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Security, Privacy Policies, and Procedures

This chapter is from the book

This chapter covers CAS-003 objective 1.2.

IT governance documents should be implemented to ensure that organizational assets are protected as well as possible. This chapter explains how the process and policy life cycles are managed and how to support legal compliance. It also discusses business documents and contracts that are commonly used to support security. It covers general privacy principles. Finally, it discusses the development of policies containing standard security practices.

Policy and Process Life Cycle Management

In a top-down approach, management initiates, supports, and directs the security program. In a bottom-up approach, staff members develop a security program prior to receiving direction and support from management. A top-down approach is much more efficient than a bottom-up approach because management’s support is one of the most important components of a security program. Using the top-down approach can help ensure that an organization’s policies align with its strategic goals.

In the context of organizational security, a policy is a course or principle of action adopted by an organization, and a process is a series of actions taken to achieve a particular end. A procedure is a series of actions conducted in a certain order or manner. Policies, procedures, and processes determine all major decisions and actions within an organization, and all organizational tasks operate within the boundaries set by policies, procedures, and processes.

To understand the relationship between the three, policies are written first to guide the creation of procedures and processes. Processes then provide a high-level view of tasks within the processes. Procedures are the detailed steps involved to complete the process.

Let’s look at an example. Say that an organization adopts a particular policy for processing accounts payable. The process designed around this policy details the high-level tasks that must occur, which may include receiving the bill, inputting the bill, authorizing the payment, printing the check, signing the check, and mailing the check. The procedures written would include each separate step involved in each task in the process.

Policies should be written based on the following life cycle:

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  • Step 1. Develop the policy.

  • Step 2. Perform quality control.

  • Step 3. Obtain approval of the policy.

  • Step 4. Publish the policy.

  • Step 5. Periodically review the policy.

  • Step 6. Archive the policy when no longer needed or applicable.

During this life cycle, the quality control should be performed prior to obtaining approval to ensure that the policy complies with laws, regulations, and standards. When the policy is published, the organization must ensure that the affected personnel are properly educated on the new policy. The new policy should be incorporated into any training received by these personnel. Each policy should at minimum be reviewed annually. If policies must be changed, version control should be implemented to ensure that the most current version of a policy is being used across the enterprise. When a policy is outdated, it should be archived.

Policies should be reviewed often and on a regular schedule. Certain business, technology, risk, and environment changes should always trigger a review of policies, including adoption of a new technology, merger with another organization, and identification of a new attack method.

For example, suppose that employees request remote access to corporate email and shared drives. If remote access has never been offered but the need to improve productivity and rapidly respond to customer demands means staff now require remote access, the organization should analyze the need to determine whether it is valid. Then, if the organization decides to allow remote access, the organization’s security professionals should plan and develop security policies based on the assumption that external environments have active hostile threats.

Policies that should be considered include password policies, data classification policies, wireless and VPN policies, remote access policies, and device access policies. Most organizations develop password and data classification policies first.

A process is a collection of related activities that produce a specific service or product (that is, serve a particular goal) for the organization. Change management and risk management are examples of processes.

Once a policy is written, the appropriate processes should be written based on the following life cycle:

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  • Step 1. Analyze

  • Step 2. Design

  • Step 3. Implement

  • Step 4. Monitor

  • Step 5. Retire

During this life cycle, step 1 is the time to analyze the policy, and step 2 is the time to design the process based on the policy. When the new process is implemented, all personnel involved in the process should be informed of how the process works. The process should be monitored regularly and may be modified as issues arise or as the base policy has been updated. Keep in mind that processes are created based on the policy. If a new policy is adopted, then a new process is needed. If a policy is edited or archived, then the process for the policy should also be edited or retired.

Once the policy and associated processes are documented, procedures must be written. Procedures embody all the detailed actions that personnel are required to follow and are the closest to the computers and other devices. Procedures often include step-by-step lists on how policies and processes are implemented.

Once an organization has analyzed the business, technology, risk, and environment changes to develop and update policies, the organization must take the next step: Develop and update its processes and procedures in light of the new or updated policies and environment and business changes. Procedures might have to be changed, for example, if the organization upgrades to the latest version of the backup software it uses. Most software upgrades involve analyzing the current procedures and determining how they should be changed. As another example, say that management decides to use more outside contractors to complete work. The organization may need to add a new process within the organization for reviewing the quality of the outside contractor’s work. As a final example, suppose that an organization decides to purchase several Linux servers to replace the current Microsoft file servers. While the high-level policies will remain the same, the procedures for meeting those high-level policies will have to be changed.

If an organization’s marketing department needs to provide more real-time interaction with its partners and consumers and decides to move forward with a presence on multiple social networking sites for sharing information, the organization would need to establish a specific set of trained people who can release information on the organization’s behalf and provide other personnel with procedures and processes for sharing the information.

Some of the processes and procedures that should be considered include the change management process, the configuration management process, network access procedures, wireless access procedures, and database administration procedures. But remember that procedures and processes should be created or changed only after the appropriate policies are adopted. The policies will guide the development of the processes and procedures.

Internal organizational drivers are the basis on which policies and processes are developed. Organizations should ensure that policies and processes are designed or reviewed when new business or business changes occur, new technologies are launched, environmental changes occur, or regulatory requirements change.

New Business

New business occurs when an organization launches or purchases a new area of business. Business changes are changes dictated by the nature of an organization’s business and are often driven by consumer demands. As a change occurs, an organization must ensure that it understands the change and its implication for the security posture of the organization. Organizations should take a proactive stance when it comes to these changes. Don’t wait for problems. Anticipate the changes and deploy mitigation techniques to help prevent them!

Suppose a business decides to launch a new endeavor whereby consumers can now directly purchase the products that were previously only sold to large retail stores. A new business policy will need to be written based on this new model, and a new process will need to be designed to handle the new business.

Security professionals are integral to any projects wherein new business is starting or business changes are occurring because the security professionals ensure that security controls are considered. Security professionals should ensure that all risks associated with the new business or business change are documented, analyzed, and reported to management. They must also document any suggested security controls that will mitigate these risks.

New Technologies

Technology changes are driven by new technological developments that force organizations to adopt new technologies. Again, organizations must ensure that they understand the changes and their implications for the security posture of the organization.

Suppose a business decides to allow personnel to implement a bring your own device (BYOD) policy. Security professionals should work to ensure that the policy defines the parameters wherein BYOD will be allowed or denied. In addition, the process would need to be written and would likely include obtaining formal approval of a device, assessing the security posture of the device, and granting the device full or limited access based on the device’s security posture.

Security professionals are integral to the inclusion or usage of any new technologies because they ensure that security controls will be considered. Security professionals should ensure that all risks associated with new technology are documented, analyzed, and reported to management. They must also suggest and document security controls to mitigate these risks.

Environmental Changes

Environmental changes are divided into two categories: those motivated by the culture in an organization and those motivated by the environment of the industry. As with new business or technologies, organizations must ensure that they understand the changes and their implications for the security posture of the organization.

Suppose a business decides to implement a new policy that provides a certain amount of “green space” for each of its facilities. Management would need to develop a process whereby these green spaces could be completed and maintained. It would likely include purchasing the land, designing the plan for the land, implementing the new green space, and maintaining the green space.

Regulatory Requirements

Regulatory requirements are any requirements that must be documented and followed based on laws and regulations. Standards can also be used as part of the regulatory environment but are not strictly enforced as laws and regulations. As with new business or technologies or environmental changes, organizations must ensure that they understand the regulations and their implications to the security posture of the organization.

The International Organization for Standardization (ISO) has developed a series of standards that are meant to aid organizations in the development of security policies. Other regulatory bodies include local, state, federal, and other government bodies.

Let’s look at an example. Suppose an organization is rewriting its security policies and has halted the rewriting progress because the executives believe that the organization’s major vendors have a good handle on compliance and regulatory standards. The executive-level managers are allowing vendors to play a large role in writing the organization’s policy. However, the IT director decides that while vendor support is important, it is critical that the company write the policy objectively because vendors may not always put the organization’s interests first. The IT director should make the following recommendations to senior staff:

  • Consult legal and regulatory requirements.

  • Draft a general organizational policy.

  • Specify functional implementation policies.

  • Establish necessary standards, procedures, baselines, and guidelines.

As you can see from this example, you don’t have to memorize the specific standards. However, you need to understand how organizations apply them, how they are revised, and how they can be customized to fit organizational needs.

Emerging Risks

Emerging risks are any risks that have emerged due to the recent security landscape. Often risks are not identified for new technologies, devices, and applications until after one of them has been deployed. Organizations should write policies and procedures to ensure that security professionals are doing the proper research to understand emerging risks. Emerging risks is an area that can be particularly dependent upon patch management. Often vendors will try to quickly release security fixes for any emerging risks.

Suppose an organization decides to deploy a new Internet of Things (IoT) device. Several weeks into the deployment, the vendor announces a security flaw that allows attackers to take over the device functionality. As a result, they release a security patch that addresses this issue. If the appropriate policies are in place, the organization’s security professionals should be monitoring the vendor for announcements regarding patch management and should deploy the patch once it can be properly tested.

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