risk sharing usually involves offsetting
financial responsibility or liability in the event of an incident
or disaster. Risk acceptance means that the organization must
accept any remaining or residual risk after all other risk
response options have been implemented. Risk must be
formally accepted and documented as well as monitored
through the risk register. Risk avoidance does not mean simply
ignoring risk; it means that an organization has chosen a
different path or solution that eliminates a particular risk
associated with an activity. Evaluating risk response options
involves considering many factors, including the cost
effectiveness of controls and how much they reduce risk
versus the cost of the control and the asset’s value,
organizational structure, governance, and other factors. More
often than not, more than one risk response is necessary.
Third-party risk management involves considering all the
different threats, vulnerabilities, and other risk factors inherent
to engaging with third-party providers. Third parties incur
many of the same vulnerabilities and threats that other
organizations do, including external attack, infrastructure and
system vulnerabilities, governance issues, and so on. Key
considerations with third parties include contractual
obligations to protect data, division of legal liability, data
ownership, and so on.
Issues, findings, and exceptions management means the
organization must have proactive measures in place to reduce
risk when situations or events occur that are out of the normal
processing parameters or configuration baselines. Examples of
these cases include vulnerabilities that cannot be easily
remediated, exceptions to security policies, and compliance
findings. Each of these types of events should be considered
carefully for risk and mitigated as much as practical by the
organization. In the end, exceptions may have to be made, but
they must be formally approved by management after due risk
consideration, thoroughly documented, and monitored through
the risk register.
Risk is dynamic; it changes according to the operating
environment, new technologies, the threat landscape, and
organizational changes. These emergent risks must be
considered, since they may present unknown vulnerabilities
that might not surface for a long time after new technologies
have been implemented or the environment has changed.
Emerging technologies are a key source of emergent risk, and
organizations must be careful about the rush to implement
those technologies. The implementation of emerging or new
technologies should justify a valid business need, and
appropriate risk assessment and analysis should take place
before their implementation. Risk responses should be
changed based on those emergent risks.
Security controls are measures or safeguards implemented
to protect organizational assets and reduce risk. The three
general types of controls you must understand are
administrative, technical, and physical. Administrative
controls usually involve policies and procedures, technical
controls involve equipment and software, and physical
controls involve physical barriers used to protect people,
equipment, and facilities. Control functions are divided into
five general categories: deterrent, preventive, detective,
corrective, and compensating. Deterrent controls must be
known in order to be effective. Preventive controls do not have
to be known in order to prevent a violation of policy or illegal
act. Detective controls are used to discover a violation of
policy or malicious act. Corrective controls are temporary in
nature and are used to solve an immediate security issue.
Compensating controls are more longer-term controls and are
used when a primary or desired control is unavailable. There
are several control frameworks published by various entities,
including government and professional frameworks. Examples
of these include the ISO/IEC 27001 controls, the NIST
controls, and the PCI DSS control set.
Controls are evaluated and selected based on their
effectiveness in protecting assets, the level of risk they help to
reduce, and compliance with governance. Controls are also
evaluated based on cost-effectiveness. If the cost of an asset
and its continued maintenance versus the revenue it produces
or its value to the organization compared to the cost of the
controls used to protect it do not correspond, a decision must
be made whether to implement the controls for the asset.
Several considerations go into control design, including
reducing risk elements such as the likelihood of an event
occurring, the impact to an asset, and the severity of the
vulnerability. Threats cannot normally be reduced through
controls, but their interactions with the organization can be
mitigated through properly designed controls. Controls are
selected based on several factors, which include the cost to
acquire and maintain, the level of risk they reduce, and the
amount of protection they offer. Existing controls in an
organization can be leveraged if they provide the proper
security protections and are interoperable with all systems. If
desired controls cannot be implemented, compensating
controls must be considered. Controls are analyzed at different
points in their life cycle, particularly during installation and
periodically to ensure they are still effective, comply with
governance, and reduce risk. Controls may need to be updated
or changed periodically when technology changes, the controls
become outdated, threats to the organization increase, and the
operating environment changes.
Control implementation must consider how the control will
interact with the infrastructure. Change and configuration
management processes are critical to ensuring the safe, secure,
and stable implementation of new security controls. Both
before and after controls have been installed, they should be
tested to ensure they meet functional and performance
requirements and are interoperable with the existing
infrastructure. Controls must also be documented thoroughly
and any risks should be included in the risk register. Controls
must be periodically tested during various assessments by
interviewing those responsible for maintaining the controls,
reviewing all documentation related to the controls, observing
the controls in operation to ensure they fulfill their security
functions, and testing the controls through technical means.
Risk monitoring and reporting are necessary to conveying
control and risk information to management. Internal
management policy as well as external governance will drive
reporting requirements. Risk practitioners should understand
reporting requirements as well as stakeholder needs so that
they will be able to report data with clarity, accuracy,
completeness, and timeliness. Risk treatment options and plans
should be conveyed to management through reporting
channels on a periodic and as-needed basis, rather than after
the risk response is complete. Data used to create information
for consumption by managers should be accurate, complete,
and trustworthy. Risk practitioners must determine, based on
their audience, how the information is presented using various
techniques. Risk control and monitoring techniques should be
part of a formally approved risk management methodology
and promulgated in the risk strategy, policy, and procedures.
Various risk reporting techniques exist, including narrative
reports, scorecards, graphs, and real-time information feeds
such as those that are part of a centralized management
dashboard.
Key performance indicators are pieces of information that
measure and show performance levels of different aspects of
the security and risk management programs. Key risk
indicators show how risk has changed. Key control indicators
show how effective controls are functioning and performing as
well as ensure compliance and reduce risk.

Quick Review
• Risk response is what is needed after risk has been
appropriately assessed and analyzed.
• Risk and control ownership must be carefully
considered as part of risk response.
• Business process owners are not necessarily risk or
control owners.
• Controls that span the entire organization are called
common controls.
• There are four generally accepted risk responses:
mitigation, sharing or transference, acceptance, and
avoidance.
• Risk mitigation means to reduce risk through the
implementation of controls.
• Risk sharing allows an organization to transfer some of
the risk to a third-party provider or through insurance.
• Risk sharing does not absolve an organization of its
responsibility, accountability, or legal liability.
• Risk acceptance means to take on any leftover risk after
all other risk treatment options have been implemented.
• Risk avoidance does not mean to ignore risk; it simply
means to avoid actions that result in the risk.
• Evaluating risk response options involves considering
several factors, including cost, effectiveness, value of
the asset, the organization, and governance, as well as
other external factors.
• Third-party risk management means that the
organization must manage any risk inherent to third-
party risk sharing, contracts, and so on.
• Third-party risk factors include the same vulnerabilities
and threats that other organizations encounter.
• Considerations with third-party risk include protection
of controls, responsibility, accountability, legal liability,
and data ownership.
• Issues, findings, and exceptions management helps to
manage risk when there are departures from normal
processes, security controls, or baselines.
• Exceptions must be approved by management,
thoroughly documented, and tracked in the risk register.
• Emerging risk must be managed due to a changing
operating environment, emerging technologies, or a
changing threat landscape.
• Emerging technologies should not be immediately
adopted until they have been evaluated for risk.
• The primary risks of emerging technologies include
interoperability and compatibility with existing systems
as well as security mechanisms.
• Controls are security measures or safeguards
implemented to protect systems and data, ensure
compliance with governance, and reduce risk.
• The three types of controls are administrative, technical,
and physical.
• Administrative (managerial) controls are implemented
through policies and procedures.
• Technical (logical) controls are implemented through
hardware and software.
• Physical (operational) controls are implemented through
physical barriers and systems used to protect people,
equipment, data, and facilities.
• The five control functions are deterrent, preventative,
detective, corrective, and compensating.
• Deterrent controls must be known in order to be
effective.
• Preventative controls do not have to be known; they
serve to prevent malicious actions or policy violations.
• Detective controls are used to discover or detect
malicious actions or policy violations.
• Corrective controls are used to remedy an immediate
security issue and are temporary in nature.
• Compensating controls are used in place of a preferred
primary control and are generally longer-term in nature.
• Control frameworks are available to assist organizations
in implementing controls to protect their systems, meet
governance requirements, and reduce risk.
• Which control framework an organization selects may
be based on governance. Some governance vehicles
require specific controls, but others are more flexible.
• Control frameworks include the NIST controls, CIS
controls, PCI DSS, and the ISO/IEC 27001/27002
control catalogs.
• Controls are designed and selected based on their cost
effectiveness, how well they perform and function, how
well they protect assets, how they assist in meeting
compliance requirements, and how well they reduce
risk.
• Controls are tested and evaluated during various points
in their life cycle, including before and after
implementation and during security assessments such as
vulnerability assessments, risk assessments, and
penetration testing.
• Controls can be tested using four primary methods:
interviews with key personnel, documentation reviews,
control observation, and technical testing.
• Change and configuration management are key
processes involved in control implementation.
• Interoperability with the existing infrastructure is a key
concern while implementing a new control.
• Controls must be thoroughly documented in the risk
register.
• Risk responses and risk treatment options should be
reported to management on both a periodic and as-
needed basis.
• Risk practitioners should understand reporting
requirements levied on the organization by both internal
management and external governance.
• Risk practitioners should ensure that all data collected
to form reports and give information to management
must be complete, accurate, and trustworthy.
• Risk and control monitoring techniques should be part
of the formally adopted risk management methodology
and included in various documents, including risk
strategy, policy, and procedures.
• Risk reporting techniques include narrative reports,
charts, and graphs such as heat maps, scorecards, and
centralized dashboards, among other techniques.
• The risk reporting technique used, as well as the
complexity of the data and the goal of the report, should
be tailored to the audience.
• Key performance indicators are pieces of information
that help measure the performance of controls and other
aspects of the security program as well as show progress
toward the organization’s goals in those areas.
• Key risk indicators show how risk has increased or been
reduced.
• Key control indicators show how controls are
performing and functioning in terms of effectiveness,
compliance, or risk reduction.

Questions
1. You are the business process owner for the manufacturing
department of your company. After a risk assessment,
several key risks have been identified that directly
involve the protection of data within your department.
Both the IT security and physical security departments
have security safeguards in place, or planned for
implementation, to help reduce those risks. Which of the
following most accurately describes ownership in this
scenario?
A. You are the risk owner, and the IT and physical
security departments are the control owners.
B. As the business process owner, you are both the risk
and control owner.
C. The IT and physical security departments own both
the risk and the controls.
D. Executive management owns both the risk and
controls; neither you nor the IT and security
department have any responsibility for that
ownership.
2. As a risk practitioner in a larger organization, you have
been asked to review the company’s risk response options
for a particular risk and make recommendations to the
company’s executive management. For some of the risk,
there are obvious controls that could be implemented, but
this will not completely eliminate all of the risk. None of
the risk can be borne by any third party, and the business
processes involved with the risk are extremely critical.
Which of the following risk treatment options would you
recommend after all possible mitigations have been put in
place?
A. Risk avoidance
B. Risk mitigation
C. Risk acceptance
D. Risk sharing
3. Your company has just established a contract with a third-
party cloud services provider. Based on the contract
language, in the event of a breach, the provider must
disclose details of the event as well as allow an audit of
the security controls that should have protected any data
disclosed during the breach. The contract language as
well as laws and regulations also stipulate that the third-
party provider retains some legal liability for the loss.
Which of the following accurately describes the
responsibility and accountability borne by both your
organization and the third-party provider during this
event?
A. All the responsibility and accountability are placed
on the third-party provider.
B. All of the responsibility and accountability are placed
on the organization.
C. The third-party provider has the responsibility for
protecting the data, but the organization retains
accountability.
D. Both the third-party provider and the organization
bear responsibility and accountability for the loss of
the data as well as legal liability.
4. Which of the following is the major risk factor associated
with integrating new or emerging technologies into an
existing IT infrastructure?
A. Security mechanisms
B. Data format
C. Vendor supportability
D. Interoperability
5. During a vulnerability scan of its systems, your
organization discovers findings that cannot be remediated
without breaking several critical line-of-business
applications. Which of the following should be the path
forward in determining a solution to this problem?
A. You should patch the systems regardless of the
impact of the line-of-business applications since
security is far more critical to the organization.
Business process owners must accept this and
configure their line-of-business applications
accordingly.
B. You must not patch a system that would affect the
line-of-business applications, since this affects the
mission and bottom line of the organization, which is
far more important to the organization than its
security posture.
C. You should employ the risk avoidance response by
not worrying about the security or business
ramifications of the problem, since it is beyond your
control and will waste critical resources in
addressing it.
D. You should evaluate the risk of patching systems and
suffering the impact to the line-of-business
applications versus the security risk if the systems
are not patched and then allow management to make
a decision based on that risk. Any exceptions should
be formally approved and documented.
6. Your company has implemented several new controls to
strengthen security inside its facility. These controls
include stronger steel doors, with new cipher locks, and
two more guard stations to keep unauthorized personnel
from entering sensitive areas. Which of the following
types and functions would those new controls be
considered?
A. Physical, detective
B. Physical, preventive
C. Administrative, preventive
D. Administrative, deterrent
7. Your company is now doing business internationally, and
as a result, one of its key business partners overseas
requires that it adopt international security standards. You
examine several different standards, and you are already
using internally developed controls that may be mapped
to a new standard. Which of the following control
standards is the most appropriate to use when working
with international partners?
A. NIST SP 800-53
B. CIS controls
C. ISO/IEC 27001/27002
D. HIPAA controls
8. Your company is concerned about implementing controls
for a new sensitive system it is about to install. Some
existing controls can be easily used, but the new system
will require more advanced network security devices
since the data sensitivity requirements are much higher
under laws and regulations imposed on the company.
These laws and regulations mandate a higher level of
protection because of the sensitivity of that system and
data. Which of the following is the most important
concern the company must consider when implementing
the new security devices?
A. Cost
B. Compliance
C. Risk reduction
D. Interoperability
9. Your company has installed a new network security
device and is testing it in parallel with the rest of the
infrastructure before cutting over all systems on the
infrastructure to rely on the device. Security mechanisms
within the device meet your strict governance compliance
requirements, and risk analysis shows that it can reduce
risk of an external attack significantly. However, some
but not all critical systems on the network refuse to
communicate with the device, making it difficult to
troubleshoot any issues and stopping critical data from
transiting the network. Which of the following is the most
likely issue you should examine?
A. Interoperability
B. Authentication mechanisms
C. Encryption mechanisms
D. Network protocol issues
10. Your organization is preparing to implement many new
security controls, including upgrading legacy network
security devices. While a thorough risk analysis has been
performed, there is still uncertainty about how the
network devices will interact with the rest of the
infrastructure. Management is concerned with
interoperability issues and the ability to monitor the
installation carefully. Which of the following will assist
in helping the implementation go smoothly?
A. Vulnerability assessment prior to installation
B. Parallel cutover
C. Risk analysis
D. Change and configuration management processes
11. You are collecting data for your annual risk and control
effectiveness report to the company’s board of directors.
You’re gathering data from multiple sources, but you are
concerned about the usefulness of the data used to create
a report. Which of the following is not a concern
regarding the data you’re collecting?
A. Completeness
B. Accuracy
C. Trustworthiness
D. Complexity
12. You are creating a schedule for risk reporting for various
managers and events. Which of the following strategies
should you employ regarding reporting of risk treatment
options and plans?
A. Report on their progress periodically and as needed.
B. Report annually to senior management and quarterly
to middle management.
C. Report results only when the risk treatment options
have been implemented and are complete.
D. Do not report on risk treatment options; only report
on increases or decreases in risk as required by
governance.
13. Which of the following documents should describe the
risk management methodology, to improve risk
assessment and analysis methodologies, adopted by the
organization?
A. Risk management policy
B. Risk management strategy
C. Risk assessment procedures
D. Organizational strategy
14. You are implementing a new method to quickly inform
management of any changes in the overall control
effectiveness or risk posture of the organization. You
want it to be in near real time but only include the critical
information necessary that managers need to make
informed decisions. You also want management to have
the ability to drill down into more detailed information if
needed. Which of the following reporting techniques
would fill these requirements?
A. Heat map
B. Narrative report
C. Centralized dashboard
D. Scorecard
15. You are developing metrics for senior management
regarding control effectiveness and the risk posture of the
organization. You need to create a metric that shows
managers how potential risk has been reduced due to
implementing several new controls over the past six
months. You want to aggregate this measurement into one
indicator. Which of the following would be the most
effective indicator to show this reduction?
A. Key performance indicator
B. Key risk indicator
C. Key management indicator
D. Key control indicator

Answers
1. A. As the business process owner, you have responsibility
and accountability for the risk, while the IT and physical
security departments are the control owners.
2. C. After all other risk reductions and mitigation actions
have been implemented, any residual risk must be
accepted. Risk mitigation has already occurred, and the
scenario states that risk cannot be shared with any third
party. Since these are critical business processes, the risk
cannot be avoided.
3. D. Both the third-party provider and the organization bear
some level of responsibility, accountability, and legal
liability for the data loss since both the contract language
and laws address this situation. However, it is likely that
the organization will ultimately bear the most
responsibility and accountability for the data loss to its
customers.
4. D. Interoperability is the major risk factor associated with
integrating new or emerging technologies into an existing
IT infrastructure. It covers a wide range of factors,
typically including backward compatibility, data format,
security mechanisms, and other aspects of system
integration.
5. D. You should evaluate the risk of patching systems and
suffering the impact to the line-of-business applications
versus the security risk if the systems are not patched and
then allow management to decide based on that risk. Any
exceptions should be formally approved and documented.
You cannot simply ignore the risk, and taking any action
without carefully considering the risk would be
detrimental to the organization, whether it is making the
choice to break the line-of-business applications or
ignoring the security ramifications of the problem.
6. B. The controls are physical because they involve using
physical barriers to secure the interior of the facility. The
controls are also preventive because they prevent people
from entering sensitive, restricted areas. The controls are
not administrative because they do not involve written
policy or procedures established by management.
7. C. ISO/IEC 27001 and 27002 are international standards
developed to ensure interoperability and translation of
security controls across international boundaries. The
other control sets, while they may possibly be used in
areas outside the United States, are unique to the U.S.
8. B. Compliance is actually the most important
consideration in this scenario because the company is
installing a system that is considered sensitive enough to
be regulated by laws and regulations. Since the data
sensitivity requirements under those laws and regulations
require that level of protection, the company has no
choice but to implement those advanced network security
devices, regardless of cost, interoperability, or any other
consideration.
9. A. Interoperability seems to be the issue here. Since
authentication and encryption mechanisms meet
compliance standards, it may be that they are not
interoperable with existing infrastructures. Network
protocols aren’t likely an issue since some devices on the
network can communicate with the new device. All
indications are that the new device may not be
interoperable with some of the other devices, security
mechanisms, or protocols on the network.
10. D. Proper change and configuration management
processes will assist in an orderly implementation and
changeover to the needed network security devices.
Management has the ability to carefully consider, prove,
and monitor changes to the infrastructure, with the ability
to back out the changes according to defined processes if
something goes wrong.
11. D. Data complexity is not an issue since it will be your
job as risk practitioner to distill the data into
understandable information for the board of directors.
You are most concerned with the completeness of the
data, how accurate it is, and whether it comes from a
trustworthy source.
12. A. You should report the progress of risk treatment
options both periodically, as determined by organizational
policy, and as needed, depending on the criticality or
importance of the information and the desires of
management.
13. A. The risk management policy, which supports external
and internal governance, should dictate the risk
management methodology used by the organization.
Often this methodology will include any risk assessment
or analysis methods mandated for use. Both the risk
management strategy and the overall organizational
strategy are long-term, higher-level documents that do not
go into this level of detail. Risk assessment procedures
are step-by-step processes, activities, and tasks used to
perform a risk assessment, but they do not direct overall
risk management methodologies.
14. C. A centralized dashboard can supply all the necessary
critical information managers need to view control
effectiveness and risk posture, all in one location.
Information can be fed to the dashboard in real time, and
managers would have the ability to drill down on
particular data elements to gain more details if needed.
15. B. In this scenario, a key risk indicator (KRI) could be
developed to show the reduction in risk. A key
performance indicator (KPI) would show the level of
performance of a control or other aspect of organizational
security, not necessarily the reduction in risk. A key
control indicator (KCI) would show the effectiveness of a
particular control, not the reduction in risk. Key
management indicators are published by executive
management and cover various metrics they are
concerned with regarding the overall performance of
organizational objectives. They do not indicate a
reduction in risk.
4 CHAPTER

Information Technology and


Security
In this chapter, you will:
• Learn to describe how business goals, information
criteria, and organizational structures affect risk
• Determine how enterprise architecture presents risk to
the organization
• Analyze factors of enterprise risk, including areas such
as data lifecycle management, hardware and software,
third-party relationships, the system development life
cycle, project management, business continuity and
disaster recovery, IT operations management, and
implementation of new technologies
• Learn basic information security concepts
• Examine different frameworks and standards
This chapter covers Certified in Risk and Information
Systems Control Domain 4, “Information Technology and
Security.” The domain represents 22 percent of the CRISC
examination.

The CRISC Task Statements relevant to this domain focus on


several key activities found in an information security
program, including identifying threats and vulnerabilities,
establishing accountability through the assignment of risks and
control ownership, creating a risk-aware culture through
security awareness training, reviewing risk analyses,
developing remediation plans to fill gaps, collaborating on the
development of risk treatment plans and on the selection and
design of controls, and ensuring that business practices align
with risk management, risk appetite, and risk tolerance, and
selected security frameworks.
Information is a commodity. Even if an organization is in
the business of producing goods to bring to market, it still
relies on its information and its technology as enablers to
produce those goods and deliver them to the market and
consumers. Without the ability to generate, process, and
otherwise use information, modern businesses would not be
able to produce goods or services and compete in market
spaces. Therefore, any negative events that affect the
organization’s ability to process information directly affect the
ability of the organization to survive. Information technology
directly supports business goals, objectives, and strategies. All
elements of a business endeavor depend on IT, including the
organization’s information (or data), its people, its line-of-
business applications and systems, and its overall
infrastructure, including all of its equipment and processes.
Information technology affects risks to the business
enterprise in two different ways. First, information technology
is used to help protect the enterprise from risk; in other words,
it serves to protect the information the business generates and
relies on. That’s the purpose of having high-capacity storage,
faster networking equipment, redundant systems, and security
devices sprinkled throughout the infrastructure. The second
way that IT affects risk is that it helps the organization to
produce the information needed to fulfill its business goals and
objectives in the first place. Without IT, there would be no
information processed, no systems designed, and no advanced
technologies developed for a business to take to market and
compete with. Therefore, IT serves to both protect information
and generate it to advance business goals.
The information the business generates and uses has several
key characteristics. First, the information should be relevant to
the processes that the business supports. It should also be
timely; stale information can prevent a business from fulfilling
its functions in both short-term and long-term time frames. It
should also be accurate and complete. This is where
information integrity comes in, which is one of the goals of
information security. Anything that affects the accuracy and
completeness of information is a risk. Information should also
be controlled for access. Confidentiality is one of the goals of
information security, and controlled access to information and
the systems that process it is a must to maintain business
function. As you might guess, another characteristic of
business information is its availability to the users who need it
whenever and however they need it. This means that
authorized users should have business information, again, on a
timely basis, but also in a format that suits their needs. Risk
factors that affect any of these information characteristics,
such as relevance, timeliness, integrity, confidentiality, and
availability, must be considered in the overall risk
management process for the organization. Any detrimental
impact on these characteristics presents a risk to the business
mission.

Enterprise Architecture
The enterprise architecture within an organization affects the
business’s risk in several different ways. Aspects of enterprise
architecture risk include interoperability, supportability,
security, maintenance, and how the different pieces and parts
of the infrastructure fit into the systems development life
cycle. The business views IT as an investment of capital funds,
much like it does facilities and other equipment: as a means of
supporting the business mission. Information systems
represent a risk to the business because of interoperability,
supportability, security, and other issues. It costs the
organization money to maintain and support all the IT assets
within the organization, in the form of parts, software licenses,
training for administrators and users, and upgrades. There are
also the intangible aspects of IT, such as business value and
liability. IT systems affect the bottom line of the organization,
so a lot of thought is put into managing risk for them.
Additionally, you should take care to remember that
information technology risk is only a piece of the entire
enterprise risk picture. In the next few sections, we’re going to
talk about different aspects of the information systems
architecture and how they contribute to the overall enterprise
risk in the organization.
Platforms
Platforms are an element of the enterprise infrastructure that
contributes to information security and business risk for
several reasons. First, it costs to field and simultaneously
maintain different operating systems and environments that
come in different platforms. Platforms also introduce risk into
the environment in the form of interoperability, security, and
supportability. A diverse platform environment (with mixed
platforms, such as Windows, Linux, Macs, Unix, and so on)
can affect interoperability with other systems due to different
versions of software, different network protocols, security
methods, and so on. A diverse environment can also affect
supportability because the organization must maintain
different skillsets and a wide knowledge base to support the
diverse platforms.
On the other hand, maintaining a homogeneous
environment can reduce costs, ensure interoperability, and
allow a more common set of security controls and
mechanisms, such as patch management and configuration
management. However, there is even risk involved in a
homogeneous platform environment because of the likelihood
that a vulnerability discovered in one system would also be
shared in many others, offering a wider attack vector for a
potential malicious actor. It is really a matter of the systems
development life cycle as to how and when platforms are
developed, introduced into the infrastructure, implemented,
maintained, and, eventually, disposed of, and there is risk
inherent in all of these different phases, as we’ll discuss in
more detail later.

Software
Software introduces risk simply because, today, it’s so critical
to business operations. Businesses need not only basic word
processing and spreadsheet software but also complex
databases, line-of-business applications, specialized software,
security software, and other types of applications. Software
must be managed within its own life cycle as well; it is
constantly being patched, upgraded, superseded, and replaced
by better, faster software with more features that usually costs
more. Risks that are inherent to managing applications within
an organization include supportability, backward
compatibility, data format compatibility, licensing, and proper
use.
Adding to this complexity are the decisions an organization
makes in terms of the selection of proprietary software, open-
source software, general-purpose commercial software, or
highly specialized software. All these different categories
incur different levels of cost, supportability, licensing, and
feature sets. Interoperability also plays a part in application
risk, as it does with other infrastructure components.
Applications that do not use common data formats or produce
usable output for the organization create the risk of expense or
additional work that goes into transforming data between
incompatible applications. Applications also introduce risk
into the business environment with the level of security
mechanisms built into them and how effective those security
mechanisms are in protecting data residing in the application.
It’s worth mentioning here that web-based applications, in
addition to presenting the same risks as normal client-server
apps, also have their own unique risks. Security is a definite
risk imposed by web-based applications since they often
directly connect to unprotected networks such as the Internet.
Other risks include those that come from the wide variety of
web programming languages and standards available for
developers to use.

Databases
Databases, as a subset of applications, impose some of the
same risks that applications and other software do.
Additionally, databases incur risks associated with data
aggregation, compatibility, privacy, and security. Aggregation
and inference are risks associated with database systems.
Unauthorized access and data loss are also huge risks that
databases introduce into the enterprise environment.
Operating Systems
Although we discussed platforms in a previous section, it’s
also worth mentioning operating systems as their own separate
risk element in the enterprise infrastructure. The terms
platform and operating system are sometimes used
interchangeably, but, truthfully, a platform is more a hardware
architecture than an operating system categorization.
A platform could be an Intel PC or a tablet chipset, for
example, which are designed and architected differently and
run totally different operating systems. Different operating
systems, on the other hand, could run on the same platform but
still introduce risk into the organization for the same reasons
discussed previously with applications. For example, there are
interoperability and supportability risks and all the other issues
that go hand in hand with the normal operating system life
cycle, such as patch and vulnerability management. Licensing,
standardization, level of user control, and configuration are
also issues that introduce risk into the organizational
computing environment.

EXAM TIP Although information security professions tend


to focus more on the technical aspects of IT risks, for the
exam, keep in mind that all IT risks also contribute to the
overall business risks in the enterprise. Make sure you look at
the larger picture beyond the IT realm.

Networks
Networks are another aspect of enterprise infrastructure that is
absolutely critical to protecting data. They are most effective
when they are implemented in a way that not only incorporates
the business logic of the organization but also follows the data
flow—taking into account how the software is most
implemented and integrated with other systems such as
databases.
Let’s first take a step back to understand what a network is.
At its most basic level, a network is a mechanism that allows
systems to communicate with each other. The components are
often devices such as switches (for local network
communication) and routers (for communications between
networks). There are a number of protection mechanisms on
networks such as firewalls (which regulate network traffic),
intrusion protection systems (which protect traffic at a deeper
level than firewalls), threat intelligence gateways (which are
designed to protect external networks prior to connecting to
firewalls), and so on. This is only a sampling of the protective
technologies that are network based. The deeper the
understanding of the technologies, the more granular a risk
assessor may be.
The philosophy one uses to set up the location of protective
network devices can be referred to as the architecture. For
example, for sensitive data, most compliance frameworks
require that the data not be stored in the database on the same
local network segment as a web server. This way, if the web
server is compromised, attackers will not have immediate
access to the data. If they sit on the same network, that may be
considered a higher risk in a risk assessment—the
recommendation being to move the database to another
network behind the web server, with firewalls and intrusion
detection systems being the intermediary between the two
local networks.
Another factor to consider is encryption of data in motion.
If a legacy system does not have encryption and it is sending
data to another location on the Internet, there is a risk to
anyone between the networks for an on-path attack (formerly
known as a “man-in-the-middle attack”). A VPN tunnel can be
set up between the two networks to ensure that at least the
traffic is encrypted as it traverses the networks (or Internet).
In the end, networks and networking can be extremely
challenging and detailed. What we have covered here only
scratches the surface of what is entailed by networks and
networking. It is worth your time to explore this topic in depth
to help create a better network and ultimately add to a risk
assessment.

Cloud
No book on risk would be complete without considering
cloud-based risks. The concept of “Anything as a Service”
(XaaS) means that, for a price, nearly anything a user or
company would use a computing system for can be delivered
to them by a cloud service provider through the cloud
infrastructure—typically through a thin client or web interface.
In such a serverless architecture, a cloud provider manages the
server and associated architecture and allocates resources as
necessary to the end users. This requires less upfront
investment in hardware and software by the customer, greater
scalability, and centralized management for administration and
security concerns. Each cloud infrastructure is a little different,
but there are three main types of cloud infrastructure to
consider when looking at risk:
• Software as a Service (SaaS) allows a customer to
essentially lease software, such as applications and
databases, thus enabling rapid rollout to the greater
user community.
• Platform as a Service (PaaS) provides the framework of
an operating system and associated software required to
perform a function (for example, the Linux operating
system and components needed to run a web server).
• Infrastructure as a Service (IaaS) provides the ability to
quickly stand up virtual machines, storage devices, and
other infrastructure that would otherwise require the
purchase of physical devices.

Gateways
A number of other technologies that can be used to protect
organizations can be factored into a risk assessment. For
example, secure e-mail gateways and secure web gateways are
a must-have to protect organizations from web-based threats.
These technologies can help to filter malware, block malicious
links or websites, help prevent phishing, or a host of other
tasks. Technically, they do not fit into the category of other
technologies so they deserve special mention. A good risk
assessor will learn about these technologies and how they can
help reduce the risks related to the organization. That
knowledge can be applied to the risk assessment process.

Enterprise Architecture Frameworks


Another facet to consider is enterprise architecture (EA). This
is different from network architecture, presented earlier. EA
focuses on the relationship between business and technology.
In most cases, this includes the relationship between security
and technology. It is very important because it provides a view
into the governance of an organization, which can provide
insight into some core problems that cause risks within the
organization.
Two frameworks for enterprise architecture are discussed in
this book: The Open Group Architecture Framework
(TOGAF) and the Zachman framework.

NOTE TOGAF and the Zachman framework are enterprise


architecture models, not enterprise security architecture
models.

The Open Group Architecture Framework


TOGAF is a lifecycle enterprise architecture framework used
for designing, planning, implementing, and governing an
enterprise technology architecture. TOGAF could be
considered a high-level approach for designing enterprise
infrastructure.
The phases used in TOGAF are as follows:
• Preliminary
• Architecture vision
• Business architecture
• Information systems architecture
• Technology architecture
• Opportunities and solutions
• Migration planning
• Implementation governance
• Architecture change management
• Requirements management
TOGAF is a business-driven, lifecycle management
framework for enterprise architecture overall, and it certainly
can be used for information security architecture as well.
Figure 4-1 depicts TOGAF visually.
Figure 4-1 TOGAF components
You can find information on TOGAF at
https://www.opengroup.org/togaf.

The Zachman Framework


The Zachman enterprise architecture framework, established
in the late 1980s, continues to be a dominant EA standard
today. Zachman likens IT enterprise architecture to the
construction and maintenance of an office building: at an
abstract level, the office building performs functions such as
containing office space. As you look into increasing levels of
detail in the building, you encounter various trades (steel,
concrete, drywall, electrical, plumbing, telephone, fire control,
elevators, and so on), each of which has its own specifications,
standards, regulations, construction and maintenance methods,
and so on. Zachman can easily be used to develop an
enterprise security architecture as part of the enterprise
architecture.
In the Zachman framework, IT systems and environments
are described at a high, functional level and then in increasing
detail, encompassing systems, databases, applications,
networks, and so on. Table 4-1 illustrates the Zachman
framework.

Table 4-1 Zachman Framework Showing IT Systems in


Increasing Levels of Detail
While the Zachman framework allows an organization to
peer into cross-sections of an IT environment that supports
business processes, the model does not convey the
relationships between IT systems. Data flow diagrams are used
instead to depict information flows.
Information about the Zachman framework is available at
https://www.zachman.com/about-the-zachman-framework.
Implementing a Security Architecture
Organizations use different means for implementing a security
architecture. Because security architecture is both a big-picture
pursuit and a detailed plan, different decision makers may be
involved, and different business processes are used.
At the enterprise level, the organization will use its policy
and governance functions to make decisions about major
aspects of security architecture, such as decisions about the
brands of servers, workstations, and network devices to be
used.
At the detail level, processes such as configuration
management and change management are used to implement
device characteristics on individual devices or groups of
devices. For instance, an upgrade to an organization’s Domain
Name System (DNS) infrastructure might result in an increase
in the number of name servers in use, necessitating that most
or all devices in the organization be updated accordingly.
Over time, organizations will make changes to their
architecture models (both at the macro level and micro level).
For instance, changes and advances in technologies such as
software-defined networking (SDN), virtualization, and
microservices architectures will compel organizations to revise
their enterprise security architecture. However, updating
architecture documents is only the beginning. Organizations
will also initiate tasks or projects to implement these
improvements in their environment. Some of these changes,
such as updates to industry device-hardening standards, may
result in little more than change management to update a few
configuration settings, but other changes may involve
multiyear projects to modernize some aspect of an
organization’s environment.

IT Operations Management
Managing the enterprise infrastructure is one of the most
work-intensive efforts in an organization, especially in a larger
business. The enterprise infrastructure in an organization
covers a broad scope of areas. Infrastructure, of course, covers
workstations, printers, and other end-user devices. It also
covers the major pieces needed to conduct business, such as
servers, cabling, switches, routers, and a variety of other
network and security devices. Most organizations also include
wireless networks in their supporting equipment. Additionally,
the infiltration of mobile devices into businesses makes this a
new and sometimes difficult area to bring under the
organization’s infrastructure umbrella. Challenges with the
enterprise infrastructure include not only maintenance,
upgrades, updates, and implementing new technologies but
also includes some of the more typical traditional management
challenges, such as budgeting, project management, and
staffing.
Key areas in IT operations management include server and
infrastructure management, end-user support, help desk,
problem escalation management, and, of course, cybersecurity.
IT managers must maintain and meet any internal agreements
that cover guaranteed service delivery in support of the
different divisions within the organization, as well as service
level agreements (SLAs) with other organizations. While
information security personnel tend to focus more on IT risk,
we find that most of the risk factors, threats, and
vulnerabilities affecting IT also affect all the operations within
the business. In the next few paragraphs, however, we’ll focus
on those that directly affect managing the IT operations in an
organization.
Management of IT operations incurs risk factors such as the
size and complexity of the organization and its IT
infrastructure, the criticality and priority of the different
systems that make up the infrastructure, and the internal
management processes of the organization. Resourcing issues
also affect the management piece of IT operations; staffing the
right people who have trained on the various technologies the
organization needs as well as creating a budget that helps
maintain the current level of support and future growth for IT
are examples of resource-related risk factors. Additionally,
compliance with legal and governance requirements in the
face of increased regulation are also risk factors the IT
managers must deal with.
Organizational structure also affects IT operations because
the IT infrastructure may be managed on either a centralized
or a decentralized basis—sometimes by one centralized IT
shop, or in the case of larger organizations, by multiple areas
within other divisions that are delegated the task of managing
their own piece of the infrastructure. IT might also be
managed on a functional basis; the accounting and human
resources divisions may have the responsibility for managing
the systems that support their mission. Additionally, the IT
infrastructure may be managed on a geographical basis, in the
case of physically separated locations in large organizations.
All these structural considerations are factors that contribute to
risk in managing IT operations.
Also directly affecting IT operations risk are two key
processes: the change and configuration management
processes. We’ve already discussed risk factors that affect the
SDLC model in an organization, as well as how new and
emerging technologies can affect the existing infrastructure.
These same risk factors also directly affect the daily
management of IT operations simply because they introduce
change into the network. Some of this change can be planned
and carefully introduced, but often there is change—from the
large-scale network side, all the way down to individual
configuration items on hosts—that may have unforeseen
consequences and affect the network in different ways. How
the organization deals with change and configuration
management is a risk factor that affects not only the SDLC but
also the management of day-to-day operations.
Threats that affect the IT operations are like those that
affect other areas of the business and could be external or
internal threats from a variety of sources. Some of these
threats have a ripple effect in that they may first affect other
areas of business and, in turn, affect IT. For example, the
threat of a poor economy may affect the profitability and
sustainment of the business, resulting in cuts, which often
include IT personnel or equipment. Obviously, there are also
direct threats to the daily management of the IT infrastructure.
These include external threats such as hackers, of course, but
also more commonly come as increases in cost to maintain
operations, issues with external service providers, and disaster-
related events (weather, fire, and so on). Internal threats could
include those carried out by malicious insiders or even careless
workers, such as theft, sabotage, accidental equipment
breakage, and so on. Internal threats could also come from
management processes and include budget cuts, loss of trained
personnel, shifts in organizational priorities, and transitioning
from one market segment to another.
Technical vulnerabilities are beyond the scope and purpose
of this book; our focus here is on those associated with the IT
management aspect of the organization. Vulnerabilities
affecting IT management include faulty processes and
procedures, lack of resources, and lack of trained technical
personnel. An end-user population that has not been trained or
held accountable for proper care and treatment of the
infrastructure could also be a vulnerability. Other
vulnerabilities might include a lack of infrastructure
monitoring, a lack of control of sensitive information in IT
systems, and a failure to maintain a stable SDLC throughout
the entire infrastructure.

Project Management
Organizations use project, program, and portfolio management
to oversee and sustain both short- and long-term aspects of
systems and processes. These categories apply to the scope
and scale of different sets of activities or processes within an
organization. Projects are limited duration sets of activities
geared toward a particular goal; programs are ongoing, longer
term, and may also encompass several individual projects as
well as other activities specific to processes that may have an
indefinite duration. Portfolio management is the oversight of
several different programs by a senior person in the
organization. Keep in mind that the major difference between
a project and a program is duration; a project has a definite
beginning and ending, whereas a program is indefinite.
At the core of a project are three primary drivers: the scope
(the amount or range of work), schedule (when work is to be
done and its completion date), and cost (including all the
resources expended toward the completion of the project). All
projects depend on these three elements to ensure success.
Any shortfalls in cost, delays in schedule, or out-of-scope
work (also called scope creep) affect the ability of the project
to succeed, on time, within budget, and all the agreed-upon
work completed. We’ll discuss the risk factors that can affect
all three of these elements next.
Since the three major elements of a project or program are
scope, schedule, and cost, risk factors associated with projects
and programs primarily affect each of these elements. Factors
that affect scope often come from disagreement on exactly
what work must be accomplished, in what order, and who will
do it. These factors should be examined and agreed upon
during the requirements process, where the project is formally
scoped. In complex projects, factors that may affect scope
include the necessity to task workers from different sections or
departments, the exact amount of work to be done, in what
order it will be done, and the priority of each task and subtask.
The political culture within the organization can adversely
affect scope as well since there may be disagreement between
departments or executives on what work is required and whose
responsibility it is to accomplish it.
The scheduling component of a project has several risk
factors as well. The amount of work to be done (scope) affects
the schedule as a risk factor because of the time given to
accomplish a specific amount of work and the resources
allocated to this work. Lack of workers or materials adversely
affects the schedule, as does the availability of equipment,
work location or site, and external factors such as contract
negotiations, government shutdowns, and so on, as examples.
Cost risk factors stem from lack of budget control during
the project, including an inaccurate budget or estimation of
cost, unexpected expenditures, a weak economy, and so on.
Project costs are affected by the cost of labor (to include
wages, insurance, and benefits) as well as the cost of supplies
or materials needed to complete the project. Additionally,
since all three of the elements of scope, schedule, and cost are
also risk factors for each other, a delay in schedule or any
extra, out-of-scope work impacts the project budget and costs
as well.
Other risk factors for projects include training, staffing the
project with the right mixture of personnel who have the right
skill sets, attitudes, and focus on making the project or
program a success. A manager without the right project
management skill set is a risk factor that can affect scope,
schedule, and cost if they do not manage those three critical
elements properly. A technician without the right technical
skills may cost the project more money in training or delay
work unnecessarily due to rework or slow production.
In addition to factors such as scope, cost, and schedule,
adding an indefinite or longer-term duration affects programs
as a risk factor because you must project how they will be
staffed, funded, equipped, and otherwise managed in the
future, over a longer, indeterminate period. Therefore, risk
factors could be long term and fluctuate over that time. Factors
such as market, economy, and technology changes will
influence risk in a program much more so than a project,
affecting its scope, schedule, and cost over a longer period.
The threats to a project or program are similar; the major
difference is the duration of the time that the threat represents
potential harm to a project or program. Keep in mind that
threats for a project or program aren’t those you might
traditionally think of as threat sources; they are rarely
malicious in nature and usually come from the business
environment itself. For example, threats to cost are usually
those that involve money or resource issues, such as price
increases, currency value fluctuation, stock market variations,
and so on. These are usually external threats; internal threats to
costs might include a sudden budget restructuring, cutting
funds for a project, bankruptcy, and so on. Threats to the
schedule might include worker shortage, strikes, inadequate
training, delays in contract negotiations, delays from suppliers,
and so on. Scope threats usually involve extra or additional
work due to faulty requirements gathering and decisions about
what falls into the project’s scope and scale.
NOTE Sometimes it’s difficult to distinguish between threats
to each of these elements individually and threats that affect all
three project elements simultaneously, as it is more often the
case that any threat affecting one element will usually, even
indirectly, affect all three.
Since vulnerabilities are weaknesses or a lack of protective
controls, the vulnerabilities found in project and program
management are inherent to weaknesses in their critical
elements and processes. For example, a weakness often found
in the cost element of a project or program is a failure of the
organization to adequately budget for all the resources it
requires for the project. The organization might not list every
piece of equipment or every major supply it needs or consider
labor costs such as overtime in the event of schedule slippage.
It may not adequately negotiate firm prices with a supplier,
who then may raise prices on critical parts or equipment.
These are all vulnerabilities inherent to the budgeting and cost
elements of a project.
Scheduling also has some common vulnerabilities
associated with it. If an organization fails to build in potential
scheduling delays, such as work stoppages, dependencies on
other organizations to fulfill parts of the schedule or even
holidays, this can lead to problems with getting the project
completed on time. Another scheduling vulnerability is to
incorrectly estimate the amount of time it takes to perform a
task or get a piece of work accomplished.
Vulnerabilities inherent to the scope element of a project
affect how much work must be done, in what order, and by
whom. A work breakdown structure (WBS) is a document that
the project manager develops that covers exactly all this
information and more. The WBS describes, in excruciating
detail, the work, its subcomponent parts and tasks, what skill
sets are needed, and what resources are required to do the job.
Other documents may break down individual tasks into much
more detail, even describing step by step how a task is
accomplished. If the project manager and team do not create
these documents, this is a weakness in that the work may not
be performed exactly as needed. Resources may not be
adequately allocated for the work, or the work may be
performed by unskilled persons. Additionally, the amount and
quality of work may not be performed to requirements. Failure
to set requirements initially in the project and periodically
check and track the work against those requirements are also
vulnerabilities associated with scope since they can affect
whether or not the work meets the established requirements.
An additional vulnerability that simultaneously affects all
three project elements is the failure to monitor or control all
these elements on an ongoing basis throughout the life of the
project or program. Scope, schedule, and cost must be
monitored on a continuing basis to ensure that they meet the
original requirements set forth in the project’s charter. The
project or program manager must monitor and control these
things to prevent cost overruns, schedule slippage, and scope
creep. Failure to monitor or control these elements is a serious
vulnerability and could jeopardize the success of the entire
project or program. Table 4-2 gives examples of some of the
risk factors, threats, and vulnerabilities related to project and
program management.
Table 4-2 Examples of Project Risk Factors, Threats, and
Vulnerabilities

Business Continuity and Disaster


Recovery Management
Business continuity and disaster recovery management are
necessary parts of running a business, regardless of its market
area. This is because incidents, disasters, and other negative
events happen to all organizations eventually, despite the most
favorable conditions and the most careful planning. Business
continuity and disaster recovery are primarily concerned with
the goal of business resilience. An entire area of expertise is
dedicated to this goal with these processes in mind;
sometimes, it’s referred to as continuity management.
One thing to keep in mind is the difference between
business continuity and disaster recovery. Business continuity
is concerned with the careful planning and deployment of
resources involved in keeping the mission of the business
going (that is, keeping the business functioning regardless of
negative events). This process is more long term and requires
continual commitment from the organization. Disaster
recovery, on the other hand, is primarily concerned with the
quick reaction involved with preserving lives, equipment, and
data immediately following a serious negative event. Disaster
recovery is (hopefully) a short duration process and does not
concern itself with conducting the daily mission of the
business. Business continuity is more concerned with the long-
term survival of the business, while disaster recovery is more
concerned with the short-term process of reacting to a disaster.
While closely related, these two efforts are not the same thing;
in fact, disaster recovery could be viewed as a subset of the
activities that go on during the overall continuity management
strategy.

Business Impact Analysis


Business continuity planning involves several steps. Since the
focus of this domain isn’t solely on business continuity and
disaster recovery, we’re not going to go into an in-depth
treatment of these processes. However, we will discuss some
of the basic concepts of business continuity and disaster
recovery as they relate to risk. Two of the key processes
involved in business continuity planning are conducting a
business impact assessment (BIA) and determining a recovery
strategy. A business impact assessment closely resembles
some of the steps you would take during a risk assessment,
simply because you are identifying assets (which include, of
course, people, equipment, facilities, and processes) and
prioritizing those assets. The reason they are prioritized is that
in the event a disaster was to occur, the business would have to
rely on certain assets or processes more so than others to get
back in business. These critical assets or processes should be
brought back online and recovered first, but to accomplish
this, they must be identified by the organization, and plans
have to be made for their recovery. That’s where the business
impact assessment comes in. The organization must identify
critical processes and assets, prioritize them for recovery, and,
additionally, measure the impact on the business if those assets
or processes were lost for any given amount of time due to an
incident or negative event. Business impact analysis was
described in more detail in Chapter 2.

Recovery Objectives
Two key areas of concern in business continuity are the
recovery point objective (RPO) and the recovery time objective
(RTO). Both areas can be measured in the context of time. The
recovery point objective is the amount of data that can be lost
based on a time measurement. In other words, if the recovery
point objective is two days, the most amount of data that can
be lost without a serious effect on the organization’s ability to
function would be two days’ worth of data. Note that this
measurement isn’t concerned with the actual amount of data in
terms of quantity, such as gigabytes, for example; instead, it’s
concerned with measuring how many days or hours’ worth of
data can be lost, at most, without impeding the function of the
business. The recovery time objective, also measured in terms
of time, is the maximum amount of time the organization can
afford to lose before it starts recovery. This measurement of
time could be days, hours, minutes, or even seconds.

Recovery Strategies
The recovery strategy developed by the organization is a result
of careful planning, as well as budgeting and allocating
resources to the continuity management efforts. The recovery
strategy should address the most efficient methods of getting
the business back online and functioning after properly
responding to the critical needs of protecting people and
equipment during the disaster itself. Keep in mind that
recovering the business to an operational state does not
necessarily mean it will be working at 100 percent of its
previous operational capacity; the business may only be able
to get a few key services up immediately following a disaster.
The organization should take a realistic look at the degree of
continuity possible, given the seriousness and scope of the
disaster, its resources, the environment it is working with after
the disaster, and the availability of people, supplies,
infrastructure, facilities, and equipment. All of this should be
considered in the recovery strategy planning.

Plan Testing
Testing the disaster recovery plan is of critical importance;
without testing the plan, the organization won’t really know
whether it’s effective until a disaster occurs. Normally, that’s a
bit too late to find out that you haven’t carefully considered all
the different events that could occur during a disaster and how
you will deal with them. Testing the plan involves making sure
that people know what their responsibilities are, that they are
well-trained, that they have all the equipment and resources
needed to adequately respond to disaster, and that they practice
these responses. Testing the disaster recovery plan will point
out deficiencies in training, equipment, resources, and
response activities.

NOTE Much more information on business continuity and


disaster recovery planning can be found in National Institute
of Standards and Technology (NIST) Special Publication 800-
34, “Contingency Planning Guide for Federal Information
Systems,” which was written for use by government agencies
but can be used by anyone or any business to help in
understanding and planning for business continuity.

Resilience and Risk Factors


Resilience is a term that refers to the ability of the business to
survive negative events and continue with its mission and
function. In other words, it could be said that resilience is the
ability of an organization to resist the effects of negative
events and its ability to bounce back after one of these events.
Resilience can affect to what degree different risk factors, as
well as threats and vulnerabilities, have on impacting the
normal business operations of the organization. A more
resilient organization can better tolerate risk factors and the
effects they have on the organization’s ability to prepare for
and respond to negative events.
Various risk factors can affect the organization’s ability to
respond to disasters as well as to continue the business and
mission functions after it has recovered from a disaster. Some
of these risk factors are inherent to the organization itself;
these include the size of the organization, its facilities, its
people, and how well it has performed business continuity and
disaster recovery planning. A higher level of management
commitment to business continuity planning reduces the effect
of risk factors on the business; less commitment may render
the organization more susceptible to these risk factors. A
larger organization may have more complexity in terms of the
number of people to take care of during a disaster, as well as
the number of critical assets or processes that must be planned
for. Small organizations don’t necessarily have an advantage;
however, a small organization may have fewer resources to
adequately plan for and address business continuity and
disaster recovery.
Another risk factor that an organization could face is
physical location and geography. For example, a business
situated on the U.S. Gulf Coast is probably more susceptible to
adverse weather, such as hurricanes and tornadoes, than a
business located inland. Businesses that are in areas prone to
heavy flooding or have forest fires or extreme snowstorms at
various times of the year should plan for these weather
conditions appropriately. Distance could also be a risk factor;
if the organization is located farther away from population
centers or infrastructure services (such as fire departments,
police, hospitals, telecommunications providers, and so on),
there is a greater risk that the organization could not
adequately respond to a disaster.
There are also risks associated with third-party providers,
and these providers can affect business continuity and disaster
recovery as well. Yet another risk factor could be the degree of
outsourcing the organization is involved with. A business that
outsources some of its processes or key functions may have
less control over those functions or processes during an
incident or disaster. The business may be at the mercy of the
third party with whom they are contracted and subject to the
third party’s disaster recovery strategies (or lack thereof).
Business continuity and disaster recovery are two areas that
should be carefully considered when engaging in business
with any external provider, usually through a service level
agreement or another method.
In addition to the factors we discussed previously, the very
nature of the organization’s mission or business could be a risk
factor. Organizations that have critical processes or produce
critical goods and services that are time-sensitive, for example,
may incur more risk than an organization that can afford to be
down or out of service for a few days. Time sensitivity can
increase the impact of a disaster on an organization, so it
should be considered when developing continuity and
recovery strategies. Market factors, such as the perishability of
goods, for example, can become risk factors that an
organization must deal with as well.
Most people associate the threats involved with business
continuity and disaster recovery with natural disasters.
Obviously, natural threats exist: severe weather, earthquakes,
fires, and so on. These are threats that can’t be typically
prevented or neutralized, but they can be planned for.
Hardened facilities, adequate ventilation, fire suppression
systems, and other physical or environmental controls can
mitigate the damage from these threats. On the other hand,
man-made threats can also affect the ability of an organization
to recover from an incident or continue to function. These can
be broken down into unintentional and intentional threats.
Intentional threats include those associated with hackers,
terrorists, theft, and other malicious actors and activities.
Unintentional threats may be attributed to accidents that are
caused by carelessness, lack of training, and so on. All of these
threats, both natural and man-made, are usually the types that
cause incidents or disasters. However, there are also threats to
the continuity management process itself.
Threats to the business’s ability to manage its continuity
and disaster recovery include incomplete or inadequate
planning as well as limited resources to carry out any
BCP/DRP activities. Because of regulatory considerations in
many cases, a business usually must have some degree of
business continuity planning accomplished; the real threat
centers on whether it is enough and adequately covers the
different facets of recovery and continuity that the business
must consider. Usually, inadequate planning and insufficient
resources committed to this area are a result of
shortsightedness on the part of the organization’s leadership
and management.
A wide variety of vulnerabilities can affect the ability of an
organization to respond to and recover from an incident or
disaster. The same vulnerabilities can also, in turn, affect the
organization’s ability to continue to function at some level or
degree after the disaster. Some of these vulnerabilities involve
the lack of resources, such as a lack of personnel, equipment
or facilities, or dedicated recovery resources. For instance, if
the organization has not acquired an alternate processing site,
there may be no way it can quickly recover its operations back
to a functional state. Other vulnerabilities include the lack of
training for personnel tasked with disaster recovery or
business continuity responsibilities. Additionally, there are
also process vulnerabilities. Process vulnerabilities are those
that result from a failure of the organization’s management to
adequately plan for, staff, and equip continuity management
efforts. For example, a lack of management commitment is a
vulnerability that will certainly lead to a lack of training,
resources, and personnel dedicated to continuity management.
An inadequate or nonexistent business impact assessment is a
vulnerability because an organization won’t be able to
adequately identify its critical processes or assets and
determine how the loss of those critical items impacts the
organization. Another critical vulnerability could be faced if
the organization has failed to adequately test the response
plan.
EXAM TIP Be familiar with the different business process
areas and their respective risk factors, threats, and
vulnerabilities. Remember that risk factors, while not a threat
or a vulnerability, contribute to the overall risk of the
organization by increasing or decreasing the likelihood or
impact of threats exploiting vulnerabilities or the
organization’s resilience to negative events.

Data Lifecycle Management


Most organizations produce a wide variety of documentation
—from publications for internal use, to confidential papers for
senior management, to publicly available documents. Without
proper controls, such documentation could be used to
compromise an organization’s security. Every organization
should have guidelines that ensure all documents produced by
the organization are classified, organized, and stored securely
to prevent their loss, damage, or theft.
As part of its governance and risk management programs,
an organization should develop data lifecycle management
programs. This process also contributes to the business
continuity planning we previously discussed. The organization
takes a good look at all its data, categorizes it in terms of
sensitivity and type (PII, proprietary, government classified,
and so on), and assigns classification values to it. To ensure
control over the protection and distribution of data, it needs to
be classified with a certain designation. This data classification
indicates what type of document it is, whether the information
it contains is confidential or can be made public, and to whom
it can be distributed. The classification also defines what
levels of data retention and storage are needed for that
document. Finally, policies must exist concerning the legal
status of data and what can be destroyed and what needs to be
retained.
Standards and Guidelines
To ensure the continuity of documentation across the
organization, a set of documentation standards and guidelines
should be introduced. These standards and guidelines can
serve as templates for all documentation to guarantee that
documents have the same look and feel and to ensure they’ll
all be distributed and stored securely, according to their scope
or sensitivity.
The standards and guidelines should address the following
topics, at a minimum:
• Data classification
• Document handling, retention, and storage
• Document disposal

Data Classification
An organization’s documentation can be voluminous,
comprising a variety of documents of varying levels of value
and importance. Depending on the type of document, the
amount of security and types of procedures used in storing and
distributing that document can greatly vary. Some documents
might be considered public, so they can be posted in a public
forum or distributed freely to anyone. Other documents might
be highly confidential and contain information that only
certain individuals should be allowed to see.
To aid in the document management effort, documents need
to be assigned security classifications to indicate their level of
confidentiality and then labeled appropriately. Each
classification requires different standards and procedures of
access, distribution, and storage. The classification also sets a
minimum standard of privileges required by a user to access
that data. If a user doesn’t have the necessary access privileges
for that classification of data, the user won’t be able to access
it. Typically, access is delineated using subjective levels such
as high, medium, and low. These should be agreed upon by
management based on the data’s sensitivity and the damage to
the organization if the data is subjected to unauthorized access.
Several levels of classification can be assigned, depending
on the type of organization and its activities. A typical
organization might have only two classifications: private and
public. Private classified documents are intended only for the
internal use of the organization and can’t be distributed to
anyone outside the organization. Public documents, however,
would be available to anyone. Government and military
institutions might have several levels of confidentiality, such
as Unclassified, Confidential, Secret, Top Secret, and so on.
Each level of classification represents the level of severity if
that information is leaked. For example, the lowest level
(Unclassified) means that the document is not considered
confidential or damaging to security and can be more freely
distributed (though not necessarily releasable publicly). At the
highest level (Top Secret), documents are highly restricted and
would be severely damaging to national security if they were
to fall into the wrong hands. Each document needs to be
assigned a classification depending on the sensitivity of its
data, its value to the organization, its value to other
organizations in terms of business competition, the importance
of its integrity, and the legal aspects of storing and distributing
that data.

EXAM TIP The type of security protections, access controls,


data retention, and storage and disposal policies to be used all
depend on a document’s security classification.

Document Handling, Retention, and Storage


Depending on the classification of a document, the procedures
and policies for handling and storing that document can be
quite different. For example, a document might incur certain
legal liabilities if it isn’t properly stored, distributed, or
destroyed. To ensure proper document management,
organizations have implemented data retention policies to help
reduce the possibility of legal issues.
Certain documents are required to be archived, stored, and
protected, while others should be disposed of after a certain
period. These policies must be created by senior management
and the legal department, which can define what retention
policies apply to different classifications of documents. The
data retention policy needs to be specific to your
organization’s data. It also needs to consider items that could
be legally damaging and information that could be damaging
to the business if it were lost, leaked, or stolen.
To protect documentation properly, it should be kept offsite
at a special document storage facility. In case of a disaster,
such as a fire at the organization facility, this will ensure that
all important documentation is secure and can be recovered.

Document Disposal
Document disposal can often be a tricky issue. In some cases,
a document needs to be destroyed to avoid future legal or
confidentiality ramifications. In other cases, it’s illegal to
destroy certain documents that are required by law as evidence
for court proceedings. Only your organization’s legal
department can decide on retention and disposal policies for
documents. Once decided on, these policies need to be
communicated to workers to ensure that sensitive documents
are either destroyed or retained as per their classification.
Without proper disposal techniques, the organization is
susceptible to dumpster diving attacks.

Data Retention Policies


Many organizations have been affected legally by archived e-
mail or data that offers evidence against them during court
proceedings. To prevent legal liabilities, organizations have
implemented data retention policies to help reduce the
possibility of legal problems arising from past messaging
communications and data.
Data retention policies should apply to electronic
information, such as files, e-mails, instant messages, and
traditional paper documentation. Some clashes might occur
between data retention policies and backup policies, where
certain files are required to be archived, while others should be
disposed of after a certain period. Only management and the
legal department can define which data is covered under either
policy. The data retention policy needs to be specific to your
organization’s information and consider items that could be
damaging legally, as well as information that can be damaging
to the business if lost. In the case of e-mail, the concept of data
retention becomes complicated because e-mail can contain file
attachments. Part of your policy might require that e-mail be
retained for a certain amount of time before deletion, while the
policy for actual electronic files could be different.

Hardware Disposal and Data Destruction


Policies
Any policies must also include guidance for the disposal of old
hardware that might contain data. As the lifetime of computers
is very low (three to five years), older equipment is constantly
swapped out for newer, faster machines with more capabilities
and resources. However, a critical security issue is apparent
regarding the proper disposal of these systems. Servers and
personal computers are typically returned with their original
hard drives, which could contain sensitive and classified data.
System administrators must follow a specific policy for the
removal and disposal of hardware to ensure that any media
containing data is completely erased or overwritten.
For electronic files, this process is more complicated.
Merely deleting a file or e-mail from a hard drive doesn’t
necessarily delete the data. Many operating systems use a
special recovery method that enables you to recover deleted
files easily. When a file is deleted, only the locator for the file
in the hard drive directory has been removed; the data itself
usually still exists in its original location. To ensure complete
destruction of data on magnetic media such as hard drives, the
media should be overwritten, or the drive physically
destroyed. Many “shredder” utilities are available that can
overwrite the contents of a hard drive with random data to
ensure that any information on the drive is unrecoverable.
Also, many high-security organizations, such as the military
and national security agencies, opt to destroy the drives
physically instead of using a shredding machine.

Systems Development Life Cycle


The systems development life cycle (sometimes known as the
SDLC, which confusingly is used as the acronym for software
as well) is essentially the entire life of a system, product, or
piece of software. The life cycle covers every single aspect of
a system or product, from the concept to development, from
implementation to disposal. There are several popular system
development life cycle models, including waterfall, iterative,
and Agile. We won’t cover any of these models here, as an in-
depth discussion on any one of them would fill an entire book.
However, we will mention some of the more generic parts or
phases of the SDLC and briefly describe them so that we can
put them in the context of risk factors, threats, and
vulnerabilities.

NOTE Some models are linear, in that they progress in a


sequential manner only, and some are cyclic in some way
(repetitive, recursive, or iterative), where a system can be re-
introduced into an earlier phase for updates or upgrades or to
fix problems or issues.
At the basic level, the SDLC consists of several phases that
include conceptualizing the system, discovering the
requirements for a system, designing its architecture,
developing the system, testing it as both a single unit and as
integrated with larger systems in its environment,
implementing the system, and, finally, disposing of the system
after it has reached the end of its useful life. Each of these
different phases of the life cycle has different aspects that
include planning, management, resourcing, and so on. Each
also has inherent risks. We’ll discuss these phases generically
in the next few paragraphs.

NOTE Some of the names we give to the different lifecycle


phases may vary among different lifecycle models, but in
general, the concepts are the same.
Software Development Life Cycle
It should be noted that in most organizations, the skills to
properly set up computers and develop software are
completely separate from one another. In fact, many
compliance frameworks consider it a serious risk to have
the software coders (often called developers) have access to
a live production environment—some focusing on the
ability of the software coders to implement their code in
production. This need to prevent this is called separation of
duties (sometimes segregation of duties). This came down
from the banking industry in that two people were required
to perform a task, which means that the likelihood of abuse
is drastically reduced. This is another critical factor for risk
assessors to take into account.
As a result of the differentiation, a software development
life cycle (SDLC) is often used as a separate term from
system development life cycle—two completely different
groups and sets of governance are part of the organization.
Typically, the CIO oversees an IT organization while a
CTO would oversee the software development within an
organization. As a result, for many organizations, SDLC
typically refers to the former and not the latter
interpretation. Both are extremely critical for many
organizations, but the approach is different even though the
goals may be the same.
Another factor today would be that with many cloud
technologies, the software development life cycle is resting
on cloud systems and system development is entirely up to
the cloud provider and not as much on the organization.
Cloud changes the whole relationship of systems
development life cycle to software development life cycle.

Planning
The first phase of the SDLC normally involves some type of
conceptual planning process, where the need for the system is
determined and a general idea is developed of what the system
needs to do and what purpose it will serve. Some models refer
to this as the initiation phase. During this phase, the feasibility
of developing or acquiring a system is studied and includes
considerations such as when the system is needed, how much
it might cost, what type of staffing it might need to develop,
implement, maintain it, what other systems it might need to
connect to or interface with, and so on. Security and privacy
professionals want to be involved in this phase of the life cycle
so that they can understand the basic concepts of the system
and provide feedback on any potential security or privacy
risks.
Often, it is the planning phase where a business case is
developed, to help the organization determine whether the
system (or changes to an existing system) is justifiable. A
business case describes the resources required to build (or
change) the system and the economic benefits expected to be
derived from the system.
The phrase move to the left or shift left describes the desire
for security and privacy professionals to be involved as early
as possible (as far to the left on a timeline) in the
conceptualization, requirements, and design of a system, in
order to help avoid situations where basic concept or design of
a system may be deeply flawed from a security or privacy
perspective.

Requirements
The next phase of the SDLC is generally the requirements
phase, and this phase is typically named as such in most
models. During this phase, different sets of requirements are
developed. These requirements might include functional
requirements, performance requirements, security
requirements, and business requirements. Requirements dictate
concrete terms, such as what a system is exactly supposed to
do, how it will do it, to what degree, and what standards it
must meet. Without a clear set of requirements, there can’t be
any good traceability back to what the system was supposed to
do in the first place. That’s why it’s very important to try to
accurately cover all the possible requirements and needs the
system may have to meet. This is also where the scope of the
development process is established. Security and privacy
professionals should be invited to develop security and privacy
requirements for the system, to ensure that later phases of the
project will include all required characteristics.

Design
The next few phases can be a bit different based on the model
under discussion and whether the product being developed is a
system or software. System developers would move from the
requirements phase into designing the architecture in terms of
developing a general high-level design of how the system is
supposed to work, what major components it might have, and
what other systems it might interface with. Software
developers similarly might design software architecture at a
higher level during this phase. As the SDLC development
process moves forward, this overall architecture is
decomposed down into smaller pieces until finally individual
components or pieces of code can be developed. Again, how
this design process progresses depends on which model is
being used. Security and privacy professionals should be asked
to review the design of the system to ensure that requirements
were properly represented.

Development
After the design phase, decisions must be made as to whether
to build a system or software or simply acquire it from a third
party. Some systems and software can be bought from other
developers, but some must be developed specifically for the
end application or end use. If the system is to be acquired from
some other source, and the design specifications are provided
to the best source, then a system or software that meets the
requirements and design will be provided. If the system is to
be developed, the next phase of the SDLC comes into play.
During this phase, the software is written, and systems are
assembled from individual components. Organizations can use
tools to examine a system’s source and object code to identify
any security-related defects that could be exploited by an
attacker.

Testing
Following the development phase, many SDLC models
include a test phase. In the test phase, different aspects of the
software and systems are tested. Many different tests can take
place during this phase. Some of these tests might involve unit
testing, which simply means to test an individual component
or unit of software at its most basic level for functionality and
performance. Integration testing, another type of testing,
usually involves testing the overall function and performance
of all the components of the system or piece of software
working together, as they would when assembled. During this
phase, other types of testing could take place, including
interface testing (testing different aspects of the system when
it interfaces with other separate systems in its environment)
and security testing (which may include compliance testing,
vulnerability testing, and even penetration testing). User
acceptance testing involves end users of the system
performing various functions to determine whether they will
accept the system in its current, developed state.

Implementation and Operation


Once a system has been tested and accepted, the
implementation phase usually follows. In this phase, systems
or software are put into production and used for their
originally intended purpose. Some development models
describe an overall implementation phase that includes the
day-to-day maintenance and operations of the system. Other
models move from the implementation phase to a more long-
term maintenance or sustainment phase for the product.
Regardless of how the phase is described in the model, during
these phases, the system is used, undergoes minor
maintenance and upgrades, and is periodically tested to make
sure it still meets its original design and requirements.

Disposal
Once a system has been in operation for a while, it may
eventually be superseded or replaced by a more efficient or
updated system. When the system is replaced or removed from
the environment, it is said to have entered the disposal phase.
Some models refer to this also as the retirement phase. During
this phase, the system is taken out of production, dismantled,
and is no longer used. Its components may be reused, or they
may be disposed of.

EXAM TIP While you will likely not be expected to know


the details of any specific SDLC model, be familiar with the
generic phases of the SDLC: Initiation, Requirements, Design,
Development, Testing, Implementation, and Disposal. Also,
keep in mind that different models may refer to these phases
by different names or even combine or separate phases out to
some degree.

SDLC Risks
Most of the risk factors inherent to the SDLC affect both the
entire model and each of the different phases separately. Since
the SDLC could be considered to have several different facets,
including a management process, an engineering framework,
and even a methodology, you could say that risk factors that
affect the SDLC are also common to other types of processes.
For instance, earlier, we discussed risk factors that affect
project and program management. These risk factors affect
scope, schedule, and cost. The SDLC suffers from similar risk
factors because each of the phases, as well as the SDLC, have
different scope, schedule, and cost elements. Each of these
phases can also be affected by risk factors that impact the
availability of resources (manpower, funding, equipment,
facilities, and so on), such as management commitment and
organizational structure.
Unique risk factors that affect the SDLC include those that
affect system changes, system configuration throughout the
life cycle, and those that affect releasing different versions of
the system as updates take place. Most of these elements occur
during implementation, maintenance, and sustainment of a
system but also can occur in other phases of the SDLC where
multiple versions of a system are fielded simultaneously, as
well as in models where there is a continuous iterative process
of updating and upgrading a system or software. Risk factors
that affect system changes include how well the change and
configuration management processes work and how changes
are implemented into the system. Change and configuration
management processes that are not well managed are risk
factors, because this could cause changes that are not
documented or not tested for security, functionality, or
performance. Additionally, factors such as the complexity of
the system, how the organization is structured to manage the
systems development process, and how rapid system changes
occur are also potential risk factors.
Threats to the SDLC manifest themselves when systems are
produced that are not interoperable or compatible with other
systems and their environment or systems are not secure.
Other threats might include systems that do not meet the
requirements they were originally intended to meet. These
threats would affect both the functionality and performance of
the system as well. Threats to the design process include faulty
design specifications as well as faulty requirements input from
the previous requirements phase. Most of the threats to the
SDLC come in the form of mismanagement,
miscommunication, incorrect expectations, and lack of a
commitment of resources or expertise.
Many different vulnerabilities can affect the SDLC; again, a
great many of them have been previously discussed as also
affecting the project or program management process. These
vulnerabilities affect scope, schedule, and cost, of course, but
can also affect the quality of the system or product. In
addition, the system’s security, functionality, and performance
are also affected by these different vulnerabilities. While
probably too many to list here, examples of vulnerabilities that
affect the SDLC start with a lack of firm requirements and
mixed expectations from the different system stakeholders. A
lack of documentation in all phases is also a significant
vulnerability to the entire SDLC, but particularly to the
requirements and design phases. Failure to develop solid
design specifications and systems architecture is a
vulnerability that can result in a faulty design that does not
meet system requirements. In the development phase, lack of
adequate consideration for system interfaces, as well as how
subcomponents fail to support higher-level components or
meet technical requirements, can result in a shoddy system or
software. Failure to test systems properly and thoroughly, as
well as their interaction with their environment, may mean that
serious functional or performance issues with the system are
not discovered until well after it is put into production.
Vulnerabilities in the implementation phase include faulty
implementation, lack of traceability to original requirements,
and failure to properly maintain a sustained system after it has
been put into production. And lastly, vulnerabilities associated
with the disposal or retirement phase of the SDLC can result in
systems that are not properly replaced or not securely disposed
of. This can cost the organization money and potential
liability.

Emerging Technologies
New or emerging technologies can present risks to
organizations simply because there are several different
important considerations when integrating the latest
technologies into the existing infrastructure. Many
organizations have an unfortunate tendency to rush out, buy,
and attempt to implement the latest and greatest technologies
on the market without careful planning or consideration of the
existing infrastructure and how it will react to the new
technologies. One of the primary considerations organizations
must look at is making a business case for the new technology,
which may be to fill a gap that the older technology does not
provide or to provide a capability that the organization must
now have to compete in the market space. In other words, the
organization really must justify new technologies to make
them worth the risk they could incur.
Emerging technologies have several risk factors inherent to
their integration into the existing infrastructure. If the
organization has been able to justify the implementation based
on a true business need for the emerging technology, it must
consider several risk factors. One of the major risk factors is
interoperability with existing infrastructure. Frequently, newer
technologies don’t always work properly with older systems
right out of the box; adjustments may need to be made to the
existing infrastructure to integrate the new technology, or even
bridging technologies may be needed to connect the two
together. Interoperability doesn’t just involve the right
connections; it can involve data formats and flows, security
methods, interfaces into other systems, and changes to
business processes. These considerations, and many others, are
risk factors that must be considered before acquiring and
integrating new technologies.
Another risk factor is security. New technologies may have
security mechanisms that are not necessarily backward
compatible with existing ones. Examples include encryption
algorithms and strengths, identification and authentication
technologies, integrity mechanisms, and even redundant or
backup systems. Additionally, the systems may involve a
learning curve that may intimidate users who must now learn
new security methods for the system. The human factor can be
a weak link in the security chain, so either lack of training or a
lack of adaptability to the new security mechanisms can
introduce risk.
Earlier, when we discussed the SDLC model, we pointed
out that system updates and changes can be risky if not
managed properly. Integrating new technologies into the
environment with older ones can introduce both intentional
and unintended changes into the environment as well,
affecting the stability of the organization’s SDLC with a
particular system. Therefore, change is also a risk factor. Even
in the disposal or replacement phase of the SDLC, introducing
new technologies to replace older ones can be problematic if
not planned and executed properly. New technologies that are
not adequately tested for functionality, performance,
integration, interoperability, and security may not be able to
adequately replace older systems, resulting in extended costs
and possibly even requiring an extension of the older systems’
life cycle.
Threats resulting from the introduction of new and
emerging technologies into the existing infrastructure are
numerous. If the organization has failed to adequately plan for
the new technology, these threats can become significant.
Some of these threats include untested or unproven
technologies, non-interoperability, incompatible security
mechanisms, and suitability of the technology for use in the
organization. The organization could also incur additional
costs and require more resources due to faulty implementation.
These threats can be minimized through careful planning and
by integrating new technologies using a stable SDLC model.
As with threats, vulnerabilities associated with emerging
technologies are numerous as well. Vulnerabilities could
include a lack of trained staff committed to managing and
implementing the new technology. Lack of adequate project
planning is also a serious vulnerability that could affect the
organization’s ability to effectively integrate new technologies.
Another vulnerability could be a weak support contract or
another type of warranty, guarantee, or support for a new
technology or system. Most of these vulnerabilities appear
when a new technology is first implemented and tend to
become mitigated or lessened as the technology is integrated
into the existing infrastructure, but they still exist.

EXAM TIP The key areas of concern with emerging


technologies are interoperability and compatibility. These two
concerns affect the security, functionality, and performance of
new technologies when they are installed into an existing
infrastructure.

Information Security Concepts,


Frameworks, and Standards
In order to successfully sit for the CRISC exam, you should be
familiar with some basic information security concepts. You
can’t be expected to know how to manage risk in a security
environment if you don’t understand the basics of information
security in the first place. Now, we’re going to assume you
have some level of experience already as an information
security professional, since risk management is a significant
portion of (and a logical career progression from) the
information security profession. You may also have had some
level of experience in specific risk management processes at
some point during your career. As such, we’re not going to go
into great detail on the basic information security concepts in
the upcoming sections; this will just serve as a quick refresher
to remind you of certain security concepts. We’ll also review a
few key control frameworks in detail, including the NIST Risk
Management Framework (RMF) and COBIT 2019, and how
these frameworks are used in managing risk. Additionally,
you’ll find that this chapter covers more material than you
might find on the exam; this is for two important reasons.
First, it’s important that you understand foundational and
conceptual knowledge about controls and some of the relevant
control frameworks you will find on both the exam and in the
real world as a risk and control assessor. Second, this book is
intended to be not only a study guide for the exam but also a
comprehensive reference you will use even after you have
passed the CRISC exam.
You may learn traditional information security doctrine, as
well as fundamental information security knowledge, from
various training courses and on-the-job experience over the
years. One such doctrine teaches that there are three
fundamental information security goals. These goals are what
we’re striving for as risk and information security
professionals; they are confidentiality, integrity, and
availability. You’ll sometimes see these three terms strung
together as an acronym, such as the CIA triad or, occasionally,
the AIC triad, depending on the different information security
literature you read. In any event, these three goals are what we
want to achieve for all our information systems and data. They
are also characteristics we want to ensure all our systems,
processes, procedures, methods, and technologies display.
Popular security theory sets forth these three overarching
security goals but also provides for auxiliary elements that
support these goals in various ways. These are concepts that,
both individually and combined, help us as security
professionals to ensure we maintain data confidentiality,
integrity, and availability, as well as protect our systems from
unauthorized use or misuse. We’ll discuss all these different
security elements and other concepts, as well as how they
support three primary goals of information security, in the next
few sections.

Confidentiality, Integrity, and


Availability
Confidentiality is the goal of keeping information systems and
data from being accessed by people who do not have the
authorization, need-to-know, or security clearance to access
that information. In other words, confidentiality means that
only authorized individuals and entities should be able to
access information and systems. Confidentiality can be
achieved through a number of security protection mechanisms,
such as rights, privileges, permissions, encryption,
authentication, and other access controls. If confidentiality of
data or information systems is breached, we get the opposite of
confidentiality, which is unauthorized disclosure.
Unauthorized disclosure is a risk to data and information
systems, and one we as security professionals struggle very
hard to protect against.
Integrity is the characteristic of data that describes the state
in which a system or its data has not been subject to
unauthorized modification or alteration. Data integrity means
that data is left in the same state as it was when it was stored
or transmitted. Therefore, when it is accessed again or
received, it should be identical to the data that was originally
stored or transmitted. Integrity is achieved in several ways, by
using checksums, message digests, and other verification
methods. Data alteration is the opposite of integrity,
particularly when the modification has not been authorized by
the data owner. Data modification or alteration can happen
accidentally, such as when it is inadvertently changed due to
human error or faulty transmission media. It can also happen
intentionally (which is usually malicious in nature when this
modification is unauthorized) by direct interaction with data
during storage or transmission (during an attack, for example).
This risk to data affects whether the data can be trusted as
authentic or true, whether it can be read as intended, or
whether it is corrupt.
Availability is the property of systems and data to be
accessible to authorized users at any time or under any
circumstances. Even if data is kept confidential, and its
integrity is kept intact, it still does us no good if we can’t
access it when we need it to perform critical business
functions. Availability ensures we have this data (and the
information systems that process it) at our fingertips. Just as
confidentiality and integrity have their opposites, data
destruction and denial of service are the opposite of
availability. These risks to our information systems could
prevent authorized consumers of that data or users of that
information system from performing their jobs, thus severely
impacting our business operations.
EXAM TIP You will need to understand the definitions of
the goals of information security—confidentiality, integrity,
and availability—very well for the exam. Almost everything in
information risk management supports those three goals, either
directly or indirectly.

Access Control
As an information security professional, you probably already
know that a security control is a security measure or protection
applied to data, systems, people, facilities, and other resources
to guard them from adverse events. Security controls can be
broken down and categorized in several ways. Access controls
directly support the confidentiality and integrity goals of
security, and indirectly support the goal of availability. Access
control essentially means that we will proactively ensure that
only authorized personnel are able to access data or the
information systems that process that data. Access controls
ensure that only authorized personnel can read, write to,
modify, add to, or delete data. They also ensure that only the
same authorized personnel can access the different information
systems and equipment used to store, process, transmit, and
receive sensitive data.
There are several different types of access controls,
including identification, authentication, and authorization
methods, encryption, object permissions, and more.
Remember that access controls can be administrative,
technical, or physical in nature. Administrative controls are
those implemented as policies, procedures, rules and
regulations, and other types of directives or governance. For
example, personnel policies are usually administrative access
controls. Technical controls are those we most often associate
with security professionals, such as firewalls, proxy servers,
VPN concentrators, encryption techniques, file and folder
permissions, and so on. Physical controls are those used to
protect people, equipment, and facilities. Examples of physical
controls include fences, closed-circuit television cameras,
guards, locked doors, gates, and restricted areas.
In addition to classifying controls in terms of
administrative, technical, and physical, we can also classify
access controls in terms of their functions. These functions
include preventative controls, detective controls, corrective or
remedial controls, deterrent controls, and compensating
controls. All the different controls can be classified as one or
more of these different types of functions, depending on the
context and the circumstances in which they are being used.
Controls were described in more detail in Chapter 3.

Data Sensitivity and Classification


Asset is a general, all-encompassing term that could include
anything of value to an organization. The term asset can be
applied to data, systems, capabilities, people, equipment,
facilities, processes, proprietary methods, and so on; it is
anything the organization values and desires to protect.
Organizations normally determine how important their assets
are to them and how much protection should be afforded to
those assets. For example, intellectual property is an extremely
valuable asset to the organization and is normally well-
protected. This is really the basic fundamental concept of risk
management: how much security or protection a particular
system or piece of data requires, based on how likely it is that
something bad will happen to it, balanced with what the
organization can really afford to spend on the protection for
that asset. In order to make reasonable decisions on how much
security an asset needs, the organization has to decide how
much the asset is worth to it. We’ll discuss worth in terms of
dollars a bit later in the chapter, but for now let’s look at it
from a perspective of asset sensitivity. In terms of sensitivity,
you’ll usually see the term data sensitivity in particular, but we
could also broadly apply sensitivity to any asset in an
organization.
Data (or other asset) sensitivity refers to how much
protection the organization feels a particular system or piece of
data requires, based on its value to the organization and the
impact if it were lost, stolen, or destroyed. For example,
information published on the organization’s public website or
in the company newsletter is public knowledge and is usually
easily retrievable if, for some reason, the hard disk containing
that data fails or is erased. Since the data is public, we may not
consider that data to be very sensitive in nature and therefore
require less protection for it than other types of data. On the
other hand, customer order data is extremely important to the
organization, simply because its business operations depend
on that data in order to function and turn a profit, so it makes
reasonable sense that the organization would spend a little bit
more time, money, and effort in protecting that particular data.
Therefore, its sensitivity, or classification level, would be
considered somewhat higher than public data. Generally, the
higher the sensitivity of the data, the more protection it is
given.
In basic security classes, you typically learn about the
different classifications of data found in both commercial
organizations and government ones. In commercial
organizations, typical data sensitivity labels include Private,
Company Sensitive, Proprietary, and so on. In the U.S.
government, data sensitivity levels include Confidential,
Secret, and Top Secret, and are classified based on the level of
damage to the security of the United States that could be
incurred if data at these various classification levels was
disclosed or lost. Remember that data sensitivity is driven by
the value of the data to the organization, the impact if it is lost,
stolen, or destroyed, and balanced by the commitment of
resources the organization is willing to provide to protect that
data. Data sensitivity and classification policies specify the
different formal levels of sensitivity in the organization and
what those levels require in terms of protection.

Identification and Authentication


Identification and authentication are often misunderstood
terms. They are related, to be sure, but they are not the same
thing and really shouldn’t be used interchangeably by a
knowledgeable security professional. Identification refers to
the act of an individual or entity presenting valid credentials to
a security system in order to assert that they are a specific
entity. When you enter a username and password into a
system, for example, or insert a debit card into an automated
teller machine and enter a personal identification number
(PIN), you are identifying yourself. Authentication, on the
other hand, is the second part of that process, where your
identity is verified with a centralized database containing your
authentication credentials. If the credentials you have
presented match those in the authentication database, you are
authenticated and allowed access to the network or resource. If
they do not match, you are not authenticated and are denied
access to the resource.
There are several different methods of identification and
authentication, including single factor (such as username and
password, for example) and multifactor, which consists of two
or more of the following: something you know (knowledge
factor), something you have (possession factor), or something
you are (biometric or inherence factor). Authentication also
uses a wide variety of methods and technologies, such as
Kerberos and 802.1X.

Authorization
Authentication to a resource doesn’t automatically guarantee
you have full, unrestricted access to a resource. Once you are
authenticated, the system or resource defines what actions you
are authorized to take on a resource as well as how you are
allowed to interact with that resource. Authorization is what
happens once you’ve successfully identified yourself and have
been authenticated to the network. Authorization dictates what
you can or can’t do on the network, in a system, or with a
resource. This is usually where permissions, rights, and
privileges come in. In keeping with the concept of least
privilege, users should only be authorized to perform the
minimum actions they need in order to fulfill their position’s
responsibilities. Authorization has a few different components.
First, there is need-to-know. This means that there must be a
valid reason or need for an individual to access a resource, and
to what degree. Second, an individual may have to be trusted,
or cleared, to access a resource. This may be accomplished
through a security clearance process or non-disclosure
agreement, for example.

EXAM TIP Understand the differences between


identification, authentication, and authorization. Remember
that identification is simply presenting credentials, whereas
authentication is verifying them. Authorization dictates what
actions an individual can take on a system once authentication
has occurred.

Accountability
Accountability means that a person is going to be held
responsible for their actions on a system or with regard to their
interaction with data. Accountability is essentially the
traceability of a particular action to a particular user. Users
must be held responsible for their actions, and there are
different ways to do this, but it is usually ensured through
auditing. First, there must be a unique identifier that is tied
only to a particular user. This way, the identity of the user who
performs an action or accesses a resource can be positively
established. Second, auditing must be properly configured and
implemented on the system or resource. What we are auditing
is a user’s actions on a system or interactions with a resource.
For example, if a user named Sam deletes a file on a network
share, we want to be able to positively identify which user
performed that action, as well as the circumstances
surrounding the action (such as the time, date, from which
workstation, and so on). This can only be accomplished if we
have auditing configured correctly and take the time to review
the audit logs to establish accountability.
NOTE Although related, accountability is not the same thing
as auditing. Accountability uses auditing as just one method to
ensure that the actions of users can be traced to them and that
they are held responsible for those actions. Other methods,
such as non-repudiation, are used as well.

Non-Repudiation
Non-repudiation is closely related to accountability. Non-
repudiation ensures that the user cannot deny that they took an
action, simply because the system is set up such that no one
else could have performed the action. The classic example of
non-repudiation is given as the proper use of public key
cryptography. If a user sends an e-mail that is digitally signed
using their private key, they cannot later deny that they sent
the e-mail since only they are supposed to have access to the
private key. In this case, the user can be held accountable for
sending the e-mail, and non-repudiation is ensured.
Note that there is no hard and fast rule about mapping
security elements and access controls to security goals; all of
these elements and controls can support any one or even more
than one goal at a time. For example, encryption, a technical
access control, can support both confidentiality and integrity at
the same time.

NOTE Although other texts may describe the supporting


elements of the security goals differently, the basic ones we’ve
described here are very common and directly support the three
goals of confidentiality, integrity, and availability.

Frameworks, Standards, and Practices


Managing risk is not an ad-hoc process. It can be a complex
effort and involves establishing a formal program with
responsible people leading it. It requires developing
procedures and processes that are defined, repeatable, and
defendable. Fortunately, you don’t have to reinvent the wheel;
most of this work has already been done for you in the form of
established frameworks, methods, standards, and practices.
One of the first things you’ll want to do when establishing a
risk program is to understand what type of framework,
processes, standards, and practices you will use since there is a
variety to choose from. You must try to use the one that fits
your organization the best, and you can’t do that unless you
have at least a basic understanding of the more defined,
standardized ones used in the industry. Let’s take a moment
and discuss the difference between frameworks, standards, and
practices.

Frameworks
A framework is a generally overarching methodology for a set
of activities or processes. It may not get into the detailed
processes and procedures; instead, it provides for a 500-foot
view of the general direction and steps used to build a more
detailed program or process. A framework is used as an
overall architecture for a greater effort. A framework has
characteristics that include defined steps and repeatability, and
it can be tailored based on the organization’s needs. In terms of
a risk management framework, you may have a set of general
steps defining how to approach risk management, which
include listing the processes and activities necessary to build
such a program or effort. You would then break down these
larger steps into specific supporting procedures for this effort
based on the needs of your organization and using standards
(described next). Frameworks are typically selected and
adopted at the strategic level of corporate management and
governance.

Standards
A standard is a mandatory set of procedures or processes used
by the organization and usually fits into an overall framework.
Standards often define more detailed processes or activities
used to perform a specific set of tasks. Standards are used for
compliance reasons and made mandatory by an organization or
its governance. The National Institute for Standards and
Technology (NIST) standards are mandatory for use by the
United States federal government, for instance, but are
published as an option for private organizations and industries
to adopt if they so choose. If an organization adopts the NIST
standards for risk management, for example, the organization
may make them mandatory for use by its personnel. Then all
processes and activities for a given effort within the
organization would have to use and meet those standards.
Some standards define the level of depth or implementation of
a security control or measure. The Federal Information
Processing Standards (FIPS) for cryptography and encryption
are an example of this; they set forth the different levels of
encryption strength for various cryptography applications that
may be required in certain circumstances. So, if you create
security policies and procedures for implementing
cryptography within the organization, the FIPS standard could
tell you to what level those policies and procedures must be
implemented.

Practices
A practice is a normalized process that has been tried and
proven as generally accepted within a larger community.
Practices could also be developed by a standards organization
or a recognized authority regarding a particular subject or
particular process. Professional industry organizations or
vendors often develop practices documents. You might also
see “best practices” promulgated by various industries or
organizations, for example. Practices are not usually
mandatory but could be made mandatory by the corporate
management or other governance if they were so inclined.
The next few sections give more detailed examples of some
of the formal frameworks and standards you should be familiar
with for the exam and in real life as a risk management
professional. We recommend you pay particular attention to
the ones developed and published by ISACA; these will likely
be present in some form on the exam. Of course, in this book,
we’re only going to give you a brief overview of each, and you
should take the time to review the actual standards and
frameworks in depth before you sit for the exam.

NIST Risk Management Framework


The NIST Risk Management Framework (RMF) is a seven-
step methodology that provides for risk management all the
way through the information systems life cycle. The steps for
the RMF are briefly described in the following sections.

Step 1: Prepare
The first step, Prepare, has the purpose of carrying out
essential activities to help prepare all levels of the organization
to manage its security and privacy risks using the RMF. It
involves identifying key risk management roles, establishing
the organizational risk management strategy, determining the
organization’s risk tolerance, assessing the organization’s risk
assessment, developing the organizational strategy for
continuous monitoring, and identifying the implemented
common controls.

Step 2: Categorize
Step 2, Categorize, involves inventorying the types of
information on target systems and assigning categorization
levels to that information based on the level of impact if the
security goals of confidentiality, integrity, and availability
were affected or compromised for the information on the
system. This step uses subjective values of high, medium, and
low to assign values to each of the three goals for a particular
type of information. Types of information processed on the
system could include business-sensitive, financial, protected
health information, and so on. FIPS 199, “Standards for
Security Categorization of Federal Information and
Information Systems,” as well as NIST Special Publication
800-60, “Guide for Mapping Types of Information and
Information Systems to Security Categories,” provide detailed
guidance on categorizing information systems.

Step 3: Select
Based on these individual values, as well as an aggregate of
them, the applicable security controls you would assign to this
information system would be accomplished in Step 3, Select.
This step provides baselines of security controls based on the
high, medium, and low values assigned during step 2. If the
aggregate value of information or system has been rated as
high, for example, the high baseline of security controls is
employed for that system. Once a security control baseline has
been established, the organization has the latitude and
flexibility to add or subtract security controls from the baseline
as it sees fit based on different factors, including the
applicability of some controls, the environment the system
operates within, and so on. The selected controls can be found
in the supporting NIST Special Publication 800-53, revision 5,
“Security and Privacy Controls for Information Systems and
Organizations,” which contains a catalog of all the NIST
controls.

Step 4: Implement
In Step 4 of the RMF, Implement, the selected controls are
applied to the information systems and data is processed on
those systems. This is a large process that can cover a good
deal of the life cycle of the system in question, and it may take
significant time and resources. In this step, the organization is
essentially securing the information system against any
validated threats and protecting identified vulnerabilities.

Step 5: Assess
Step 5, Assess, is where a lot of security professionals who
manage certification and accreditation activities or perform
risk assessments come into the picture. During this step, the
controls the organization selects for the information system are
formally assessed, verifying that they were implemented
correctly and validating whether they perform as they were
designed. They are assessed based on their effectiveness in
protecting against the threats they were implemented to protect
against. During this step, the system is assessed in its current
state, with all existing controls and mitigations in place. Based
on the assessment findings, there may be recommendations for
further controls and mitigations, as well as alterations to the
existing security posture for the system. In this step, the level
of risk to the system and its data is normally analyzed and
determined.

Step 6: Authorize
Step 6, Authorize, involves the decision from the entity in
charge to authorize a system to be implemented and put into
operation. This decision is based on various factors, including
the level of risk assessed during step 5, the risk appetite the
organization has settled on, and the tolerance for risk the
organization is willing to accept. The decision to authorize a
system for use may also come with caveats, including
conditional authorization based on the continued mitigation
and reduction of risk by the system or data owner. This
authorization is a formal authority for the system to operate,
made by someone with the legal authority to make that
decision. It is typically in writing and only valid for a specified
period, after which the system must be reassessed for risk and
control compliance.

Step 7: Monitor
Continuous monitoring of security controls defines step 7 in
the RMF; just because an authorization decision is rendered
doesn’t mean the system will now be operated forever without
continually monitoring its security posture for new or changed
risks. Existing controls should be monitored for continued
compliance and effectiveness against identified threats. New
risks will be occasionally discovered for the system as new
threats and vulnerabilities are identified, and the system will
have to be reauthorized after a certain period. Note that the
RMF is a cyclical process; all these steps will be accomplished
again for each system at various times over its life cycle.

ISO 27001/27002/27701/31000
Whereas the NIST RMF is very much an American
framework, the International Organization for Standardization
(ISO) frameworks are used globally. The ISO family is largely
focused on keeping information assets secure, ensuring
privacy, and managing risk across the following major
documents:
• ISO/IEC 27000:2018 Provides the overview of
information security management systems (ISMS).
• ISO/IEC 27001:2013 Specifies the requirements for
establishing, implementing, maintaining, and
continually improving an ISMS within the context of
the organization. It also includes requirements for the
assessment and treatment of information security risks
tailored to the needs of the organization.
• ISO/IEC 27002:2022 Gives guidelines for
organizational information security standards and
information security management practices, including
the selection, implementation, and management of
controls, taking into consideration the organization’s
information security risk environment(s).
• ISO/IEC 27701:2019 Specifies requirements and
provides guidance for establishing, implementing,
maintaining, and continually improving a privacy
information management system (PIMS).
• ISO 31000:2018 Provides guidelines on managing risk
faced by organizations.

COBIT 2019 (ISACA)


COBIT (formerly an acronym for Control Objectives for
Information and Related Technologies) is a framework
developed by ISACA and facilitates the governance of
enterprise information and technology. This framework has
been around for several years and through several iterations. It
also provides for integration of other popular frameworks and
standards, including The Open Group Architecture Framework
(TOGAF), the Project Management Body of Knowledge
(PMBOK), the Information Technology Infrastructure Library
(ITIL), PRojects IN Controlled Environments 2 (PRINCE2),
the Committee of Sponsoring Organizations of the Treadway
Commission (COSO), and the many International
Organization for Standardization (ISO) standards. This
interoperability enables new users of COBIT to leverage any
of these other standards they have already been using in their
adoption of COBIT.
COBIT consists of two layers in its model, governance and
management, which further break down into a total of 40
separate objectives. Table 4-3 quickly summarizes these layers
and their respective objectives.
Table 4-3 COBIT 2019 Governance and Management
Objectives
Note that while COBIT covers a variety of business and IT
processes and areas, those specific to risk management happen
at both layers—governance and management—and are tightly
integrated with other processes. COBIT, in this regard, is not a
risk management framework per se, as is the NIST RMF, but
offers more of a broader view of management and governance
across all major areas of a business. The next topic we cover,
ISACA’s Risk IT Framework, supports COBIT and provides a
more granular view of risk management practices and
activities.

NOTE Understand that while COBIT is important to the


overall risk discussion, it is not a risk framework itself. It does,
however, support management and governance of IT as well as
other critical business areas. It also leads to a more detailed
discussion on the ISACA Risk IT Framework, which does deal
with IT risk.

The Risk IT Framework (ISACA)


The Risk IT Framework is a more concise, risk-related set of
processes than that offered by the related framework COBIT
2019. While COBIT covers the “big picture” of governance
and management processes that support risk management
programs in the organization, the Risk IT Framework gets
more into the key processes of risk management, such as risk
governance, evaluation, and response. The Risk IT Framework
is also a mere summary of ISACA’s The Risk IT Practitioner
Guide, available to ISACA members, which is an even more
in-depth treatment of the processes and activities encountered
during risk management.
The Risk IT Framework comes from traditional risk
management principles of various enterprise risk management
(ERM) standards and describes activities and processes
thought of as best practices in the industry. It provides a
starting place for the establishment of these processes—sort of
a map to navigate from a nonexistent or immature risk
management program to a formalized, defined set of
processes. The Risk IT Framework focuses more on the
business risks of using IT in the organization’s structure and
how risk is involved with the gap often found between IT
implementation and business goals. Table 4-4 lists the
different domains of the Risk IT Framework model, with each
of their three major processes.

Table 4-4 Domains and Processes of ISACA’s Risk IT


Framework
Keep in mind we’ve only covered a few of the risk-related
frameworks and standards available in the industry. Also, be
aware that we’ve only scratched the surface of these bodies of
knowledge here in this chapter; a full discussion of each one of
them is quite beyond the scope of this book. You should obtain
and review these publications in depth before you sit for the
exam. There are also many other available frameworks and
standards developed and promulgated by other professional
organizations, government entities, industries, vendors, and so
on. You should be familiar with as many of these as is relevant
to your work since they help you turn risk management from
“magic” into an art and science for your organization. The
frameworks and standards we have described earlier are the
ones most relevant to your studies for the CRISC exam.
EXAM TIP While you may not be expected to know the
intricate details of each framework described here, it will be
helpful to know at least the basic characteristics and
descriptions of each. You may be asked to identify a particular
characteristic of a framework on the exam.

Security and Risk Awareness


Training Programs
Both security awareness and risk awareness training programs
are critical controls to reduce risk within an organization. They
can cover a whole range of topics, including phishing, data
handling, data sensitivity, compliance requirements, wireless
challenges, how data is lost, how to submit incidents, and so
on. Both help to improve the risk posture of organizations at
an individual level by increasing general employee awareness
of threats and required practices as well as leader awareness of
organizational risks. Not having any training is an indication,
from a risk perspective, that people may not know how to
handle different types of risks or even how to recognize risks.
Awareness programs are a very necessary part of risk
management. They can’t be viewed as simply just another
two-hour training session to check a box for management or
compliance. Awareness is essential because it helps form and
maintain the organization’s risk culture. It also educates
personnel at all levels of the organization, including
employees and other workers, managers, and senior
leadership, on the organization’s risk strategy, its appetite and
tolerance levels for risk, its risk management plan, and other
relevant topics necessary to manage risk in the organization.
Beyond the education on organizational governance and risk
management processes, awareness training can give all
members of the organization the knowledge they need to better
identify, assess and evaluate, and respond to risk. Awareness
training may be required for compliance with governance in
some cases, but even if it’s not, it should be considered critical
to the overall risk management strategy in the organization and
given due consideration in the organizational priority list. The
next two sections discuss the different tools and techniques
used in awareness training and how to develop an awareness
program within an organization.

Awareness Tools and Techniques


Like most training, awareness training should meet several
criteria. First, it should be geared toward specific groups of
audiences. This might include basic training that everyone
receives, more advanced training for managers or senior
leaders, and in-depth training for personnel with assigned risk
management responsibilities, such as risk owners, risk
analysts, and so on. Second, training shouldn’t be a one-time
event. Periodic, recurring training is a good idea simply
because it can be used to reinforce and refresh stale knowledge
and bring workers up to date on the latest tools, techniques,
and risk considerations. Finally, awareness training should be
well organized and conducted by knowledgeable instructors,
both from inside and outside the organization. Internal trainers
can give the benefit of the organization’s specific views on risk
culture, appetite, and tolerance, while external trainers bring
the benefit of objective knowledge and risk management
methods from the industry.
The subject of the training depends on the audience, of
course. The basics may include familiarization training with
rules and regulations regarding risk within the organization as
well as the basic steps of risk management. Basic concepts and
definitions may also be provided in familiarization training.
Specific training on risk management techniques and tools
may be reserved for those workers who have direct risk
management responsibilities. There also may need to be
training for senior leadership on how to develop risk
management strategies and plans for the organization.
An organization can deliver awareness training in several
different ways, and using various combinations of training
types can help to deliver an effective training program.
Classroom training is, of course, one standard method. Other
methods might include individual-based training that comes
from reading, computer-based training, and so on. Workers
might also be required to read a risk management handbook
that defines the different rules and regulations covering risk
within the organization. Specialized training on risk
management might have to be provided by an external training
provider for those individuals with defined risk management
responsibilities.

Developing Organizational Security and


Risk Awareness Programs
Establishing the security and risk awareness programs in an
organization can be a challenge. One way organizations fail is
to simply direct someone to develop a training program, when
the organization has not even established its risk management
strategy or plans. Developing the organization’s approach for
risk is an essential first step before implementing awareness
training. The organization must develop, formally if possible,
its stance on risk appetite and tolerance as well as its risk
management strategy. It should decide what risk management
methodologies it will use as well as what standards and
frameworks. Only then can a training program be developed
based on a good, solid risk management framework within the
organization.
Establishing the awareness training programs also requires
buy-in from management at all levels. The program should be
adequately funded, and allowances should be made for
workers to be able to take part in the training. Management
should be committed to awareness training as part of its
overall risk management strategy. Sufficiently trained and
experienced instructors or a training program manager should
be selected to develop and maintain the program. Finally, the
training program should articulate not only the risk culture of
the organization but also the different risk management needs
the organization has. These might include specific risk factors,
threats, vulnerabilities, and so on, considered when the
training is developed. Workers that participate in awareness
training should be able to easily put into practice the concepts,
tools, and techniques they learn. Additionally, the training
program should be periodically evaluated for effectiveness, as
well as updated with current risks, governance, tools, and
techniques.
Beyond initial or recurring awareness training, ongoing
communication within the organization is a must for
effectively managing both security and risk awareness.
Workers in general, but also specifically those with key risk
management duties, should be given information on an
ongoing basis regarding organizational risks and how to
manage and deal with them. Obviously, some information
would be restricted from the general organizational population,
but specific instances of threats and vulnerabilities, risk
factors, and so on should be provided to risk managers in key
areas so they can keep updated on the most current risk
posture for the organization.

EXAM TIP While training programs are sometimes the first


things that are cut from the budget or the last things to be
developed in a program, don’t underestimate the importance of
awareness training within the overall risk management
strategy. Training not only can make the risk management
process within the organization more effective, it can also
actually help to reduce or mitigate risk because it educates
people about the subject, and this alone may minimize risk.

Data Privacy and Data Protection


Principles
Throughout this chapter, we have discussed the core concepts
of information security that any program should be striving
for. This section outlines key data privacy and data protection
principles and associated policies and procedures that
organizations should consider when aiming to reduce risk.
Security Policies
Security policies and procedures are official organization
communications created to support those critical principles of
data privacy and data protection. These policies and
procedures define how the workers must interact with the
organization’s computer systems to perform their job
functions, how to protect the computer systems and their data,
and how to service the organization’s clients and constituents
properly. Essentially, these policies define how an organization
will implement the principles that must be upheld.

Access Control
The following access control principles and policies help
provide a consistent organizational structure and procedures to
prevent internal fraud and corruption in your organization:
• Least privilege The least privilege principle grants
users only the access rights they need to perform their
job functions. This requires giving users the least
amount of access possible to prevent them from abusing
more powerful access rights.
• Separation of duties The separation of duties principle
ensures that one single individual isn’t tasked with high-
security and high-risk responsibilities. Certain critical
responsibilities are separated between several users to
prevent corruption.
• Job rotation Job rotation provides improved security
because no worker retains the same amount of access
control for a position indefinitely. This prevents internal
corruption by workers who might otherwise take
advantage of their long-term position and security
access.
• Mandatory vacation A mandatory vacation policy
requires employees to use their vacation days at specific
times of the year or to use all their vacation days
allotted for a single year. This policy helps detect
security issues with employees, such as fraud or other
internal hacking activities, because the anomalies might
surface while the user is away. Increasingly,
organizations are implementing a policy requiring
mandatory administrative leave for situations in which
an employee is under any sort of investigation, systems
related or otherwise.

Physical Access Security


As part of its overall access control, your organization must
have strong physical access controls and an associated policy,
and it must ensure that all workers are educated on the policy’s
use.
Depending on the security level of the organization,
physical security may include guarded or unguarded entrances.
Even on guarded premises, the use of security access cards
ensures that only identified, authenticated, and authorized
persons can enter a facility. Each security access card is coded
with the authorization level of the user, who will be able to
access only areas of the facility required by their job function.
For example, only network and systems administrators would
be able to access a server and network communications room
with their access card.
Workers must be trained to always close automatically
locking doors behind them and not allow unidentified people
to follow them through (known as tailgating). Most security
access cards include a photograph of the cardholder to further
identify users in the event they are challenged for their
identity. Workers must be encouraged to report suspicious
individuals within the premises who are unfamiliar and do not
have proper identification.
A published organizational security policy that addresses
physical access allows your workers to have proper knowledge
of security procedures and to be equally active in the
responsibility for physical security.

Network Security
Several policies provide standard guidelines for implementing
network security principles within an organization and
encompass areas such as the use of the Internet and internal
network, data privacy, security incident response, human
resources (HR) issues, and document security. These policies
are often enforced by technical controls such as data loss
prevention (DLP) tools that monitor for breaches of policy and
issue a report when a breach occurs. Other tools may alert an
administrator to machines joining the network that don’t meet
security requirements (having out-of-date antivirus signatures,
for example) or report to an administrator when an
unauthorized machine has been added to the network or an
inappropriate website has been visited.

Acceptable Use
An acceptable use policy (AUP) is a policy consisting of a set
of established guidelines for the appropriate use of computer
networks within an organization. The AUP is a written
agreement, read and signed by workers, that outlines the
organization’s terms, conditions, and rules for Internet and
internal network use and data protection.
An AUP helps educate workers about the kinds of tools
they will use on the network and what they can expect from
those tools. The policy also helps to define boundaries of
behavior and, more critically, specifies the consequences of
violating those boundaries. The AUP also lays out the actions
that management and the system administrators may take to
maintain and monitor the network for unacceptable use, and it
includes the general worst-case consequences or responses to
specific policy violations.
Developing an AUP for your organization’s computer
network is extremely important for both organizational
security and limiting legal liability in the event of a security
issue. An AUP should cover the following issues:
• Legality The organization’s legal department needs to
approve the policy before it’s distributed for signing.
The policy will be used as a legal document to ensure
that the organization isn’t legally liable for any type of
Internet-related incident and any other transgressions,
such as cracking, vandalism, and sabotage.
• Uniqueness to your environment The policy should be
written to cover the organization’s specific network and
the data it contains. Each organization has different
security concerns—for example, a medical facility
needs to protect data that differs significantly from that
of a product sales organization.
• Completeness Beyond rules of behavior, the AUP
should also include a statement concerning the
organization’s position on personal Internet use on
company time.
• Adaptability Because the Internet is constantly
evolving, the AUP will need to be updated as new
issues arise. You can’t anticipate every situation, so the
AUP should address the possibility of something
happening that isn’t outlined.
• Protection for employees If your employees follow the
rules of the AUP, their exposure to questionable
materials should be minimized. In addition, the AUP
can protect them from dangerous Internet behavior, such
as giving out their names and e-mail addresses to
crackers using social engineering techniques.
The focus of an acceptable use policy should be on the
responsible use of computer networks and the protection of
sensitive information. Such networks include the Internet—for
example, web, e-mail (both personal and business), social
media, and instant messaging access—and the organization’s
intranet. An AUP should, at a minimum, contain the following
components:
• A description of the strategies and goals to be supported
by Internet access in the organization
• A statement explaining the availability of computer
networks to workers
• A statement explaining the responsibilities of workers
when they use the Internet
• A code of conduct governing behavior on the Internet
• A description of the consequences of violating the
policy
• A description of what constitutes acceptable and
unacceptable use of the Internet
• A description of the rights of individuals using the
networks in the organization, such as user privacy
• A description of the expectations for the access and use
of information
• Proper use of social media
• A disclaimer absolving the organization from
responsibility under specific circumstances
• A form for workers to sign indicating their agreement to
abide by the AUP
Note that many organizations’ websites contain an
acceptable use policy or terms of use statement that protects
them from any liability from users of the site.

Social Media
Websites such as Facebook, Twitter, and Instagram are more
popular than ever, and workers often use these sites,
sometimes during the workday, to keep up with friends,
family, and activities. While keeping your workers’ morale
high is a plus, it’s important to limit social media usage at
work, as it can be a hit to overall productivity. Perhaps even
more importantly, workers who are posting negative
comments about your organization, or even posting potentially
private intellectual property, can be a competitor’s dream. For
example, consider a disgruntled employee who begins
tweeting about your organization’s secret spaghetti sauce
recipe, which is then copied by a competitor. Not good!
However, some pleasant scenarios for an organization can
be directly attributed to workers’ social media usage. That’s
why it’s important to determine what level of social media use
your organization is comfortable with while workers are on the
clock. Many organizations have a policy that social media use
during work is only allowed on breaks and lunch hours and
that workers may not discuss or disclose any information
regarding their workplace or intellectual property.

Personal E-Mail
As with social media, many workers have personal e-mail
accounts they may want to keep an eye on throughout the day;
this lets them know that bills are being paid, packages have
been delivered, and so on. Maybe they even use e-mail to keep
up with friends. Although this can be positive for workers’
morale, it is important that an organization understands how
personal e-mail is being used throughout the workday. An
important consideration is a potential threat associated with
sophisticated adversaries in cyberspace who know a great deal
about the organization’s workers and may use their personal e-
mail account for spearfishing and other nefarious activities. If
malware is introduced through this personal e-mail usage
during the workday, it then becomes your problem—assuming
they’re using one of the organization’s systems to read their
personal e-mail. That malware could potentially leak trade or
other secrets about your organization. Again, as with social
media, it is important for an organization to dictate the terms
of how personal e-mail will be used throughout the workday
and whether personal e-mail is allowed to be used on the
organization’s more sensitive systems. For example, it is
generally considered bad practice to allow personal e-mail to
be used on production computers, where malware could have a
catastrophic effect if introduced into the environment.

Due Care, Due Diligence, and Due Process


Due care, due diligence, and due process are terms that apply
to the implementation and enforcement of organization-wide
security policies. An organization practices due care by taking
responsibility for all activities that take place in corporate
facilities. An organization practices due diligence by
implementing and maintaining these security procedures
consistently to protect the organization’s facilities, assets, and
workers. Although many organizations outline plans for
security policies and standards, they often never officially
implement them or don’t properly share the information with
workers. Without direction from management in the form of
training, guidelines, and manuals, and without workers input
and feedback, security policies will not be successful.
By practicing due care, the organization shows it has taken
the necessary steps to protect itself and its workers. By
practicing due diligence, the organization ensures that these
security policies are properly maintained, communicated, and
implemented. If the organization doesn’t follow proper due
care and due diligence initiatives, it might be considered
legally negligent if organization security and customer data are
compromised.
Due process guarantees that in the event of a security issue
by a worker, the worker receives an impartial and fair inquiry
into the incident to ensure the worker’s employment rights are
not being violated. If during an investigation or inquiry, the
worker’s rights are violated, the organization may face legal
ramifications via lawsuits or governmental employment
tribunals.

Privacy
Privacy policies are agreements that protect individually
identifiable information. An organization engaged in online
activities or e-commerce has a responsibility to adopt and
implement a policy to protect the privacy of personally
identifiable information (PII). Increasingly, regulations such as
the European Union’s General Data Protection Regulation
(GDPR), the California Consumer Privacy Act (CCPA), and
the U.S. Health Insurance Portability and Accountability Act
(HIPAA) require a privacy policy that is acknowledged before
use. Organizations should also take steps to ensure online
privacy when interacting with other organizations, such as
business partners. Privacy obligations also extend to an
organization’s use of the PII of its workers.
The following recommendations pertain to implementing
privacy policies:
• An organization’s privacy policy must be easy to find,
read, and understand, and it must be available prior to or
at the time the PII is collected or requested.
• The policy needs to state clearly what information is
being collected; the purpose for which that information
is being collected; possible third-party distribution of
that information; the choices available to an individual
regarding the collection, use, and distribution of the
collected information; a statement of the organization’s
commitment to data security; and what steps the
organization takes to ensure data quality and access.
• The policy should disclose the consequences, if any, of
a person’s refusal to provide information or the refusal
to permit its processing.
• The policy should include a clear statement of what
accountability mechanism the organization uses, such as
procedures for dealing with privacy breaches, including
how to contact the organization and register complaints.
• Individuals must be given the opportunity to exercise
choice regarding how PII collected from them online
can be used when such use is unrelated to the purpose
for which the information was collected. At a minimum,
individuals should be given the opportunity to opt out of
such use.
• When an individual’s information collected online is to
be shared with a third party, especially when such
distribution is unrelated to the purpose for which the
information was initially collected, the individual
should be given the opportunity to opt out.
• Organizations creating, maintaining, using, or
disseminating PII should take appropriate measures to
ensure its reliability and should take reasonable
precautions to protect the information from loss, misuse,
or alteration.
Each organization must evaluate its use of the Internet and
its internal systems to determine the type of privacy policy it
needs in order to protect all involved parties. The privacy
policy will protect the organization from legal issues, raising
employees, customers, and constituents’ comfort levels
regarding the protection of their information. A privacy policy
should include the following elements:
• Information collection Collect, use, and exchange only
data pertinent to the exact purpose, in an open and
ethical manner. The information collected for one
purpose shouldn’t be used for another. Notify persons of
information you have about them, its proposed use and
handling, as well as the enforcement policies.
• Direct marketing The organization can use only non-
PII for marketing purposes and must certify that the
persons’ personal information won’t be resold to third-
party organizations.
• Information accuracy Ensure the data is accurate,
timely, and complete and has been collected in a legal
and fair manner. Allow people the right to access,
verify, and change their information in a timely,
straightforward manner. Inform people of the data
sources and allow them the option of removing their
names from the marketing lists.
• Information security Apply security measures to
safeguard the data on databases. Establish worker
training programs and policies on the proper handling of
PII. Limit the access to a need-to-know basis on
personal information and divide the information so that
no one worker or unit has the whole picture. Follow all
government regulations concerning data handling and
privacy.

EXAM TIP Privacy policies must be easy to find, and they


must provide information on how to opt out of any use of
personally identifiable information.
Human Resources
An organization’s HR department is an important link
regarding the organization and worker security. The HR
department is responsible for hiring employees, tracking
contractors, consultants, and other temporary workers,
ensuring workers conform to company codes and policies
during their term of work, and maintaining organization
security in case of a worker termination. The following
sections outline the responsibility of human resources during
the three phases of the employment cycle: hiring,
maintenance, and termination.

Hiring
When hiring employees for a position within the organization,
the HR department is responsible for the initial employee
screening. This usually takes place during the first interview:
an HR representative meets with the potential employee to
discuss the organization and to get a first impression, gauging
whether this person would fit into the organization’s
environment. This interview generally is personality based and
nontechnical. Further interviews are usually more oriented
toward the applicant’s skill set and are conducted by the
department advertising the position. Both types of interviews
are important because the applicant could possess excellent
technical skills for the position, but their personality and
communications skills might not be conducive to integration
with the work environment.
During the interview process, HR also conducts
background checks of the applicant and examines and verifies
their educational and employment history. Reference checks
are also performed, where HR can obtain information on the
applicant from a third party to help confirm facts about the
person’s past. HR will also verify professional licenses and
certifications. Depending on the type of organization, such as
the government or the military, the applicant might have to go
through security clearance checks or even a credit check,
medical examination, and drug testing.
To protect the confidentiality of organization information,
the applicant is usually required to sign a non-disclosure
agreement (NDA), which legally prevents the applicant from
disclosing sensitive organization data to other organizations,
even after termination of employment. These agreements are
particularly important with high-turnover positions, such as
contract or temporary employment.
When an employee is hired, the organization also inherits
that person’s personality quirks or traits. A solid hiring process
can prevent future problems with new employees.

Tracking Temps, Contractors, and Consultants


Many organizations have more than just employees in their
workforce. Most will have a few contractors, consultants, and
temps—and some will have a lot! In organizations where these
“non-employee” workers have managed identities to regulate
their access to computers and workspaces, it’s necessary for
organizations to carefully track them with the same precision
as regular employees.
Who better to do this than HR? For legal reasons, many
organizations’ HR departments are reluctant to also track the
non-employee workforce, but information security
requirements demand centralized, competent tracking just the
same.
Today’s human resource information systems (HRISs) have
the ability to segregate employees from other types of
workers. This helps HR departments manage employees and
non-employee workers separately, as often they must.

Codes of Conduct and Ethics


The HR department is also responsible for outlining an
organization’s policy regarding codes of conduct and ethics,
which are general lists of what the organization expects from
its workers in terms of everyday conduct—dealing with fellow
workers, managers, and subordinates, including people from
outside the organization such as customers and clients.
These codes of conduct could include restrictions and
policies concerning drug and alcohol use, theft and vandalism,
sexual harassment, and violence in the workplace. If a worker
violates any of these policies, they could be disciplined,
suspended, or even terminated, depending on the severity of
the infraction.

Termination
The dismissal of workers can be a stressful and chaotic time,
especially because terminations can happen quickly and
without notice. A worker can be terminated for a variety of
reasons, such as performance issues, personal and attitude
problems, or legal issues such as sabotage, espionage, or theft.
Alternatively, the worker could be leaving to work for another
organization. The HR department needs to have a specific set
of procedures ready to follow in case a worker resigns or is
terminated. Without a step-by-step method of termination,
some procedures might be ignored or overlooked during the
process and thus compromise the organization’s security.
A termination policy should exist for each type of situation
where a worker is leaving the organization. For example, you
might follow slightly different procedures for terminating a
worker who’s leaving to take a job in an unrelated industry
than a worker who’s going to work for a direct competitor. In
the latter case, the worker might be considered a security risk
if they remain on the premises for their two-week notice
period, where they could transmit organization secrets to the
competition.
Similarly, terminating a contractor or consultant will
involve different policies and procedures since their
employment relationship is with another organization. Finally,
organizations with one or more labor unions must navigate
those waters according to collective bargaining agreements
and rules.
A termination policy should include the following
procedures for the immediate termination of a worker:
• Securing work area When the termination time has
been set, the worker in question should be escorted from
their workstation area to the HR department. This
prevents them from using their computer or other
organization resource once notice of termination is
given. Their computer should be turned off and
disconnected from the network. When the worker
returns to their desk to collect personal items, someone
should be with them to ensure that they do not take
private organization information. Finally, the worker
should be escorted out of the building.
• Return of identification As part of the termination
procedure, the worker’s identification should be
returned. This includes identity badges, pass cards, keys
for doors, and any other security device used for access
to organization facilities. This prevents the person from
accessing the building after being escorted from the
premises.
• Return of equipment All organization-owned
equipment must be returned immediately, such as
desktops, laptops, cell phones, tablets, organizers, or
any other type of electronic equipment that could
contain confidential information.
• Suspension of accounts An important part of the
termination procedure is the notification to the network
administrators of the situation. They should be notified
shortly before the termination takes place to give them
time to disable any network accounts and phone access
for that worker. The network password of the account
should be changed, and any other network access the
worker might have, such as remote access, should be
disabled. The worker’s file server data and e-mail
should be preserved and archived to protect any work or
communications the organization might need for
operational or legal reasons.
EXAM TIP All user access, including physical and network
access controls, needs to be disabled for a worker once they
have been terminated. This prevents the worker from
accessing the facility or network.

Chapter Review
The enterprise architecture within an organization affects the
risk of the business in several different ways. Aspects of
enterprise architecture risk include interoperability,
supportability, security, maintenance, and how the different
pieces and parts of the infrastructure fit into the systems
development life cycle.
Key areas in IT operations management include server and
infrastructure management, end-user support, help desk, and
problem escalation management, and, of course, cybersecurity.
Organizations use project, program, and portfolio
management to oversee and sustain both short- and long-term
aspects of systems and processes.
At the core of a project are three primary drivers. These are
scope (amount or range of work), schedule (when work is to
be done and its completion date), and cost (including all the
resources expended toward the completion of the project).
Business continuity is concerned with the careful planning
and deployment of resources involved in keeping the mission
of the business going (that is, keeping the business functioning
regardless of negative events). Disaster recovery is primarily
concerned with the quick reaction involved with preserving
lives, equipment, and data immediately following a serious
negative event.
Resilience refers to the ability of the business to survive
negative events and continue with its mission and function.
Data lifecycle management is a lifecycle process concerned
with the creation, protection, use, retention, and disposal of
business information.
The systems development life cycle, or SDLC, is essentially
the entire life of a system or product, from concept to
development, from implementation to disposal. Security
should be a part of every step in the SDLC, thus ensuring
security by design.
New or emerging technologies can present risks to
organizations simply because there are several different
important considerations when integrating the latest
technologies into an existing environment.
Access controls ensure that only authorized personnel can
read, write to, modify, add to, or delete data. They also ensure
that only the same authorized personnel can access the
different information systems and equipment used to store,
process, transmit, and receive sensitive data.
The three goals of security, known as the CIA triad, are
confidentiality, integrity, and availability. Supporting these
three goals are other elements of security, such as access
control, data sensitivity and classification, identification,
authentication, authorization, accountability, and, finally, non-
repudiation.
Standards, frameworks, and practices relevant to risk
management include NIST RMF, COBIT 2019, and the
various ISO standards.
Data classification policy defines data sensitivity levels, as
well as handling and disposal procedures to ensure adequate
protection of sensitive information.
Industry frameworks, standards, and practices can be
adopted when building an information security program, as
opposed to building these elements from scratch.
The NIST Risk Management Framework (RMF) is a seven-
step methodology that provides for risk management all the
way through the information systems life cycle.
COBIT is a management framework developed by ISACA
and facilitates the governance of enterprise information and
technology. COBIT consists of two layers, governance and
management, which further break down into a total of 40
separate objectives.
The Risk IT Framework comes from traditional risk
management principles of various enterprise risk management
(ERM) standards and describes activities and processes
thought of as best practices.
Information security awareness training ensures an
organization’s workforce is aware of policy, behavior
expectations, and safe computer and Internet usage.
Security policies and procedures are official organization
communications that are created to support those critical
principles of data privacy and data protection.
Effective physical access controls ensure that only
authorized personnel are permitted to access work centers,
processing centers, and other work areas. This contributes to
an environment with better information security as well as
workplace safety.
An organization practices due care by taking responsibility
for all activities that take place in corporate facilities.
An organization practices due diligence by implementing
and maintaining these security procedures consistently to
protect the organization’s facilities, assets, and workers.
Due process guarantees that in the event of a security issue
by a worker, the worker receives an impartial and fair inquiry
into the incident to ensure the worker’s employment rights are
not being violated.
Each organization must evaluate its use of the Internet and
its internal systems to determine the type of privacy policy it
needs in order to protect all involved parties.
An organization’s HR department is an important link
regarding organization and worker security. The HR
department is responsible for hiring employees, tracking
contractors, consultants, and other temporary workers,
ensuring workers conform to company codes and policies
during their term of work, and maintaining organization
security in case of worker termination.
Quick Review
• Two common enterprise architecture frameworks are
The Open Group Architecture Framework (TOGAF)
and the Zachman framework.
• Business continuity and disaster recovery are primarily
concerned with the goal of business resilience.
• Two of the key processes involved in business
continuity planning are conducting a business impact
assessment (BIA) and determining a recovery strategy.
• Two key areas of concern in business continuity are the
recovery point objective (RPO) and the recovery time
objective (RTO).
• Resilience is the ability of an organization to resist the
effects of negative events and its ability to bounce back
after one of these events.
• Data classification refers to policies that define the
proper use, handling, and protection of data at various
sensitivity levels.
• The term systems development life cycle represents an
evolution of the original term software development life
cycle, reflecting an earlier age when most organizations
wrote their own custom business applications.
• Some of the risks associated with emerging technology
involve staff unfamiliarity, resulting in improper
implementation or use.
• Access controls directly support the confidentiality and
integrity goals of security and indirectly support the
goal of availability.
• Identification refers to the act of an individual or entity
presenting valid credentials to a system. Authentication
involves the verification of one’s identity with a
centralized database. Authorization refers to the access
rights or privileges assigned to a user account. Non-
repudiation is a record-keeping property of a system
whereby a user will not be able to deny having
performed some action.
• A framework is a generally overarching methodology
for a set of activities or processes.
• A standard is a mandatory set of procedures or
processes used by the organization and usually fits into
an overall framework.
• A practice is a normalized process that has been tried
and proven as generally accepted within a larger
community.
• Periodic security awareness training can be used to
reinforce and refresh stale knowledge and bring workers
up to date on the latest tools, techniques, and
risk considerations.
• The least privilege principle grants users only the access
rights they need to perform their job functions.
• Separation of duties ensures that one single individual
isn’t tasked with high-security and high-risk
responsibilities.
• Job rotation provides improved security because no
worker retains the same amount of access control for a
position indefinitely.
• Mandatory vacations enable security and audit staff to
examine absent workers’ procedures and records to
identify signs of misbehavior or fraud.
• An acceptable use policy (AUP) is a policy consisting of
a set of established guidelines for the appropriate use of
computer networks within an organization.
• Social media policy governs acceptable use regarding
the sharing of organization information and
representation of the organization.
• The use of personal e-mail is a potential distraction as
well as a risk for information leakage and the
introduction of malware into an environment.
• Privacy policies are agreements that protect individually
identifiable information.
• Human resources should track not only employees but
temporary workers, contractors, and consultants to
ensure the integrity of access controls.

Questions
1. You are managing a project that involves the installation
of a new set of systems for the accounting division of
your organization. You have just been told that there have
been budget cuts and the project will not be able to
purchase additional equipment needed for the installation.
You now have to find other areas to cut in order to fund
the extra equipment. Which element of project
management is most affected by this threat?
A. Schedule
B. Scope
C. Cost
D. Quality
2. As a risk practitioner in a larger organization, you have
been asked to review the company’s SDLC model for
potential risk areas. The model includes the
Requirements, Design, Development, Implementation,
and Disposal phases. Software and systems are moved
from the development environment immediately into the
production environment and implemented. Which SDLC
phase would you recommend that the business add to
reduce risk of integration or functionality issues as the
system is implemented?
A. Initiation
B. Test
C. Sustainment
D. Maintenance
3. Lack of a well-written work breakdown structure
document can contribute to a vulnerability that affects
which aspect of project management?
A. Cost
B. Schedule
C. Scope
D. Quality
4. Which of the following is the major risk factor associated
with integrating new or emerging technologies into an
existing IT infrastructure?
A. Security mechanisms
B. Data format
C. Vendor supportability
D. Interoperability
5. Which of the following is a short-term process primarily
concerned with protecting personnel, facilities, and
equipment immediately following a disaster or major
incident?
A. Disaster recovery
B. Business continuity
C. Business impact analysis
D. Recovery point objective
6. Which of the following would be a vulnerability that
stems from the business not identifying its critical assets
and processes during the continuity management process?
A. Failure to adequately consider system requirements
during the SDLC
B. Failure to perform a business impact analysis
C. Failure to consider interoperability with integrating
new technologies
D. Failure to maintain redundant systems or data
backups
7. Your business just went through a major storm, which has
flooded your data center. Members of your recovery team
are attempting to salvage equipment as well as locate
critical data backups. No one seems to know exactly what
they’re supposed to do, and they don’t have the right
equipment available to them. Additionally, there is no
coordinated effort within the team to perform specific
tasks. Which of the following vulnerabilities most likely
led up to this scenario?
A. Failure to back up sensitive data
B. Failure to acquire an alternate processing site
C. Lack of a business impact analysis
D. Failure to test the disaster recovery plan
8. After a few incidents where customer data was
transmitted to a third party, your organization is required
to create and adhere to a policy that describes the
distribution, protection, and confidentiality of customer
data. Which of the following policies do you create?
A. Privacy
B. Due care
C. Acceptable use
D. Service level agreement
9. You need to create an overall policy for your organization
that describes how your users can properly make use of
company communications services, such as web
browsing, e-mail, and File Transfer Protocol (FTP)
services. Which of the following policies do you
implement?
A. Acceptable use policy
B. Due care
C. Privacy policy
D. Service level agreement
10. Which of the following security goals is concerned with
ensuring that data has not been modified or altered during
transmission?
A. Confidentiality
B. Availability
C. Integrity
D. Non-repudiation
11. Which of the following is most concerned with ensuring
that users cannot deny that they took an action?
A. Accountability
B. Non-repudiation
C. Auditing
D. Authorization
12. Which of the following describes a set of mandatory
procedures or processes used by an organization?
A. Standard
B. Framework
C. Practice
D. Policy
13. Which of the following frameworks might be used in
business governance and IT enterprise management?
A. NIST RMF
B. COBIT 2019
C. The Risk IT Framework
D. ISO 27001
14. You are implementing an organization-wide risk
management strategy, and you are using the NIST Risk
Management Framework (RMF). You have just
completed step 1 of the RMF, “Categorize information
systems.” Which of the following steps should you
complete next in the RMF sequence?
A. Authorize system.
B. Assess security controls.
C. Continuous monitoring.
D. Select security controls.
15. Which of the following statements most accurately
reflects the effect of information technology (IT) on risk
to the business enterprise? (Choose two.)
A. Information technology is a serious risk to the
mission of the organization.
B. Information technology is used to protect the
organization’s information.
C. Information technology is used to eliminate risk to
the mission of the organization.
D. Information technology is used to generate the
organization’s information.

Answers
1. C. Cost is the element of project management that is most
affected by the threat of not enough funding.
2. B. A test phase introduced into this model would reduce
risk by ensuring that a system or software application
meets performance and functionality standards before it is
introduced into the production environment, potentially
eliminating costly issues before they occur.
3. C. Lack of a well-written work breakdown structure
document can contribute to a vulnerability that affects a
project’s scope.
4. D. Interoperability is the major risk factor associated with
integrating new or emerging technologies into an existing
IT infrastructure. It covers a wide range of factors, which
typically include backward compatibility, data format,
security mechanisms, and other aspects of system
integration.
5. A. Disaster recovery is a short-term process primarily
concerned with protecting personnel, facilities, and
equipment immediately following a disaster or major
incident.
6. B. Failure to perform a business impact analysis could
cause a vulnerability in that the organization would not be
able to adequately identify its critical business processes
and assets.
7. D. Failure to test the disaster recovery plan on a periodic
basis—as well as make sure people are trained and have
the right equipment—can result in poor or ineffective
recovery efforts.
8. A. A privacy policy concerns the protection and
distribution of private customer data. Any company,
especially one engaged in online activities or e-
commerce, has a responsibility to adopt and implement a
policy for protecting the privacy of individually
identifiable information.
9. A. An acceptable use policy establishes rules for the
appropriate use of computer networks within your
organization. The policy describes the terms, conditions,
and rules of using the Internet and its various services
within the company’s networks.
10. C. Integrity is concerned with ensuring that data has not
been modified or altered during transmission or storage.
11. B. Non-repudiation is concerned with ensuring that users
cannot deny that they took a particular action.
12. A. A standard is a set of mandatory procedures or
processes used by an organization.
13. B. COBIT is used in business governance and IT
enterprise management.
14. D. Step 2 of the RMF is “Select security controls” and is
accomplished after information systems have been
categorized.
15. B, D. Information technology is used to generate the
business’s information as well as protect it.
A APPENDIX

Implementing and Managing a


Risk Management Program

This appendix takes a more pragmatic view of building and


managing a risk management program. Rather than the
somewhat academic view in the CRISC job practice, we draw
directly from our experience building several risk management
programs in our careers.
We have built or improved numerous risk management
processes and programs between the three of us. The process
and technique are not overly complicated. The most
challenging part of building a risk management process is
figuring out how to engage with executives in the organization
—so that they understand what the process is all about and
participate meaningfully. After all, it’s their business, and we
just want to make sure they make informed decisions related
to various types of risks.

Today’s Risk Landscape


It’s a crazy world for an IT or cyber risk leader. While we find
the profession both challenging and rewarding, increasing
pressures on all sides are making the job more difficult (see
Figure A-1). Some of the factors at play include the following:
Figure A-1 Pressure comes from all sides on security and risk
programs today.
• Innovation and chutzpah of cybercrime
Cybercriminal organizations are thriving. Ransomware,
extortion, social engineering, and DDoS are highly
successful, drawing even more into this dark industry.
Intruders develop new attack methods in shorter periods
of time, indicating the presence of increases in research
and development.
• Upward pressure on regulations The success of
cybercriminals is putting pressure on governments to
pass laws requiring organizations (and governments) to
do more to protect sensitive information. Industry sector
regulations like GLBA and HIPAA, along with
emerging privacy regulations like GDPR and CCPA, are
building layers of regulation on already strained
businesses.
• Downward pressure on spend Despite the two factors
mentioned, management is trying to keep a lid on rising
costs and hold the line on spending increases while
expecting security organizations to better defend them
from attack. A related problem is the limited talent pool
of qualified security and risk professionals to guide
organizations out of the mess they’re in.
• Increasing complexity of digital transformation
Organizations’ IT environments have never been more
complex. Despite pressure to standardize on tools and
technologies, the move to cloud services and cloud
infrastructure means IT organizations have more kinds
of technologies, more types of services, and more kinds
of operations to manage.
• Introduction of IoT devices Increasingly, IT
departments have to deal with more than just servers,
desktops, laptops, printers, and mobile devices on their
networks. Many other devices are plugged into internal
networks, including “smart” devices, appliances, and
voice-activated assistants. The so-called “attack
surface” expands faster than a security team can ever
hope to monitor and protect it.
• BYOD Increasingly, organizations’ workers use
personally owned devices, mainly smartphones, to
access and manage business information and systems.
Such organizations have effectively ceded control of
their information and information systems if these
devices are not actively managed.
• Telework The COVID-19 pandemic thrust new
working conditions on virtually every enterprise in the
world, many of which were unprepared to deal with this
and related changes. Organizations that were already
stretched and accepting too much risk had still more risk
to take on.
• Cloud-based services Cloud-based services decrease
the effort and friction of acquiring new information
systems. Sometimes, however, this goes too far,
resulting in individuals and workgroups that unilaterally
decide to employ cloud-based services, escaping the
scrutiny of legal and cybersecurity professionals.
Corporate information has escaped the control of IT and
risk owners in many cases.
• Increasing variety of security tooling Many thousands
of security software companies compete in the
marketplace with their tools. Security leaders are
increasingly distracted by these vendors and their
promises of stopping whatever the latest attack
techniques happen to be at the moment.
• Difficulty in finding qualified security professionals
Most organizations struggle to find enough qualified
security professionals to fill their teams. Organizations
take months, half a year, or more to find new hires. We
won’t argue or debate the finer points on this matter,
except to say that companies have a hard time finding
the people they want to hire on their security teams.
These factors weigh heavily on security organizations,
resulting in sub-par security architecture, planning,
monitoring, and response, with too few personnel working on
important issues.
Allegory of the Battlefield
Consider the following photograph that shows Major
General Alexander M. Weyand poring over a battlefield
map in Korea:
(Image courtesy U.S. National Archive)
Imagine, if you will, that General Weyand is taking in
information from scouts on the enemy’s position and
discussing where and when to deploy troops to counter the
enemy’s moves and even gain territory. This is all about the
allocation of scarce resources to provide the maximum
margin of victory.
The soldiers on the front line depend on this strategizing
—their very lives depend on it. Political leaders depend on
this strategizing as well so that their armies will meet their
objectives of countering the enemy’s objectives.
Imagine, for a moment, that an army lacked this
planning and decision-making function. Without it, lower-
level officers would be commanding their regiments to go
this way and that, based on what they could see within their
limited purview. Lacking big-picture information and
purpose, they may succeed or fail, but they won’t be
operating with a clear, central purpose.
Risk management is the modern equivalent of those field
commanders. In risk management, security specialists are
examining threat intel, considering available internal
capabilities, and making decisions on which of many issues
are the most important to discuss and take action on.
Formal risk management is the modern equivalent of field
commanders studying the enemy’s plans, available
resources, and most effectively applying their resources to
meet their objectives.
Most organizations do not do this, at least not in any
repeatable way. Instead, when decisions are made, they
usually lack any analysis or triage to determine the best
way forward on any given issue. The result: high-risk
matters get little attention, while other issues get more than
their fair share. Scarce resources are applied to the wrong
issues, while the highest risk issues go poorly resolved or
entirely unaddressed.

What Is a Risk Management


Program?
To fully describe a risk management program, first we’ll step
back and describe what a program is. In business today, a
program is a set of defined roles and responsibilities as well as
processes or procedures that are carried out indefinitely.
A risk management program is simply a process or set of
processes through which
• Risks are discovered.
• Risks are cataloged.
• Risks are analyzed.
• Business decisions about what to do about risks are
made.
Also, follow-up is performed to ensure these business
decisions are carried out on time and as agreed upon.
The primary artifacts found in a typical risk management
program include the following:
• Program charter This document defines the purpose
and scope of the risk management program, roles and
responsibilities, and describes its processes and records.
• Process or procedures This document describes the
steps in various risk management processes and
procedures, who carries them out, and what records are
maintained.
• Risk register This is the central repository of risks that
have been identified. The risk register is one of the
historical records of a risk management program.
• Risk analyses Individual risks are often studied in
greater detail, with additional risk analysis to help
decision-makers decide what to do about these risks.
• Minutes This is a business record of decisions and other
actions taken.
So far, this may sound formal. Risk management should be
consistent and methodical so that its proceedings are managed
and recorded.

The Purpose of a Risk Management


Program
Many kinds of threats and risks demand the attention of
cybersecurity leaders. Even the best-equipped organizations
have insufficient resources to deal effectively with every
identified risk. A risk management program facilitates
informed decision-making that helps to prioritize resources to
deal with identified risks.
When properly designed and implemented, a risk
management program serves as a triage apparatus to help
identify and distinguish more significant risks from lesser
risks. Instead of going into the detail of determining the actual
probability and financial impact of threats, risk management’s
triage sorts out risks to help management understand which
risks are more critical to deal with sooner and which can be
dealt with later.
A common mistake made in risk management programs is
the time spent in detailed analysis to determine accurate
probabilities of threat events and actual costs of threat events.
While, at times, it may be helpful to determine estimates of
probability and impact, this is not the sole purpose of risk
management. Instead, the triage function of risk management
identifies those risks needing prompt attention versus those
whose attention can wait.
In this respect, a qualitative analysis method can be far
more useful than a quantitative one. If risks are considered still
“very high,” it really doesn’t matter if it’s 85.2 percent versus
95.7 percent; it’s still coming, and it’s still bad.
When properly designed and implemented, risk
management identifies the most critical risks and facilitates
business-level decision-making by business leaders to deal
with those risks.
Not Only IT Risk Management
Many in the business think of risk management as
consisting primarily of cyber risk and increasingly of
privacy risk. The scope of risk in the CRISC certification
consists of all IT risk, which goes beyond cyber to include
various aspects of operational risk, such as the capacity and
availability of IT systems to continue running properly.
The methodology of risk management, however,
transcends IT altogether. Other risk domains include
workforce risk, economic risk, market/competitive risk,
currency exchange risk, geopolitical risk, natural hazards
risk, fraud risk, and more. The techniques used in risk
management are agnostic to the context of risk.
Risk management is risk management, regardless of the
focus or the context. It’s only necessary for a risk
management program to have someone skilled in the
techniques of risk management and someone skilled in the
subject matter of the risk management program. The
program can succeed, whether both of these are a single
person or two people.

The Risk Management Life Cycle


Like many business activities, risk management is a life-cycle
process. Risks are identified in many ways, and specific
activities are performed for each of those risks. The entire life
cycle is described in detail in this section.

Risk Discovery
In Chapter 2, we made a list of the ways in which new IT risks
can be discovered, with complete explanations for each. We’ll
provide just the summary here:
• Audits
• Penetration tests
• Security advisories
• Whistleblowers
• Threat modeling
• Risk assessments
• Security and privacy incidents
• Operational incidents
• News and social media articles
• Professional networking
• Passive observation
• Risk-aware culture
This list should not be construed as complete. Instead, it
should help you understand that there are many ways in which
a risk manager will discover new risks. Put another way, it
would be dangerous to limit the identification of new risks to a
fixed set of inputs, as this could artificially eliminate a source
that is critical for some. Risk discovery is sometimes
methodical and sometimes spontaneous. The spontaneity of
risk discovery compels us to advise you to consider all
possible likely and unlikely sources of risk. We can no more
tell you the types of risk sources to include than we can tell
you which of those sources will be related to your next risk
event.

The Risk Register


The risk register (sometimes known as a risk ledger) is the
centerpiece of business records in a risk management program.
Each entry in the risk register represents a different IT risk that
has been identified at some point in time, as recently as earlier
today or as distant as a year or two in the past.
Since this appendix focuses on establishing a risk
management program, we recommend implementing an initial
risk register using a spreadsheet program such as Microsoft
Excel or Google Sheets. It’s our style to build a program or a
process using largely manual procedures and then introduce
automation later.
A risk register starts quite simply, with columns like these:
• Risk name
• Risk description in terms of the risk context
• Threat description
• Vulnerability description
As you accumulate records in the risk register, you’ll find it
helpful to add more columns. These columns indicate when
the entry was recorded, its context, and a business-centric
explanation:
• Entry date
• Entered by
• Risk description in business terms
• Risk context
While the description of risk in business terms appears to
be just another bullet item, it is perhaps the most important
field in the risk register. Without it, risk managers will have a
more difficult time describing the risk in business terms to
executives who may be asked to decide on the disposition of
the risk. Including this column in the risk register compels the
risk manager to begin thinking about the risk in business terms
early, giving them time to ponder and develop the risk story.
Rating risks for severity is a topic all its own, discussed in
more detail in the following subsections.
You will need to add more columns as you move through
the life cycle and make risk treatment decisions. These
columns describe basic risk treatment parameters:
• Risk status
• Risk treatment selection
• Risk treatment description
• Risk treatment owner
• Risk treatment commit date
As risk treatment activities reach their conclusions, you’ll
need additional columns:
• Risk treatment completion date
• Risk closure date
Over time, you’ll be spending considerable time in the risk
register. You’ll want to view risks in various contexts and
categories at times. Some columns that help classify risks
include the following:
• Location.
• Business unit.
• Technology type. This may consist of one or more
columns that enable you to view risks in discrete
categories. For instance, you may wish to view all risks
related to mobile devices, endpoints, specific types of
servers, database management systems, network
devices, or other components.

Rating Risks—Qualitative
Not all risks are created equal. Some may be nearly trivial,
while others represent an existential threat to the organization.
A risk register must contain some columns used to describe
the level of risk for each entry.
The two basic qualitative measures of risk are probability
and impact, as detailed next:
• Probability This specifies the likelihood of an actual
occurrence of the risk. In qualitative terms, probability
is typically expressed as High, Medium, or Low or in
basic numeric terms such as 1 (Low) to 3 (High), 1 to 5,
or 1 to 10.
• Impact This specifies the impact on the organization
due to an actual occurrence of the risk. Like probability,
impact in qualitative risk ratings is expressed as High,
Medium, or Low or on a numeric scale such as 1–3, 1–
5, or 1–10.
Note that, in qualitative risk rating, no attempt at an actual
probability or impact is being made. Instead, the purpose of
qualitative risk ratings is one of triage—these ratings help the
risk manager distinguish entries with higher risks from entries
with lower risks.
Qualitative Terms Help with Ratings
Rating the probability and impact of risks on numeric
scales of 1–3 or 1–5 can, at times, be too abstract. For this
reason, we recommend a list of terms be associated with
these levels for both probability and impact. Using these
terms as a guide can help the risk manager perform more
consistent risk ratings for risk register entries.
For event probability on a scale of 1–5, these terms can
be used:
• 5 = Certain
• 4 = Likely
• 3 = Possible
• 2 = Unlikely
• 1 = Rare
Similarly, these terms can be used for impact:
• 5 = Global
• 4 = Country
• 3 = Department
• 2 = Team
• 1 = Individual
These impact terms describe the scope of impact for a
risk event. The highest-rated events would affect the entire
organization, while the lowest-rated events would affect
only a single worker.

Two additional qualitative measures can be introduced that


help the risk manager better understand the overall risk for
each entry:
• Asset value This qualitative term expresses the value of
the asset(s) involved in a specific risk. Like other
qualitative terms, asset value is expressed as High,
Medium, or Low or on a numeric scale. Generally, this
represents an asset that would have to be recovered or
replaced should a relevant threat occur.
• Operational criticality This term expresses the
operational importance of an asset or function. An asset
that the organization depends on for high-value
operations (even if the value of the asset itself is low)
would be assigned a higher value.
While these two measures are not seen as often in
qualitative risk analysis, they help distinguish risks in that all-
important triage used to identify the most critical risks.
Calculating Overall Risk The four qualitative risks explained
here can help the risk manager sort out various risks in the risk
register. One final column can help tie them all together that
would simply be called “Risk.” This column can easily be
calculated by multiplying the ratings of the four risk columns
together. For example, a risk item in the risk register is rated as
follows:
• Probability = 4
• Impact = 2
• Asset value = 2
• Operational criticality = 1
The risk value in this example is 4 × 2 × 2 × 1 = 16.
Using Qualitative Risk Ratings In qualitative risk analysis,
the individual risk columns, as well as the column representing
overall risk, exist to help the risk manager better understand
how various risks compare to one another. No attempt is made
to calculate the actual probability of occurrence or the costs
incurred if a risk event occurs. Instead, qualitative risk ratings
help the risk manager understand which risks warrant more
focus and attention.
Other columns in the risk register provide opportunities for
focus, including those columns specifying the type of asset or
system, the business unit, the geographic location, and more.
The ability to focus on a portion of the risk register associated
with a specific part of the organization, a particular location, or
other distinguishing characterization helps the risk manager
focus on the risks that matter more versus the ones that matter
less.
In a sample risk management scenario, a risk manager is
preparing to have a conversation with the part of IT that
manages end-user endpoints—primarily laptop and desktop
computers—in a particular region of the world. To prepare, the
risk manager can filter the risk register to view just the risks
associated with end-user endpoints as well as risks in
particular global regions. The resulting risk will contain just
those items, which the risk manager can then examine more
deeply to distinguish the items of greater concern from those
of lesser concern. Now, the risk manager can have a more
meaningful conversation with the IT leaders about risks
directly associated with their work.
NOTE The purpose of qualitative risk analysis is triage—to
distinguish risks from one another and to more easily identify
larger risks.

Rating Risks—Quantitative
Sometimes, a risk manager is asked to go beyond qualitative
risk rating and provide actual probabilities and financial
impacts of risks. “How much will it cost us if customer data is
stolen?” is a reasonable question that an executive may pose to
a risk manager. Arguably, the risk manager should attempt to
arrive at an estimate to help the executive better understand
the consequences of a security breach.
In our practice, we do not attempt to uplift every item in the
risk register from qualitative to quantitative terms. Doing so
would take a considerable amount of time and not result in
much additional insight. Instead, we embark on quantitative
risk analysis when examining individual risks. We discuss this
further in the section “Performing Deeper Analysis.”
The Risk Register Is a Living Document
The risk register is a living document, and even when risks
are reduced, this is recorded and reflected in the document;
they are not simply deleted. This provides a history of risk
management within the organization. The contents of the
risk register should be managed accordingly.

Types of Risk Registers


Many kinds of risks are present everywhere in an organization,
and it makes little sense to put them all together in one risk
register. Imagine if there was a risk entry associated with
currency exchange risk, and adjacent to it is another entry that
expresses the misconfiguration of a server. Both are useful,
even valuable, but they are vastly different in their context and
importance. Further, particularly in larger organizations, other
individuals will manage these risks and discuss them with
different executives.

Layers of Risk Registers


Different levels of risk are typically maintained in separate
risk registers. Most often, these basic three risk registers will
exist:
• Entity-level risk These are the overall “big picture”
risks that affect an entire organization. The types of
subject matter in an entity-level risk register generally
include the following:
• Workforce-related risks
• Currency exchange risks in organizations operating
in multiple countries, or with suppliers in other
countries
• Economic risks having to do with macroeconomic
business cycles
• Risks that exist as an aspect of organizational
culture
• Program-level risk These are risks most often
associated with business processes throughout the
organization. Examples of the types of risks found at
this level include the following:
• Effectiveness of vulnerability management If, for
instance, the IT department is lackadaisical in its
security patching, an entry may be created in the
risk register that describes this systemic problem.
• Identity management An organization may have
little discipline in its access request, fulfillment, and
termination procedures.
• BYOD An organization may not have controls to
prevent employees’ use of personally owned
devices for managing critical data, leading to a
significant data leakage risk.
• Asset-level risk These risks are associated with
individual assets and groups of assets. Often, these risks
are identified with scanning tools and other tooling.
Examples of risks at this level include the following:
• Misconfiguration of critical devices
• Missing critical patches
• Newly discovered unmanaged devices

Communicating Between the Layers


A single risk manager may be involved in two or all three of
these risk registers in smaller organizations. More often,
however, different persons manage each risk register
separately. One might think that these risk registers would be
isolated from each other. While this may be true, organizations
are wise to be cognizant of opportunities for communication
between those who manage various risk registers.
Classic examples of the crossover between risk registers
include the following:
• Chronic occurrence of an IT department exceeding
patching SLAs may compel a risk manager to create a
program-level risk item describing a risk with the
operational process of patching.
• Chronic occurrence of a product engineering group
avoiding engagement with security and privacy teams
may compel a risk manager to create an entity-level risk
describing a culture that lacks the essential cultural
ingredient of “security and privacy by design.”
The most frequent communication between risk register
layers is a chronic or repeated failure of processes at lower
layers that suggests a systemic problem at a higher layer.
NOTE Our frequent use of the term risk manager signifies a
role rather than a job title. The job title of risk manager is
generally seen only in larger organizations, whereas those with
other job titles fulfill the role.

Reviewing the Risk Register


Risk managers should have intimate familiarity with the
contents of their risk register(s). This requires a risk manager
to frequently examine the contents of the risk register, using
various filtering (“slicing and dicing”) techniques to view
subsets of the entire risk register. This attention could
approach what we would call “preening,” where a risk
manager examines and periodically adjusts contents in the risk
register.
Most often, a risk manager will occasionally adjust an
aspect of risk rating of a risk register item. As the risk manager
becomes intimately familiar with the risk register, sometimes
the risk manager will realize that a particular risk entry’s risk
rating should be adjusted a bit up or down, making risk ratings
more credible and reasonable.

NOTE A risk program aspiring to higher maturity should


require recording rating changes and other changes to the risk
register, or perhaps use a change control process requiring two
or more persons to understand and agree to changes to the risk
register.
In an example described earlier in this appendix, a risk
manager is preparing for a conversation with a particular
leader in an organization by examining risk register items
relevant to that leader’s mission. This is a helpful example, but
a risk manager should not wait for a conversation to focus on
those relevant risks. Instead, the risk manager should routinely
examine smaller sets of risks in logical groupings such as
location, type of asset, and business unit to become even more
familiar with the risk landscape in different parts of the
organization.

Formal Risk Register Reviews


While the risk manager may be spending quality time alone
with the risk register, formal reviews with one or more
additional people are warranted. These reviews can help
improve the quality of the risk register through consensus.
Reviews strengthen the integrity of the risk register, as they
will represent the opinion of a group rather than a single
individual.
Few other persons may have skills or experience in risk
management in smaller organizations. Risk register reviews
with others are still valuable: as the risk manager describes
risks to others, opportunities for improvements can still be
identified.
Better organizations will document risk register reviews
and record any changes to risk register entries.
Reviewing Risks with Staff It is often appropriate for the risk
leader to review the contents of the risk register with other
security, privacy, and risk staff members. Generally, these
discussions will consist of a closer look at the details in the
risk register, including a look at ratings, and any completed
work on risk analysis that includes potential risk treatment
options.
Staff members can be a good source of new material for the
risk register. Reviews may, at times, remind staff members of
other matters that may be good candidates for the risk register.
Frontline personnel are often aware of good and poor practices
in technology operations and business processes; earning their
trust and using them for intel on new risks can be a valuable
pursuit.
When possible, staff reviews should not be limited to
personnel in cybersecurity but could include staff from IT and
other departments.

NOTE Risk-averse organizations may consider employing


reminders of confidentiality before reviewing risk register
contents with staff.
Reviewing Risks with Business Leaders At times, it is
appropriate for the risk leader to review the contents of the risk
register with business leaders. This discussion can take many
forms, including the following:
• A detailed review of all relevant risks
• A high-level review of the “Top N” risks
• A high-level review of the nature of top risks
These reviews may be considered formal or informal,
depending on many factors, including the maturity of the risk
program and governance in the organization.
These reviews are not a part of risk treatment but instead
are an assessment of the universe of relevant risks. These
reviews help business leaders be better informed of the risks
that have been identified, and possibly would include
discussion on what risks may be the subject of focus in the
near term.

Identifying Candidates for Deeper Analysis


The purpose of risk register reviews is about reaching an
agreement on each risk’s ratings and other data as well as
overall risk reduction in the organization. Risk reduction is
accomplished by selecting risks that are considered suitable
candidates for next steps: deeper analysis and, eventually, risk
treatment.
The purpose of deeper analysis is to help the risk manager
decide if a specific risk is ready for risk treatment—the
decision made by business leaders on the final disposition of
the risk. Before that decision can be made, the risk manager
must first analyze the risk in more detail.
In the risk management program, the risk manager may
establish formal criteria or rely more on gut instinct for
selecting risks to study in more detail. A blended approach
will likely be used in this selection, where risks meet criteria
and are more “visible” than others. This visibility may be
related to applicable regulation, internal politics, market
reputation, service profitability, or other factors.
A risk manager may select less politically charged risks in a
new risk management program. Business leaders may then be
more comfortable making risk treatment decisions due to the
absence of emotional or political factors. When business
leaders are more familiar with the risk treatment process, risks
with greater visibility (whatever that may mean) can be
selected and treated.

Performing Deeper Analysis


When a risk has been selected for deeper analysis, it’s time for
the risk manager to begin working on it. The purpose of this
deeper analysis is to determine one or more viable risk
treatment options that, hopefully, business owners will agree
with and ratify.
Individual risks are generally not simple: discerning risk
treatment options may require much thought and discussion.
We prefer the ideal small group discussion, where the risk
manager and one or two subject matter experts brainstorm to
identify feasible risk treatment options.
There is no ideal number of options to analyze, although,
pragmatically, we prefer three to five options to be considered.
If more than five options are selected, risk analysis will take
additional time; with fewer than three, management may feel
that too few options were considered.

NOTE In our continuing discussion of risk management, risk


analysis, and risk treatment, we use terms that imply a simple
spreadsheet program for recording risks and performing risk
analysis. The use of a spreadsheet may be practical for an
emerging risk management program.

The Analysis Worksheet


The worksheet used for additional analysis compares the
untreated risk score with the risk score for each of several
possible risk treatment options. We like to use a simple model,
as described here:
Untreated risk:
• The same columns from the risk register, including
likelihood, impact, criticality, asset value, and risk
score.
Treated risk:
• An additional set of risk score columns, including
likelihood, impact, criticality, asset value, and risk
score.
• Additional columns that express the time, effort, and
cost required to perform the risk treatment.
• Columns that express the reduction in risk and residual
risk.
Risk treatment:
• One or more columns that would specify who or what
department or team would perform the risk treatment.
Each risk treatment option occupies a new row in the
worksheet. Each option is scored, with the scores representing
the levels of likelihood, impact, criticality, and asset value, as
well as the new calculated risk score, as though the risk
treatment was in place.
Once each risk treatment option is scored, the risk reduction
and residual risk are shown. The risk reduction and residual
risk, together with other columns showing hard costs and
impact on the workforce, can help the risk manager better
understand the feasibility of each risk treatment option.
Depending on the complexity of the risk, a detailed analysis
may require many hours of research and study. The amount of
time available for this work will depend on the risk manager’s
availability compared with other tasks. In some cases, detailed
risk analysis may be considered a luxury.
Figure A-2 depicts a simple risk analysis worksheet that
includes the initial risk rating, plus a description of various
risk treatment options with their ratings.

Figure A-2 A simple risk analysis worksheet showing risk


treatment options
NOTE We prefer to use a separate workbook for performing
detailed risk analysis; otherwise, the central risk register
workbook will soon be overcrowded with numerous risk
analysis tabs.

Qualitative and Quantitative Risk


For risks that involve relatively low costs, it may be sufficient
for the risk manager to rely only on qualitative risk analysis
techniques to portray which treatment options are more
effective than others at reducing risk. However, when the costs
of the risk and risk treatment are significant, the risk manager
may need to perform a quantitative risk analysis to determine
estimates of actual risk treatment costs. Quantitative risk
analysis is instrumental when the risk treatment option
includes significant hard and/or soft costs.

Selecting Treatment Options


For the risk analysis to contribute to successful risk treatment,
the risk manager needs to understand how the business leaders
in their organization think about risk. The risk manager should
select one or more risk treatment options that business leaders
can understand. Business leaders need to feel that their
decision is not forced or coerced, and that the options
represent a range of reasonable options.
As the risk manager ponders risk treatment options, they
need to remember the goal is to bring the elements together to
tell a story.

Considering Risk Appetite and Risk Tolerance


Organizations are all over the place regarding risk appetite and
risk tolerance. It is our experience (through many years of
consulting) that most organizations have no formal statement
or practice of risk appetite. In other words, management has
not drawn a line in the sand stating that risks above a certain
magnitude will not be routinely accepted.
Organizations lacking a formal risk appetite policy or
statement must rely instead on gut feel for determining
whether to accept any particular risk. While not ideal, as long
as the risk manager properly facilitates the risk treatment
conversation, business leaders can still make an informed risk
decision, even without formal risk guardrails.
A better situation is when the organization has formally
defined risk appetite, which states the highest risks that the
organization is permitted to accept. We advise another caution
here: risk managers should resist the call to reclassify specific
risks to a lower level, just to facilitate acceptance. Suppose a
particular risk exceeds the allowable risk appetite. In that case,
the organization’s risk tolerance comes into play: just how
much more risk will the organization accept on an exception
basis, and who is required to approve such an exception?
Understand that we’re still in the risk analysis phase but are
anticipating possible outcomes for risk treatment discussions
and an eventual decision. Risk managers should be prepared
with talking points to argue for and against each risk treatment
option as well as the array of risk mitigation options.
Remember that it is not the risk manager’s responsibility to
make risk decisions but rather to facilitate discussions leading
to business leaders making informed decisions.

Developing a Risk Treatment


Recommendation
We like to think about the risk analysis of a risk register item
as the development of an entire package of information to be
presented to senior management. The package will typically
consist of the following:
• A brief description of the risk
• The context of the risk
• Typical risk scenarios, with their probability and impact,
if and when realized
• Risk treatment options
• The recommended risk treatment option
• Backup information should management wish to
explore the matter further
When taking risk treatment options to senior management,
we have reduced this to a single presentation slide and speak
to the matter in business terms. Typically, there will be some
discussion and a few questions. Depending on the formality of
the organization, there may be a formal vote or verbal support
for or against a decision.
It’s vital to develop talking points, anticipate questions, and
rehearse the briefing with a trusted peer. You generally have
one opportunity to tell the story of the risk, its potential impact
on the organization, and what you propose be done about it.

NOTE It’s always better to be prepared with more


information than is used in a risk treatment proceeding.
Risk Treatment Overruled
As a risk manager in a public company, I (Peter) brought to
senior leadership in one of our risk management reviews a
matter of workplace security and safety: a particular
business office had no access control that segregated work
areas from the reception area. Visitors during business
hours could simply walk through the door and into the
entire office suite where about 100 employees worked. My
recommendation was to accept this risk.
The company president stood up and said, “No, I will
not accept this risk. We should have a wall and door
constructed to keep visitors out of the work area unless they
are permitted to enter.”
While this may at first appear to have been a correction
or a reprimand, I took it as an engaged senior executive
taking a different point of view and making an informed
risk decision. At this point, I knew that senior leaders were
engaged and not merely rubber-stamping my
recommendations.

The Risk Treatment Decision


Up to this point, the risk manager has been analyzing one or
more risks, developing viable risk treatment and risk
mitigation options, and preparing a package to present to
senior management. During the meeting in which the risk
manager has presented the story of the risk and the
recommended course of action (or inaction, in the case of risk
acceptance), senior leaders should be allowed to ask questions
about the matter before being asked to ratify the
recommendation (or decide otherwise). Note the questions,
who asked them, and how they were answered—this will help
in future proceedings.
The call for the actual decision may range from formal to
informal. An accurate accounting of the decision is critical, as
it should be a part of officially published meeting minutes
used to document the decision. Note those present and
(optionally) who agreed and who disagreed.

NOTE In some cases, it may be wise to discuss the risk


treatment matter with senior executives in one-on-one
discussions, where they may be more apt to ask questions to
understand the situation better. These discussions will also
help the risk manager better prepare for the risk treatment
discussion, and in some cases, it may even sway the risk
manager to pursue a different remedy.
Risk Mitigation When the risk treatment decision is
mitigation, the decision should also include the naming of the
person responsible for performing the risk treatment and
executives’ desire for the timing of risk treatment. This is
particularly important if the risk treatment owner is not present
in the discussion.
Any discussion about risk treatment options should be
captured so that the risk treatment owner will have additional
background and insight into why the particular risk treatment
option was selected. This may help the risk treatment owner
proceed more quickly with planning and execution without
circling back to decision-makers to better understand the
rationale behind the decision.
All of the basic facts about risk mitigation (who made the
decision, when the decision was made, who the risk treatment
owner is, when the risk treatment should be completed, and so
on) should be entered into the risk register. Then, the risk
manager can conduct effective follow-up over the coming
weeks, months, and quarters and report on the progress to the
decision-makers.
Risk Acceptance If the risk treatment decision is acceptance,
we recommend that this decision not be perpetual but instead
have an expiration date. After that expiration date, the risk will
be reopened and a new risk treatment decision made. The
reason for expiring risk acceptance is this: conditions related
to the risk may change in a year, so much so that a different
decision may be needed in the future. Many things can change
in a year:
• How the organization uses information systems
• The organization’s reliance on critical business
processes on information systems
• Changes in underlying information technology
• Changes in threats
• Changes in tools that help mitigate threats
• Changes in business priorities
One year may seem like a short period, but a lot can happen in
a year. Make sure executives are on board with this concept.
Organizations with formal risk management programs
sometimes utilize a risk acceptance letter—a signed memo in
which a business unit leader or department head chooses to
accept a specific, identified risk versus another risk treatment
option such as mitigate, transfer, or avoid. In the risk
acceptance letter, the signatory accepts the potential
consequences if an event related to the risk occurs in the
future.
CISOs Are Not Risk Owners
Many organizations have implicitly adopted the mistaken
notion that the chief information security officer (CISO) is
the de facto risk owner for all identified risk matters.
In a properly run risk management program, risk owners
are business unit leaders and department heads who own
the business activity where a risk has been identified. For
instance, if a risk is identified regarding the long-term
storage of full credit card numbers in an e-commerce
environment, the risk owner would be the executive who
runs the e-commerce function. That executive would decide
to mitigate, avoid, transfer, or accept that risk.
The role of the CISO is to operate the risk management
program and facilitate discussions and risk treatment
decisions, not to make those risk treatment decisions. A
CISO can be considered a risk facilitator but not a risk
owner.
Even when embraced and practiced, this concept does
not always stop an organization from sacking the CISO
should a breach occur. A dismissal might even be
appropriate, for example, if the risk management program
that the CISO operated was not performing as expected.

Risk Transfer One of the four basic risk treatment options,


risk transfer means that some outside organization is willing to
take on the risk. Often, this comes in the form of cyber
insurance, but it could just as easily be a business process
outsourcing (BPO) arrangement in which a service provider is
willing to accept certain risks.
We provide a note of caution here. While an organization
can outsource risk, no organization can outsource
accountability. Here is an example: a successful service
business specializing in water damage mitigation outsources
its entire IT and IT security functions to a large service
provider, including information systems where customers
register and request one-time or recurring services. The IT
service provider suffers a breach, resulting in the exposure of
its customers’ personal information and numerous identity
theft and fraud cases. The service business attempts to explain
that the external service provider is the party responsible for
the breach. However, the customers are unhappy, blame the
service business, and threaten to organize a class-action
lawsuit for the damages.
In this example, the service business cannot absolve itself
because the IT outsourcer’s lapse resulted in the breach. The
service business decided to use this particular IT outsourcer
and cannot absolve itself of responsibility because of an
unfavorable outcome.
Cyber insurance is similar to this example. An organization
with cyber insurance may suffer a breach, and the cyber
insurance company may compensate the organization for
particular losses. However, the organization will have lost
some goodwill and may have a long-lasting tarnished
reputation that can take years to undo.
It is imperative that senior executives fully grasp the
complete picture of risk transfer.
Risk Avoidance Risk avoidance is often the least understood
risk treatment option. With risk avoidance, the activity that
causes the risk is itself discontinued.
Here is an example: a risk assessment reveals the use of an
unsanctioned cloud service provider to process sensitive
information. End users decided to employ a free online service
to perform language translation and use it for translating
sensitive documents, including contracts. In its end-user
licensing agreement (EULA), the service provider claims
ownership over any content that it translates. When this matter
was brought to light in a risk treatment discussion, business
executives directed the organization to immediately
discontinue use of the service provider, thus avoiding the risk.
The Fifth Option in Risk Treatment
For decades, risk management frameworks have cited the
same four risk treatment options: accept, mitigate, transfer,
and avoid. There is, however, a fifth option that some
organizations select: ignore the risk.
Ignoring a risk situation is a choice, although it is not
considered a wise choice. Ignoring a risk means doing
nothing about it, not even making a decision about it. It
amounts to little more than pretending the risk does not
exist. It’s off the books. It is not even added to a risk
register for consideration, but it represents a risk situation
nonetheless.
In some cases, such as for minimal risk items, this may
be perfectly acceptable. A theft of a paperclip may simply
be too small for consideration for a risk register. It would
probably be wise to leave this off of a risk register unless
there is a specific reason to add it. In some cases, listing
minimal risk is very critical because compliance
requirements dictate that specific risks be considered in risk
evaluations. Developing the right level of detail for a risk
register requires experience, listening to an organization’s
culture, and striking the right balance.
Organizations without risk management programs may
implicitly ignore all risks, or many of them at least.
Organizations might also be practicing informal and maybe
even reckless risk management—risk management by gut
feel. Without a systematic framework for identifying risks,
many are likely to go undiscovered. This practice could
also be considered as ignoring risks through the implicit
refusal to identify them and treat them properly.
Note that ignoring risk, particularly when governance
requires that you manage it, is usually a violation of the
principles of due diligence and due care. Many
organizations can be legally charged with “willful
negligence” if they have a duty to manage risk, and they
simply don’t.
Other Risk Response Options Other common risk response
options include contingency, enhance, and exploit.
Contingency is all about creating contingency plans in case
a risk materializes. For instance, an organization might
develop a playbook within its security incident response or
business continuity planning process to respond to a specific
type of event.
Enhance may be a response to a positive risk such as a
project coming in under budget. If a few dollars spent earlier
in the project will save some money long term, it may make
sense to enhance the risk. In another example, a security
engineering team determines that a new detective control helps
to reduce other risks not considered initially.
Exploit can be very much related to the same situation. If a
project finishes early, the resources may be reassigned to
another project. Note that this use of the term exploit is
different from that of malware or an attacker exploiting a
vulnerability in an information system, business process, or
worker.

Publishing and Reporting


Like any formal business program, risk leaders publish
periodic reports and metrics from the risk management
program. The risk program needs to inform business
executives on the state of risk in the organization and
proceedings in the program. Several aspects of risk reporting
are discussed here.

Risk Register
The risk register itself is considered a detailed, operational
business record. Reporting about the risk register generally
consists of high-level depictions of risk instead of reporting
the detail. Challenges in reporting risk include the following:
• Trends Changes in the size of the risk register, or the
aggregate or average risk levels, may be misleading,
particularly in newer risk programs that still identify
risk.
• Completeness A risk register should not be considered
a complete record of risk, as there may be numerous
undiscovered and unidentified risks.

New Risks
Risk leaders may opt to disclose the number of, or even some
details about, new risks identified in the reporting cycle. This
reporting is a good indication that the risk program continues
to keep its risk radar operating and open to risk discovery.

Risk Review
Reporting and metrics on risk reviews are an indication of
engagement and involvement. Executives should expect risk
leaders to periodically engage business leaders and department
heads throughout the organization and may want to know how
often (and with whom) this occurs.

Risk Treatment
The rate at which risk treatment decisions are made, and trends
in risk treatment options, shows that the risk leader continues
to work through the risk register.

Risk Mitigation Follow-Up


When mitigation is the chosen risk treatment for a given risk,
the risk leader needs to track that risk mitigation and report on
whether mitigation is performed on schedule. Mitigation
activities that are behind schedule can be highlighted so that
executives can understand where their directives are falling
short and which are being completed on time.

Risk Renewals
As discussed earlier in this appendix, risk acceptance should
not be perpetual but should expire. Risk leaders may want to
publish, as a leading indicator, the number of risks nearing
renewal. Those risks will be redeliberated and new decisions
made, whether to continue to accept the risks for another year
or take a different approach.
Risk Prioritization
In risk reporting, leaders often care only about the top-priority
risk, such as a top 5, 10, or 20 risks. These may not be
precisely the top risks, according to the risk manager.
However, these priorities represent an articulation of risk
appetite and risk tolerance, as well as leadership’s culture and
focus on risk. All too often, risk prioritization with managers
boils down to nothing more than cost, unfortunately.

The Sensitivity of Risk Reporting Information


In most organizations, detailed information about risk,
particularly vulnerabilities and safeguards, is treated as highly
confidential. If it became public, that information might allow
the organization to be attacked. Further, this information
would reveal clues about the organization’s risk culture. This
is especially true in government and healthcare, in our
experience.
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GLOSSARY

acceptable use policy (AUP) Organizational policy that


describes both acceptable and unacceptable actions when
using organizational computing resources, as well as the
consequences of violating the policy.
access control The processes and technologies involved in
protecting information, systems, and data against unauthorized
disclosure, modification, or loss through the control of access
to those resources physically and/or logically.
accountability The ability to trace an action or event to a
specific subject and to hold that subject responsible for their
actions.
AIC triad See CIA triad.
assessment The process of determining whether a program,
project, or control is meeting specified objectives as well as
determining whether the controls selected to protect the
system are performing their desired function to the level
required.
asset Anything of value to an organization; assets can include
tangible items such as information, data, equipment, supplies,
facilities, and systems as well as intangible items such as
customer loyalty and reputation.
asset valuation The practice of assigning a monetary value to
an asset.
attack An offensive action that results in potential harm to an
asset.
attack surface The set of components that could be the target
of attack by an adversary.
audit A formal inspection of a control, process, or system to
determine whether it is being followed, operates effectively,
and meets its objectives.
authentication The process of validating credentials a user
has supplied to verify that they are the actual authorized user
and that the credentials belong to that user.
authorization The process of giving authenticated users the
proper accesses to systems, data, and facilities.
availability The goal of having information and systems
available to authorized users whenever and however they need
them.
bow-tie analysis A risk analysis technique used to depict the
relationships between various elements of risk.
brainstorming A problem-solving technique in which
participants spontaneously generate potential ideas for
discussion and analysis.
business case In the context of risk management, a written or
oral presentation that explains the reasoning for the expense
and effort associated with risk response.
business continuity The process, generally detailed in a
supporting plan, that keeps the company operating and
functioning in the event of a power outage, IT malfunction, or
major disaster.
business impact assessment (BIA) The process of analyzing
critical business processes, as well as the assets used to
support them, and determining the impact to them when a loss
of or disruption in access to those assets occurs.
business process outsourcing (BPO) The process of
outsourcing one or more business processes to a service
provider.
business triage A decision-making system used to prioritize
resources to maximize outcomes.
capability The ability for the organization to implement a risk
response.
capability maturity model integration (CMMI) A business
process maturity model developed by Carnegie Mellon
University and now owned by ISACA.
change management The overall process used to manage the
request, review, approval, and execution of changes to IT
systems or business processes.
CIA triad The three security principles of confidentiality,
integrity, and availability.
COBIT A management and governance framework developed
and used extensively by ISACA in its various risk
management and business process frameworks.
code review A manual examination of software source code to
identify defects, including those that may be exploited by an
attacker. See also code scan.
code scan An automated examination of software source code
to identify defects. See also code review.
common control A control spanning the entire organization
that protects multiple assets rather than only a specific asset. A
physical control is a good example of a common control, and
the responsible entity for that control would be the common
controls provider.
confidentiality The goal of protecting systems and
information from unauthorized disclosure.
configuration management The use of recordkeeping to
record changes made to configuration settings in an
information system.
control A measure put in place to increase protection for an
asset, to make up for a lack of protection for an asset, or to
strengthen a weakness for an asset. Controls can be
administrative, technical, or physical and operational. They
can also be further divided by functionality (deterrent,
preventative, detective, and so on).
control baseline The initial set of controls selected, based on
the security categorization to be applied to systems and data
and maintained throughout their life cycle.
control deficiency analysis The process of determining the
difference between the existing state of a control’s
effectiveness and its desired state.
control gap A situation where controls do not exist or are
insufficiently designed to meet a control objective.
control objective An overarching statement describing the
intent of a group of controls.
control ownership The person or entity responsible for the
proper implementation and maintenance of security controls
within the organization.
cost The financial impacts of any decision as well as the less-
easily quantified aspects such as loss of goodwill, loss of
brand status, and other hard-to-define attributes. Cost also
includes the maintenance of the responsive mitigation over its
required life span.
criticality analysis A study of each system and process, a
consideration of the impact on the organization if it is
incapacitated, the likelihood of incapacitation, and the
estimated cost of mitigating the risk or impact of
incapacitation
culture The values and norms in an organization that define
how people treat each other and work together to achieve
organization objectives.
data classification Policies that define sensitivity levels and
handling procedures, and controls used to protect information
at various levels.
data destruction The willful or malicious destruction of data
that renders it unavailable for intended uses.
data discovery A manual or automated technique in which a
target system is examined to determine the presence of
specific types of data; additionally, this may include an
examination of access rights to particular sets of data.
data sensitivity The level of protection required for
information or data based on its impact to the organization if it
were disclosed to unauthorized people, subject to unauthorized
modification, or otherwise lost.
Deming cycle A generic business life cycle model consisting
of Plan, Do, Check, and Act.
denial of service (DoS) An attack on a system that renders it
unavailable for legitimate uses.
design review The examination of the design of a system or
process to determine whether it is sound and meets stated
objectives.
disaster recovery (DR) The process of reacting to an incident
or disaster and recovering an organization, its personnel, and
systems to a functioning state.
due care The process of taking the necessary responsibility
and steps to protect an organization and its workers.
due diligence The reasonable amount of investigation taken
prior to entering into a legal agreement.
due process An impartial and fair inquiry of violations of
organization policy.
economy of use The design principle that states that you
should attempt to design and implement controls that can be
applied to more than one system or set of data or that provide
more than one function in effectively mitigating risk. The goal
is to minimize single-use controls (controls that apply only to
a specific system or set of data) because they can be more
expensive and specialized to implement.
effectiveness The extent to which the response reduces the
likelihood or the impact of the risk event to the organization;
also, the degree and depth to which a control fulfills its
security requirements.
efficiency The interaction of a control with its environment,
affecting factors such as cost, reliability, supportability, and
interoperability.
enterprise risk management (ERM) The practice of
identifying and managing strategic risk in an organization.
event An instance of threat realization.
event-tree analysis A bottom-up risk analysis technique that
focuses on all possible risk impacts and looks for all possible
risk events.
exception management The process of accepting,
documenting, and tracking exceptions to security policies and
risk mitigation strategies.
exploit 1) A specific tool or method that can be used to carry
out a threat. 2) The act of attacking an asset, made possible by
the presence of a vulnerability.
Factor Analysis of Information Risk (FAIR) A risk analysis
methodology used to analyze the factors that contribute to
individual risks.
false negative A situation where a vulnerability isn’t detected
but does actually exist.
false positive A situation where a vulnerability is reported that
isn’t actually legitimate.
fault-tree analysis A top-down risk analysis technique that
focuses on risk events and looks for all possible causes of the
event.
Federal Information Processing Standards (FIPS) Public
standards published by the National Institute of Standards and
Technology (NIST) for use in U.S. government systems.
Federal Information Security Management Act (FISMA)
A U.S. federal law requiring federal agencies to develop
information security programs and capabilities aligned to
NIST Special Publication 800-53.
framework An overall methodology prescribing higher-level
processes or controls.
fuzzing A technique used to generate various forms of input to
a system to identify potential vulnerabilities that could allow
an attacker to compromise the system.
gap assessment An examination of a system or process to
determine whether it complies with established requirements
or standards.
governance The legal or corporate standards that prescribe
how an organization will conduct itself with regard to its
behavior in handling information and data.
governance, risk, and compliance (GRC) system See
integrated risk management (IRM) system.
Gramm-Leach-Bliley Act (GLBA) U.S. law that requires
financial institutions (including banks, loan companies,
insurance, and investment companies) to protect sensitive
financial data and make their information-sharing practices
known to their customers. Of particular interest to security
professionals is the Safeguards Rule incorporated into GLBA,
which requires institutions under the jurisdiction of the Federal
Trade Commission to have specific measures in place to
protect customer information.
Health Insurance Portability and Accountability Act
(HIPAA) Law passed in 1996 requiring the U.S. government’s
Health and Human Services Department to establish
requirements for protecting the privacy and security of
personal health information (PHI). The two important
elements of HIPAA of interest to security professionals are the
HIPAA Privacy Rule and the HIPAA Security Rule, which set
forth specific standards to protect electronic PHI.
identification The process of initially presenting credentials to
a system to identify an authorized user.
impact The level of potential harm or damage to an asset or
the organization if a given threat were to exploit a given
vulnerability.
inherent risk The level of risk associated with a specific
activity or function, prior to applying any protective controls
or safeguards.
integrated risk management (IRM) system An information
system used to track and manage various governance, risk, and
compliance activities, including risk management.
integrity The goal of preventing unauthorized modification to
a system or data.
ISO/IEC The International Organization for Standardization
(ISO) and the International Electrotechnical Commission
(IEC), which together are responsible for a majority of the
information technology standards used worldwide, including
several that apply to information security and risk
management.
IT general control (ITGC) A control that is applied across all
information systems and supporting processes in an
organization.
job rotation A practice where an organization occasionally
moves personnel from one job to another to help prevent
practices contrary to policy.
key control indicator (KCI) A specific indicator that shows
the relative effectiveness of a control.
key performance indicator (KPI) An indicator that is used to
understand and enable the measurement of a control’s
performance.
key risk indicator (KRI) A highly probable indicator
designed to accurately predict an important level of risk based
on a defined threshold.
least privilege A security principle that dictates that subjects
should be given only the minimum level of rights,
permissions, and privileges necessary to perform their
designated functions or jobs, and no more than that.
life cycle A characteristic of a business process where a
sequence of activities is repeated.
likelihood The certainty that an incident will occur; often
expressed statistically as a probability of occurrence.
mandatory vacation A practice where an organization
requires that each employee use a minimum amount of
vacation each year to provide the opportunity for audit,
security, and privacy specialists to examine the employee’s
practices or records during their absence.
materiality A quantitative or qualitative expression of
significance.
maturity The degree of formality and optimization of a
business process or capability.
maturity assessment An assessment of processes or
capabilities to determine their maturity. See also maturity.
maximum tolerable downtime (MTD) A theoretical period,
measured from the onset of a disaster, after which the
organization’s ongoing viability would be at risk.
multifactor authentication Any means used to authenticate a
user that is stronger than just the use of a user ID and
password. Examples of multifactor authentication include
digital certificates, tokens, smart cards, and biometrics.
need-to-know A security concept that requires a subject have
an actual requirement to access systems or data, based on their
job requirements.
NIST The U.S. Department of Commerce’s National Institute
of Standards and Technology, a standards development
organization.
NIST Risk Management Framework (RMF) The overall
risk management methodology published and promulgated by
the National Institute of Standards and Technology (NIST) in
Special Publication 800-37.
non-repudiation The security concept that requires a subject
to be accountable for their actions, such that they cannot deny
that they took an action.
OCTAVE The Operationally Critical Threat, Asset, and
Vulnerability Evaluation (OCTAVE) methodology developed
by Carnegie Mellon University and the U.S. government to
assist organizations in identifying and assessing information
security risk.
Payment Card Industry Data Security Standard (PCI
DSS) A set of security requirements levied on merchants that
process credit card transactions by the major payment card
industry providers, including Discover, Visa, MasterCard, and
American Express. PCI DSS was developed to impose security
requirements and controls on retailers (merchants and service
providers) to reduce credit card fraud and identity theft.
penetration test An authorized assessment that actively
identifies and exploits vulnerabilities or weaknesses in a
system or process.
personally identifiable information (PII) Data elements that
uniquely identify a natural person.
platform A hardware, software, or cloud infrastructure upon
which to base computing operating systems, applications, and
networks. It may involve different operating systems, network
protocols, or particular types of hardware.
port scanner A software program that determines which ports
on a target system are listening for incoming requests. See also
vulnerability scanner.
portfolio A grouping of programs managed as a whole.
Portfolio management involves the oversight of several
different programs by a senior person in the organization.
practice A proven, standardized methodology or way of
performing particular tasks or processes.
privacy The principles and practices of ensuring the
protection and proper use of the personally identifiable
information (PII) of customers, constituents, and workers.
probability The chance that an event will occur.
program 1) A grouping of similar projects; programs are
usually ongoing and longer term in nature and may also
encompass several individual projects. 2) Activities specific to
processes that may have an indefinite duration.
project A limited-duration set of activities geared toward a
particular goal; projects have definitive start and stop dates,
resource allocations, scopes, schedules, and costs.
project management A set of processes covering a defined
project from start to finish, generally looking to cut costs such
as time, scope, and overall project cost.
protocol analyzer A hardware or software tool that collects
network traffic for the purpose of examination, either for
determining network issues or for capturing plaintext
usernames, passwords, or other sensitive information being
sent in the clear.
qualitative assessment An assessment technique that uses
subjective values, such as low, moderate, and high, to describe
various components of risk, such as likelihood and impact.
Qualitative techniques rely on data that is often not easily
described in numerical terms.
quantitative assessment An assessment technique that uses
nonsubjective values, such as numerical or other measurable
data, to describe various components of risk, such as
likelihood and impact. Quantitative techniques rely on data
that is numerically derived and not easily subject to individual
opinion.
quick win A high-reward, low-cost risk response that is both
effective and efficient.
recovery point objective (RPO) The maximum tolerable
period in which data can be lost by the organization because of
an incident or disaster.
recovery time objective (RTO) The maximum amount of
time allowed to pass between an incident and recovering a
business process to an operational state.
residual risk The risk that remains after the application of risk
treatment, acceptance, or transfer.
resilience The ability of the business to survive negative
events and continue with its mission and function.
return on investment (ROI) The ratio between investment
and value received.
risk The possibility of harm that can come to an asset or an
organization.
risk acceptance An active decision made to assume risk
(either inherent or residual) and take no further action to
reduce it.
risk acceptance letter A formal memo in which a business
leader agrees to accept an identified risk.
risk analysis The detailed examination of an individual risk
identified in a risk assessment.
risk appetite The organization’s overall acceptable level of
risk for a given business venture.
risk assessment The process of identifying and assessing
various factors, including threats, threat actors, vulnerabilities,
assets, and likelihood to determine their impact on the
organization.
risk avoidance A risk treatment option taken when the level
of risk is still not acceptable after controls have been
considered, resulting in an activity being canceled or not being
started.
risk capacity The amount of loss that an organization can
incur without seriously affecting its ability to continue as an
organization.
risk culture The overall attitude toward risk, promulgated and
supported by the organization’s leadership.
risk factor Any factor that may contribute to an increase or
decrease in risk; risk factors could be external or internal, and
they could affect either likelihood or impact should a risk
event actually occur.
risk identification The realization of a new risk to an
organization, its systems, or its processes.
Risk IT Framework ISACA’s own risk management
methodology; it is strongly tied to and integrated with COBIT.
The Risk IT Framework merges traditional IT models with a
more risk-focused mindset.
risk ledger See risk register.
risk management The life cycle process of managing risk
within an organization at all levels, according to the
organization’s risk appetite, tolerance, and strategy.
risk mitigation Involves the application of controls that lower
the overall level of risk through the reduction of the
vulnerability, the likelihood of the threat exploit, or the
reduction of the impact to the asset, if the risk were to be
realized.
risk monitoring Ongoing risk assessment activities in which
risks are periodically reviewed to determine whether the
nature of threats, threat actors, vulnerabilities, impact, or
probabilities of occurrence have changed.
risk owner The person ultimately responsible and accountable
for a risk.
risk ownership The state of being responsible and
accountable for a risk.
risk profile A collection of detailed data on identified IT risks,
typically applied to a specific system or groups of systems.
risk ranking The process of placing risks into a sequence,
usually with the greatest risks appearing first.
risk realization The awareness that a potential risk scenario
has become actualized.
risk register The master product or document that reflects the
different risk scenarios and factors for the organization; it
could be broken down by asset or system and reflects the
different risk factors, including threats, vulnerabilities, assets,
likelihood, and impact to assets.
risk response action plan A list of the risk responses that
have been chosen, and the charts of their progress and
associated timeline, with an appropriate action owner or
owners.
risk scenario An identified risk event possibility, which
consists of a threat actor, threat, vulnerability, and asset.
risk sharing Often referred to as risk transference, risk
sharing entails the use of a third party to offset part of the risk.
It can involve the outsourcing of some activities to a third
party to reduce the financial impacts of a risk event.
risk tolerance The organization’s level of acceptable variation
from the risk appetite.
risk transference See risk sharing.
root-cause analysis (RCA) A method of problem-solving that
seeks to identify the root cause of an event or problem.
Sarbanes-Oxley Act of 2002 (SOX) U.S. law passed in 2002
establishing requirements for public companies in the United
States, as well as auditors and accounting firms, to improve
the accuracy and reliability of corporate disclosures
concerning securities laws. The law is enforced by the U.S.
Securities and Exchange Commission (SEC) and provides
governance for the integrity and accuracy of data produced by
an organization. For security professionals, this has the effect
of imposing specific integrity and protection controls on
information systems and processes.
scope The set of systems, processes, personnel, data, or work
centers to be included in an assessment.
security categorization The process of determining the
impact to the organization regarding the confidentiality,
integrity, and availability of information and systems. The
security categorization uses qualitative benchmarks of low,
moderate, and high. FIPS 199 and NIST Special Publication
800-60 offer a defined process for the security categorization
of information.
security control A security measure or protection applied to
data, systems, people, facilities, or other resources to protect
them from adverse events. See also control.
segregation of duties See separation of duties.
separation of duties The process design and access control
concept that enforces the rule that no single individual can
carry out certain high-value or high-risk tasks.
service level agreement (SLA) A contractual agreement,
signed by an organization and a third-party provider, that
details the level of security, data availability, and other
protections afforded the organization’s data held by the third
party.
sniffer See protocol analyzer.
Software as a Service (SaaS) A third-party cloud-based
service that offers outsourced use of software; this allows an
organization to use licensed software at a lower cost than
buying, installing, and maintaining hardware and software.
stakeholder Any business-related individual, department, or
entity directly affected by risk to the organization.
standard A prescribed set of detailed processes, which may
include specific levels of performance or function, used to
complete and measure a given task or function.
statement of impact A qualitative or quantitative description
of the impact on an organization if a process or system is
incapacitated for a time.
systems development life cycle (SDLC) A framework
describing the entire useful life of a system or software, which
usually includes phases relating to requirements definition,
design, development, acquisition, implementation, operations,
and disposal.
tailgating A practice of unauthorized persons following
authorized persons through a security door or entrance.
The Open Group Architecture Framework (TOGAF) A
life-cycle enterprise architecture framework used for the
designing, planning, implementation, and governance of an
enterprise architecture.
third-party risk management (TPRM) The set of activities
used to identify and manage risks associated with the use of
external suppliers and service providers.
threat An event or occurrence that has the potential to cause
harm or damage to people, places, or things or to adversely
affect operations.
threat actor A threat agent that is one or more people. See
also threat agent.
threat agent An entity that has the intent to initiate a threat
event. This doesn’t have to be a person; it could also be nature,
in the case of a natural disaster.
threat assessment An assessment that attempts to determine
all potential threat actors and threats that may affect a given
asset or its vulnerabilities.
threat landscape The set of threats that have been identified
that are associated with a business activity or business asset.
threat modeling A threat assessment that attempts to
determine all possible vectors of attack and includes risk
factors that may affect the ability of a threat actor to initiate or
complete a threat event.
threat realization A threat that is carried out that causes harm
or damage to people, places, or things.
three lines of defense The concept of defense within a risk
management framework that consists of operational
management, risk and compliance management, and audit and
accountability.
triage See business triage.
vulnerability A weakness in a system, asset, or process, such
as a flaw in software code; it can also be considered a lack of
protection for an asset, such as an unlocked server room door.
vulnerability analysis Examination of a vulnerability in a
system, asset, or process.
vulnerability assessment An assessment that attempts to
discover potential weaknesses for an asset. This involves
identifying the assets that will be covered within the scope of
the assessment, conducting scans and other tests against those
assets, and providing a report of the vulnerabilities that have
been found.
vulnerability scanner A software program designed to scan a
system to determine what services the system is running and
whether any unnecessary open ports, operating systems and
applications, or back doors can be exploited because of a lack
of patching or other flaws. See also port scanner.
walkthrough An interview with a control, process, or system
owner as a part of an assessment.
work breakdown structure (WBS) A detailed decomposition
of the work to be performed during the project, including
specific step-by-step tasks, as well as required resources.
workers An inclusive term that means employees (full-time
and part-time), temporary workers, contractors, consultants,
and others who are a part of an organization’s workforce.
Zachman framework An enterprise architecture framework
used to describe an IT architecture in increasing levels of
detail.
INDEX

A
acceptable use policies (AUPs), 169–170
acceptance, risk, 84–85, 200–201
access control
non-repudiation, 158
PCI DSS, 100
principles and policies, 167–168
types, 155–156
account suspension, 175
accountability
auditing relationship, 13
overview, 158
risk ownership, 83
third-party risk, 87
adaptability issues in AUPs, 169
administrative controls, 32, 94
advisories, 24
aggregation of data, 108–109
ALE (annual loss expectancy), 60–62, 103
analysis
controls, 31–37, 103–104
data, 108–109
risk. See risk analysis methodologies
analysis worksheets, 197–198
annual loss expectancy (ALE), 60–62, 103
annualized rate of occurrence (ARO), 60
Anything as a Service (XaaS), 131
architecture and design reviews, 42
ARO (annualized rate of occurrence), 60
assess step in RMF, 161
assessments
data collection for, 42–43
defined, 40
IT risk. See IT risk assessment
scope, 42
types, 41–42
asset-level risk registers, 193
asset value (AV)
control selection factor, 103
qualitative risk analysis method, 191
risk analysis, 56
assets
collecting and organizing data for, 9–10
description, 26, 156
examples, 7–8
identifying in risk analysis, 56, 58
IT risk assessment, 43–44
management systems, 9
organizational, 6–10
sources of data for, 8–9
attacks, defined, 26
attainability in KPIs, 111–112
audience for training programs, 166
audits
accountability, 158
description, 42
new risk identification, 23
overview, 13
risk register information source, 55
AUPs (acceptable use policies), 169–170
authentication, 157
authorization, 157–158
authorize step in RMF, 161–162
AV (asset value)
control selection factor, 103
qualitative risk analysis method, 191
risk analysis methodology, 56
availability
description, 154–155
health data, 73
key performance indicators, 111–112
avoidance, risk, 85
awareness training programs, 165–167

B
BAAs (business associate agreements), 87
background checks in hiring, 173
battlefield allegory, 185–186
Bayesian analysis method, 66
BCDR. See business continuity and disaster recovery (BCDR)
management
BCP (business continuity planning) projects, 67–68
BIA. See business impact analysis (BIA)
bottom-up risk scenario development, 39
bow-tie analyses, 65–66
brainstorming and risk identification, 25
brand equity assets, 8
building assets, 7
business alignment, 45
business associate agreements (BAAs), 87
business context in risk analysis, 56
business continuity and disaster recovery (BCDR)
management
business impact analysis, 66, 141
overview, 140–141
plan testing, 142
recovery objectives, 141
recovery strategies, 141–142
resilience and risk factors, 142–144
business continuity planning (BCP) projects, 67–68
business impact analysis (BIA)
criticality analysis, 69–70
inventory key processes and systems, 67
overview, 66, 141
recovery objectives, 70
statements of impact, 68–69
business impact in risk analysis, 58
business leaders, risk register reviews with, 195–196
business processes
asset organization by, 9
organizational governance, 5–6
BYOD devices, 184, 193

C
CA (criticality analysis), 69–70
California Consumer Privacy Act (CCPA), 171
categorize step in RMF, 160–161
causal analysis step in root cause analysis, 37
CCBs (change control boards), 89
CCPA (California Consumer Privacy Act), 171
Center for Internet Security (CIS), 97–98, 100
centralized dashboards for controls, 110
change control boards (CCBs), 89
change management, 89–90
controls, 104
IT operations management, 136
SDLC, 151
change risk in emerging technologies, 153
chief information security officers (CISOs), 201
chronology step in root cause analysis, 37
CIS (Center for Internet Security), 97–98, 100
CISOs (chief information security officers), 201
classification
assets, 58
data, 145–146, 156–157
clearance for authorization, 158
cloud services
enterprise architecture, 131
risk, 184
COBIT 2019, 162–164
Code of Professional Ethics, 15
code reviews, 42
code scans, 42
codes of conduct and ethics, 174
collection of data, 108–109
Committee of Sponsoring Organizations of the Treadway
Commission (COSO), 163
common controls, 36, 82
common controls providers, 36
Common Vulnerability Scoring System (CVSS) score, 32
communication between risk register layers, 194
compatibility in emerging technologies, 153
compensating controls, 94–95
completeness issues
acceptable use policies, 169
risk registers, 203
complexity increases, 184
compliance management, 12–13
compliance risks, 23
concepts in IT risk assessment, 40–45
conduct, codes of, 174
confidentiality
data classification, 145–146, 157
health data, 73
information security, 128
overview, 154–155
configuration assessments, 24
configuration management
controls, 104
IT operations management, 136
overview, 89–90
SDLC, 151
consultants
risk register information source, 56
tracking, 173–174
contingency responses, 203
continuity. See business continuity and disaster recovery
(BCDR) management
contractors, tracking, 173–174
contractual requirements, 14–15
controls
analysis, 103–104
change and configuration management, 104
deficiency analysis overview, 30–31
design, 101–102
effectiveness evaluation, 31–34, 106
frameworks, 98–101
gaps, 34
key control indicators, 113
key performance indicators, 110–112
key risk indicators, 112–113
monitoring techniques, 109
overview, 93
ownership, 36, 82–83
recommendations, 34–35
reporting techniques, 109–110
security, 155–156
selecting, 102–103
standards, 96–101
testing, 104–106
types and functions, 93–96
corrective actions in root cause analysis, 37
corrective controls, 94–95
COSO (Committee of Sponsoring Organizations of the
Treadway Commission), 163
cost
controls, 103
pressure on, 184
project management, 137–139
risk response options, 85
countermeasure controls, 96
critical processes risks, 143
criticality analysis (CA), 69–70
culture in organizational governance, 4
currency of technology in risk scenario development, 40
CVSS (Common Vulnerability Scoring System) score, 32
cyber insurance, 202
cybercrime, 183
cybersecurity risks, 23

D
dashboards for controls, 110
data
availability, 155
classification, 145–146, 156–157
collecting for assessment, 42–43
destruction policies, 147, 155
discovery, 42
retention policies, 146–147
sensitivity, 156–157
data governance risks, 24
data in motion, 131
data lifecycle management
overview, 144–145
standards and guidelines, 145–146
data processing in risk reporting, 108–109
databases
enterprise architecture, 130
networks, 130–131
risk analysis, 56
Delphi method, 66
denial of service, 155
design
controls, 101–102
SDLC phase, 149–150
destruction of data, 147, 155
detective controls, 94–95
deterrent controls, 94–95
development phase in SDLC, 150
differentiation step in root cause analysis, 37
direct marketing, privacy policies for, 172
discovery
data, 42
risk, 188–192
disposal
documents, 146
hardware, 147
SDLC phase, 151
distance risks in BCDR, 143
documents and documentation
classification, 145–146
control implementation, 104–105
disposal, 146
handling, retention, and storage, 146
reviews in IT risk assessment, 43
due care, 171
due diligence, 171
due process, 171

E
e-mail, 170–171
EF (exposure factor) in control selection, 103
effectiveness
controls, 102–103, 106
risk response options, 85
effort in KRIs, 112
electric generators, 70
emerging risk
managing, 90–93
technologies, 152–153
encryption for networks, 131
enhance responses, 203
enterprise architecture
cloud, 131
databases, 130
frameworks, 132–135
gateways, 132
networks, 130–131
operating systems, 130
overview, 128–129
platforms, 129
security architecture, 135
software, 129–130
enterprise risk management (ERM), 10–11
entity-level risk registers, 193
equipment
description, 7
recovery strategies, 141–142
returning in termination, 175
ERM (enterprise risk management), 10–11
ethics codes, 15, 174
evaluation
controls effectiveness, 31–34, 106
defined, 40–41
risk analysis, 59
event-tree analysis, 64–65
events
defined, 26
overview, 25–26
types, 28
vocabulary terms, 26–27
exception management, 89–90
exploits
description, 26
risk responses, 203
exposure factor (EF) in control selection, 103
external audits as risk register information source, 55

F
Factor Analysis of Information Risk (FAIR), 65
families, control, 97, 99
fault-event-tree analysis, 64–65
Federal Information Processing Standards (FIPS), 160
financial system asset inventory, 8
findings, managing, 89–90
FIPS (Federal Information Processing Standards), 160
five whys in root cause analysis, 37–38
formal risk register reviews, 195
frameworks
controls, 98–101
enterprise architecture, 132–135
information technology and security, 159
IT risk assessment, 45–51
risk management, 10–11

G
gap assessments, 41
gateways in enterprise architecture, 132
General Data Protection Regulation (GDPR), 171
geography issues
asset collection and organization, 9
business continuity and disaster recovery, 143
goals in organizational governance, 2–3
governance
assessments, 24
organizational. See organizational governance
overview, 1–2
questions, 17–20
review, 15–17
risk, 10–15
governance level in COBIT, 163–164
governance, risk, and compliance (GRC) tools, 53
government classified documents, 145–146, 157
guards, 168
guidelines for data lifecycle management, 145–146

H
hardware disposal, 147
Health Insurance Portability and Accountability Act (HIPAA)
controls requirements, 96
OCR involvement, 73
privacy issues, 171
heat maps for controls, 110
hiring employees, 173
human resources
codes of conduct and ethics, 174
hiring, 173
terminating, 174–175
tracking, 173–174

I
IaaS (Infrastructure as a Service), 131
identification
assets, 6–8
and authentication, 157
risk, 22–25
identification step in root cause analysis, 37
ignoring risk, 202
impact
business continuity and disaster recovery, 144
business impact analysis, 68–69
description, 26
key risk indicator criteria, 112
qualitative risk analysis, 190
risk analysis, 58–59
implement step in RMF, 161
implementation testing for controls, 104–105
incidents
new risk identification, 23
risk register information source, 55
indicators
key control, 113
key performance, 110–112
key risk, 112–113
industry development as risk register information source, 55
information assets, 7
information policies for privacy, 172
information sources for risk registers, 55–56
information technology and security
access control, 155–156, 167–168
accountability, 158
authorization, 157–158
business continuity and disaster recovery management,
140–144
confidentiality, integrity, and availability, 154–155
data lifecycle management, 144–147
data sensitivity and classification, 156–157
emerging technologies, 152–153
enterprise architecture. See enterprise architecture
frameworks, 159
human resources, 173–175
identification and authentication, 157
IT operations management, 135–137
network security, 168–172
non-repudiation, 158–159
overview, 127–128
physical access security, 168
project management, 137–140
questions, 178–182
review, 175–178
security and risk awareness training programs, 165–167
security concepts, 154
security policies, 167
standards, 159–165
systems development life cycle, 147–152
Information Technology Infrastructure Library (ITIL), 162–
163
Infrastructure as a Service (IaaS), 131
inherent risk
description, 26
IT risk assessment, 71
innovation in cybercrime, 183
integrated risk management (IRM) tools, 53
integration testing in SDLC, 150
integrity, 155
intellectual property assets, 7
intent threat category, 30
intentional threats in BCDR, 143
interface testing in SDLC, 150
internal audits as risk register information source, 55
International Organization for Standardization (ISO)
frameworks, 162
interoperability
controls, 105
emerging technologies, 153
interviews
asset identification, 8
hiring, 173
IT risk assessment, 43, 106
inventories
financial system assets, 8–9
key processes and systems, 67–68
IoT devices, 184
IRM (integrated risk management) tools, 53
ISACA
COBIT, 162–164
Code of Professional Ethics, 15
key risk indicators, 112–113
Risk IT Framework, 11–12, 49–51, 164–165
system testing, 45
ISO (International Organization for Standardization)
frameworks, 162
ISO/IEC 27000, 162
ISO/IEC 27001, 100–101, 162
ISO/IEC 27002, 101, 162
ISO/IEC 27005, 49
ISO/IEC 27701, 162
ISO/IEC 31000, 162
ISO/IEC 31010, 49
ISO/IEC standards overview, 48–49
issues management, 89–90
IT equipment assets, 7
IT operations management, 135–137
IT risk assessment
analysis and evaluation overview, 40
business impact analysis, 66–70
concepts, 40–45
inherent and residual risk, 71–72
miscellaneous risk considerations, 72–73
overview, 21–22
questions, 75–79
review, 73–75
risk analysis methodologies, 56–66
risk events, 25–28
risk identification, 22–25
risk ownership, 51–52
risk ranking, 51
risk registers, 52–56
risk scenario development, 38–40
standards and frameworks, 45–51
threat landscape, 29–30
threat modeling, 28–30
vulnerability and control deficiency analysis, 30–38
IT systems portfolios for asset identification, 8
ITIL (Information Technology Infrastructure Library), 162–
163

J
job rotation, 168

K
key control indicators (KCIs)
business processes, 6
controls, 113
key performance indicators (KPIs)
business processes, 6
controls, 110–112
key processes and systems inventories, 67
key risk indicators (KRIs)
business processes, 6
controls, 112–113

L
laws as risk register information source, 56
layers in risk registers, 193–194
least privilege principle, 157–158, 167
legal requirements, 14–15
legality issues in AUPs, 169
likelihood
description, 27
risk analysis, 58–59
Likert scale in qualitative risk analysis, 62
lines of defense, 12–13
logical controls, 94
loss event frequency in FAIR, 65

M
management buy-in for training programs, 166
management level in COBIT, 163–164
managerial controls, 94
mandatory vacations, 168
market factor risks in BCDR, 143
maturity assessments, 41
maximum tolerable downtime (MTD), 70
measurability of key performance indicators, 111
methods threat category, 30
military classified documents, 145–146
minutes, 187
mission risks in BCDR, 143
mitigation of risk
deeper analysis, 200
follow up, 204
process, 83–84
risk analysis, 58
monitor step in RMF, 162
monitoring
controls, 109
risk, 106–108
MTD (maximum tolerable downtime), 70
multifactor authentication, 157

N
National Institute of Standards and Technology (NIST)
business continuity and disaster recovery, 142
control effectiveness, 33–34
control framework, 98–99
control guidelines and standards, 96–98
quantitative risk analysis, 62–63
risk assessment guidelines, 45–47
Risk Management Framework, 11–12, 97, 160–162
Special Publication 800-17, 97
Special Publication 800-30
quantitative risk analysis, 62–63
risk assessment guidelines, 45–47
Special Publication 800-34, 142
Special Publication 800-37, 11–12
Special Publication 800-53, 33–34, 97–99, 161
Special Publication 800-60, 161
standards, 159–160
natural threats in BCDR, 143
NDAs (non-disclosure agreements), 173
need-to-know authorization, 158
network security
acceptable use policies, 169–170
due care, due diligence, and due process, 171
overview, 168
personal e-mail, 170–171
privacy, 171–172
social media, 170
networks
enterprise architecture, 130–131
new risk identification, 24
new risks, reporting, 203
news articles for risk identification, 23
NIST. See National Institute of Standards and Technology
(NIST)
non-disclosure agreements (NDAs), 173
non-repudiation, 158–159

O
objectives in organizational governance, 2–3
objectives threat category, 30
observation in IT risk assessment, 43
OCR (Office of Civil Rights), 73
OCTAVE (Operationally Critical Threat, Asset, and
Vulnerability Evaluation) methodology, 47–48
Office of Civil Rights (OCR), 73
online data for asset identification, 8
operating systems in enterprise architecture, 130
operational controls, 32, 94
operational criticality in qualitative risk analysis method, 191
operational management, 12
operational risks, 23
Operationally Critical Threat, Asset, and Vulnerability
Evaluation (OCTAVE) methodology, 47–48
organizational governance
assets, 6–10
business processes, 5–6
culture, 4
overview, 2
policies and standards, 5
strategy, goals, and objectives, 2–3
structure, roles, and responsibilities, 3–4
organizational units, asset organization by, 9
outsourcing risks in BCDR, 143
ownership of risk and control, 36, 51–52, 82–83

P
PaaS (Platform as a Service), 131
passive observation for new risk identification, 24
Payment Card Industry Data Security Standard (PCI DSS),
99–100
penetration tests
description, 41
new risk identification, 23
personal e-mail, 170–171
personally identifiable information (PII), 171
personnel assets, 7
PHI (protected health information), 73
physical access security, 168
physical controls, 32, 94
physical location risks in BCDR, 143
PII (personally identifiable information), 171
plan testing in BCDR, 142
planning phase in SDLC, 149
Platform as a Service (PaaS), 131
platforms in enterprise architecture, 129
PMBOK (Project Management Body of Knowledge), 162
policies
acceptable use, 169–170
access control, 167–168
organizational governance, 5
privacy, 171–172
retention and destruction, 146–147
security, 167
termination, 174–175
portfolios in project management, 137
practices, 160
preparation step in RMF, 160
preventive controls, 94–95
PRINCE2 (PRojects IN Controlled Environments 2), 163
prioritization, risk, 204
privacy
assessments, 24
network security, 171–172
risks, 23
private classified documents, 145–146
probability
description, 27
qualitative risk analysis method, 190–191
probable loss magnitude in FAIR, 65
processes
asset organization by, 9
organizational governance, 5–6
risk management programs, 187
professional ethics, 15
program charters, 186
program-level risk registers, 193
programs
project management, 137
risk management, 186–188
training, 165–167
project management, 137–140
Project Management Body of Knowledge (PMBOK), 162
PRojects IN Controlled Environments 2 (PRINCE2), 163
property assets, 7
protected health information (PHI), 73
protection issues in acceptable use policies, 169
public documents, 145–146
publishing, 203–204

Q
qualitative analysis method
deeper analysis, 198
risk analysis, 59–60, 62–63
risk management programs, 187
risk ratings, 190–192
quantitative analysis method
deeper analysis, 198
risk analysis, 59–63
risk management programs, 187
risk ratings, 192

R
ranking risk, 51
ratings
qualitative analysis, 190–192
quantitative analysis, 192
RCA (root cause analysis)
key risk indicators, 113
steps, 36–37
RE (Risk Evaluation) domain, 11, 49–51
real-time data, 108–109
recommendations for risk treatment, 199–203
records, 7
recovery objectives in business impact analysis, 70
recovery point objectives (RPOs), 60–61, 141
recovery strategies, 141–142
recovery time objectives (RTOs), 60–61, 141
regulations
asset organization by, 10
overview, 14–15
pressure on, 183–184
risk register information source, 56
relationship threat category, 30
relevancy
key performance indicators, 111–112
risk scenario development, 39
reliability in key risk indicators, 112
renewals, risk, 204
reporting, risk. See risk reporting
reputation assets, 8
requirements phase in SDLC, 149
residual risk
description, 27
IT risk assessment, 71–72
risk acceptance, 84
resilience in BCDR, 142
responsibilities in organizational governance, 3–4
results threat category, 30
retention
data, 146–147
documents, 146
retirement phase in SDLC, 151
return of identification in termination, 175
return on investment (ROI) in control recommendations, 35
reviewing risk registers, 194–196
risk
description, 26
emerging technologies, 152–153
SDLC, 151–152
risk acceptance, 84–85, 200–201
risk analysis, description, 27
risk analysis methodologies
asset identification, classification, and valuation, 58
bow-tie analyses, 65–66
Factor Analysis of Information Risk, 65
fault- and event-tree analysis, 64–65
likelihood determination and impact analysis, 58–59
miscellaneous, 66
overview, 56–58
qualitative analysis, 59
quantitative analysis, 59–62
risk appetite
deeper analysis, 198
description, 13–14
risk analysis, 58
risk assessments
description, 27
IT. See IT risk assessment
risk register information source, 55
risk avoidance, 202
risk-aware culture, 24
risk awareness training programs, 165–167
risk derivation in FAIR, 65
Risk Evaluation (RE) domain, 11, 49–51
risk events
overview, 25–26
types, 28
vocabulary terms, 26–27
risk factors
business continuity and disaster recovery, 142
emerging, 91–92
risk governance
enterprise risk management and risk management
frameworks, 10–11
ISACA Risk IT Framework, 49
legal, regulatory, and contractual requirements, 14–15
lines of defense, 12–13
overview, 10
risk identification, 22–25
Risk IT Framework
key risk indicators, 112–113
overview, 164–165
process areas, 49–50
risk landscape, 178–182
risk management
description, 27
frameworks, 10–11
overview, 12–13
Risk Management Framework (RMF)
controls, 97–99
steps, 11–12, 160–162
risk management life cycle
deeper analysis, 196–198
publishing and reporting, 203–204
risk discovery, 188–192
risk registers, 193–196
risk treatment recommendations, 199–203
risk management programs
processes, 186–187
purpose, 187–188
risk managers, 194
risk mitigation
deeper analysis, 200
follow up, 204
process, 83–84
risk analysis methodology, 58
risk ownership
considerations, 36
IT risk assessment, 51–52
risk prioritization, 204
risk profiles
description, 13
ISACA Risk IT Framework, 50
risk ranking in IT risk assessment, 51
risk ratings
qualitative analysis, 190–192
quantitative analysis, 192
risk registers
columns, 189–190
data structures, 52–55
description, 27, 188
information sources, 55–56
layers, 193–194
managing, 192
reports, 203
reviewing, 194–196
types, 193
updating, 56
risk renewals, 204
risk reporting
controls, 109–110
data processing, 108–109
key control indicators, 113
key performance indicators, 110–112
key risk indicators, 112–113
monitoring techniques, 109
overview, 81–82, 106–108
questions, 119–125
review, 114–118
treatment plans, 108
risk response
acceptance, 84–85
avoidance, 85
control design. See controls
ISACA Risk IT Framework, 49
managing, 89–93
mitigation, 83–84
options, 83–86
overview, 81–82
ownership, 82–83
questions, 119–125
review, 114–118
sharing, 84
third-party risk, 86–88
risk reviews in reports, 203
risk scenario development
bottom-up, 39
considerations, 39–40
overview, 38
top-down, 38–39
risk tolerance
deeper analysis, 198
description, 13–14
risk analysis methodology, 58
risk transfer, 201–202
risk treatment
description, 27
recommendations, 199–203
reports, 203
RMF (Risk Management Framework)
controls, 97–99
steps, 11–12, 160–162
ROI (return on investment) in control recommendations, 35
roles in organizational governance, 3–4
root cause analysis (RCA)
key risk indicators, 113
steps, 36–37
RPOs (recovery point objectives), 60–61, 141
RTOs (recovery time objectives), 60–61, 141

S
S.M.A.R.T. guidelines, 111–112
SaaS (Software as a Service), 131
safeguard controls, 96
SANs (storage area networks), 70
SANS Top 20 Critical Security Controls, 100
scaling process in threat modeling, 29
scenario components in FAIR, 65
schedules in project management, 137–139
scope
assessment, 42
project management, 137–139
threat modeling, 29
scorecards for controls, 110
SDLC. See systems development life cycle (SDLC)
secure configuration assessments, 24
securing work area in termination, 174
security
emerging technologies, 153
policies, 167
tools, 185
training programs, 165–167
security advisories, 24
security architecture in enterprise architecture, 135
security concepts in information technology and security, 154
security controls, 155–156
security incidents
new risk identification, 23
privacy, 23
risk register information source, 55
security professionals shortage, 185
security scans for asset identification, 9
security testing in SDLC, 150
SEI (Software Engineering Institute), 47–48
select step in RMF, 161
semiquantitative values, 62
sensitivity
asset organization by, 9
data, 156–157
key risk indicators, 112
risk reporting information, 204
separation of duties principle, 148, 167
service level agreements (SLAs)
IT operations management, 136
third-party risk, 87
service providers, asset organization by, 9
sharing risk, 84
single-factor authentication, 157
single loss expectancy (SLE)
control selection factor, 103
quantitative risk analysis, 60–62
skills threat category, 30
SLAs (service level agreements)
IT operations management, 136
third-party risk, 87
SLE (single loss expectancy)
control selection factor, 103
quantitative risk analysis, 60–62
social media
policies, 170
risk identification, 23
Software as a Service (SaaS), 131
Software Engineering Institute (SEI), 47–48
software in enterprise architecture, 129–130
specificity in key performance indicators, 111
staff
project management, 138
risk register reviews with, 195
stakeholders in risk environment, 106–107
standards
controls, 96–101
data lifecycle management, 145–146
information technology and security, 159–165
IT risk assessment, 45–51
NIST. See National Institute of Standards and Technology
(NIST)
organizational governance, 5
statements of impact in business impact analysis, 68–69
storage area networks (SANs), 70
storage of documents, 146
strategic risks, 22
strategies
organizational governance, 2–3
recovery, 141–142
structure in organizational governance, 3–4
supply chain risks, 23
suspension of accounts, 175
systems
IT risk assessment, 43–44
testing, 44–45
systems development life cycle (SDLC)
design phase, 149–150
development phase, 150
disposal phase, 151
implementation and operation, 150
overview, 147–148
planning phase, 149
requirements phase, 149
risks, 151–152
separation of duties, 148
test phase, 150

T
tailgating, 168
technical controls, 32, 94
technical data, 108–109
technologies, emerging, 91
telework, 184
temps, tracking, 173–174
termination, employee, 174–175
testing
controls, 104–106
penetration, 23, 41
recovery plans, 142
SDLC, 150
system, 44–45
The Open Group Architecture Framework (TOGAF)
COBIT, 162
enterprise architecture, 132–133
third-party risk
business continuity and disaster recovery, 143
factors, 87
managing, 88
overview, 86–87
threats, 88
vulnerabilities, 88
threat actors, 26
threat intelligence as risk register information source, 55
threat landscape, 29–30
threat modeling
description, 26, 41
new risk identification, 24
overview, 28–30
threat realization, 26
threats
business continuity and disaster recovery, 143
criticality analysis, 69
description, 26
emerging, 92, 153
IT operations management, 136–137
project management, 138–140
risk analysis, 56
third-party, 88
time sensitivity risks in BCDR, 143
timeliness in key performance indicators, 111–112
TOGAF (The Open Group Architecture Framework)
COBIT, 162
enterprise architecture, 132–133
Top 20 Critical Security Controls, 100
top-down risk scenario development, 38–39
tracking employees, 173–174
training
project management, 138
security and risk awareness programs, 165–167
treatments
options, 198
plans, 108
recommendations, 199–203
reports, 203
trends in risk registers, 203
triage apparatus
qualitative risk analysis, 192
risk management programs as, 187

U
unintentional threats in BCDR, 143
uninterruptible power supplies (UPSs), 70
uniqueness issues in AUPs, 169
unit testing in SDLC, 150
updating risk registers, 56
UPSs (uninterruptible power supplies), 70
user acceptance testing in SDLC, 150

V
vacations, mandatory, 168
validation of data, 108–109
valuation of assets, 58
virtual assets, 7
vocabulary terms for risk, 26–27
vulnerabilities
business continuity and disaster recovery, 144
description, 26
emerging technologies, 92–93, 153
IT operations management, 137
project management, 139–140
risk analysis, 56
SDLC, 152
third-party risk, 88
vulnerability and control deficiency analysis
control effectiveness, 31–34
control gaps, 34
control recommendations, 34–35
overview, 30–31
risk and control ownership, 36
root cause analysis, 36–37
vulnerability assessments
description, 41
risk register information source, 55

W
walkthroughs in IT risk assessment, 43
whistleblowers for new risk identification, 24
work breakdown structures (WBSs), 139
worksheets, analysis, 197–198

X
XaaS (Anything as a Service), 131

Z
Zachman framework, 133–135

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