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RISK MANAGEMENT: ASSESSING RISK
• Risk Management (RM) is the process of
identifying, assessing and controlling financial, legal, strategic and security risks to an organization's capital and earnings. • RM is the entire program of planning for and managing risk to information assets in the organization. • RM Framework The overall structure of the strategic planning and design for the entirety of the organization's RM efforts. • RM process The identification, analysis, evaluation, and treatment of risk to information • Risk exists in every environment. From an organization's perspective, the evaluation and reaction to this risk, including financial risk, competitive risk, and economic risk, is commonly referred to as Enterprise Risk Management (ERM). • The aspect directly related to InfoSec is commonly referred to as IT risk management, or IT security risk management. This discussion uses the term lnfoSec risk management or simply Risk Management (RM). • Risk management is the process of discovering and assessing the risks to an organization's operations and determining how those risks can be controlled. • 1. Where and what is the risk (risk identification)? • 2. How severe is the current level of risk (risk analysis)? • 3. Is the current level of risk acceptable (risk evaluation)? • 4. What do I need to do to bring the risk to an acceptable level (risk treatment)? • The RM framework is the overall structure of the strategic planning and design for the sum of the organization's RM efforts. The RM process is the implementation of risk management, as RM Framework • The RM framework consists of five key stages: • 1. Executive governance and support • 2. Framework design • 3. Framework implementation • 4. Framework monitoring and review • 5. Continuous improvement Roles of Communities of Interest in Managing Risk • Each community of interest in an organization bears responsibility for the management of risk. The executive management of the organization is ultimately accountable for the risk management program that is implemented. • The three communities of interest directly linked to managing the risks to information assets, each has a particular strategic role to play: • InfoSec- Because members of the InfoSec community best understand the threats and attacks that introduce risk, they often take a leadership role in addressing risk. • IT- This group is responsible for building secure systems and ensuring their safe operation. For example, IT builds and operates information systems that are mindful of operational risks and have proper controls implemented to reduce risk. • General management and users - When properly trained and kept aware of the threats faced by the organization, this group plays a part in the early detection and response process. Users must be made aware of threats to data and systems and must be educated on practices that minimize those threats. Members of this community also ensure that sufficient resources (money and personnel) are allocated to the InfoSec and IT groups to meet the security needs of the organization. • Executive Governance and Support The entire RM program begins with a formal acknowledgement by the organization's most senior governance group that RM is invaluable and critical to the organization's long-term sustainability (supportable) and viability(capability). • Governance group must demonstrate its commitment to the RM effort by notifying the entire organization that 1)A major RM project is underway. 2)The project is of the utmost importance to the strategic future of the organization, and 3)The participation and cooperation of all aspects of the organization are mandated and are essential to the project's success. Legal and Regulatory Compliance • It is the governance group's responsibility to ensure that the RM process is in complete compliance with all applicable requirements. This is commonly done by assigning a member of the organization's legal team to the RM framework team, or by requiring that all work products from the team are reviewed and approved by designated legal advice. • Organizations must continually scan the legal horizons to ensure they are prepared for authorized compliance in the area of information security and privacy • The RM Policy For RM program development and implementation, the project leader, in cooperation with the governance group, drafts a risk management policy. This policy converts the instructions and perspectives(views) provided to the RM framework team by the governance group into consistent guidance that structures and directs all subsequent risk management efforts within the organization. • RM policy, much like the Enterprise Information Security Policy (EISP), is a strategic document that formalizes much of the intent of the governance group. No two policies are identical. • Purpose and scope- What is this policy for and to whom does it apply? • RM intent and objectives- What is the general view of RM by the governance group and how will that be translated into goals and objectives for RM for the entire organization? • Roles and responsibilities - A list of the assignments and expectations for each essential responsible for the RM program. • The CISO will serve as project team leader for the RM framework development team and is responsible for ensuring completion of the framework and implementation of the process within the timelines, budgets, and other constraints specified. Assigning Key Responsibilities • Who will be the project manager of the RM framework team? • Who will be assigned to the framework team? • Who will be assigned to the process team? Who will manage each of these teams? • In most organizations, either the CIO, CISO, or their equivalent leads the RM effort. • The CIO serves as the champion and the CISO as the project manager. Developing Priorities and Objectives • The project leader will translate intent(purpose) into set of goals and objectives for the RM effort. • Goals & objectives could include the following: • Develop a common understanding of risk across multiple functions and business units so we can manage risk cost-effectively on an enterprise- wide basis. • Achieve a better understanding of risk for competitive (economical) advantage. • Build safeguards against earnings-related surprises. • Complete initial RM framework development by a defined date. • Report RM program progress to the governance group on a defined periodic basis. Some goals and objectives could also be directed toward the RM project itself. • Implement the entire RM framework and process based on a defined, allocated budget. • Report RM process findings to the governance group on a defined periodic basis. Providing Resources • Once a policy has been developed governance group must allocate the resources needed to support RM program development and implementation. This is usually a multi-phase effort, beginning with the allocation of enough resources to support the framework design. Once the framework design is approved by the governance group, supplemental resources are allocated to support the framework implementation, followed by another review phase and then resource allocation for RM process implementation and execution. Framework Design • The framework team begins designing the RM process by which the organization will understand its current levels of risk and determine what, if anything, it needs to do to bring that level down to an acceptable level in alignment with the risk in the process. Designing the RM program means not only defining and specifying the detailed tasks to be performed by the framework team, but also those to be performed by the process team. • The framework team must also formally document and define the organization's risk and draft the RM plan. Risk Tolerance and Risk Appetite • Governance group communicates its intent (purpose) to the RM framework development team, it also needs to communicate its general perspective (view) on what level of risk is acceptable and what risk must be reduced or resolved in some fashion. • The amount of risk that remains after all current controls are implemented is residual risk. • Risk appetite can be defined as the willingness of an investor to bear risk. • The difficulty lies in the process of formalizing exactly what the organization "can live with:' This process is the heart of risk appetite. • A well-defined risk appetite should have the following characteristics: • Reflective of strategy, including organizational objectives, business plans, and stakeholder expectations. • Reflective of all key aspects of the business. • Acknowledges a willingness and capacity to take on risk. • Is documented as a formal risk appetite statement. • Considers the skills, resources, and technology required to manage and monitor risk exposures in the context of risk appetite. • Is inclusive of a tolerance for loss or negative events that can be reasonably measured. • Is periodically reviewed and reconsidered with reference to evolving industry and market conditions. • Has been approved by the board. The Risk Management Plan • The document that contains specifications for the implementation and conduct of the RM efforts is referred to as the risk management plan. The RM plan includes not only the specifications of the RM process, but also of the RM framework. • Plan is used to conduct the RM process, and is used in conjunction with the RM policy to guide the collection and evaluation of risk information. • It contains a detailed set of the steps to perform in the conduct of both the RM framework and the RM process, along with supporting information on who performs each step and how. Framework Implementation • Once the framework team has finished designing the RM program (framework and process), it begins implementing the program. • The implementation of the RM plan based on a number of traditional IT implementation methods: • • The organization may distribute the plan to all mid- to upper-level managers for a desk check prior to deployment. • • The organization could pilot test it in a small area to gauge initial issues and success prior to deployment across the entire organization. • • The organization may use a phased approach in which only a portion of the RM program is initially implemented, such as initial meetings with key managers or initial inventory of information assets. • • The bold organization may simply choose a direct cutover (rapid transition from one phase of a business enterprise or project to another ) in which the new RM project is launched in totality across the entire organization. • Whatever rollout method is selected, it is important for the RM framework team to carefully monitor, communicate, and review the implementation Framework Monitoring and Review • After the initial implementation the framework team continues to monitor the conduct of the RM process while simultaneously reviewing the utility and relative success of the framework planning function itself. In the first few iterations, the framework team will examine how successful it was in designing and implementing the RM framework, plan, and RM process, and what issues required adjustments of the plan. Continuous Improvement • Is a maintenance process that implements a formal program designed to continuously review and improve any type of organizational effort. • The performance measures implemented in the RM process provide the data used to assess the performance outcome of the overall RM effort. As the team continues to assess the performance of the RM effort, it can adjust the plans for future RM cycles to improve past performance and increase the probability of success of future iterations. The Risk Management Process • Process uses the specific knowledge and perspective of the team to complete the following tasks: • Establishing the context, which includes understanding both the organization's internal and external operating environments & other factor that could impact the RM process. • Identifying risk, which includes: • • Creating an inventory of information assets • •Classifying and organizing those assets meaningfully • • Assigning a value to each information asset • • Identifying threats to the cataloged assets • • Pinpointing weak assets by tying specific threats to specific assets. • Analyzing risk, which includes: • • Determining the likelihood that weak systems will be attacked by specific threats • •Assessing the relative risk facing the organization's information assets, so that risk management and control activities can focus on assets that require the most urgent and immediate attention • •Calculating the risks to which assets are exposed in their current setting • •Looking in a general way at controls that might come into play for identified weaknesses and ways to control the risks that the assets face • •Documenting and reporting the findings of risk identification and assessment • Treating the unacceptable risk: • • Determining which treatment/control strategy is best considering the value of the information asset and which control options are cost effective • • Acquiring or installing the appropriate controls • • Overseeing processes to ensure that the controls remain effective
Mastering Opportunities and Risks in IT Projects: Identifying, anticipating and controlling opportunities and risks: A model for effective management in IT development and operation