Next week, I am scheduled for a semi-annual risk assessment with my dentist. He performs a very specific, highly focused type of risk assessment that is totally worth the $125 it will cost. In addition to performing specialized maintenance (hypersonic cleaning), he will provide a threat assessment (for oral cancer, cavities, periodontal disease and other anomalies). I’ll leave his office confident that my mouth is in a low-risk situation for the next six months as long as I continue to follow best practices and perform daily maintenance procedures. I am only vulnerable to these threats if I fail to follow a daily program of brushing and flossing.
I could always choose to save the small fee for these risk assessments and wait for a major dental disaster to occur. The problem with this approach is that a single incident may cost thousands of dollars if I need a root canal or some other type of procedure. Ten years of checkups are less costly than even a single disaster.
Enterprise IT risk assessments
Unfortunately, in the world of local government and SMBs, the most common approach to risk management is to allow a major catastrophe to occur before realizing the value of an enterprise risk management program.
I am at a loss to explain it. Incidents or problems involving your information and IT infrastructure are far more costly than risk management programs. Data loss, breaches, major downtime, malware, lawsuits and fines for compliance violations may cost hundreds of thousands or millions of dollars. They can permanently shut down your small business or really irritate your board of directors in a corporate environment. In the public sector, constituents pay for major screw-ups through increased taxes while the events are often covered up and the culprits skirt the blame and keep their jobs.
When was your organization’s last risk assessment? Can you put your hands on the report? If you haven’t had a risk assessment recently, it’s a safe bet that your policies are sorely lacking. Defining an organizational policy for risk assessment is an essential component of any comprehensive suite of security policies. Both HIPAA and GLBA require periodic risk assessments, but it is a sound practice for all types and sizes of organizations.
Where to start?
If you haven’t previously conducted an enterprise IT risk assessment you should carefully consider your starting point. For example, if you have few or no security policies, it may be wise to form an IG (information governance) committee and begin by developing of a comprehensive set of policies, procedures, standards and guidelines. On the other hand, your management team may benefit from the kind of wake-up call that a devastatingly thorough risk assessment can produce. A 100-page report that says you suck at security and risk management on every page may be just what you need to get everyone’s attention.
The results of a risk assessment should be used to reduce your organization’s risk exposure, improve CIA (confidentiality, integrity and availability), initiate positive change, and begin building a security culture. While using risk assessments as a punitive device isn’t the best approach, such reports often expose malfeasance and incompetence of proportions so vast that appropriate consequences are in order. In other words, if you have been paying a CIO $200,000 and the assessment uncovers gaping policy, security and privacy holes, you should certainly replace the CIO with one who has the required skill set.
Scope the project carefully
Risk assessments come in a lot of flavors and the specific purpose and scope must be worked out with the auditors in advance. A few years ago, a client of mine released an RFP for a risk assessment after we worked extensively on the development of their information security policies. The proposals ranged from $15,000 to well over $150,000. This can happen even with a pretty clear scope. Big 4 firms, for instance, have hourly rates that may be several times what a local, independent practitioners may charge. NIST SP 800-30 provides valuable information on how to perform risk assessments, including some information on scoping.
Risk assessments may be qualitative or quantitative. You may be able to do some of the quantitative work in-house by gathering cost data for all your assets in advance of the assessment. Regardless of the scope and approach, the auditors will ask to see lots of documentation.
One positive outcome of a risk assessment is that it may force your management team to rethink EVERYTHING – in-house application development, infrastructure support, IT staffing & responsibilities, LOB (line of business) staffing & responsibilities, budgets, and just about everything else related to the manner in which your organization is run.
Risk assessments are way cheaper than disasters, so go schedule your checkup.