Starting last August, we began the current series of articles to provide our readers with a deep dive into the NIST Framework and its approach to Identify, Protect, Detect, Respond to and Recover from cybersecurity incidents. The final category within NIST’s Identify function is Risk Management Strategy, and there are six basic tenets for your company’s success:
Establish a team or committee: Ideally, your group will consist of representative stakeholders from across the organization who, as a whole, understand the business value of the organization’s data, systems, processes and services.
Ensure the group is informed: In addition to understanding your business, members of the risk team must be advised of any legal, regulatory, policy or other sector-specific privacy, security or operational requirements.
Identify any business or security constraints or assumptions: Examples of common constraints are budget approvals, time deadlines, the company’s view of success and legal mandates. Assumptions, on the other hand, might include an organization’s judgment that the vast majority of its employees are loyal and law abiding, and that the company’s security technologies can be relied upon to operate as designed. These factors should be captured and reviewed periodically to determine whether they remain valid over time.
Communicate cyber risk decisions in clear, unambiguous terms: Perhaps the most important part of developing a comprehensive cyber risk management strategy is to broadcast the organization’s risk priorities (based on impact and likelihood), risk tolerance and risk governance. Senior leadership should consider adopting formal risk tolerance statements, organized by major categories of risk, which clearly communicate the organization’s appetite for accepting harm or foregoing opportunities.
Consider the Care Quality Commission in England, an independent government entity that regulates healthcare providers and which receives patient health records. In its risk tolerance statement, the CQC states: “The organisation has a Senior Information Risk Owner to oversee our approach to information risk management. We will adopt a low risk tolerance to information risk.” The Commission also maintains a Strategic Risk Register to capture its decisions, identify risk owners, list mitigating actions and timeframes, quantify the residual/current risk after mitigation, and provide commentary on mitigation status and effectiveness.
Implement cyber risk management as part of enterprise risk management: The general framework an organization uses for identifying, prioritizing, accepting, and communicating risk should be the same at the enterprise level as it is for managing IT systems.
Manage, measure, review and modify the strategy: Sometimes an organization’s strategy will have gaps and need improvement. Other times, the strategy will need revision simply because the organization itself has changed.
In short, a company’s cyber risk management strategy must be viewed as a dynamic process that, at least initially, may require as much attention as the risks it is trying to mitigate. By implementing the six steps outlined here, you can improve your organization’s risk posture now and for the long term.