“We don’t know what we don’t know,” said our client, somewhat embarrassed. They had spent a lot of money on cybersecurity tools, staff, and services, but they still couldn’t answer key questions such as:
- How much did your risk go down after you put all these tools in place?
- Can you prove that your people, vendors, and clients are protected?
- Where can I go and read all your policies on cybersecurity and privacy?
- How can you show me that you are compliant with outside regulations?
- How well is your cybersecurity program protecting your people, your vendors, and your clients?
Yes, this was embarrassing, but it’s a heck of a lot better to be embarrassed than liable. And that’s exactly what you will be if you can’t demonstrate that you have an effective, up-to-date, verifiable, and auditable cybersecurity program.
What is Cybersecurity Governance?
Cybersecurity governance is a holistic strategy for making security management a part of all aspects of a business, bringing the cyber and IT departments into alignment with a company’s overall goals.
Key benefits of a good governance plan include improved risk management and mitigation, better team accountability, and pain-free regulatory compliance.
Why does Cybersecurity Governance Matter?
In the minds of too many executives, cybersecurity is just a complicated (and annoying) aspect of the information technology department. Essentially the thinking goes: Cybersecurity involves computers and networks . . . which means cybersecurity is exclusively an IT problem to deal with. Cybersecurity, in this view, is fundamentally an “operational” headache. It’s “back-office stuff.”
This is completely wrong.
Think for a moment about the number of people in your organization who handle potentially sensitive data. Your human resources department does. Accounts payable and receivable certainly do. If you create or sell any sort of product, there is likely intellectual property in digital form. We can go on and on. How, then, can we view the protection of all that data as merely “back-office stuff”? That data is your business. Cybersecurity, therefore, is your business.
To be successful–to truly protect your organization, rather than just racing to put out one fire after another, your cybersecurity program needs to be about more than operations. It needs to be an integral part of your overall business strategy. This is where governance comes in.
Essential Aspects of Cybersecurity Governance
The most essential aspect of a successful cybersecurity program and governance is independence! Think of it this way:
IT is there to create value. Cybersecurity is there to protect value.
There is an obvious conflict when cybersecurity is thrown in with IT, reporting to the CIO or CTO, and commingling resources. Consider what happens when IT wants to roll out this amazing new feature that will increase the value of the company tenfold, and you have the cyber people telling you to slow down and make sure that the new feature is cyber-compliant?
Frameworks and Policies
Good cybersecurity governance depends on a comprehensive framework that outlines the structure, objectives, and policies related to cybersecurity. This framework provides the foundation for managing and overseeing cybersecurity activities.
In order for your efforts to be (and remain) effective, you’ll also need well-defined cybersecurity policies and procedures that establish guidelines for employees and stakeholders to follow. What specific types of policies you need depends on the type of business, but a few general examples to consider include data classification, access controls, incident response, and acceptable use of technology resources.
Risk Management
Cybersecurity programs become more complex by the day. In addition to all the internal departments we just mentioned, you have all your subcontractors to think about. You are likely engaging at least one (and probably more!) third-party vendor of software and tools. These many layers of complexity only mean one thing: expanded risk to your business.
Today, practically all companies irrespective of size are “in the cloud.” What is this “cloud?” It is a third-party service. A third-party service that all of a sudden is mission-critical to your business. Are they compliant? What happens when they get hacked? What is their priority? Is it your data, or is it their reputation and revenues? Bottom line: third-party risk is your problem.
Having good governance in place will make assessing this risk a simple, regular, repeatable task keeping your auditors happy, your executives sleeping easier, and your world a safer place!
Security Culture and Awareness
All the fancy security software in the world won’t do you a lick of good if Tim in accounting opens an email attachment that releases ransomware onto your network.
A good cyber governance program helps ensure that everyone in your organization is armed with knowledge about safe and unsafe behavior when it comes to handling data. Everyone needs to understand that cybersecurity is not just another IT problem but is in fact everyone’s problem.
This security-aware culture starts at the very top. From the C suite on down, everyone must understand that cybersecurity is part of the very oxygen that your organization depends on for survival.
Accountability and Oversight
Remember all those vendors and subcontractors we discussed above? Or hey, remember Tim in accounting? It’s not enough to say, “people need to do the right things.” You have to follow that up and ensure that those right things actually occur. To do this, you should have instant answers to questions such as:
- Whose job is it to check up on your subcontractors, making sure they are on top of their data protection?
- Who is in charge of implementing any and all necessary software and security patches?
- If something goes wrong, who gets brought in and when?
- Is there an incident response plan? (Please, please tell me you have an incident response plan!)
- Who is in charge of executing that plan?
- What happens if that person is on maternity leave at the time?
If you hesitated over any of these questions, there are some holes in your oversight.
Accountability is an essential aspect of cybersecurity governance because assigning tasks is not enough—you need to know who is doing what, and when, and how… and then make sure that those “do’s” get done.
Common Challenges for Cybersecurity Governance
Implementing a cybersecurity governance plan can present certain challenges for organizations. Here are some common obstacles they may encounter:
Complex Environments
Cybersecurity is a complex and ever-evolving field. The constant emergence of new threats, technologies, and regulatory requirements can overwhelm organizations trying to establish governance frameworks. Keeping up with the evolving landscape and ensuring compliance with the latest standards can be demanding.
Meanwhile, many organizations rely on vendors and third-party partners for services and solutions. Managing the cybersecurity risks associated with these external entities can be challenging, particularly because you are unlikely to have much control over the security practices of your partners.
Human Obstacles
There are a few ways in which your staff may themselves be an obstacle to a cyber governance program (intentionally or unintentionally!).
A primary issue can be a lack of understanding of the importance of cybersecurity governance. Some organizations may not fully grasp the potential risks and consequences of cyber threats, which can hinder their commitment to implementing effective governance measures.
Effective cybersecurity governance involves collaboration and communication across different departments and levels within an organization. However, siloed approaches, poor communication channels, or conflicting priorities can hinder collaboration, making it difficult to implement consistent and coordinated governance measures.
Last but not least, good old fashioned stubbornness can also present a problem. Implementing cybersecurity governance often requires changes in organizational culture, processes, and workflows. Resistance to change can arise from employees, stakeholders, or even senior management, who may be reluctant to adopt new policies or procedures.
Limited Resources
Implementing robust cybersecurity governance requires adequate resources, including financial investments, skilled personnel, and technological infrastructure. Small and medium-sized organizations often face resource constraints, making it challenging to allocate sufficient funds and personnel to establish and maintain effective governance practices.
What’s more, there is a shortage of skilled cybersecurity professionals in the job market, making it challenging for organizations to find and retain qualified personnel to implement and manage cybersecurity governance measures effectively. The demand for cybersecurity talent often exceeds the available supply.
Overcoming these obstacles requires commitment from organizational leadership, adequate resource allocation, fostering a cybersecurity-aware culture, and leveraging external expertise and partnerships. It is crucial to prioritize cybersecurity as an integral part of business operations to effectively implement and maintain robust governance practices.
It also requires that you use the right tools for the job. What is your number one criterion for the right tools? Automation! If a tool, a function, a control can be automated then you should consider that very carefully. If it can’t be automated, or contribute to automation, then you should include the costs of running the tool (licensing, resources, and people), plus the risk that the reliance on staff introduces when using it.
The best scalpel in the world will be of little use without an expert surgeon. Don’t get the scalpel without having the surgeon first! If you don’t have the surgeon, can’t afford one, or can’t find one, skip the scalpel and get a robot that can do the surgery instead. The end goal here is a successful intervention, not who has the shiniest toys.
How to Implement a Cybersecurity Governance Plan
When implementing a cybersecurity governance program, it is essential to follow a systematic approach. Here is a list of steps to consider:
1. Establish Objectives
First understand what you are trying to protect. What, where, and how valuable are the assets you are trying to protect? Then, clearly define the objectives and goals of the cybersecurity governance program. Identify what you aim to achieve, such as protecting sensitive data, ensuring compliance, mitigating risks, building resiliency and enhancing your overall security posture.
2. Obtain Leadership Support
Just like in Monopoly “Do not pass ‘GO’” unless you have secured support from senior leadership, including the executive team and board of directors. Leadership buy-in is crucial for allocating resources, establishing priorities, and promoting a culture of cybersecurity throughout the organization. If you don’t have that and you’re charged with running the cyber program, look for another job!
3. Conduct a Risk Assessment
Perform business impact analysis and a comprehensive risk assessment to identify and prioritize potential cybersecurity risks and vulnerabilities. Assess the potential impact of these risks on critical assets and operations, enabling you to develop targeted risk mitigation strategies.
4. Develop Policies and Procedures
Create a set of cybersecurity policies and procedures that address your specific identified risks and align with industry best practices and regulatory requirements. These policies should cover areas such as data classification, access controls, incident response, acceptable use, and vendor management.
5. Assign Roles and Responsibilities
Clearly define the roles and responsibilities within the cybersecurity governance program. Designate a responsible person or team, such as a Chief Information Security Officer (CISO), to oversee the program’s implementation and ongoing management. Assign responsibilities to individuals or teams across the organization for specific cybersecurity tasks.
6. Establish Training and Awareness Programs
Develop and implement training and awareness programs to educate employees about cybersecurity risks, best practices, and their roles and responsibilities in safeguarding information. Promote a culture of security awareness throughout the organization.
7. Implement Security Controls
Deploy appropriate security controls to mitigate identified risks and vulnerabilities. This may include measures such as firewalls, intrusion detection systems, encryption, access controls, security monitoring tools, and security awareness training. Always remember: The cost of controls can never exceed the value of the assets!
8. Incident Response Planning
Develop a comprehensive incident response plan that outlines the steps to be taken in the event of a cybersecurity incident. Establish procedures for incident detection, reporting, containment, investigation, and recovery. Train, test, and periodically update the plan to ensure its effectiveness.
9. Perform Audits and Assessments
Conduct regular audits and assessments to evaluate the effectiveness of the cybersecurity governance program. This includes assessing compliance with policies and procedures, reviewing security controls, and identifying areas for improvement.
10. Continuous Monitoring and Improvement
Establish processes for continuous monitoring of security controls, threat intelligence, and emerging vulnerabilities. Stay updated with the evolving threat landscape and technological advancements. Regularly review and enhance the cybersecurity governance program based on lessons learned, new risks, and changing business needs.
11. Foster a Culture of Security
Promote a culture of security awareness and accountability throughout the organization. Encourage employees to report security incidents, adhere to policies and procedures, and actively participate in maintaining a secure environment.
12. Engage External Expertise
Last but not least, consider engaging external cybersecurity experts or consultants to provide specialized knowledge, conduct audits, and offer guidance during the implementation and maintenance of the governance program. Look for solutions, not tools. Remember the scalpel/surgeon?
A solution will have both. Not just the tool, or just the service, but both. Just like our industry-leading solution cyberCTRL.
The evolving nature of cyber threats means that this is no one-and-done exercise. Implementing cybersecurity governance is not a one-time effort. It requires ongoing monitoring, maintenance, and adaptation to address emerging threats and technological advancements. Organizations must allocate resources for continuous monitoring, regular audits, and updates to their governance frameworks.
If this seems overwhelming, get in touch with us. Our industry-first platform, cyberCTRL, can be tailored to meet the precise requirements of your business. You can get the help you need without paying for the tools you don’t.
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