By The Open Group
IT Risk Management is currently in a state of flux with many organizations today unsure not only how to best assess risk but also how to place it within the context of their business. Ben Tomhave, a Security Architect and former Gartner analyst, will be speaking at The Open Group Baltimore on July 20 on “The Strengths and Limitations of Risk Management Standards.”
We recently caught up with Tomhave pre-conference to discuss the pros and cons of today’s Risk Management standards, the issues that organizations are facing when it comes to Risk Management and how they can better use existing standards to their advantage.
How would you describe the state of Risk Management and Risk Management standards today?
The topic of my talk is really on the state of standards for Security and Risk Management. There’s a handful of significant standards out there today, varying from some of the work at The Open Group to NIST and the ISO 27000 series, etc. The problem with most of those is that they don’t necessarily provide a prescriptive level of guidance for how to go about performing or structuring risk management within an organization. If you look at ISO 31000 for example, it provides a general guideline for how to structure an overall Risk Management approach or program but it’s not designed to be directly implementable. You can then look at something like ISO 27005 that provides a bit more detail, but for the most part these are fairly high-level guides on some of the key components; they don’t get to the point of how you should be doing Risk Management.
In contrast, one can look at something like the Open FAIR standard from The Open Group, and that gets a bit more prescriptive and directly implementable, but even then there’s a fair amount of scoping and education that needs to go on. So the short answer to the question is, there’s no shortage of documented guidance out there, but there are, however, still a lot of open-ended questions and a lot of misunderstanding about how to use these.
What are some of the limitations that are hindering risk standards then and what needs to be added?
I don’t think it’s necessarily a matter of needing to fix or change the standards themselves, I think where we’re at is that we’re still at a fairly prototypical stage where we have guidance as to how to get started and how to structure things but we don’t necessarily have really good understanding across the industry about how to best make use of it. Complicating things further is an open question about just how much we need to be doing, how much value can we get from these, do we need to adopt some of these practices? If you look at all of the organizations that have had major breaches over the past few years, all of them, presumably, were doing some form of risk management—probably qualitative Risk Management—and yet they still had all these breaches anyway. Inevitably, they were compliant with any number of security standards along the way, too, and yet bad things happen. We have a lot of issues with how organizations are using standards less than with the standards themselves.
Last fall The Open Group fielded an IT Risk Management survey that found that many organizations are struggling to understand and create business value for Risk Management. What you’re saying really echoes those results. How much of this has to do with problems within organizations themselves and not having a better understanding of Risk Management?
I think that’s definitely the case. A lot of organizations are making bad decisions in many areas right now, and they don’t know why or aren’t even aware and are making bad decisions up until the point it’s too late. As an industry we’ve got this compliance problem where you can do a lot of work and demonstrate completion or compliance with check lists and still be compromised, still have massive data breaches. I think there’s a significant cognitive dissonance that exists, and I think it’s because we’re still in a significant transitional period overall.
Security should really have never been a standalone industry or a standalone environment. Security should have just been one of those attributes of the operating system or operating environments from the outset. Unfortunately, because of the dynamic nature of IT (and we’re still going through what I refer to as this Digital Industrial Revolution that’s been going on for 40-50 years), everything’s changing everyday. That will be the case until we hit a stasis point that we can stabilize around and grow a generation that’s truly native with practices and approaches and with the tools and technologies underlying this stuff.
An analogy would be to look at Telecom. Look at Telecom in the 1800s when they were running telegraph poles and running lines along railroad tracks. You could just climb a pole, put a couple alligator clips on there and suddenly you could send and receive messages, too, using the same wires. Now we have buried lines, we have much greater integrity of those systems. We generally know when we’ve lost integrity on those systems for the most part. It took 100 years to get there. So we’re less than half that way with the Internet and things are a lot more complicated, and the ability of an attacker, one single person spending all their time to go after a resource or a target, that type of asymmetric threat is just something that we haven’t really thought about and engineered our environments for over time.
I think it’s definitely challenging. But ultimately Risk Management practices are about making better decisions. How do we put the right amount of time and energy into making these decisions and providing better information and better data around those decisions? That’s always going to be a hard question to answer. Thinking about where the standards really could stand to improve, it’s helping organizations, helping people, understand the answer to that core question—which is, how much time and energy do I have to put into this decision?
When I did my graduate work at George Washington University, a number of years ago, one of the courses we had to take went through decision management as a discipline. We would run through things like decision trees. I went back to the executives at the company that I was working at and asked them, ‘How often do you use decision trees to make your investment decisions?” And they just looked at me funny and said, ‘Gosh, we haven’t heard of or thought about decision trees since grad school.’ In many ways, a lot of the formal Risk Management stuff that we talk about and drill into—especially when you get into the quantitative risk discussions—a lot of that goes down the same route. It’s great academically, it’s great in theory, but it’s not the kind of thing where on a daily basis you need to pull it out and use it for every single decision or every single discussion. Which, by the way, is where the FAIR taxonomy within Open FAIR provides an interesting and very valuable breakdown point. There are many cases where just using the taxonomy to break down a problem and think about it a little bit is more than sufficient, and you don’t have to go the next step of populating it with the actual quantitative estimates and do the quantitative estimations for a FAIR risk analysis. You can use it qualitatively and improve the overall quality and defensibility of your decisions.
How mature are most organizations in their understanding of risk today, and what are some of the core reasons they’re having such a difficult time with Risk Management?
The answer to that question varies to a degree by industry. Industries like financial services just seem to deal with this stuff better for the most part, but then if you look at multibillion dollar write offs for JP Morgan Chase, you think maybe they don’t understand risk after all. I think for the most part most large enterprises have at least some people in the organization that have a nominal understanding of Risk Management and risk assessment and how that factors into making good decisions.
That doesn’t mean that everything’s perfect. Look at the large enterprises that had major breaches in 2014 and 2013 and clearly you can look at those and say ‘Gosh, you guys didn’t make very good decisions.’ Home Depot is a good example or even the NSA with the Snowden stuff. In both cases, they knew they had an exposure, they had done a reasonable job of risk management, they just didn’t move fast enough with their remediation. They just didn’t get stuff in place soon enough to make a meaningful difference.
For the most part, larger enterprises or organizations will have better facilities and capabilities around risk management, but they may have challenges with velocity in terms of being able to put to rest issues in a timely fashion. Now slip down to different sectors and you look at retail, they continue to have issues with cardholder data and that’s where the card brands are asserting themselves more aggressively. Look at healthcare. Healthcare organizations, for one thing, simply don’t have the budget or the control to make a lot of changes, and they’re well behind the curve in terms of protecting patient records and data. Then look at other spaces like SMBs, which make up more than 90 percent of U.S. employment firms or look at the education space where they simply will never have the kinds of resources to do everything that’s expected of them.
I think we have a significant challenge here – a lot of these organizations will never have the resources to have adequate Risk Management in-house, and they will always be tremendously resource-constrained, preventing them from doing all that they really need to do. The challenge for them is, how do we provide answers or tools or methods to them that they can then use that don’t require a lot of expertise but can guide them toward making better decisions overall even if the decision is ‘Why are we doing any of this IT stuff at all when we can simply be outsourcing this to a service that specializes in my industry or specializes in my SMB business size that can take on some of the risk for me that I wasn’t even aware of?’
It ends up being a very basic educational awareness problem in many regards, and many of these organizations don’t seem to be fully aware of the type of exposure and legal liability that they’re carrying at any given point in time.
One of the other IT Risk Management Survey findings was that where the Risk Management function sits in organizations is pretty inconsistent—sometimes IT, sometimes risk, sometimes security—is that part of the problem too?
Yes and no—it’s a hard question to answer directly because we have to drill in on what kind of Risk Management we’re talking about. Because there’s enterprise Risk Management reporting up to a CFO or CEO, and one could argue that the CEO is doing Risk Management.
One of the problems that we historically run into, especially from a bottom-up perspective, is a lot of IT Risk Management people or IT Risk Management professionals or folks from the audit world have mistakenly thought that everything should boil down to a single, myopic view of ‘What is risk?’ And yet it’s really not how executives run organizations. Your chief exec, your board, your CFO, they’re not looking at performance on a single number every day. They’re looking at a portfolio of risk and how different factors are balancing out against everything. So it’s really important for folks in Op Risk Management and IT Risk Management to really truly understand and make sure that they’re providing a portfolio view up the chain that adequately represents the state of the business, which typically will represent multiple lines of business, multiple systems, multiple environments, things like that.
I think one of the biggest challenges we run into is just in an ill-conceived desire to provide value that’s oversimplified. We end up hyper-aggregating results and data, and suddenly everything boils down to a stop light that IT today is either red, yellow or green. That’s not really particularly informative, and it doesn’t help you make better decisions. How can I make better investment decisions around IT systems if all I know is that today things are yellow? I think it comes back to the educational awareness topic. Maybe people aren’t always best placed within organizations but really it’s more about how they’re representing the data and whether they’re getting it into the right format that’s most accessible to that audience.
What should organizations look for in choosing risk standards?
I usually get a variety of questions and they’re all about risk assessment—‘Oh, we need to do risk assessment’ and ‘We hear about this quant risk assessment thing that sounds really cool, where do we get started?’ Inevitably, it comes down to, what’s your actual Risk Management process look like? Do you actually have a context for making decisions, understanding the business context, etc.? And the answer more often than not is no, there is no actual Risk Management process. I think really where people can leverage the standards is understanding what the overall risk management process looks like or can look like and in constructing that, making sure they identify the right stakeholders overall and then start to drill down to specifics around impact analysis, actual risk analysis around remediation and recovery. All of these are important components but they have to exist within the broader context and that broader context has to functionally plug into the organization in a meaningful, measurable manner. I think that’s really where a lot of the confusion ends up occurring. ‘Hey I went to this conference, I heard about this great thing, how do I make use of it?’ People may go through certification training but if they don’t know how to go back to their organization and put that into practice not just on a small-scale decision basis, but actually going in and plugging it into a larger Risk Management process, it will never really demonstrate a lot of value.
The other piece of the puzzle that goes along with this, too, is you can’t just take these standards and implement them verbatim; they’re not designed to do that. You have to spend some time understanding the organization, the culture of the organization and what will work best for that organization. You have to really get to know people and use these things to really drive conversations rather than hoping that one of these risk assessments results will have some meaningful impact at some point.
How can organizations get more value from Risk Management and risk standards?
Starting with latter first, the value of the Risk Management standards is that you don’t have to start from scratch, you don’t have to reinvent the wheel. There are, in fact, very consistent and well-conceived approaches to structuring risk management programs and conducting risk assessment and analysis. That’s where the power of the standards come from, from establishing a template or guideline for establishing things.
The challenge of course is you have to have it well-grounded within the organization. In order to get value from a Risk Management program, it has to be part of daily operations. You have to plug it into things like procurement cycles and other similar types of decision cycles so that people aren’t just making gut decisions based off whatever their existing biases are.
One of my favorite examples is password complexity requirements. If you look back at the ‘best practice’ standards requirements over the years, going all the way back to the Orange Book in the 80s or the Rainbow Series which came out of the federal government, they tell you ‘oh, you have to have 8-character passwords and they have to have upper case, lower, numbers, special characters, etc.’ The funny thing is that while that was probably true in 1985, that is probably less true today. When we actually do risk analysis to look at the problem, and understand what the actual scenario is that we’re trying to guard against, password complexity ends up causing more problems than it solves because what we’re really protecting against is a brute force attack against a log-in interface or guessability on a log-in interface. Or maybe we’re trying to protect against a password database being compromised and getting decrypted. Well, password complexity has nothing to do with solving how that data is protected in storage. So why would we look at something like password complexity requirements as some sort of control against compromise of a database that may or may not be encrypted?
This is where Risk Management practices come into play because you can use Risk Management and risk assessment techniques to look at a given scenario—whether it be technology decisions or security control decisions, administrative or technical controls—we can look at this and say what exactly are we trying to protect against, what problem are we trying to solve? And then based on our understanding of that scenario, let’s look at the options that we can apply to achieve an appropriate degree of protection for the organization.
That ultimately is what we should be trying to achieve with Risk Management. Unfortunately, that’s usually not what we see implemented. A lot of the time, what’s described as risk management is really just an extension of audit practices and issuing a bunch of surveys, questionnaires, asking a lot of questions but never really putting it into a proper business context. Then we see a lot of bad practices applied, and we start seeing a lot of math-magical practices come in where we take categorical data—high, medium, low, more or less, what’s the impact to the business? A lot, a little—we take these categorical labels and suddenly start assigning numerical values to them and doing arithmetic calculations on them, and this is a complete violation of statistical principles. You shouldn’t be doing that at all. By definition, you don’t do arithmetic on categorical data, and yet that’s what a lot of these alleged Risk Management and risk assessment programs are doing.
I think Risk Management gets a bad rap as a result of these poor practices. Conducting a survey, asking questions is not a risk assessment. A risk assessment is taking a scenario, looking at the business impact analysis for that scenario, looking at the risk tolerance, what the risk capacity is for that scenario, and then looking at what the potential threats and weaknesses are within that scenario that could negatively impact the business. That’s a risk assessment. Asking people a bunch of questions about ‘Do you have passwords? Do you use complex passwords? Have you hardened the server? Are there third party people involved?’ That’s interesting information but it’s not usually reflective of the risk state and ultimately we want to find out what the risk state is.
How do you best determine that risk state?
If you look at any of the standards—and again this is where the standards do provide some value—if you look at what a Risk Management process is and the steps that are involved in it, take for example ISO 31000—step one is establishing context, which includes establishing potential business impact or business importance, business priority for applications and data, also what the risk tolerance, risk capacity is for a given scenario. That’s your first step. Then the risk assessment step is taking that data and doing additional analysis around that scenario.
In the technical context, that’s looking at how secure is this environment, what’s the exposure of the system, who has access to it, how is the data stored or protected? From that analysis, you can complete the assessment by saying ‘Given that this is a high value asset, there’s sensitive data in here, but maybe that data is strongly encrypted and access controls have multiple layers of defense, etc., the relative risk here of a compromise or attack being successful is fairly low.’ Or ‘We did this assessment, and we found in the application that we could retrieve data even though it was supposedly stored in an encrypted state, so we could end up with a high risk statement around the business impact, we’re looking at material loss,’ or something like that.
Pulling all of these pieces together is really key, and most importantly, you cannot skip over context setting. If you don’t ever do context setting, and establish the business importance, nothing else ends up mattering. Just because a system has a vulnerability doesn’t mean that it’s a material risk to the business. And you can’t even know that unless you establish the context.
In terms of getting started, leveraging the standards makes a lot of sense, but not from a perspective of this is a compliance check list that I’m going to use verbatim. You have to use it as a structured process, you have to get some training and get educated on how these things work and then what requirements you have to meet and then do what makes sense for the organizational role. At the end of the day, there’s no Easy Button for these things, you have to invest some time and energy and build something that makes sense and is functional for your organization.
To download the IT Risk Management survey summary, please click here.
Former Gartner analyst Ben Tomhave (MS, CISSP) is Security Architect for a leading online education organization where he is putting theories into practice. He holds a Master of Science in Engineering Management (Information Security Management concentration) from The George Washington University, and is a member and former co-chair of the American Bar Association Information Security Committee, senior member of ISSA, former board member of the Northern Virginia OWASP chapter, and member and former board member for the Society of Information Risk Analysts. He is a published author and an experienced public speaker, including recent speaking engagements with the RSA Conference, the ISSA International Conference, Secure360, RVAsec, RMISC, and several Gartner events.
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