Gs Us Roadmap For A World Class Information Security Management System– Isoiec 270012005
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Gs Us Roadmap For A World Class Information Security Management System– Isoiec 270012005
- 1. GSU's Roadmap for a World-Class Information Security Management System– ISO/IEC 27001:2005 Tammy Clark, Chief Information Security Officer, William Monahan , Lead Information Security Administrator “ You will now have a starting place and a destination, and you will be able to determine what it will cost you to get there. You will be going someplace.” H. Stanley Judd
Editor's Notes
- Background: GSU is located in downtown Atlanta – approximately 27,000 students (undergraduate & graduate) - second largest university in Georgia. CIO – JL Albert Information Security Program – Tammy Clark (CISO), William Monahan (Information Security Lead Admin), Miss Nancy Chang (Information Security Intermediate). Started aligning the university’s security plan with ISO 17799 (now ISO 27002) in September of 2004 (what the standard says – current state of security– strategic & tactical goals) – incrementally have addressed the 133 controls (risk assessments, data classification, incident response, security awareness training…) – taking it to the next level with ISO 27001 ((ISMS) = controls + governance))
- Can only provide a 3000’ view of our ISMS activities in 45 minutes. It is all about governance – In the early stages of the GSU Information Security program (2000-2004), a myriad of initiatives, processes (technology/people/processes) were introduced to the enterprise. The program evolved from reactive mode (chasing the threats and problems) to proactive (managing information security, large scale incident reductions, preventive and corrective actions). From late 2004 – 2006, the next phase of the program was a campus wide effort to comply with ISO 27002 (17799), through assessing the control objectives, individual controls and ensuring that GSU was either mitigating risk, accepting risk, transferring risk, or not affected…all of which had to be justified by top management and University IT department heads and managers. Finally, in 2007, our CIO JL Albert went forward in championing the initiative to get 2 areas of the University certified under ISO 27001. From Nov 2005 going forward, a major paradigm shift happened at GSU, when the Security Review policy was brought forward by JL to the President, and sanctioned/mandated security reviews on IT projects that cost over $4999. JL instituted an ITPR process which included a security review and approval as the final step in the process. This allowed Information Security to recommend controls and re-engineered processes that integrated information security into the departments’ business processes. The resultant effect has been that the university’s information security program is viewed as a business enabler, a change agent, and integral to the success of the University’s academic and business objectives.
- Strategic planning ensures that University information security program objectives are met in a consistent, measureable, and cost effective manner. It provides an umbrella framework that allows for prioritization, gap analysis, metrics, and effective integration of security processes and solutions into the University’s infrastructure. At the strategic operational level, there is a consistent push each year to prioritize action items based on the results of targeted risk assessments, regulatory and policy implications and/or guidance, and University strategic academic and business goals. This all works behind the scenes to keep the information security program poised to take advantage of opportunities to integrate into business processes, influence decisions of top management about future directions of information technology, and build the perception that information security adds value to the overall enterprise.
- Meeting between Mao and Dr. Kissinger – you have to sell 27001. Selling Points for Top Management – Protecting the university’s reputation. Compliance More robust and reliable infrastructure due to the reduction of business discontinuities that arise when security defenses are breached. Avoid liability for illegal or malicious acts committed with the university's computer or network resources. Selling Points for Key Enterprise Stakeholders – Protecting their department’s reputation. Compliance More robust and reliable infrastructure due to the reduction of business discontinuities that arise when security defenses are breached. Avoid liability for illegal or malicious acts committed with the university's computer or network resources. Understanding of Key Strategic and Business Goals – Business objectives and ISMS objectives should be aligned – not just CIA – privacy, nonrepudiation, transparency, ethics, democracy… Researcher example - Identity management/digital signatures/federation via smart card technologies
- Top Management support is critical. At GSU, our CIO ‘sells’ our ISMS initiative to top management at the University (President, Provost, Deans, VP’s, etc.), while CISO and staff continually promote the concepts and initiatives to middle tier managers and below. All in all, without that level of support and participation that our CIO provides, the chances for success would measurably decrease. You’ve got to find a myriad of ways to demonstrate to your CIO/top management that information security governance is a top priority and critical to the success of your program and initiatives to protect confidential data. COMMUNICATE, COLLABORATE, AND CELEBRATE THE ACHIEVEMENT OF GOALS , SMALL OR LARGE, ALONG THE PATHWAYS TO YOUR FINAL DESTINATION!
- ISO 27001 Certification The ISO 27001: 2005 certification process is comprised of two steps, which at minimum provides one control into the organization, dependent of its size and its objectives concerning risk management (ISMS scope and limits). The first stage has as a goal the purpose of enabling auditors to understand how an ISMS is registered in the policy, and the risk management objectives of the organization. In this regard, the auditors will have knowledge of documents relating to the creation (definition of scope and limits, control objectives…) and ISMS implementation (assessment report, treatment plans…). An assessment report could be produced. The second stage will be to confirm that the organization, in the process of installing and improving its ISMS, acts in accordance with its policies, objectives, and business processes. It is based on the results of the first stage. This organizational audit will seek to confirm that ISMS complies with the requirements of the ISO 27001: 2005 standard. The auditors will obtain knowledge of the ISMS performance reports, its controls, procedures, and processes. A report audit will be produced, and the certification from the appreciation of certification chosen. The ISO 27001: 2005 certification requires 3 years (repeatable after audit) during which the organization receives monitoring control. Revised in 2005 and renamed in 2007, ISO 27002 is a guide of good practices for information security management which can represent an interest for any type of organization (companies, governmental bodies…) no matter its size or its branch of industry. This standard defines objectives and recommendations in terms of information security and its ambition is to answer global information security concerns in regards to the organizations total activities.
- Control Objectives (Annex A of ISO 27001)corresponding with the domains in ISO 27002, along with a description of controls: See http://www.praxiom.com/iso-17799-objectives.htm
- Using the ISO 27000 series to framework your information security program: Compatible with other standards and guidelines Assists with compliance Customizable—not a ‘one size fits all’ approach Favors incremental deployment of controls Assists in integrating business requirements with IT and information security goals/objectives Helps you to prioritize areas of greatest risk/need Consistent and measurable
- The use of the PDCA model not only assists in the development of a comprehensive and effective Information Security Management System—it also emphasizes development and improvement of policies, objectives, processes and procedures, routine reviews and continuous improvements
- The Plan phase The plan phase represents the development of the information security management system framework and takes into account the characteristics of the organization (mission, location, assets, activities, corporate culture…) as well as any laws, regulations, and contractual obligations to which it is subjected. When the global framework of information security management is established, it must determine the specific settings of ISMS. Scope—definition is up to you—suggest you take an incremental approach of incorporating two or three areas of your campus such as Information Security, Finance, Alumni and focus on building the framework out before you add additional areas. Should be defined in terms of characteristics of the business: location, assets, technology, take into account interfaces and dependencies ISMS has with other parts of your campus that are not within the scope (HR, Legal, etc.), third parties your campus partners with (in Georgia, the Board of Regents supplies IT support and services to many of the USG campuses) Policy—Keep it clear and succinct; include scope and boundaries; provide management support and direction; set objectives; establish risk assessment criteria Risk Assessment Approach—Up to you to choose the method that works best for your university—with expectation that results are comparable and reproducible
- The Do phase This step concerns the ISMS implementation and integration within the organization. In this regard, the fist step is the definition of a risk treatment plan, measure system, and efficiency assessment in regards to implemented controls. The measure and assessment system of controls efficiency should enable the production of reproducible and comparable results. This system should consider the rapport between control costs and their efficiency. The second step in the ISMS introduction phase is the implementation regarding the risk treatment plan containing the chosen controls and also a training program. A training program will ensure that individuals are skilled in order to carry out the tasks assigned to them. It also determines the necessary skills for the achievement of their tasks and if necessary to propose training and to evaluate this efficiency. The organization will keep an outline of competences and qualifications acquired. The last step concerns ISMS management and resource sufficiency. It is advisable to make sure that the ISMS established is compatible not only with identified controls but also with the policies and procedures selected. Moreover, in order to ensure the longevity of continuous improvement processes, the organization must identify and provide the necessary resources to introduce, review, maintain and improve the ISMS.
- The Check phase Opportunity to forge a partnership/collaborative working relationship with your internal auditors. We found that the following encouraged their active participation and interest: --Clearly defined objectives and goals --Attainable scope/certification timeframe --Automated process to audit ISMS that would save time and effort --Future state: demonstrated value of project in terms of time savings for auditors as we bring departments in under our 27001 project, all of the objective evidence will be within our automated system and our internal auditors, provisioned with accounts, will be able to examine a myriad of supporting documentation and processes that allow them to assess risk, compliance, controls, etc. Auditable requirements in ISO 27001: --Required processes: Document control Internal audits Corrective Actions Preventive Actions --Required documentation: Statements of policy and objectives Scope and boundaries Procedures and controls Description of Risk Assessment Methodology Risk Assessment Report and RTP Metrics Objective evidence SOA
- The Act phase The Check phase should identify any necessary ISMS improvements in order to ensure that the information security risks are correctly managed. An organization must not only implement improvements but also preventive actions in order to anticipate all incapability’s between the different ISMS processes. In this regard, it must consider controls, processes, policies, and procedures already established in order to ensure that ISMS functions will work correctly. It is then necessary to communicate with key stakeholders in connection with actions and implemented improvements in order to preserve the dynamic of continuous improvement. Indeed, the success of this management’s information security approach depends on the full comprehension of ISMS components. Finally, as for each process or action, the organization should ensure, by means of assessment that the evaluation achieves its objectives. This measurement step will allow the documentation of the organization’s risk management progression.
- If You Don't Know Where You 're Going , Any Road Will Get You There In December of 2004, we developed a holistic, comprehensive security plan based on ISO 17799—133 controls and 11 domain areas As we developed the initial plan, we conducted a ‘state of security’ assessment in each domain area and developed action plans to address deficiencies We modify our plan each year to incorporate changes in the ISO 17799 standard, as well as new requirements due to compliance legislation, university policies, risk analyses We also develop action plans each year which lead to the addition of policies, procedures, and new solutions being layered into our security infrastructure
- Vote early and vote often GSU implemented a Risk Assessment policy in November of 2005 (as a byproduct of updated ISO 17799:2005 updates) – are conducting approximately 50 risk assessments per year – this proactive approach has yielded big dividends Not just about recommending managerial and technical controls – have improved efficiencies via Risk Assessments (secure LDAP) Most nonconformities are a result of recommendations not being implemented or undue delay. High Risk – mitigation plan immediately Medium Risk – do it within one year Low Risk – not going to worry about it
- Would rate GSU as a 2.5 out of 5 on the Capability Maturity Model. We just started having a third party (internal audit) following up on our High Risk projects to ensure that controls were adequate/commensurate with risk and that they were implemented in a timely manner – will be done before preassessment in December. ISO mandates that we reevaluate risk – lessons learned from shredders. We are migrating from NIST 800-30 to BS 7799-3:2005 for our Risk Assessments. NIST Special Publication 800-30, "Risk Management Guide for Information Technology Systems." BS 7799-3:2005 Information security management systems. Guidelines for information security risk management" . Internal auditors and BSI will keep everyone honest – what gets checked gets done
- Copyright Tammy Clark, May 2007. Permission is granted for this material to be shared for non-commercial, educational purposes, provided that this copyright statement appears on the reproduced materials and notice is given that the copying is by pe