Avoiding Audit Fatigue: Achieving Compliance In A Multi-compliance World In Nine Steps Gartner Security/Risk Management Conference July 2010 It's common for information security managers to be held responsible for failed audits where they had little control or influence in the rest of the organization. This presentation provides nine steps that information security managers can use to break the compliance blame cycle and build an information security program that more effectively mitigates security risk. By successfully executing these steps, the information security manager will no longer continually react to and manage the audit preparation crisis du jour. Instead, the information security manager will institute and rely upon regular, defined activities to complete the heavy lifting of preparing for a successful audit long before the audit occurs. This session also describes how IT security managers can achieve alignment among all stakeholders so that information security and compliance activities become integrated into daily business operations. Completing the nine steps in this presentation requires business stakeholders, IT management, and information security management to all mutually support the same goal. This session describes how to gain this alignment and defines the various compliance roles so that information security and compliance activities become integrated into daily

1. Avoiding Audit Fatigue: Achieving Compliance In A Multi-Compliance World In Nine Steps Gene Kim, CISA, TOCICO JonahCTO and Founder(Twitter: @RealGeneKim) Gartner 2010

2. Where Did The High Performers Come From?

3. Agenda The problems of compliance du jour and the audit blame cycle How did the high performing IT organizations make their “good to great” transformations? Nine practical steps overcome audit fatigue What does integration of security controls into daily operation feel like? Additional resources Authors Gene Kim, Founder/CTO, Tripwire, Inc. Jennifer Bayuk, Cybersecurity Program Director, Stevens Institute of Technology

4. “Boss, We Are Ready For The Upcoming Audits…”

5. “OMG. OMG. The Auditors Are Coming When?!?”

6. “IT Operations Not Quite As Ready As They Thought…”

7. “Infosec Must Do Heroics, Generating Reports And Presentations From Scratch…”

8. “Despite Heroics, The Business Still Fails The Audit…”

9. “InfosecAs Professional Apologist…’”

10. Problems: Accountability Infosec often discovers too late that business and IT management were not as prepared for the audits as was represented Business, IT and infosec must perform heroics to generate proof of compliance, often requiring new documents and presentations from scratch in response to auditor questions Business may fail an audit test, requiring remediation work, audit retests, fines, loss of auditor confidence in the infosecprogram, as well as loss of personal trust in the infosec manager A security breach may occur, and the business must now explain how it occurred despite passing the audit

11. Problem: Organizational Information security is often organized and designed to minimally interfere with business and IT operations, but creates barriers to meeting compliance goals Information security is held accountable, but control effectiveness relies upon other business and IT management to be adequately prepared

12. Problems: The Real Business Cost Scheduled value-adding work and projects are delayed because of all the urgent and unplanned audit prep work Business continues to implement controls as a part of a one-time audit preparation project to achieve compliance, with little thought on how to maintain compliance over time Next time requires just as much effort, instead of integrating controls into daily business and IT operational processes The business starts treating audit prep as a legitimate value-adding project, even charging time against it Multiple regulatory and contractual requirements result in IT controls being tested numerous times by numerous parties, requiring management to perform work multiple times

13. Information Security and Compliance Risks Information security practitioners are always one change away from a security breach Front page news Regulatory fines Brand damage High profile security failures are increasing external pressures for security and compliance Sarbanes-Oxley (SOX) Act of 2002, the Gramm-Leach-Bliley Act, Health Insurance Portability and Accountability Act (HIPAA), emerging privacy laws, and the Payment Card Industry Data Security Standard (PCI DSS)

14. Going from Good to Great

16. Lowest amount of unplanned work

17. Highest change success rate

18. Best posture of compliance

19. Lowest cost of complianceSize of Operation # Servers Efficiency of Operation Server/sysadmin ratio Source: IT Process Institute (2001)

21. Fewest number of repeat audit findings

22. One-third amount of audit preparation effort

23. High performers find and fix security breaches faster

24. 5 times more likely to detect breaches by automated control

25. 5 times less likely to have breaches result in a loss event

26. When high performers implement changes…

27. 14 times morechanges

28. One-half the change failure rate

29. One-quarter the first fix failure rate

30. 10x fasterMTTR for Sev 1 outages

31. When high performers manage IT resources…

32. One-third the amount of unplanned work

33. 8 times moreprojects and IT services

34. 6 times moreapplicationsSource: IT Process Institute, May 2008

35. Visible Ops: Playbook of High Performers The IT Process Institute has been studying high-performing organizations since 1999 What is common to all the high performers? What is different between them and average and low performers? How did they become great? Answers have been codified in the Visible Ops Methodology

36. Over Ten Years, We Benchmarked 1500+ IT Orgs Source: EMA (2009) Source: IT Process Institute (2008)

37. 2007: Three Controls Predict 60% Of Performance To what extent does an organization define, monitor and enforce the following? Standardized configuration strategy Process discipline Controlled access to production systems Source: IT Process Institute, May 2008

38. Nine Practical Steps To Overcome Audit Fatigue And The Blame Cycle

39. The Nine Steps To Avoid Audit Fatigue Step 1: Align with tone at the top Step 2: Create a set of merged infosec and compliance/business goals Step 3: Define ideal information security goal indicators Step 4: Gain an end-to-end understanding of the information flow Step 5: Agree upon control ownership, roles and responsibilities Step 6: Define the control tests so business process control owners will agree with the results Step 7: Schedule and conduct regular control tests Step 8: Organize metrics and remediation reports Step 9: Detect and respond to significant changes to the control environment

40. Step 1: Align With Tone At The Top Ensure that compliance activity is clearly managed from the top down.

41. Step 2: Merge Information Security Into The Compliance/ Business Goals Document IT governance goals and the risks to achieving those goals Confirm that information security and compliance helps achieve those goals. For instance: A manufacturing company must comply with a regulatory requirement that certain chemical toxins are never released into the atmosphere in amounts over 10 particles per second. The manufacturing control system has been designed to ensure that this toxin is released at a rate of only 1 particle per second.

42. Step 2: Merge Information Security Into The Compliance/ Business Goals What is the business objective? Ensure smooth operation of the manufacturing process, in accordance to the business plan and all associated laws and regulations. What are the information security and compliance risks? The manufacturing control system could fail and release more than the allowed amount of the chemical toxin into the atmosphere. The measurement system may not detect this release. Also, the manufacturing control measurement data could be altered or lost, which would prevent management from validating emissions output compliance. What is my information security goal to address this risk? We must maintain integrity over the particle release measurement process and the measurement data.

43. Step 2: Merge Information Security Into The Compliance/ Business Goals What control will we implement to meet this goal? An access and measurement testing control process will protect the toxin release measurement software against tampering. The control will alert operations when changes to access are detected and when abnormal variations in the toxin measurements occur. The alert response will include automated and manual procedures that verify that the algorithm installed in the production system is the same as the one that underwent rigorous pre-production system testing. What does plant management (the business process owner) need to do to support this goal? The control process would require the business process owner to configure the production system to minimize the access any given individual needs to change the algorithm and the corresponding data. The control process would also require the business process owner to minimize the job functions that require access to the algorithms and the measurement data.

44. Step 3: Define Ideal Information Security Measures Develop theoretical ideal indicators that demonstrate that information security goals are being met. Examples # of access roles not validated by management % of accounts not matching management-defined roles % of configurations not pre-approved by management % of changes not approved by management % of systems with centralized logging

45. Step 4: Gain End-to-End Understanding Do an end-to-end business process walk-through to understand and document: Where does sensitive information enter, transit, get stored, and exit the organization? What are the risks to organizational goals and information flow? Where is reliance placed on technology to prevent and detect control failures?

46. Step 4: Gain End-to-End Understanding A merchant has a business process that supports a customer loyalty program. The program includes issuing branded credit cards. The consumer credit information flow starts with a customer filling out an online application form, which is… Sent to the credit calculation application, is then… Sent to a sales application, and… Ends up in an application that runs on the desktop of every customer service representative. What is the business goal? To ensure that customers approved for the credit card services are capable of meeting their obligations, so that any credit extended to the customer is likely to be repaid.

47. Step 4: Gain End-to-End Understanding What are the business, information security and compliance risks? Customer information is inaccurate Customer information is inadvertently disclosed, violating regulatory requirements Through what applications does the information flow? The online application form is delivered through a third-party vendor, The credit calculation is done on cloud computing resources The sales application is run internally by IT operations The customer service application is run by a combination of internally developed server software and desktop software on the customer service desktops.

48. Step 5: Agree Upon Control Ownership, Roles And Responsibilities Clearly define roles and responsibilities for audit compliance activities at the process owner level.

49. Step 6: Define The Control Tests So Control Owners Will Agree With The Results Make sure that evidence that demonstrates compliance goals have been met can be generated in an automated manner, upon demand. This will mirror the accountability spreadsheet that the auditors will likely construct This is what enables information security to not be left holding the bag when IT operations is disorganized or unprepared.

50. Step 7: Schedule And Conduct Regular Control Tests Conduct tests of controls effectiveness frequently enough be able to rely on their effectiveness regardless of variances in audit scope and timing. Ensure that sample size is safely larger than the auditor’s You will find unprepared IT control owners long before the audits “Hope is not a strategy. Trust is not a control.”

51. Step 8: Organize Metrics And Remediation Reports Track the completion of required remediation work, ideally to be completed well in advance of the audit. By compliance objective By business process By control owner This will look like a PMO status report

52. Step 9: Detect And Respond To Significant Changes To The Control Environment Have the situational awareness to know when the information flow or control environment has significantly changed, requiring these steps to be redone For example, when an application is changed to allow consumer data to be downloaded to desktops instead of being viewed through pre-defined application reports).

53. What Does Integration Of Security Controls Into Daily Operations Look Like?

54. Find What’s Most Important First

55. Quickly Find What Is Different…

56. Before Something Bad Happens…

57. Find Risk Early…

58. Communicate It Effectively To Peers…

59. Hold People Accountable…

60. Based On Objective Evidence…

61. Answer Important Questions…

62. Ever Increasing Situational Mastery…

63. Show Value To The Business…

64. Be Recognized For Contribution…

65. And Do More With Less…

67. Fewest number of repeat audit findings

68. One-third amount of audit preparation effort

69. High performers find and fix security breaches faster

70. 5 times more likely to detect breaches by automated control

71. 5 times less likely to have breaches result in a loss event

72. When high performers implement changes…

73. 14 times morechanges

74. One-half the change failure rate

75. One-quarter the first fix failure rate

76. 10x fasterMTTR for Sev 1 outages

77. When high performers manage IT resources…

78. One-third the amount of unplanned work

79. 8 times moreprojects and IT services

80. 6 times moreapplicationsSource: IT Process Institute, May 2008

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