CISM Manual Part 1
CISM Manual Part 1
CISM Manual Part 1
discussed. The glossary is an extension of the text in the manual the appropriate answer that is MOST likely or BEST, or the
and can, therefore, be another indication of areas in which the candidate may be asked to choose a practice or procedure that
candidate may need to seek additional references. would be performed FIRST related to the other answers. In every
case, the candidate is required to read the question carefully,
eliminate known wrong answers and then make the best choice
USING THE CISM REVIEW MANUAL WITH OTHER
possible. Knowing that these types ofquestions are asked and
ISACA RESOURCES how to study to answer them will go a long way toward answering
The ClSMReview Manual can be used in conjunction with other them correctly. The best answer is of the choices provided. There
CISM exam preparation. These products are based on the CISM can be many potential solutions to the scenarios posed in the
job practice, and referenced task and knowledge statements can questions, depending on industry, geographical location, etc. It
be used to find related content within the CISM Review Manual. is advisable to consider the information provided in the question
These resources include: and to determine the best answer of the options provided.
- CISM Review Questions, Answers and Explanations Manual
9’" Edition Each CISM question has a stem (question) and four options
- CISM Review Questions, Answers and Explanations Database — (answer choices). The candidate is asked to Choose the correct or
12 Month Subscription best answer from the options. The stem may be in the form of a
- Chapter CISM Review Courses question or incomplete statement. In some instances, a scenario
or description also may be included. These questions normally
include a description of a situation and require the candidate to
ABOUT THE CISM REVIEW QUESTIONS, ANSWERS answer two or more questions based on the information provided.
AND EXPLANATIONS PRODUCTS
The CISMM’ Review Questions, Answers & Explanations Manual A helpful approach to these questions includes the following:
9’“ Edition consists of 1,000 multiple—choice study questions, - Read the entire stem and determine what the question is asking.
answers and explanations arranged in the domains of the current Look for key words such as “BEST,” “MOST,” “FIRST,” etc.
CISM job practice. and key terms that may indicate what domain or concept that is
being tested.
Another study aid that is available is the CISM® Review - Read all of the options, and then read the stem again to see if
Questions,Answers & Explanations Database — 12 Month you can eliminate any of the options based on your immediate
Subscription. The database consists of the 1,000 questions, understanding of the question.
answers and explanations included in the CISM” Review - Re—read the remaining options and bring in any personal
Questions, Answers & Explanations Manual 9"'Ed17ti0n. With this experience to determine which is the best answer to the question.
product, CISM candidates can quickly identify their strengths and
weaknesses by taking random sample exams of varying length Another condition the candidate should consider when preparing
and breaking the results down by domain. Sample exams also for the exam is to recognize that information security is a global
can be chosen by domain, allowing for concentrated study, one profession, and individual perceptions and experiences may
domain at a time, and other sorting features such as the omission not reflect the more global position or circumstance. Because
of previous correctly answered questions are available. the exam and CISM manuals are written for the international
information security community, the candidate will be required
Questions in these products are representative of the types of to be somewhat flexible when reading a condition that may be
questions that could appear on the exam and include explanations contrary to the candidate’s experience. It should be noted that
of the correct and incorrect answers. Questions are sorted by the CISM exam questions are written by experienced information
CISM domains and as a sample test. These products are ideal for security managers from around the world. Each question on the
use in conjunction with the CIS "’ Review Manual 15'“ Edition. exam is reviewed by lSACA’s CISM Exam Item Development
These products can be used as study sources throughout the study Working Group, which consists of international members. This
process or as part of a final review to determine where candidates geographic representation ensures that all exam questions are
may need additional study. It should be noted that these questions understood equally in every countiy and language.
and suggested answers are provided as examples; they are not
actual questions from the examination and may differ in content Note: When using the CISM review materials toprepare
from those that actually appear on the exam. forthe exam, it should be noted that they cover a broad ‘
spectrum of information security management issues. Again,
candidatesshould not assume that reading these manuals
TYPES OF QUESTIONS ON THE CISM EXAM and answering review questions will fully prepare them '
CISM exam questions are developed with the intent of for the examination. Since actual exam questions ofien relate
measuring and testing practical knowledge and the application to practical experiences, candidates should refer to their own
of information security managerial principles and standards. As expatiences and other reference sources, and draw upon the
previously mentioned, all questions are presented in a multiple— experiences of colleagues and others Who have earned the
choice format and are designed for one best answer. CISM designation.
The candidate is cautioned to read each question carefully. Many
times a CISM exam question will require the candidate to choose
K1.l4 Knowledge of roles and responsibilities of the RELATIONSHIP OF TASK TO KNOWLEDGE STATEMENTS
information secuntyhmanager _ The task statements are what the CISM candidate is expected
K115 Knowledge 0f organizational structures, lines Of to know how to perform. The knowledge statements delineate
authority and escalation pomts _ . . ,. each of the areas in which the CISM candidate must have a good
K1.16 Knowledge of information secunty respons1b1ht1es of understanding to perform the tasks. The task and knowledge
staff across the organizatlon (e.g., data owners, end statements are mapped, insofar as it is possible to do so. Note that
users, pnv1leged or high-nsk users) although there is ofien overlap, each task statement will generally
K1.l7 Knowledge of processes to monitor performance of map to several knowledge statements.
information security responsibilities
K1.18 Knowledge of methods to establish new, or utilize
existing, reporting and communication channels
throughout an organization
K1.19 Knowledge of methods to select, implement and
interpret key information security metrics (e.g., key goal
indicators [KGIs], key performance indicators [KPIs],
key risk indicators [KRlsD
T1.6 Identify intemai and external influences to K1.2 Knowledge of the relationship of information security to business goals, objectives,
the organization (e.g., emerging technologies, functions, processes and practices
social media, business environment, risk K1.7 Knowledge of methods to integrate information security governance into corporate
tolerance, regulatory requirements, third-party governance
considerations, flireat landscape) to ensure that K1.11 Knowledge of the internal and external influences to the organization (e.g., emerging
these factors are continually addressed by the technologies, social media, business environment, risk tolerance, regulatory
information security strategy. requirements, third—party considerations, threat landscape) and how they impact the
information security strategy
T1.7 Gain ongoing commitment from senior K1.12 Knowledge of key information needed to obtain commitment from senior
leadership and other stakeholders to support leadership and support from other stakeholders (e.g., how information security
the successful implementation of me supports organizational goals and objectives, criteria for determining successful
information security strategy. implementation, business impact)
K113 Knowledge of methods and considerations for communicating with senior leadership
and other stakeholders (e.g., organizational culture, channels of communication,
highlighting essential aspects of information security)
T18 Define, communicate and monitor information K1.15 Knowledge of organizational structures, lines of authority and escalation points
security responsibilities throughout the K1 .16 Knowledge of information security responsibilities of staff across the organization
‘ organization (e.g., data owners, data (e.g., data owners, end users, privileged or high-risk users)
custodians, end users, privileged 0r high—risk K1.17 Knowledge of processes to monitor performance of information security
users) and lines of authority. responsibilities
K1 .18 Knowledge of methods to establish new, or utilize existing, reporting and
communication channels throughout an organization
T1.9 Establish, monitor, evaluate and report key K1.10 Knowledge of strategic budgetary planning and reporting methods
information security metrics to provide K1 .19 Knowledge of methods to select, implement and interpret key information security
management with accurate and meaningful metrics,(e.g., key goal indicators [KGis], key performance indicators [KPls], key risk
information regarding the effectiveness of the indicators [KRis])
information security strategy.
Brotby, W. Krag, and IT Governance Institute; Information Security Governance: Guidancefor Information Security Managers,
ISACA, USA, 2008
Brotby, W. Krag; Infimnaz‘ion Security Governance: A Practical Development and Implementation Approach, Wiley & Sons, 2009
Committee of Sponsoring Organizations of the Treadway Commission (COSO), Internal Controlwlntegmted Framework, USA, 2013
International Organization for Standardization (ISO), ISO/IEC 27001 :2013 Information technology—Security techniques—[nfbrmation
security managementsystems—Requiremen1S, Switzerland, 2013
ISO, [SO/[EC 270022013 Information tec/mology~—Security techniques—Code ofpractz'cefor information security controls,
Switzerland, 2013
ISO, [SO/[EC 2 7014:2013 Information teclmology—Security tec/miques—Govemance ofiiy’ormation security, Switzerland, 2013
National Institute of Standards and Technology (NIST), NlSTSpecial Publication 800—53, Revision 4 Security and Privacy Controlsfor
Federal Information Systems and Organizations, USA, 2013
1-3 Which of the following approaches BEST helps the A' Data owner .
information security manager achieve compliance with 13- Information seeurity manager
various regulatory requirements? 0 Domain administrator
D. Busmess manager
A. Rely on corporate counsel to advise which regulations
are the most relevant. 1—1 0 In implementing information security governance, the
B. Stay current with all relevant regulations and request information security manager is PRIMARILY
legal interpretation. responSIble for:
C. Involve all impacted departments and treat regulations as
just another risk. A. deyeloping the security strategy.
D. Ignore many of the regulations that have no penalties. 13- rev1ew1ng the security strategy.
C. communicating the security strategy.
D. approving the security strategy.
1-8 A. Business and regulatory requirements are the 1-10 A. The information security manager is responsible
driving factors for data retention. for developing a security strategy based on business
B. Integrity is a key factor for information security; objectives with the help of business process owners
however, business and regulatory requirements are the and senior management.
driving factors for data retention. B. The information security strategy is the responsibility of
C. Availability is a key factor for information security; a steering committee and/or senior management.
however, business and regulatory requirements are the C. The information security manager is not necessarily
driving factors for data retention. responsible for communicating the security strategy.
D. Confidentiality is a key factor for information security; D. Final approval of the information security strategy must
however, business and regulatory requirements are the be made by senior management.
driving factors for data retention.
Information security governance needs to be integrated into The strategy should keep in mind that information security is never
the overall enterprise governance structure to ensure that the static. Threats, vulnerabilities and exposures are always changing
organizational goals are supported by the information secun'ty because of intemal and external factors. Internal factors include
program. The governance framework is an outline or skeleton of changes in technology, personnel, business activities and financial
interlinked items that supports a particular approach to a specific capacity to absorb loss. External factors include changing markets,
objective as stated in the strategy. Several governance frameworks emerging threats, new technologies, increasing sophistication of
may be suitable for an organization to implement, including COBIT attackers and new regulations. Risk and impact assessments are
5 and ISO/I EC 27000. High-level architecture can serve as a often a good indicator of changes that may need to be made to
framework as well. The framework will serve to integrate and guide strategy elements. Another indicator is number of secun'ty incidents.
activities needed to implement the information security strategy.
To continue to be effective, the strategy must be a living
Information security governance is a subset of corporate govemance document with objectives, approaches and methods changing to
and must be consistent with the enterprise’s governance. If meet new conditions. In many cases, the high-level objectives
may not change significantly while the approaches, methods and No profession or activity has achieved reliable and effective
technologies may evolve as conditions warrant. maturity prior to the development of a suite of good metrics.
Metrics must be considered at three levels—operational,
Internal metrics and ongoing monitoring will aid the information management and strategic.
security manager in keeping aware of changing conditions.
Keeping current on external events that may affect the enterprise One of the most important requirements for good metrics is to
and its risk is also key. find out what information is needed at the different organizational
levels to make informed decisions. This information becomes
For an effective information security program and strategy, it is the basis for effective information security metrics. Of course,
necessary to have ongoing support from senior management, the information needed by the chief executive officer (CEO) or
business owners and department heads. Information security managing director is different from what is needed by a system
cannot be driven up from the middle of an organization. Without administrator to make informed information security decisions.
support of senior management, the issues of inadequate funding, The first step to establish a system of metrics is to determine
insufficient staffing and poor compliance will be ongoing. what is meaningfiil to the recipients. Then those metrics must be
An organization’s culture is largely a reflection of senior monitored, evaluated and communicated to the appropriate people
management, and senior management’s lack of support will be on a timely basis.
reflected in the entire organization. This is evidenced by the
organization’s perception of and relationship to information
security specifically and risk management generally.
1.1 INFORMATION SECURITY GOVERNANCE
OVERVIEW
A lack of commitment and support from senior management Information can be defined as “data endowed with meaning
cascades down and result in little support from business owners and purpose.” It plays a critical role in all aspects of our lives.
and department heads. Because this group is largely responsible Information has become an indispensable component of
for policy administration and compliance enforcement, it is likely conducting business for virtually all organizations. In a growing
that information security policy compliance will be poor. number of companies, information is the business.
Support can be gained by educating senior management or Approximately 80 percent of national critical infrastructures in
developing persuasive business cases. Unfortunately, more often, the developed world are controlled by the private sector. Coupled
it is a serious incident or major compromise that is needed to with often ineffective bureaucracies, countless conflicting
generate management commitment. In organizations that are jurisdictions and aging institutions unable to adapt to dealing with
subject to strong governmental regulation, frequent audits and burgeoning global information crime, a preponderance of the task
costly sanctions, support and commitment may be high as a result. of protecting information resources critical to survival is falling
squarely on corporate shoulders. However, studies continue to
It is ofien said that security is only as strong as the weakest link, show that a large percentage of organizations do not adequately
and this is certainly true for information security. For information address either existing or emerging security issues. The findings
security to be effective across the entire organization, everyone of the 2015 Ernst and Young Global Information Security Survey
should have responsibilities related to information security or risk highlight the problem. According to the survey:
management. It is up to the information security manager to define - Only 12 percent of organizations believe that information
those responsibilities for everyone in the organization. The next security meets the needs of the organization, and 67 percent are
step is to inform employees of those responsibilities on an ongoing still making improvements.
or frequent basis. Most employees will do most of what is required - Sixty—nine percent noted that the information security budget
most of the time if they are clearly aware of their responsibilities should increase by as much as 50 percent to be able to protect the
and the consequences of failing to do so. To reinforce responsible organization in line with the risk tolerance set by management.
information security behavior, it is necessary to monitor compliance
on a regular basis because information security is often an The conclusion that can be drawn from this report is that
afierthought for busy employees focusing on other tasks. information security failures are predominantly a failure of
governance and cannot be solved by technology alone. The need
What cannot be measured cannot be managed. Information for adequate protection of information resources needs to be
security has been managed for some time without good raised at the board level, like other critical governance functions,
metrics in an ad 1106, haphazard and often ineffective way. The to be successful. The complexity, relevance and criticality of
resistance to developing good metrics appears to be related to information security and its governance mandate that it be
management’s desire to avoid knowing too much that might addressed and supported at the highest organizational levels.
require taking action; this enables management to sidestep
being held accountable and supports plausible deniability. Ultimately, to achieve significant improvement in information
For some information security managers, a suite of effective security, senior management and the board of directors must
information security metrics may increase oversight, performance be held accountable for information security governance and
accountability and workload. Whatever the underlying causes, must provide the necessary leadership, organizational structures,
information security suiTers from a lack of or poor metrics oversight, resources and processes to ensure that information
especially at the management and strategic levels—precisely security governance is an integral and transparent part of
where informed decision making must take place. enterprise governance.
Increasingly, those who understand the scope and depth of ' Providing greater confidence in interactions with trading partners
risk to information take the position that, as a critical resource, - Improving trust in customer relationships
information must be treated with the same care, caution and - Protecting the organization’s reputation
prudence that any other asset essential to the survival of the - Enabling new and better ways to process electronic transactions
organization and, perhaps society, would receive. - Providing accountability for safeguarding information during
critical business activities, such as mergers and acquisitions,
Often, the focus ofprotection has been on the IT systems that business process recovery, and regulatory response
process and store the vast majority of information rather than - Effective management of information security resources
on the information itself. But this approach is too narrow to
accomplish the level of integration, process assurance and overall In summary, because new information technology provides
security that are required. Information security takes the larger the potential for dramatically enhanced business performance,
View that the content, information and the knowledge based on effective information security can add significant value to the
it must be adequately protected, regardless of how it is handled, organization by reducing losses from security«related events
processed, transported or stored. and providing assurance that security incidents and breaches are
not catastrophic. In addition, evidence suggests that improved
Senior management is increasingly confronted by the need to stay perception in the market has resulted in increased share value.
competitive in the global economy and heed the promise of ever
greater gains from the deployment of more information resources. 1.1.2 OUTCOMES OF INFORMATION SECURITY
Even as organizations reap those gains, the increasing dependence
on information and the systems that support it, and advancing risk
GOVERNANCE
from an increasing host of threats, are forcing management to make Information security governance includes the elements required to
difiicult and ofien costly decisions about how to effectively address provide senior management assurance that its direction and intent
information security. In addition, scores of new and existing laws are reflected in the security posture of the organization by using
and regulations are increasingly demanding compliance and higher a structured approach to implementing a security program. Once
levels of accountability in an efiort of governments to address those elements are in place, senior management can be confident
increasingly sophisticated attacks and growing losses that pose that adequate and effective information security will protect the
mounting threats to their national critical infrastructures. organization’s vital information assets.
' Information security overheads that are maintained at a According to the developers of the Business Model for
minimum level while maintaining a security program that Information Security"M (BMTS‘M) (see section 1.2.5), “It is no
enables the organization to achieve its objectives longer enough to communicate to the world of stakeholders why
' A properly prioritized and distributed effort to areas with the we [the organization] exist and what constitutes success, we must
greatest probability and highest impact and business benefit also communicate how we are going to protect our existence.”
- Institutionalized and commoditized standards-based solutions This suggests that a clear organizational strategy for preservation is
with the greatest cost—efiectiveness equally important to, and must accompany, a strategy for progress.
‘ Complete solutions, covering organization and process as well
as technology based on an understanding of the end-to-end In addition to protection of information assets, effective
business of the organization information security governance is required to address legal
' A continuous improvement culture based on the understanding and regulatory requirements and is becoming mandatory in the
that security is an ongoing process, not an event exercise of due care.
4. Resource optimizafioansing information security
knowledge and infrastructure efiiciently and effectively to: 1.2.1 BUSINESS GOALS AND OBJECTIVES
° Ensure that knowledge is captured and available
Corporate governance is the set of responsibilities and practices
- Document security processes and practices
exercised by the board and senior management with the goals
° Develop security architecture(s) to define and utilize
of providing strategic direction, ensuring that objectives are
infrastructure resources efficiently
achieved, ascertaining that risk is managed appropriately and
5. Performance measurement—Monitoring and reporting on
verifying that the enterprise’s resources are used responsibly.
information security processes to ensure that objectives are
Strategy is the plan to achieve an objective. The strategic direction
achieved, including:
of the business is defined by the objectives set forth in the
- A defined, agreed—upon and meaningfiil set of metrics that
strategy. To be of value to the organization, information security
are properly aligned with strategic objectives and provide the
must support the business strategy and the activities that take
information needed for effective decisions at the strategic,
place to achieve the objectives.
management and operational levels
- Measurement process that helps identify shortcomings and
Information security governance is a subset of corporate
provides feedback on progress made resolving issues
governance. It provides strategic direction for security activities
- Independent assurance provided by external assessments
and ensures that objectives are achieved. It ensures that
and audits
information security risk is appropriately managed and enterprise
- Criteria for separating the most useful metrics from the
information resources are used effectively and efficiently.
variety of things that can be measured
6. Assurance process integration—Integrating all relevant
To achieve effective information security governance,
assurance factors to ensure that processes operate as intended
management must establish and ensure maintenance of a
from end to end by:
framework to guide the development and management of a
- Determining all organizational assurance functions
comprehensive information security program that supports the
- Developing formal relationships with other assurance fimctions
business objectives.
- Coordinating all assurance functions for more cost-effective
security
The governance framework will generally consist of the following:
- Ensuring that roles and responsibilities between assurance
1. A comprehensive security strategy intrinsically linked with
fimctions overlap and leave no gaps in protection
business objectives
- Employing a systems approach to information security
2. Governing security policies that clearly express management
planning, deployment, metrics and management
intent and address each aspect of strategy, controls
and regulation
1.2 EFFECTIVE INFORMATION SECURITY 3. A complete set of standards for each policy to ensure that
people, procedures, practices and technologies comply with
GOVERNANCE policy requirements and set appropriate security baselines for
Information security governance is the responsibility of the board
the enterprise
of directors and senior management. It must be an integral and
4. An effective security organizational structure with sufficient
transparent part of enterprise governance and complement or
authority and adequate resources, void of conflicts of interest
encompass the IT governance framework. While senior management
5. Defined workflows and structures that assist in defining
has the responsibility to consider and respond to increasingly
responsibilities and accountability for information
complex and potentially destructive information security issues,
security governance
boards of directors will be required to make information security
6. Institutionalized metrics and monitoring processes to ensure
an intrinsic part of governance, integrated with the processes they
compliance, provide feedback on control effectiveness and
have in place to govern other critical organizational resources.
provide the basis for appropriate management decisions
This includes monitoring and reporting processes to ensure that
governance processes are effective and compliance enforcement is
This framework provides the basis for developing a cost—effective
sufficient to reduce risk to acceptable levels.
information security program that supports the organization’s
business goals. Implementing and managing a security program
is covered in chapter 3. The objective of the program is a set of
activities that provide assurance that information assets are given best be achieved with technologies defined in the physical
a level of protection commensurate with their business value architecture. The physical architecture comprises the specific
or with the risk their compromise poses to the organization. devices such as servers, databases, firewalls, switches and routers,
The relationships among IT, information security, controls, along with their interconnections. Controls must be developed
architecture and the other components of a governance framework that are consistent with the standards and control choices will
are represented in figure 1.1. While linkage between IT and affect the specifics of both the physical and the operational
information security may occur at various higher levels, strategy architectures. Finally, both the strategy and information security
is the point where information security must integrate IT to procedures are input into the operational architecture.
achieve its objectives.
Figure 1.1 shows the relationship between IT and information
Note that the main requirement for IT is an adequate level security governance and the sequence of the development process.
of performance; for information security, it is managing risk Once the information security strategy has been developed, it
to an acceptable level. Once outcomes, requirements and the must inform the IT strategy to ensure adequate protection for
objectives that will meet the requirements are established, information assets and align subsequent IT development and
high—level conceptual security architecture can be considered. management processes with information security requirements.
The security architecture should simply be an overlay on the
enterprise architecture, although ideally these would be created In Practice: Identify an IT—related goal in
simultaneously to "bake in” the security elements. your organization. Next, consider the IT-related
goal in the context of the enterprise’s goals.
When the basic information security/risk management strategy is How does the IT—related goal serve to support
formulated, a logical architecture showing the various functions the enterprise’s overall goals? If it does not,
and data flows can be developed. A road map can then be laid out what could be done to change the goal so it
with the specific steps needed to attain the goals defined in the better aligns with the organization? Use the
strategy. The specifics include the control objectives necessary information provided in this chapter to guide
to achieve acceptable risk levels. Some of these objectives will your recommendations.
1.2.2 DETERMINING RISK CAPACITY AND Many organizations have a corporate security function as well
as an IT security operation dealing specifically with security
ACCEPTABLE RISK (RISK APPETITE)
of the IT systems. While this is an essential fimction that must
Every organization has a particular risk capacity, defined as the
be governed by the information security policies and standards,
objective amount of loss an enterprise can tolerate without its confidential information disclosed in an elevator conversation or
continued existence being called into question. Subject to the sent Via the postal mail would be outside the scope of IT security
absolute maximum imposed by this risk capacity, the owners or
but squarely in the purview of information security.
board of directors of an organization set the risk appetite for the
organization. Risk appetite is defined as the amount of risk, on
Cybersecurity is an area of concern and importance to
a broad basis, that an entity is willing to accept in pursuit of its information security governance and management. It includes
mission. In some cases, setting the risk appetite may be delegated both information and IT security, and although definitions
by the board of directors to senior management as part of
vary widely, a common position holds that cybersecurity is a
strategic planning. subdiscipline of information security. Specific areas of concern
for cybersecurity include advanced persistent threats (APTs),
Acceptable risk determination or risk appetite and the criteria malware, ransomware, phishing in all its forms, and the host of
by which it can be assessed is an essential element for virtually other threats related to, and enabled by, cyberspace.
all aspects of information security as well as most other aspects
of organizational activities. It will determine many aspects of In the context of information security governance, it is important
strategy including control objectives, control implementation,
that the scope and responsibilities of information security
baseline security, cost—benefit calculations, risk management are clearly set forth in the information security strategy and
options, severity criteria determinations, required incident reflected in the policies. It is also essential that information
response capabilities, insurance requirements and feasibility
security is fully supported by senior management and the various
assessments, among others.
organizational units. Without clearly defined information security
responsibilities, it is impossible to determine accountability.
Risk appetite is translated into a number of standards and
policies to contain the risk level within the boundaries set by
the risk appetite. These boundaries need to be regularly adjusted 1.2.4 GOVERNANCE, RISK MANAGEMENT AND
or confirmed. Within these boundaries, risk may be accepted, COMPLIANCE
a formal and explicit process that affirms that the risk requires Governance, risk management and compliance (GRC) is
and warrants no additional response by the organization as long an example of the growing recognition of the necessity for
as it and the risk environment stay substantially the same and convergence, or assurance process integration, as discussed in
accountability for the risk is assigned to a specific owner. section 1.2.6 Assurance Process lntegration—Convergence.
Risk acceptance generally should not exceed the risk appetite of GRC is a term that reflects an approach that organizations can
the organization, but it must not exceed the risk capacity (which adopt to integrate these three areas. Ofien stated as a single
would threaten the continued existence of the organization). Risk business activity, GRC includes multiple overlapping and related
tolerance levels are deviations from risk appetite, which are not activities within an organization, which may include internal
desirable but are known to be sufficiently below the risk capacity audit, compliance programs such as the US Sarbanes-Oxley Act,
that acceptance of risk is still possible when there is compelling ERM, operational risk, incident management and others.
business need and other options are too costly. Risk tolerance may
be defined using IT process metrics or adherence to defined 1T Governance, as discussed previously, is the responsibility of
procedures and policies, which are a translation of the IT goals senior management and the board of directors and focuses on
that need to be achieved. Like risk appetite, risk tolerance is creating the mechanisms an organization uses to ensure that
defined at the enterprise level and reflected in the policies created personnel follow established processes and policies.
by senior management. Exceptions can be tolerated at lower levels
of the enterprise as long as the overall exposure does not exceed Risk management is the process by which an organization
the risk appetite at the enterprise level. manages risk to acceptable levels within acceptable tolerances,
identifies potential risk and its associated impacts, and prioritizes
1.2.3 SCOPE AND CHARTER OF INFORMATION their mitigation based on the organization’s business objectives.
Risk management develops and deploys internal controls to
SECURITY GOVERNANCE
manage and mitigate risk throughout the organization.
Information security deals with all aspects of information, in any
medium (e.g., written, spoken, electronic), regardless of whether Compliance is the process that records and monitors the policies,
it is being created, Viewed, transported, stored or destroyed.
procedures and controls needed to ensure that policies and
This is contrasted with IT security, which is concerned with standards are adequately adhered to.
security of information within the boundaries of the technology
domain, usually in a custodial capacity. It is important to note this It is important to recognize that efi'ective integration of GRC
distinction. IT usually is not the owner of most of the information processes requires that governance is in place before risk can be
in its systems; rather, it owns the machinery that processes it. The effectively managed and compliance enforced.
information is in IT’s care, control and custody, and, therefore, IT
fiinctions as a custodian for the data owners.
According to Michael Rasmussen, an industry GRC analyst, the elements linked together by six dynamic interconnections. All
challenge in defining GRC is that, individually, each term has “many aspects of the model interact with each other. If any one part of
different meanings within organizations.” Development of GRC was the model is changed, not addressed or managed inappropriately,
initially a response to the US Sarbanes—Oxley Act, but has evolved the equilibrium of the model is potentially at risk. The dynamic
as an approach to enterprise risk management (ERM). interconnections act as tensions, exerting a push/pull force in
reaction to changes in the enterprise, allowing the model to adapt
While a GRC program can be used in any area of an organization, as needed.
it is usually focused on financial, IT and legal areas. Financial
GRC is used to ensure proper operation of financial processes and Figure1.2—Business Model for infomation Security
compliance With regulatory requirements. In a similar fashion, IT
GRC seeks to ensure proper operation and policy compliance of [T
processes. Legal GRC may focus on overall regulatory compliance.
3. Process—Includes formal and informal mechanisms (large 3. Enablement and support—Connects the technology element
and small, simple and complex) to get things done and to the process element.
provides a vital link to all of the dynamic interconnections. ' One way to help ensure that people comply with technical
Processes identify, measure, manage and control risk, security measures, policies and procedures is to make
availability, integrity and confidentiality, and they also ensure processes usable and easy. Transparency can help generate
accountability. They derive from the strategy and implement acceptance for security controls by assuring users that
the operational part of the organization element. To be security will not inhibit their ability to work effectively.
advantageous to the enterprise, processes must: - Many of the actions that affect both technology and
- Meet business requirements and align with policy processes occur in the enablement and support dynamic
- Consider emergence and be adaptable to changing requirements interconnection. Policies, standards and guidelines must be
° Be well documented and communicated to appropriate designed to support the needs of the business by reducing or
human resources eliminating conflicts of interest, remaining flexible to support
- Be reviewed periodically, once they are in place, to ensure changing business objectives, and being acceptable and easy
efficiency and effectiveness for people to follow.
. Technology—Composed of all of the tools, applications 4. Emergence—Connotes surfacing, developing, growing and
and infrastructure that make processes more efficient. As evolving, and refers to patterns that arise in the life of the
an evolving element that experiences frequent changes, enterprise that appear to have no obvious cause and whose
it has its own dynamic risk. Given the typical enterprise’s outcomes seem impossible to predict and control. The
dependence on technology, technology constitutes a core part emergence dynamic interconnection (between people and
of the enterprise’s infrastructure and a critical component in processes) is a place to introduce possible solutions such as
accomplishing its mission. feedback loops; alignment with process improvement; and
° Technology is often seen by the enterprise’s management consideration of emergent issues in system design life cycle,
team as a way to resolve security threats and risk. While change control and risk management.
technical controls are helpfiil in mitigating some types of 5. Human factors—Represents the interaction and gap
risk, technology should not be Viewed as an information between technology and people and, as such, is critical to an
security solution. information security program. If people do not understand
- Technology is greatly impacted by users and by organizational how to use technology, do not embrace technology or will
culture. Some individuals still mistrust technology; some not follow pertinent policies, serious security problems can
have not learned to use it; and others feel it slows them down. evolve. Internal threats such as data leakage, data theft and
Regardless of the reason, information security managers misuse of data can occur within this dynamic interconnection.
must be aware that, just as with physical and administrative Human factors may arise because of experience level, cultural
controls, some people will try to sidestep technical controls. experiences and differing generational perspectives. Because
human factors are critical components in maintaining balance
Dynamic Interconnections within the model, it is important to train all of the enterprise’s
The dynamic interconnections link the elements together and human resources on pertinent skills.
exert a multidirectional force that pushes and pulls as things 6. Architecture—A comprehensive and formal encapsulation of
change. Actions and behaviors that occur in the dynamic the people, processes, policies and technology that comprise an
interconnections can force the model out of balance or bring it enterprise’s security practices.
back to equilibrium. The six dynamic interconnections are: - A robust business information architecture is essential to
1. Governance—Steering the enterprise and demanding strategic understanding the need for security and designing the
leadership. Governing sets limits within which an enterprise security architecture.
operates and is implemented within processes to monitor - It is within the architecture dynamic interconnection that the
performance, describe activities and achieve compliance while enterprise can ensure defense in depth. The design describes
also providing adaptability to emergent conditions. Governing how the security controls are positioned and how they
incorporates ensuring that objectives are determined and relate to the overall enterprise architecture. An enterprise
defined, ascertaining that risk is managed appropriately, and security architecture facilitates security capabilities across
verifying that the enterprise’s resources are used responsibly. lines of businesses in a consistent and cost—effective manner
. Culture—A pattern of behaviors, beliefs, assumptions, and enables enterprises to be proactive with their security
attitudes and ways of doing things. It is emergent and learned, investment decisions.
and it creates a sense of comfort.
' It is important to understand the culture ofthe enterprise 1.2.6 ASSURANCE PROCESS INTEGRATION—
because it profoundly influences what information is
CONVERGENCE
considered, how it is interpreted and what will be done with it.
- Culture may exist on many levels, such as national The tendency to segment security into separate but related
(legislation/regulation, political and traditional), functions has created the need to integrate the variety of assurance
organizational (policies, hierarchical style and expectations) processes found in a typical organization. These activities are
and social (family, etiquette). It is created from both external often fragmented and segmented in silos with difl‘erent reporting
and internal factors, and is influenced by and influences structures. They tend to use different terminology and generally
organizational patterns. reflect different understandings of their processes and outcomes
with, at times, little in common. These assurance silos can include
risk management, change management, internal and external obtain valuable login information. This situation highlights and
audit, privacy offices, insurance offices, human resources (HR), reinforces the need to bring together—in fact, convergewall
legal, and others. Evaluating business processes from start to components of an organization’s security through an integrated
finish (along with their controls), regardless of which particular and deliberate approach. To be effective, this converged approach
assurance process is involved, can mitigate the tendency for should reach across people, processes and technology, and enable
security gaps to exist among various assurance fiinctions. enterprises to prevent, detect, respond to and recover from any
type of security incident.
GRC, discussed in section 1.2.4, is a recent effort to address
integration issues among the major functions of governance, risk In addition to the costs that companies face to deal with the
management and compliance. immediate effects of an incident, security incidents can cause
more costly, long-term harm such as damage to reputation and
BMIS, covered in section 1.2.5, is an effort by ISACA to develop brand. Beyond the impact to market capitalization, if the issue
a fully integrated approach to information security using a threatens the public good, regulators may intervene, enacting
systems approach. stricter requirements to govern future business practices.
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EDM01.02
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EDM01.03
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